The following policies and procedures are devised by us, in compliance with the SEBI Circular No.
MIRSD/SE/Cir-19/2009 dated 3rd Dec. 2009.
1. Penny Stocks :-
Penny Stock is a share that trades at a relatively low market price with low market capitalization, these stocks
are generally considered to be highly speculative and risky because of their lack of liquidity, large bid-ask
spreads, small capitalization and limited disclosure. Depending on the market condition and our RMS policy.
We reserve the right to refuse to trade in such Penny Stock.
2. Setting up client's trading limits :-
The stock broker may from time to time impose and vary limits on the orders that the client can place through
the stock broker's trading system (including exposure limits, turnover limits, limits as to the number, value
and/or kind of securities in respect of which orders can be placed etc.) The client is aware and agree that the
stock broker may need to vary or reduce the limits or impose new limits urgently on the basis of the stock
broker's risk perception and other factors considered relevant by the stock broker including but not limited to
limits on account of exchange/SEBI directions /limits ( such as broker level/market level limits in security
specific/volume specific exposures etc.) and the stock broker may be unable shall not be responsible for such
variation, reduction or imposition in advance. The client agrees that the stock broker shall not be responsible
for such variation, reduction or imposition or the client's inability to route any order through the stock broker's
trading system on account of any such variation, reduction or imposition of limits. The client agrees that the
losses, if any due to the above act of the sock broker i.e. review of limits, restrictions, etc., shall be borne
exclusively by the client alone.
3. Condition under which a client may not be allowed to take further position or the broker may close
the existing position of a client.
The stock broker has margin based RMS system. Client may take exposure up to the amount of margin
available with us. Client may not be allowed to take position in case of non- availability/shortage of margin as
per RMS policy of the company. The existing position of the client is also liable to square off/close out without
giving notice due to shortage of margin/non making of payment for their pay-in obligation/ outstanding debts.
4. Applicable brokerage rate :-
Brokerage will be charged within the limits prescribed by SEBI/Exchange.
5. Imposition of penalty/delayed payment charges :-
Clients will be liable to pay late pay in/delayed payment charges for not making payment of their
paying/margin obligation on time as per the exchange requirement/schedule at the rate of 18% per month.
The client which is contrary to this agreement/rules/regulations/bye laws of the exchange or any other law for
the time being in force at such rates and in such form as it may deem fit. Further where the stock broker has to
pay any fine from any authority in connection with/as a consequence of/in relation to any of the
orders/trades/deals/actions of the client, the same shall be borne by the client.
6. The right to sell client's securities or close client's positions, without giving notice to the client, on
account of non payment of client's dues :-
Without Prejudice to the stock brokers other right (Including the right to refer the matter to arbitration) the stock
broker shall be entitled to liquidate/ close out all or any of the clients position without giving notice to the client
for non payments of margins or other amounts including the pay in obligation, outstanding debts. Etc and
adjust the proceeds of such liquidation/close out, if any, against the clients liabilities/obligations.
The stock broker has the right but not the obligation, to cancel all pending orders and to sell/close/liquidate all
open positions /securities/ shares at the pre-defined square off time or when Mark to Market ( M-T-M-)
percentage reaches or crosses stipulated margin percentage, whichever is earlier. The stock broker will have
sole discretion to decide referred stipulated margin percentage depending upon the market condition. In the
event of such square off, the client agrees to bear all the losses based on actual executed prices, the client
shall also be solely liable for all and any penalties and charges levied by the exchange.(s).
7. Shortages in obligations arising out of internal netting of trades :-
Stock broker shall not be obliged to deliver any securities or pay any money to the client unless and until the
same has been received by the stock broker from the exchange, the clearing corporation/clearing house or
POLICIES & PROCEDURES
other company or entity liable to make the payment and the client has fulfilled his/her/its obligation first. The
policy and procedure for settlement of shortages in obligation arising out of internal netting of trades is as under:
8. Temporarily suspending or closing a client's account at the client's request :-
- The short delivering client is debited by an amount equivalent to 1% above of closing rate of day prior to Pay in
/Pay out date.
- In cases of securities having corporate actions all cases of short delivery of cum transactions which cannot be
auctioned on cum basis or where the cum basis auctioned on cum basis or where the cum basis auction payout
is after the book closure/record date, would be compulsory closed out at higher of 10% above the closing price
on the auction day or the highest traded prices from first trading day of settlement till the auction day.
On the request of the client in writing, the client account can be suspended temporarily and same can be
activated on the written request of the client only. During the period client account is suspended, the market
transaction in the client account will be prohibited. However client shares/ledger balance settlement can take
place. In the request of the client in writing the client account can be closed provided the client account is settled.
If the client wants to reopen the account in that case client has to again complete the KYC requirement.
9. Deregistering a Client :-
Notwithstanding anything to the contrary stated in the agreement, the stock broker shall be entitled to terminate
the agreement with immediate effect in any of the following circumstances:
10. Inactive Client account :-
- If the action of the client are prima facie illegal/ improper or such as to manupulate the price of any
securities or disturb the normal/proper functioning of securities or disturb the normal/ proper functioning
of the market, either alone or in conjunction with others,
- If ther is any commencement of a legal process against the client under any law in force.
- On the death/lunacy or other disability of the Client.
- If the Client suffers any adverse material change in his/her/its financial position or defaults in any other
agreement with the Stock broker.
- If there is reasonable apprehension that the clients unable to pay its debts or the client has admitted its
inability to pay its debts, as they become payable.
- If the client is in breach on any term condition or covenant of this Agreement:
- If the client has made any material misrepresentation of facts, including ( without limitation) in relation to
- If the client has voluntarily or compulsorily become the subject of proceedings under any bankruptcy or
insolvency law or being a company, goes into liquidation or has a receiver appointed in respect of is
assets or refers itself to the Board for Industrial and Financial Reconstruction or under any other law
providing protection as a relief undertaking.
Client account will be considered as inactive if the client does not trade for period of one year. Calculation will be
done at the beginning of every month and those clients who have not traded even a single time will be
considered as inactive, the shares/credit ledger balance if any will be transferred to the client within one week of
the identifying the clients inactive. The client has to make written request for reactivation of their account.
11. Client acceptance of policies and procedures stated herein above :-
I/We have fully understood the same and do hereby sign the same and agree not to call into question the validity,
enforce ability and applicability of any provision/clauses this document any circumstances what so ever. These
Policies and Procedures may be amended/ changed unilaterally by the broker, provided the change is informed
to me/us with through any one or more means or methods. I/We agree never to challenge the same on any
ground including delayed receipt /non receipt or any other reasons whatsoever. These Policies and procedures
shall always be read along with the agreement and shall be compulsorily referred to while deciding any dispute
/difference or claim between me/us and stock broker before any court of law/judicial/ adjudication authority.