This document shall be Risk ManagementPolicy of the Company while carrying out its business activities as a Member ofNational Stock Exchange of India Ltd and Bombay Stock Exchange Ltd.
This document shall be used as guidelinesfor the activities namely client identifications and introductions,surveillance, record keeping for executing and carrying out the day to daytransactions by the Company and its business associates.
A. Pre-Trading
1. Registrationof Client / KYC:
a. Collectionof KYC form
Collection of KYC form from the prospective client with in personverifications procedure
Receipt of duly filled Client Registration Application Forms, withsupporting documents
Checking of Application Forms and allotment of the unique clientcode
Re-checking of Forms and capturing of information into the system
Documentation of Forms.
The forms shall be checked for theircompleteness and correctness with the supporting documents, by the designatedstaff and the key fields are entered into system. A Unique Client Code (TradingCode) shall be allotted to the clients. Allocation of Client code is systemizedso that the same code is not allotted to another client.
Forms shall be once again re-checked withthe information captured in the system under Maker-Checker concept.
Itis the policy of the Company to ensure that effective KYC programme is put inplace by establishing appropriate procedures and ensuring their effectiveimplementation. It covers proper management oversight, system and controls,segregation of duties, training and helps in fighting against money launderingand thereby detects, deters and disrupts money laundering.
The Company should send the KYC, UCC detail& all other documents as executed by clients along with the welcome letter to the clients directly so that the client should have a copy of the documents signed with the company.
The client is required to pay initial margin as specified by NSE / BSE / SEBI before placing any order. The Company reserves the right not to execute the order if the client has not placed the required initial margin.
Total deposits of the clients are uploaded in the system and clients are provided exposure on the basis of margin applicable for respective security as per VAR based margining system of the Stock Exchange and / or margin defined by RMS based on their risk perception.
The Company allows the trading of “PennyStock / Illiquid Securities and Z Group Securities” subject to rules,regulation, Articles, Byelaws, Circulars, Directives and Guidelines of SEBI andExchange as well as considering the prevalent market and other circumstances atrelated point of time. The Company reserves the right to restrict the clientsto buy / sell in penny stocks / illiquid securities only on the basis of 100%upfront margin and on Delivery basis. Also the Company may have in placefurther restrictions in terms of quantity / value in each / all penny stock /illiquid securities.
In addition to the due diligence, the Company shall carry out further due diligence while verifying the KYC document on regular basis.
The Company shall adhere with the Circulars, Rules and Regulations laid down by NSE / BSE / SEBI from time totime.
i. The client shall be required to make the payment as per the Rules and Regulations prescribed the Stock Exchanges in this regard
ii. The pay-out of funds shall be made onT+1 basis after confirming the successful pay-in of the securities by the client.
i. Collection of deliveries of securities from clients shall normally be called from the clients on T+1 basis.
ii.In case of delivery of pay-in obligations of large quantity / value scrips shall be called for prior to pay-in to make early pay-in or as early as possible after the execution of sell order and shall be tendered to the clearing house under early-pay in mechanism to the extent required.
iii. Deliveries of securities to the clients shall be effective within 24 hrs from the pay-out.
a. The day to day operations are being looked after by the Designated Officials of the Company.
b. The on-line surveillance desk is to be monitored by Designated Officials where real time client wise / scrip wise position, M to M Margin requirements, available margin and exposure limits with all exchange segments are monitored.
c. The various compliance requirements of all the Exchanges shall be ensured by the Compliance officer under the supervision of the Directors
(As per requirements of SEBI Circular No.SEBI/HO/MIRSD/POD-1/P/CIR/2024/4 dated January 12, 2024)
If any suspicious activity is observed in the Trading Account, the client may request us to voluntarily freeze/block the online access of the trading account through any of the following communications to us at the e-mail ID stoptrade@sachdevastocks.com and/or telephone number +91-9041064111
a) Email from registered e-mail ID
b) SMS / Call from registered mobile number
After validating that request, Member will issue the acknowledgement as well as freeze/block the online access of the client's trading account.
The timelines forfreezing/ blocking of the online access of the clients’ trading account is as under:
1 Trading hours shall be as follows:Capital Market Segment: 9.15 a.m. to 3.30 p.m., Equity Derivatives Segment: 9.15 a.m. to 3.30 p.m., Currency Derivatives Segment:09.00a.m. to 05.00 p.m., Commodity Derivatives Segment: 09.00 a.m. to 11:30 p.m.
2 To begin with, the time limit of 15 minutes is being specified for the purpose of issuing acknowledgement as well as freezing/blocking of the online access of the trading account. This time limit shall be contracted after a review in next six months after the date of its applicability to enhance protection of investors from suspicious activities.
The Trading Member shall take the following actions on the receipt of request through any modes of communications as provided by the Trading Member for freezing/blocking of the online access of the trading account from the client:
a Validate that the request is received from the client as per prescribed mode of communication and issue the acknowledgement as well as freeze/block the online access of the client's trading account and simultaneously cancel all the pending orders of the said client.
b.Post freezing/blocking the client’s trading account, send a communication on the registered mobile number and registered e-mail ID of the client, stating that the online access to the trading account has been frozen/blocked and all the pending orders in the client’s trading account, if any, have been cancelled along with the process of re-enablement for getting the online access to the trading account.
c. Details of open positions (if any)should also be communicated to the client along with contract expiry information within one hour from the freezing/blocking of the trading account. This will eliminate the risk of unwanted delivery settlement.This time limit shall be contracted after a review in the next six months after the date of its applicability to enhance protection of investors from suspicious activities.
The Trading Member shall re-enable the online access of trading account after carrying out necessary due diligence including validating the client request and unfreezing / unblocking the online access of the trading account.
Post freezing/blocking the client’s trading account, send a communication on the registered mobile number and registered e-mail ID of the client, stating that the online access to the trading account has been frozen/blocked and all the pending orders in the client’s trading account, if any, have been cancelled along with the process of re-enablement for getting the online access to the trading account.
a.Freezing/blocking is only for the online access to the client’s trading account, and there shall be no restrictions on the Risk Management activities of the Trading Member.
b.The request for freezing/ blocking does not constitute request for marking client Unique Client Code(UCC) as inactive in the Exchange records.
