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Econo Broking Pvt. Ltd.
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Policies

Policy for accepting new clients

Econo Broking Private Limited
Commercial Unit No. 201 to 202A,
2nd Floor, Dalal Street Commercial Co-operative Society limited,
Block No. 53, Building No. 53 E,
Zone-5, Road-5E,
Gift City, Gandhinagar - 382 355.
Gujarat, India
TEL: (0278) 2413100.
EMAIL: info@econobroking.com website: www.tradedealonline.com
Policy for accepting new clients
  1. All the documents like Id Proof residence proof will be verified by KYC department with the originals.

  2. Having verified the proof with original documents same will be returned to the clients. The clients must provide the names and signature of the introducer.

  3. In case of trading account, Bank details and DP details need to be obtained. Further at later on stage after account opening, if client wants to add additional bank details for pay-in and pay-out purpose, client shall have to provide scan copy of cheque / bank statement / pass book of his/her bank account with his/her name printed on the same (pre-printed).

  4. All the clients shall be required to visit DP dept. in-person. The PAN details of the clients shall be verified with Income tax site & then account will be opened as per the name appearing on the PAN card as per the Income Tax department.

  5. The officer-in-charge will carry out due diligence i.e. their whereabouts, experience in capital market and shall make the client aware of risk factor in dealing in capital market.

  6. On collection of requisite documents and carrying out in-person verification with the appropriate format. Then account will be opened and copy of the complete KYC will be handed over against acknowledgement which must be preserved on record.

  7. This will be applicable for all segments including DP.

  8. The concern officer who is carrying out in-person verification must put his/her signature on KYC form.

Policies & Procedures

Mandatory Document dealing with Policy and Procedures Pursuant to SEBI's Circular dated Dec. 3, 2009
  1. Refusal of order for Penny Stocks

    Trade Deal Financial Services Pvt. Ltd. shall have the absolute discretion to accept, refuse or partially accept any buy or sell order for execution from a client in respect of penny stocks, illiquid stocks, stocks having low liquidity, illiquid "options", far month "options", writing of "options", stocks in S, Z and B2, T and TS category and any other contracts which as per the perception of Trade Deal Financial Services Pvt. Ltd. are extremely volatile or subject to market manipulation.

    Trade Deal Financial Services Pvt. Ltd. may permit restrictive acceptance of orders in such scrips / contacts in controlled environments like orders received from clients being forwarded by branches to centralized desk at HO instead of allowing trading in such scrips / contracts at branch level or through Online trading platform. Trade Deal Financial Services Pvt. Ltd. shall not be responsible for delay in execution of such orders and consequential opportunity loss or financial loss to client.

    Trade Deal Financial Services Pvt. Ltd. may cancel orders in such scrips received from clients before execution or after partial execution without assigning any reason thereof.

  2. Setting up client's Exposure Limits

    The client agrees and confirms to abide by the exposure limits, if any, set by Member or by the exchange or Clearing Corporation or SEBI from time to time.

    The Stock Broker/ Trading Member may from time to time, at its sole discretion, impose and vary limits on the orders that the client place (including exposure limits, turnover limits, market level limits, limits as to number, value and / or kind of securities / contracts in respect of which buy or sell orders can be placed etc.) The client is aware and agree that the stock broker/ trading Member may need to vary or reduce the limits or impose new limits urgently on the basis of Member's risk perception and other factors considered relevant by Member and Stock Broker/ Trading Member may be unable to inform to the client of such variation, reduction, imposition in advance. The client agrees that the Stock Broker/ Trading Member shall not be responsible for such variation, reduction and imposition of limits.

  3. Applicable Brokerage Rate

    The Client confirms and agrees that the brokerage shall be paid in the manner intimated by the Member to the client from time to time, including as a percentage of the value of the trade or as a flat fees or otherwise, together with the service tax as may be applicable from time to time on the same.

    The Client hereby agrees to the brokerage slabs/rates, as mentioned in this document, which do not exceed the maximum limits prescribed by the SEBI/NSE.

  4. Imposition of penalty/delayed Payment Charges (This must not result in funding by the broker in contravention of the applicable laws)

    The client understands and agrees that applicability of delayed payment charge by either party is solely at the discretion of the Stock Broker.

    Without prejudice to margin funding guidelines issued by SEBI, any amounts which are overdue from a client toward settlement obligation or margin obligation either in cash segment and/or derivative segment may attract delayed payment charges at the rate of 2 % per month or part thereof or such other rate as may be determined by the stock broker.

    While levying delayed payment charges on the debit balance in the running account of a client, Trade Deal Financial Services Pvt. Ltd will not consider any credit balance in the other family or group account of the client.

  5. 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 member's other rights (including the right to refer a matter to arbitration), the Member shall be entitled to liquidate / close out all or any of the Client's positions for non-payment of margins or settlement obligations without giving prior notice. Member may also sell off all or any securities of the client lying with member as collateral or otherwise for any amounts due by the client and adjust the proceeds of such liquidation/close out against the client's liabilities /obligations. Any and all losses and financial charges on account of such liquidation / closing-out shall be charged to and borne by the Client.

  6. Internal Shortage

    In case of purchase of securities by the Client at times Member may be unable to deliver the securities to the said purchaser on the payout day due to non-receipt of the said securities from another Client of same Member who has sold the securities against the said purchase transaction. In such cases, member may buy the shares from the market on T + 2 day or on settlement day and deliver the same to the client or he may give close out at the rate as determined by the member.                                                 

  7. Close out in case of internal Shortages

    The Client hereby agrees that if he/she/it has short delivered any securities against his/her/its pay-in-obligation which resulted into internal shortage (i.e. buy position of another client of Member and could not be auctioned in the market), close out shall be debited to his account at the rate which is, (high of Closing Rate of (T / T+1 / T+2 day) + 5% to 20%), as the case may be, or such other percentage as may be revised by Member from time to time. The Client should not hold company responsible for any loss/damage arising out of the same.   Internal auction or Close out shall be done on T + 2 day.

  8. Restrictions/Prohibition to take further position or closing existing position

    The Member may, in its sole discretion not allow taking further position to the client or may close the existing position of a client due to any restrictions in relation to volume of trading / manipulating or fraudulent trades/ outstanding business or margins stipulated by the exchange, clearing corporation/ clearing house and/or the Member and / or any other extraordinary event warranting such restrictions. The Client waives any and all claims for loss or damage arising directly or indirectly from any such restrictions.

  9. Temporarily suspending or closing a client's account at the client's request

    The Client may suspend or close his/her/its trading account temporarily by giving written request to the member. Such temporary closing or suspending of trading account will not affect the rights and obligation incurred prior to such suspension or closure. Any request for temporary suspension or closure shall not be processed by the member unless all the dues are paid by the client.

  10. Deregistering the Client

    The Member may, at its sole discretion, deregister client's account to protect his interest which may include
    • The Member may, at its sole discretion, deregister client's account to protect his interest which may include
    • On the basis of the information found in sites of CIBIL
    • Any breach of the terms of this agreement
    • Upon the death, winding up, bankruptcy, liquidation or lack of legal capacity of the client
    • The Client having misrepresented facts at the time of entering into this agreement or at the time of giving instructions or otherwise
    • Member has reasons to believe that account is being used for fraudulent purposes.
    • The client fails to fulfill his /its payment obligations under this agreement or otherwise due to member
    • Any other reason which member thinks reasonable for deregistering the account


  11. Policy for in active Clients

    In case client has not used his account for a period exceeding 6 months but not later than 2 years across the exchanges, then his account shall be freeze for further trades and the said account shall be re-activated only after having received verification from client for his/her/their basic details such as PAN, Address, Bank Details, E-mail address, Mobile no. etc. through a verification call given by official of the company on registered mobile no. of client. Further if client has not operated / used his account for more than 2 years, his account shall be deregistered and his account shall be reactivated only after proper recording of reason for such non use, in writing, after taking all the required proof and verifying the same with client on registered mobile no.

    In case of In-Active Clients (Clients not traded in / operated their account since last 3 to 6 months), payout of credit balance or shares lying in pool account will be given to client’s respective bank account or to demat account.

PMLA Policy

RMS Policy

Audit Trail Policy



AUDIT TRAIL POLICY
Audit Trails are maintained for both systems as well as application process by user activities and applications.
The series of records of computer events about the operating systems. The applications and the user activities. The different audit trails are required to be maintained and audit trails provides information about computer systems and helps to audit of the computer system.
The audit trails is used to establish individual accountability which has helped the user proper behavior.
Any events to circumvent security policy will be revealed immediately and the appropriate actions are taken immediately.
Any specific problem is always investigated by use of audit trails and system activity to find out what exactly happens.
The event is reconstructed at appropriate level and it is analyzed to find any misuse or mischief created by any user and also to prevent unauthorized use of the system and the network on real time basis. It has also helped the virus attack and it has prevented the unacceptable system performance. The identification process immediately detects the unauthorized access was attempted and resultant damaged is assessed and controls which were attacked.
System maintains several audit trails on concurrent basis which are recorded and saved.
Further such records are reviewed on regular basis which also includes keystroke monitoring. These logs are preserved in the system.
The review of audit trails has been utilize to find tune the system performance and to avoid any flow violations of security policy committed in application, this helps the misuse of the system by any individual user and all users remains accountable.
The audit trails also examine the access control and its violation.
The record of email application logs and its logs prevents the data pilferage the appropriate action after establishing the misuse and attempt of accessing the data in unauthorized way.
System administrator is required to record the logs of user activities. The sensitive server applications and accessing the network is required to examine regularly.
The attempts of log-in and unsuccessful log in are been checked.
Application level audit trails are monitored and records are been maintained to examine the confidential information is not available to any unauthorized user.
User audit trails the commands directly initiated by the user and also any unauthorized attempts and files and resources access any attempt to delete the log is viewed and noted very seriously.
There is this audit logs are preserved for minimum 1 year and they are not available for review, access or monitor by anyone other than CEO or system administrator they are confidentially preserved.
The audit trails are reviewed after any events or any software malfunctioning.
The periodic review of audit trail data is being carried out by system administrator and under directions from CEO.

Business Continuity & Contingency Plan



Business Continuity & Contingency Plan
Introduction
In order to manage the unforeseen disaster and to come out of the ill effects of the same with least damages to business, business continuity plan (BCP ) and Disaster Recovery Plan ( DRP ) have been in place. Now it becomes a master document for the company to see through the ill facade of business uncertainty.
These two master plans, which are put into use complement each other and through our organization's constant review of business and system processes, the plans shall get updated commensurate with the size of business and its growth. The plan has been arrived at after making detailed risk evaluation of the location(s) where from the businesses are operated.
MOTTO: Contingency plans stated both, as part of BCP & DRP is active and fault-free. The plans relating to minor or routine electronic or communication failures are dealt with as part and parcel of Business Continuity Plan while contingency plan for the organization for severe calamites like Earthquake, Flood, Fire or any other natural or man made disaster are dealt with under DRP Plan.
Objective of Surveillance
  • Business Process Continuity ensuring desired level of efficiency
  • Continuity of Business Data integrity & confidentiality
  • Data Security
  • Speedy retrieval of data and other operational aspects.
Areas of Surveillance
  • Physical Surveillance of IT assets
    • 24-hour building security guard
    • Maintain proper location of system so that unauthorized access by third parties do not happen
    • Ensure proper physical lock of main gate and server room and restrict admission into server room to other employees not entrusted with any server room management related task
    • Improve upon the systems through in-house maintenance.
    • Always ensure that third party vendor is accompanied into the server room and activities monitored.

  • Connectivity
    • We have two alternatives sites from where the connectivity can be availed, in case the connectivity at any place is not available.
    • The branches get connected either through NOW or dedicated leased lines, or local branches get connected through dial up (ISDN/PSTN) and also through Broad Band.

  • Data
    • ODIN Manager and Database Server Back up is taken.
    • Backup Schedule:-
    • Odin database backup process:-
    • Backup plan consist of taking backup with reference to following system or data base:-
    • Daily Database Backup Report containing all the six types of daily backup as above, person taking backup to sign and the same signed by another who verified it and note down to whom media is handed over ( in Implementation stage)
    • Database Restore Process- menu screen shots, option selection and steps till completion of process is provided in Manual format earmarked as DR

  • User responsibility & accountability:
    • Password policy/standards defined and observed as per respective exchange regulations and circulars issued from time to time.
    • User management norms defined and observed as per respective exchange regulations and circulars issued from time to time.

  • Change Control Management:
    • Management desires that as the business is new and growing, in keeping with growth, shall maintain numbered Change Request Form (CRF) for all requests changes in software submitted to Financial Technologies or other software vendors.
    • System Administrator maintain record of all the versions and patches installed for various OS and application from time to time for
      HO
      Branch
      Retail Clients

  • Maintenance and up gradation of hardware and software
    • Verification of UPS and Battery and Generator Set on a quarterly basis is introduced
    • Each staff is strictly warned not to put any inflammable item upon any electrical systems
    • To make the environment dust free.
    • A call list for the emergencies
    • The physical access by only authorized employees is introduced.
    • We also propose to permit entry to the server room only by introducing the "Secured Electronic Identification" by means of Smart Cards.
    • We are in the process of equipping the entire company against fire hazards and shall install suitable fire fighting equipments.

  • Preparation, Maintenance and Revision of documentation: of various critical system processes by itself is identified as one of the critical resource to switch to contingency plan or to avert electronic blunders preventing business disruption.
    • Application System ( Documentation is done for Day Begin processes, Data restore, Data Backup Process, Escalation for response to email)

  • Escalation Process shall be practiced in the following order:
    • In case of Day Begin or Day End Failure
    • Other System processes failure

  • Business Processes are to be performed strictly in adherence with the policies and procedures defined by various authorities and exchanges and the practices are suitably changed as per circulars/directives on a AS IS basis before deadline.
  • Business process contingency
    • For online trading no of internet lines-2
    • If connectivity failure of any of the above tow lines are reported, the affected clients are called back to reconfigure client machine IP to switch over to the other line.
    • ODIN registry files are available on ftp site and available to all the clients
    • These files can be downloaded at client systems and continue trading.
    • Antivirus and firewalls are to be updated on an online basis.

  • Critical Processes Management
    • Server Startup Process menu screen shots, option selection and steps till completion of each of the processes is provided in Manual Format
Surveillance
  • Preventive
    • Daily Start-up process Status report is monitored

  • Detective
    • All Server's Event viewer monitoring is done on a daily basis

  • Corrective
    • Usually Clients are guided through the menus by the helpdesk staff to ensure smooth uninterrupted running of the programs. Various Helpdesk staff are allotted specific call support task specific to the job domain of the staff and customer complaints received over phone or through email are monitored as per escalation procedure separately explained elsewhere. The same is informed to all through circular/email.

  • Plan Drill
    • Backup Restore Plan is tested regularly.
    • Backup connectivity as available is tested every month
    • Management's Surprise visits to various IT locations to confirm that no stranger has any access to the IT setup.
    • Loose data cables and loose electrical wires are closely monitored.
    • Whole plan is regularly reviewed to ensure that plan is modified with the change in processes and documentation is accordingly revised.

  • Capacity Management
    • We have close monitoring on hardware performance. We allow CPU usage to edge 50%.Hardware is upgraded as soon as CPU usage edge over 50% for reasonable time period. Server hardware, routers, switches are housed on proper racks and access to area is controlled. The capacity is properly air conditioned. We have designated agencies to maintain hardware as well as software resources.
    • We also continuously monitor the performance of each and every hardware installed in the office and we have policy to ensure to replace unserviceable hardware on regular basis.
    • We also continuously review and compare hardware capability and capacity with reference to our growth plan and the present volume of activity and accordingly modification replacement of hardware is being done.

  • Risk Management (Policy Document)
    • We have installed ODIN as affront-end and also use NEAT wherever required. Both these software are provided with controllable risk parameters.
    • We have online real-time basis risk management software with well defined parameters installed in our trading system provided by outside vendor who has provided similar software and proven functioning of the same.
    • The risk parameters are the very well defined by the Chairman & Managing Director and the risk management team sitting at Head Office .The executive personnel do not any authority to change any risk parameters defined and instructed to them and installed on the software.
    • Further, the trade surveillance and monitoring of trading activities of different constituents connected to our main server is being viewed on continuous basis and alerts, warnings are sent to the erring constituents immediately and corrective actions are taken instantly.
    • Further, strict monitoring and follow-ups is being kept on all the branches after day end reports and any warnings or correction in security parameters on the risk management software is required with specific branch or a client is taken before day end.
    • Further, the analysis of trading activity of major clients is being regularly done to ensure that no risk of bad debts or faulty activity is carried out by any constituents.
Business Continuity Plan
We have ensured to create mirror image of entire setup for business contingencies and continuity plan to avoid any hazards at two different locations.
We have planned growth for ensuing years to meet the growth requirement, the monitoring, re-structuring, re-defining the network requirement, hardware requirements and software requirements is being done continuously in consultation with in house IT teams sitting at both the location and outside IT experts.
We have created appropriate hierarchy of management personnel and executives by providing appropriate training and giving right kind of exposure. We continuously focus our attention on training and development of Human Resources with us. We also ensure that the entire team of company remains positive and willing and able workforce for company by organizing several events time and again of their interests.
We also have created business organization required for sincere needs with reference to the envisaged growth and sourcing or equipping our selves by hiring outside experts either on full time basis or on retainer basis to ensure that business continue in all circumstances.
We keep vigil on market movements and hire expert advice on market movements and safeguard everyone including our branches and clients to ensure to keep manageable exposure to the market in the event market may go against their respective positions.
We have always remained most competitive in offering our services to our clients and have kept vigil on market development in brokerage and depository service charges. We provide value added services like 'SPEED-e', Investment Advice and assistance to resolve their grievances on any investment issue, Internet Trading, Portfolio Management Advise at free of cost to remain competitive.
Disaster Recovery Plan
  1. Preamble

    This plan is to be known by the short name DRP. This plan document is the only approved document that replaces/over rules all the past instructions issued by various officials in so far as that conflicts with the present plan.

    If and when NSE/BSE/MCDX/NCDXE issues any instruction to broking member with reference to the domain of this plan and if the same conflicts with the laid down plan, then the Exchange or other statutory authorities rule shall be binding and DRP plan shall be modified suitably to incorporate such changes.

    If and when NSE/BSE/MCDX/NCDXE issues any instruction to broking member with reference to the domain of this plan and if the same conflicts with the laid down plan, then the Exchange or other statutory authorities rule shall be binding and DRP plan shall be modified suitably to incorporate such changes.

  2. Plan Follow up Yardstick

    Plan Status categories are
    Plan In Place
    Action Plan to be implemented
    Plan for follow-up and surveillan

  3. Plan

    1. The Plan in place
      1. The Broker has initiated DRP plan since the inception of broking business.

      2. Standard office floor layout plans take care of the unforeseen disasters, physical access risk to IT and other resources from visiting third parties and clients.

      3. Central DRP Team consists of ------------------------.

      4. For each branch, the branch-head is responsible to interact with Central DRP team and follow DRP Plan implementation and surveillance. Crisis Management at branch is handled by branch head.

      5. The Branch-In-Charges are communicated of their DRP task by the Central DRP team members.

      6. HOD System is assigned the duty to manage the affairs at the time of crisis and coordinate with other team members and external agencies.

      7. Exchange's Mock Trading session is conducted always on the backup server.

      8. Emergency contact Nos. of important utility functions and functionaries are displayed at HO.

      9. NO-Smoking policy is strictly enforced at HO and branches.

      10. HO and branches to maintain insurer's policy no, branch location, contact address, telephone and fax nos. which is required for lodging claim intimation.

      11. Online Data Backup of Branch's critical data to be daily taken by HO

      12. Policy for preservation of old data is in place.

      13. Regular Media backups to be taken and kept at off site location.

      14. Preventive test of the UPS system and its battery load by switching off Mains to be conducted

      15. HO floors have no recent water damage evident on the walls, floors, or ceiling arising out of plumbing leakage, leakage from mainframe water cooling systems or air conditioner.

      16. Water, sewer, or drain-pipes do not pass through ceiling or walls of the system room of HO.

      17. Hard copy of the latest emergency passwords for servers, routers etc. are stored at off-site with the top five officials of the company

      18. HO and Branch strictly to ensure password secrecy policy for servers and other user IDs.

      19. There are no instances of disaster happening at the HO/ branch or its neighborhood observed in recent past.

      20. There is no Proximity to a center storing or dealing with hazardous materials and there is no risk of any fire or noxious fumes anticipated from neighborhood for HO and branches.

      21. No dust or other contaminations are spread in the environment from within the premises or neighborhood

      22. The area is politically or for other social factors not disturbed in the past and area is not affected by civil disorders occasionally leading to riots/firing / bombing etc.

      23. Computer room maintenance and cleaning carried out at regular intervals

      24. The floor's roof at HO is sound and not dampening.

      25. Cabling for electrical installation at HO is safe

      26. Network cable line has been drawn separated from the electrical cables

      27. The HO building has proper drainage facility and business being located at first and third floor, inundation risk is remote

      28. Power and surge protection requirements have been identified and adequate surge protection devices have been installed

      29. Power-lines are kept in three phase which is as per prevailing standard of safety. ( one phase for computer with UPS, second for AC and other high power consuming devices like fans and Coolers and the third for lights)

      30. Periodic checking to ensure that overloaded outlets within the HO/Branch for any of the phase to be identified and remdied.

      31. Server Room Access is prevented for third party vendors without authorization. Server Room Access is totally restricted for any other visitor. Appropriate server room access control measures for employees are followed. UPS- Hardware-Software vendor is always escorted to server room and their activities monitored and reported to HO System.

      32. Physical security of the premises during off-hours is satisfactory

    2. Action Plan to be implemented
      1. The Emergency Contact Nos. should now be displayed at branch for HO-systems personnel, Service Engineer of FT, Operating Systems, hardware, UPS system, Communication service providers, Electrician, Electricity Company Complain no, Disaster Central Team Members.

      2. Branches to ensure adequate UPS battery backup or else Standby generator set of required capacity

      3. Fire suppression capabilities such as necessity of fire extinguishers to be evaluated for its utility in the present location after due consideration.

      4. Communication line between the branch and HO is working satisfactorily. Efforts are targeted to ensure backup communication line for branch and HO. The available backup communication line for branch and HO is tested to ensure that the same is working properly

    3. Plan for follow up and surveillance
      1. Risk and Impact on Business: Branches to conduct in house meeting in the every month to assess minimum critical time required to resume business in case of business interruption under various scenarios like natural calamity (flood/EQ/fire), man made calamity (riot, arson) or electronic calamity (server crash, communication line down, electronic fraud) and clearly communicate the same to Central DRP team.(2). The DR Plan directive in the form of a questionnaire is to be circulated to review risk at each branch locations

      2. To monitor second level of checking of critical data and other system generated reports/statements

      3. Branch to conduct situation based drills and discuss disaster prevention awareness program with the branch staff once every six months

      4. Branches to ensure adequate UPS battery backup or else Standby generator set of required capacity

Information Security Policy
We have introduced the physical controls at server room, back office room by not permitting any unauthorized entry physically.
No visitor is allowed in this area without prior approval and they are not allowed to carry any laptops, pen drives, floppies, cds etc., inside the secured areas.
All employees are not allowed to carry any information in any form from the office while leaving the office. No direct access to Internet is provided to anyone other than authorized persons. All the computers are controlled, their activities are frequently viewed by senior officials time and again to ensure that no pilferage of any sensitive information.
No third party vendors, contractors are permitted in restricted zone. Any meetings with this person if required are held at non secured zone office at the front office.
Physical controls of office premises and facilities
Physical security guard stationed at the entry point guards the office.
No unauthorized entry is permitted.
Suitable locking arrangements are maintained
The keys remain with senior most directors of the Company. For alternative arrangement, the set of keys are kept at a secured place in vicinity of the office.
Protecting against external environmental risks
We have created earthquake proof structure at office premises.
The Zero level is raised much higher than the ground level to ensure to avoid the damage due to floods.
No open or vacant area is left in the office.
Photographic video, audio or any recording equipments like cameras in mobile devices are not permitted inside the secured area. Even employees are not allowed to carry their mobile phones with camera to have full proof physical security of sensitive information.
We have also ensured to discard all unused or unserviceable equipments, Records, papers not required are destroyed to avoid the unnecessary piling up of unused materials to avoid the dust, fire, explosion, vibration, chemical, electrical damage.
Information Security policy and Network Security Policy
Purpose The purpose of this policy is to out line acceptable use of computer equipment at company. These rules are in place to protect the entire company's team and company. In appropriate use expose risks including virus attack, compromise of network system and service and legal issues
The Scope This policy covers employees,contracters,consultants, and temporaries including all personnel affiliated with third parties. This policy applies to all equipment that is owned or leased leased by company.
Policy
  • The legitimate use of network and reasonable level of privacy is ensured.
  • Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
  • This policy recommends that any information that is considered sensitive is Encrypted.
  • Regular Audit of network system is done on periodic basis to ensure the Compliance of this policy.
Security and proprietary information
The interface for information contained on Internet/Intranet/Extranet-related system should be classified as either confidential or not confidential, defined by corporate confidentiality guideline, detail of which can be found in Human Resources policies. Examples of confidential information include but are not limited to: company private, corporate strategies, competitor
  1. Sensitive, trades secret, specifications, customer lists, And research data. Employees should take all necessary steps to prevent unauthorized access to this information.
  2. keep password secure and do not share accounts. Authorized users are responsible for the security of their password and accounts. System level password should be changed quarterly, user level password should be changed every six month.
  3. All PCs,laptop and workstations should be secured with a password protected screensaver with the automatic activation feature set at 10 minutes or less, or by logging off (control-alt-delet for win2k users) when host will be unattended.
  4. Use encryption of information in compliance with this policy's Acceptable Encryption use policy.
  5. Because information contained on portable computers is especially vulnerable, special care should be exercised Protect laptop in accordance with "Laptop Security Tips"
  6. Postings by employees from a company email addresses to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of company, unless posting is in the course of business duties.
  7. All hosts used by the employee that are connected to the company securities pvt ltd. Internet/Intranet/Extranet. Owned by company shall be continually executing approved virus scanning software with a current virus database. Unless overridden by departmental or group policy.
  8. Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.
Unacceptable Use
The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities (e.g. systems administration staff may have a need to disable the network access of a host if that host is disrupting production services)
Under no circumstances is an employee of company authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing company's owned resources.
The lists below are by no means exhaustive, but attempt to provide a framework for activities which fall into the category of unacceptable use.
System and Network Activities
The following activities are strictly prohibited, with no exceptions:
  1. Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by the company.

  2. Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music and the installation of any copyrighted software for which company or the end user doesn't have an active license is strictly prohibited.

  3. Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws, is illegal. The appropriate management should be consulted prior to export of any material that is in question.

  4. Introduction of malicious programs into the network or server(e.g./ viruses, worms, Trojan horse, email bombs, etc.)

  5. Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home.

  6. Making fraudulent offers of products, items, or services originating from any company account.

  7. Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access, unless these duties are with the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes.

  8. Port scanning or security scanning is expressly prohibited unless prior notification to this policy is made.

  9. Executing any form of network monitoring which will intercept data not intended for the employee's host, unless this activity is a part of the employee's normal job/duty.

  10. Circumventing user authentication or security of any host, network or account.
  11. Interfering with or denying service to any user other than the employee's host (for example, denial of service attack)

  12. Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's terminal session, via any means, locally or via the Internet/Intranet/Extranet.

  13. Providing information about, or lists of company's employees to parties outside the company

Email and Communication Activities

  1. Sending unsolicited email messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material ( email spam)

  2. Any form of harassment via email, telephone or paging, whether through language, frequency, or size of messages.

  3. Unauthorized use, or forging, of email headers information.

  4. Solicitation of email for any other email addresses, other than that of the poster's account, with the intent to harass or to collect replies.

  5. Use of unsolicited email originating from within company networks of other Internet/Intranet/Extranet service providers on behalf of, or to advertise, any service hosted by company , or connected via company's network.

  6. Posting the same or similar non-business-related messages to large numbers of Usenet newsgroups(newsgroup Spam)

Enforcement
Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.
We have introduced the physical controls at server room, back office room by not permitting any unauthorized entry physically.
No visitor is allowed in this area without prior approval and they are not allowed to carry any laptops, pen drives, floppies, cds etc. inside the secured areas.
All employees are not allowed to carry any information in any form from the office while leaving the office. No direct access to Internet is provided to anyone other than authorized persons. All the computers are controlled, their activities are frequently viewed by senior officials time and again to ensure that no pilferage of any sensitive information.
No third party vendors, contractors are permitted in restricted zone. Any meeting with this person if required are held at non secured zone office at the front office.
Physical controls of office premises and facilities
Physical security guard stationed at the entry point guards the office. No unauthorized entry is permitted.
Suitable locking arrangements are maintained.
The keys remain with senior most directors of the Company. For alternative arrangement, the set of keys are kept at a secured place in vicinity of the office.
Protecting against external environment risks
We have created earthquake proof structure at office premises.
The Zero level is raised much higher than the ground level to ensure to avoid damage due to floods.v No open or vacant area is left in the office.
Photographic video, audio or any recording equipments like cameras in mobile devices are not permitted inside the secured area. Even employees are not allowed to carry their mobile phones with camera to have full proof physical security of sensitive information.
We have also ensured to discard all unused ot unserviceable equipments, records, papers not required are destroyed to avoid the unnecessary piling up of unused materials to avoid the dust, fire, explosion, vibration, chemical, electrical damage.

Policy for Closure of Client's Account and Policy for In Active Clients

Closures of client account and dormant accounts
In case client has not used his account for a period exceeding 12 months, his account shall be In Activated, freezed for further trading and his account shall be reactivated only after proper recording of reason for such non use in writing, after taking reactivation form along with all the required proof in support and after performing IPV (In Person Verification) of such clients.
Any Client's account would be closed on the basis of closure request received from that client either on the basis of account closure forms received or on the basis of closure request received from that particular client's registered e-mail address maintained in our records. Any accounts where there is no trading activity over two years and having no significant balance or uncleared debit balance with no activities more than or equal to 6 months, such clients would be served with an advance notice of 30 days through e-mail on their registered e-mail address maintained in our records to close their account by submitting account closure forms and in absence of the same, accounts (trading and demat) of such clients would be closed by us on expiration of 30 days notice period and the balance amount on those account would be transferred to Kasar account or any other account as decided by the management of the company from time to time.

Internal Shortage

Procedures



Procedures and policies followed by the company

We are following the procedure for different areas of operations as under:

This procedure has been explained to all concerned, dealing officials and no deviations are permitted at their level if any deviations required they have to obtain approval from the director.

  1. Registration and documentation and updations

    The branches/ sub brokers given duly stamped empty client agreement forms similarly at head office stamped empty KYC forms are kept ready. As and when the client approaches for account opening the due diligence of the client is carried out by the director at head office and by the branch head/ sub broker at their offices.

    The required copies of documents like PAN Number, address proof and bank details DP details etc. are collected and verified with original and originals are returned back to the respective clients. PAN number is verified from Income Tax web site.

    The action taken report data is checked before activating the client. Further in person verification is carried out by concern officials mentioned above. The client is made to understand risk in dealing in capital market during in person verification.

    Then only the client is activated in UCC and concern client is informed about the Client ID and make to understand the risk dealing in the capital market.

    Any up-dations in address, bank details, DP details etc. the dealing officials collect the proof and verifies with originals and update in back office and this papers are kept with respective KYCs .

    All KYCs are stored client code wise Branch wise / sub broker wise and easily accessible.

    No client is entertained if he walks in for client registration. We verify the financial details from his bank account and copy of latest income tax return.

    We have adopted the concept of maker and checker while dealing with KYC in order to avoid any mistakes.

    The copy of client registration form is given to the client and acknowledgement is obtained. We do not offer any promotional schemes nor offer any thing free to the clients. We do not out source client registration work.

    Total numbers of active clients are 5500

  2. Sales Policies followed by the member

    We do not have the sales personnel or relation ship managers as such and we do not induce any client to trade nor do we give our views about market movements. We also do not provide any market tips. All trades exclusively occurred at the instances of the clients. Whenever we decide to consider for opening any new branches or accepting any new sub broker details market survey is conducted and complete due diligence of sub broker is carried out.

  3. Closures of client account and dormant accounts

    Any clients who has not traded over six month and have zero balance or insignificant debit or credit balance are treated as dormant accounts. The dealing officials are advised to re confirm the trade request made by such account holders. The clients who have not traded over two years are deleted from the server and if client desires to trade new KYC is obtained.

    Any accounts where there is no trading activity over two years and having no significant balance such accounts are closed on annual closing of books of account and the balance amount on those account is transferred to Kasar account and such accounts are closed . A letter is obtained from the client to close the account. In case client has not traded over six month such client places the order, re- confirmation is obtained by calling the clients.

    We do not allow client to transfer from one branch/ sub broker to another branch/ sub broker.

  4. Order receipt and execution

    Orders are received either on phone or in person at head office, branch/ sub broker office. They are punched in to the systems carefully as instructed by the client. In case of client trading by telephone, client's voice is recognized by concerned operators. In case of doubts operators are instructed to reconfirm by calling the client at the registered contact numbers with us.

    We do not have telephone recording system for orders.

    We convey over telephone in case trade has taken place against his limit orders.

  5. Sending contract notes, daily margin statement quarterly statements of accounts to the clients

    We print contract notes in duplicate. Original copy is sent to clients and acknowledgment of client is obtained in duplicate copy and maintain day wise.

    The contract notes are sent through ECN and the acknowledgement is obtained through ECN Logs In case bounced mail we send hard copies and acknowledgment is obtained .The designated email ID and password is issued to the client through a welcome letter. In case client desires to change his/ her Email Ids the letter to that effect is obtained and change is carried out.

    We send electronically on daily basis the outstanding positions along with M To M, margin paid and short fall in margin (if any) to each client. The margin shortfall is monitored by the director on daily basis.

  6. Collection of pay in , margin , limits setting for exposures & turnover for clients, terminals, branches & sub broker level (Risk Management)

    The director continuously monitor for ensuring each and every clients makes the PAY IN in-time. In case of delay from clients side in PAY IN appropriate action is taken by the director. The trading limits are reduced or zeroed in till such time the full PAY IN is received. Similarly the branch/ sub broker limits are also reduced or closed. Normally, we face the issues of timely PAY IN from the clients when market is falling, in such event the director calls each and every client to either square up their position or make the PAY IN on next day morning. In the event of any doubt the positions are squared up if the market is continuously falling and most of the times our clients have buy positions.

    We have written down policies for risk management and which is also exhibited to the clients.

    We debit late payment charges in the case of late payment received against the debit balances to the clients.We do not do any funding to clients.

    We do not allow any third party transfers in any client accounts nor do we accept cash or DD or bankers cheques.

  7. Monitoring debit balances

    The director continuously monitors debit balances and the follow up at client level as well as at branch/ sub broker level and every day the statement of outstanding is send to each dealing offices. The old debit balances over 15 days are watched and trading limits are closed. In the event net debit over 90 days are treated as bad and appropriate action is taken for recovery there of.

  8. Liquidation of client position

    In case when client do not pay short fall in margin on T + 1 basis we telephone the client and squared up of his/ her positions. Provided client do not assure for the payment in a day or two.

    Client will not authorize the square up his position we do not maintain the record of telephone calls made for margin calls. However, such actions are resorted to, in emergencies only.

  9. Policies for Internal Shortages

    Clients are instructed not to sale securities purchased yesterday in the event of sale stocks purchased on previous trading day and received short from the exchange it goes to auction and the client's account is debited on account of auction. We do not hold any securities of the client unless payment is outstanding over Rs. 1 Lac.

  10. Transfer of trades

    We do not transfer any trades in back office. The transfer of trades on account of mistakes done by dealing operators are only transferred as per the system lay down by the exchange. However, such transfer of trades are very few and on account of mistakes done by operators. The operators are trained and warned for more then one such mistakes.

  11. Investor's redressed Mechanism

    Any complain is received on phone or orally the first thing we ask them to give it in writing. Complain is entered in complain register and put up before the director. The director issues appropriate instructions and the resolution are arrived at. However there are no complains as such during the period.

    The complain register is maintained at head office clients are informed about the E mail for investor's grievances through contract notes.

    The director monitors the pending investor complains and also calls the client and the branch/ sub brokers in charge immediately after market hours and appropriate action is taken for rederesal and necessary instructions are issued to the concerned officials.

    The complaints are handled by the director.

    However there is no complaint pending as on the date.

    The director during the personal hearing with the client examines all aspects and also verifies relevant records and payments made by the clients.

    We do not maintain more then one back office software.

    We do not operate on POA for clients trading accounts.

  12. Allotment, surrender trading terminals

    We have CTCL as front-end. We have allotted client id and default password to all our branches and sub brokers based on appropriate NCFM certificates and the information is up loaded to the Exchange in required modules.

    At head office we use NEAT and NEAT OP. the IDs have been created and required information have been uploaded to the exchange and supported by NCFM certificates

    All CTCL IDs are uploaded to the exchange in ENIT and after successful up-ladation, branches are allowed to log in. The limits are set based on the deposits given by the branch/ sub brokers.

    We carry out surprised inspection of the branches and ensure that no unauthorized use of the trading terminal is done by the branches. We also maintain the branch inspection report.

    The procedure for opening and closing of branches/ sub brokers is explained at Point No. 02

    We convey to the clients of the closed branch/ sub brokers by telephone.

    In case client desirous to trade he is conveyed over telephone. We have a check list which list downs the steps followed for opening and closing of the branch/ sub brokers.

    In case of closing the business with sub broker the cancellation procedure like issuing public notice and surrendering the sub broker registration to SEBI the exchange.

  13. Payments, receipts of fund and Securities from / to clients.

    The pay out is made and pay in received from the clients through a designated bank account declared by the clients. Any PAY IN cheques is received from any other accounts is rejected and if the client is produces the proof of account , in such case the additional bank details is uploaded to the back office after verification of documents. We do not use clients stocks for any other purposes other than making pay in on his behalf. No third party transfers of securities are permitted

  14. Receipts, deliveries of securities from/ to clients

    The pay out is made and pay in received from the clients through a designated DP account declared by the clients. Any PAY IN is received from any other accounts is rejected and if the client is produces the proof of account , in such case the additional DP details is uploaded to the back office after verification of documents.

  15. Power of Attorney

    We do not have any Power of attorney in any trading accounts.

  16. Capacity of systems with reference to volume

    We have adequate and updated system installed at our Head office which addresses our trading as well as back office needs. However all the branches / sub brokers are allotted CTCL id, our system with reference to capacity is more than adequate.

  17. Branch audit

    We carry out branch/ sub brokers inspection every year and check all aspects as laid down by SEBI like sign board, display of notice board, SEBI certificate, contact person name and telephone number.

    Further, we also verify that no cash dealing is done by the branch.

    We further verify that the branch is not trading out side the trading system.

    Further we also verify that branch do not obtain the signed blank DP Instructions from the clients.

    We check from the clients that they receive statement of accounts, contract notes etc.

    We also maintain the report of branch/ sub broker's inspection carryout by us.

    We have appointed internal auditor as prescribed by the exchange with detailed scope as specified by the exchange. Any adverse remarks made by the internal auditors are placed before the board and corrective action are undertaken immediately.

    No new branches are opened without survey conducted in that area. In case we decide to open the branch the sub broker registration is obtained first and then only terminal is activated in case of sub brokers branches and company does not wish to open new branches own in the present circumstances.

  18. PMLA

    We have a separate a written down policy which has been explained to all our dealing officials. The policy is regularly reviewed by the directors.

    Due diligence is carried out for
    1. Opening a client account
    2. Entering in to a sub broker agreement
    3. Appointing any personnel


    We carry out in person verification of the clients and therefore there are no benami accounts.

    We do not have any accounts as specified entities in guideline for anti money laundering by SEBI.

    In due diligence of the clients we also ask the client to fill up the introducers column and signature of the introducer is obtained.

    We are in the process of establishing automated alerts for dormant and suspicious transactions in the back office software.

    We have appointed the principal officer and the Anti Money Laundering Policy has been forwarded to FIU.

    We make aware our clients and branch in charge about Anti Money Laundering Policy and impart training to them from time to time.

    Further, we also classify the clients into different categories like high risk clients, low risk clients and medium risk clients with specific reference to ANTI MONEY LAUNDING policy.

    We have developed the reporting system for suspicious transactions.

  19. Internet trading

    We have obtained permission for internet trading and KYC agreement is obtained for clients wishing to do internet trading.

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