Internal Procedure Policy

INTERNAL CONTROL, POLICY & PROCEDURES

1. Introduction

MALOO EQUITRADE (hereinafter referred to as the ‘FIRM’) a partnership firm , registered under the provisions of the Indian Partnership act 1932, is a SEBI registered broker of the National Stock Exchange of India Ltd. (NSE) and MCX Stock Exchange Ltd (MCX-SX).

The firm has adopted various policies & procedures for internal control measures & tools for compliance of various Acts, rules & regulations of the Exchanges.

A. CLIENT REGISTRATION POLICY

New account opening form containing Rights and obligation documents, Risk Disclosure Document, Guidance for DO’s and Don’ts for trading on Exchange, Policies & Procedure must be be signed by the client. The client may or may not sign the Voluntary documents.

The required documents should be collected from the clients strictly as per the documents mentioned in the checklist of the agreement book.

Thorough checking by back office in charge including in-person verification, tallying the supporting documents with the original and interview of client.
After Signature of the Partner on behalf of ME the new Client Code is allotted
Uploading the client details to the NSE and KRA
On receipt of Valid Report, Confirming the codes allocated to clients the same is intimated over telephone and Welcome Letter alongwith photocopy of KYC along with documents received from the client is send to the client
The KYC Filing of Client Registration Kit & updation of Index
Periodical Review of financial data
Deactivation of Client Code on receipt of written documents from Client.
Intimation in writing to Client regarding deactivation of client code & reason thereof

Walk in Clients: The firm has decided not entertain Walk In Clients. All clients / would be Clients are required to submit proper references or introducers

Financial Documentation: All clients are required to submit updated financial data, namely, their Balance Sheet, Salary Income Certificate. Incase of re-activation of UCC, the clients are also required to submit written request. Clients, specially operating in F&O Segment are compulsorily required to submit their latest financial position every year without fail.

Maker & Checker Concept: The firm appoints different person for checking CRF/data submitted by client and data entered in computer for uploading to master file & the Exchanges. Even after uploading of data, the compliance officer checks the data entered from the CRF. All blank spaces in the CRF is crossed by the compliance officer, if found not crossed by the client.

Marketing Division: The firm does not have any marketing Division

Closure of Client Accounts/ Dormant Accounts: Clients accounts are closed either by client himself or action initiated by the firm. On receipt of written request from the client, the de-activates the client code in its front & back office. CRF form is marked closed only after proper verification of client’s ledger account & clearance received from accounts department regarding dues & margin. Moreover written communication is also sent to client confirming closure of his account.

Client’s accounts are also closed on action initiated by the firm in the following cases:

If client fails to meet his obligation within stipulated time or time provided by the firm
If clients fails to provide proper documents as required under SEBI rules & regulations even after repeated request by the firm.
If client is declared fugitive under any law in India or abroad.
If client is declared insolvent under any law in India or any criminal cases are filed or pending and such information is not disclosed at the time of registration with the firm

Transfer of Client from one branch to another: The firm may on written request received from a client, may allow the client to place his orders through another branch with a written notice to both the branches and/or office memo through email. However, if the client has also signed tripartite agreement, the client will be asked to provide ‘no objection’ from the sub broker and ‘sub brokers’ confirmation in writing to such request.

In case closure of any branch, the written notice with one month period is required to be given to all client of the branch giving them option to place their order in future from any other branch or corporate/head office or closure of their account with the firm.

The firm also mark all inoperative client account as ‘dormant’ till the same is closed or reactivated after written request is received from the client. UCC allotted to closed account is not used for next five years for any other new client.

B. TRADING POLICY

Active Client master list should be uploaded in the NEAT/BOLT trading terminal and all the orders from the clients should be checked for the client codes in the list. This will ensure minimal wrong code punching by the dealers.

Dealers should be vigilant in executing the orders of the client. They should check & report to senior authorities if any client is giving order of abnormal quantity or rates.

Every client should be contacted after the market hours for trade confirmation. The clients should be asked for the settlement of their obligation before settlement date of the exchange.

Every client must be attended by the staff allocated for the purpose and in his absence, compliance officer must ensure that client is attended by another dealer. Staff/ dealer should check the margin availability/credit limit of the client before executing any trade on his behalf.

No trades will be transferred to code other than entered in trading terminal after trading hours unless there is genuine mistake on part of the dealer of client mentioning the UCC at the time of placing the order. Transfer of code can be done only by the ‘compliance office’ during the allowable time frame by the exchange on system provided by it.

This step will help us to trace any discrepancies in the trade as well as timely receipt of cheques and securities from the clients and provide better service.

Contract Note

Contract note generation is done at Back office.

We are sending physical contract notes to the clients on daily basis. All the courier list is preserved properly for verification and resolving any non-delivery issue with the client. [we are sending the physical copy of contract note for returned/ or failure list on daily basis under Certificate of Posting through Post Office] Daily reconciliation is prepared for contract Note generated / /sent/returned/physically sent for better control & compliance.

PAYMENT POLICY

Payments to clients shall be made on Pay out basis i.e within 24 hours of pay out ( T+2 day) . Payment for outstation clients will be made on Pay-out basis on those branches where CMS facilities are available through HDFC/ AXIS bank. For other branches where CMS facilities are not available cheques would couriered to them from HO.
For clients who are desirous of keeping the pay out money with us as margin money can do so by submitting a letter to that effect mentioning therein not to issue cheques until a written request is made. However, such request at a time will be valid for one financial year only.
For clients who are desirous of keeping the pay out money with us for future transactions can do so by submitting a letter to that effect mentioning therein to keep their account as ‘running account’ and periodical cheques may be paid or received. However, the clients are required to neutralize their account once in ever one/three months of first transaction.
Clients, who have debit balance in one segment and credit balance in other segment will be paid only if their net balance is credit.
Margin Money to the clients will be returned only after adjusting debit balance, if any, in their account and/or if they have not defaulted in their obligation to deliver shares/securities.
Payments to the clients will be directly deposited in their account if mandate is given by them to this effect and they have account in the same bank, where the firm has its account.

RECEIPT POLICIES

Cheques from clients would be accepted only of those banks whose details have been provided during client registration.
2.No third party cheques would be accepted.
3. NO CASH PAYMENT IS ACCEPTED.
4. Clients are advised not deposit any cash/cheque directly to firm’s account. If cheque is deposited then intimation should be given in writing along with pay in slips otherwise credit will not given to client till proper documents are received from client.
5. Local Cheques received within 2 PM will be posted to the ledger on the same day. The effect of the cheques received beyond 2 PM would be given on the next day.
6. High Value cheque received from clients must be deposited within stipulated time.

7.For outstation branches , payments made by the clients would be not posted to the account of the clients unless HO receives credit for the same by the bank since outstation clearing cheque takes a period of 15-20 days to get cleared.

MARGIN POLICY

Capital Market Segment

No Purchase order will be entertained unless 10% upfront margin or credit balance is lying in the client account.
2.If, margin is specifically exempted to any client by the management, the same should be in writing.
3. In case, where margin is exempted to any client, the payment must be received within 48 hours of the execution of the order or within 24 hours of delivery of contract note, whichever is earlier.
4. No short sale will be allowed.
5. Sale order will be executed only on delivery of shares to ‘Ben’ account’ before orders are executed unless management allows the shares to be sold before receipt of shares.
6. On non delivery of shares in time due to fault of client, auction charges alongwith 10% extra fine will be payable by the client.

Future & Option Segment

No trading will be entertained unless up front margin is received in advance for value of trade to be executed on behalf of any client.
2.Margin will be accepted in ‘Cheque’ only unless management decides otherwise.
3. If margin is accepted in the form of shares, a hair cut on and above 40% will be computed on the price at the day end. All short fall will have to be met immediately by the client in cash or before opening of next trading session, which ever is earlier. No letter or written communication in this regard will be sent to any client for shortage of margin. The client will be responsible for any shortage of his margin with us for his outstanding trades.
4. No complain will be entertained for squaring off of outstanding trades or liquidating of margin by the management in absence of short fall of margin at any stage by the client. It will be sole discretion of the management to decide on ‘spot’ whether to square off outstanding trades of a client and margin be liquidated to meet the short fall.
5. Any amount payable on account of ‘Mart to market’ has to be paid in cash by the client before opening of next trading session. Amount paid must be in the form of clear bank balance or high value cheques given on the day of trade. If clear balance of margin/ MTM are not available, the management will at its sole discretion square off the trades of any client, which in its opinion can put the firm or its other clients to unnecessary market risk.
6. The firm reserves the right to liquidate a client’s position, if the client fails to maintain proper margin with the client. Further, firm also reserves the right to liquidate/neutralize a clients position in extra ordinary fall or rise in market price sensitive index, which in the opinion of the firm may have a bearing on the future survival of the firm and its business.

SECURITIES

Collection of securities

To ensure that clients are delivering the shares from their own account and all the deliveries to/from the clients correspond with the details provided by the client with their registration.
2. The statement should be checked with the securities obligation of the clients. Any third party delivery from the clients should not be delivered to Clearing house.
3. No credit to clients should be given even though shares received from third party has been delivered to clearing house due to any technical reasons beyond management’s control. If client provides sufficient written proof of ownership of such account/share, than after updating client database, client may be given effect of the same.
4. The reports provided by Exchange should be used to check whether there is any short pay-in/ out of securities to/from Clearing house.

Delivery of Securities

The firm will be making direct pay-out of shares to client account of which details are given in Client Registration Kits.
2. The direct pay-out file should be created by the backoffice software.
3. The instruction slip for shares delivery from the Pool account in case of client to client transaction or break delivery from the Clearing house should be signed by partners
4. Pay out shares shall be given to clients only when they have clear balance in their ledger account. (*the clear balance means that cheques issued by clients should have been cleared in bank.)
5. Shares of clients having debit balance will be kept with the firm as hold back margin.
6.The hold back margin account will be reviewed reviewed one in a month/quarter as desired by the client and shares will be credited to the accounts of the client if they have clear balance during the time of periodic review.
7. The value of shares to be kept in the holdback margin shall be to the extent the client is having debit balance calculated after taking hair cut into account i.e if the client is having a debit balance of Rs. 100000/- then the shares of worth Rs 140000/- (approx) will be retained in holdback margin and any excess shares shall be released to the account of the client.
8. In case shares are sold which are lying in our hold back margin a demat charges of Rs 14 per script will be debited to the client’s ledger account. Similarly in case of Inter-settlement demat charges of Rs 14/- per script would be debited.

INVESTOR REDRESSAL SYSTEM/ MECHANISM

The firm has a separate manual register for recording all clients related complain either received personally or via post or via email.
The firm has also designated email ID for sending complain by its investors or clients. The email Id has been disclosed in the Welcome letter sent to all clients at the time of registration as well as are mentioned on the contract note.
The firm has also kept manual investors complain register at its all branches and the same are verified by the compliance officer or its team of official from time to time.
The branch manager is responsible for sending the copy of complain received or written in complain register within 24 hours of the complain to compliance officer at head office either personally or via email.
On receiving the complain, the Compliance officer is authorised to dispose off the complain on its merit and write personally to the client of all action taken by him for satisfaction of the client.
If the compliance deserves the attention of the higher management or if the compliance officer is unable to dispose off complain to the satisfaction of the client or the exchange or the SEBI, the designated partners are informed of the situation by the compliance officer and all documents are placed before them within seven days of the receipt of the complain.
The designated partner’s review the pending complains every seven days along with matters needed their attention.

Branch Control Policy

A list of Branch will be displayed at Head Office with name of In-charge, Address, Contact Number & Email details.
Compliance Officer will be responsible for checking & controlling day to day affairs of the branches for any trading problems.
Branches will be opened for sole purpose of allowing clients to get their orders executed. Clients will be allowed to trade from only one specified branch for better control & service. Branch manager will be responsible for all activities & trades executed from any branch and solving any client related problems in consultation with compliance officer.
All Client Registration Kits will be approved at the head office and will be required to be counter signed by the branch head from where client has shown his interest to trade. Branch head will be responsible for all trades executed from his branch and putting all surveillance system to keep tab on ‘unfair’ trade practices like ‘123’ etc.
All contract notes will be generated at head office and will be distributed from respective branches within 24 hours of the trade. All clients will be required to specify the place of delivery of contract note.

BACKUP POLICY

All important data backup is taken on daily basis. Backup is taken to preventing loss of data in the event of equipment failure or destruction.

Backup Storage
There shall be a separate or set of storage for each backup day. The old data is kept for 7 days and after that the storage media is reused.

Monthly Backups
Every month a monthly backup shall be made using the latest backup on the USB hard disk and the same is taken to separate location by the partners

MALOO EQUITRADE(“ME”)

Policy regarding treatment of INACTIVE ACCOUNTS

INACTIVE ACCOUNTS: Where no transaction has taken place in client’s trading account during the last 3 months from the date of last transaction, then it will be considered as inactive accounts.

CONSEQUANCES OF INACTIVE ACCOUNTS:

On a client being declared inactive,

(1) The client’s funds and security account shall be settled.

(2) In case the demat account / bank account details are not available and the client is not contactable, the securities / funds are transferred into a separate account of MALOO EQUITRADE and held till such time.

(3) The account of the client shall be locked and the client shall not be permitted to execute a fresh transaction in the account.

CLIENT DECLARED INACTIVE VOLUNTARILY:

A client may write to ME stating that he wishes to transfer his account into an “inactive” status, based on which the account will be marked as such.

CLIENT DECLARED INACTIVE BY PASSAGE OF TIME:

Any client who has not traded continually for a period of 5 years and has also not renewed his running account authorization for 5 continuous years will automatically be moved to the “inactive” category.

CLIENT DECLARED INACTIVE BY LAW:

Any client will be moved to the “inactive” category if required by law.

PROCEDURE TO ACTIVATE THE LOCKED CLIENT ACCOUNT:

ü Any e-mail request to reactive the account and process the transaction. Such e-mail request shall be sent only from e-mail id of the Client registered with ME; or

ü A written request to reactive the account and process the transaction along with latest financial proof is taken duly signed by client and submitted to ME.

MALOO EQUITRADE (“ME”)

Policy regarding Modification of Client Codes.

With reference to SEBI circular ref. no. CIR/DNPD/6/2011 dated July 5, 2011 regarding modification of Client Codes of Non-Institutional trades. As per the SEBI circular, the following client code modifications would be considered as genuine modifications, provided there is no consistent pattern in such modifications and it can be done by principal officer only.

Where original client code/name and modified client code/name are similar to each other but such modifications are not repetitive.
Where original client code and modified client code belong to a family. (Family for this purpose means spouse, dependent parents, dependent children and HUF)

Shifting of any trade (institutional or non institutional) to the error account of the ME shall not be treated as modification of client code under SEBI circular dated July 5, 2011, provided the positions arising out of trades in error account are subsequently liquidated/closed out in the market and not shifted to some other client code in back office.
ME would be required to disclose the client codes which are classified as ‘Error Accounts’ to the Exchange at the time of UCC upload.
The principal officer will be responsible to monitor the Error account on monthly basis
The priicipal officer should make sure that Client code modification is not done in back office under any circumstances.

MALOO EQUITRADE

Unauthenticated News Circulated through various modes of communication Policy Pursuant to SEBI’s Circular No. Cir/ISD/1/2011 dated 23/03/2011, addendum Circular No. Cir/ISD/2/2011 dated 24/03/2011 and NSE Circular No. NSE/INSP/2011/114 dated 24/03/2011.

In view of the above Circular of SEBI & Exchanges, we have adapted the following as our policy on Unauthenticated News Circulated

Proper internal code of conduct and controls are there as separately mentioned in our policy on internal control.
Employees/temporary staff/voluntary workers etc. employed/working in our Office shall not be encouraged or they shall not circulate rumors or unverified information obtained from client, industry, any trade or any other sources without verification.
Access to Blogs/Chat forums/Messenger sites etc. are either restricted under supervision of some responsible employee of the company or access shall not be allowed.
Logs for any usage of such Blogs/Chat forums/Messenger sites (called by any nomenclature) shall be treated as records and the same should be maintained as specified by the respective Regulations which govern our company.

Employees are directed that any market related news received by them either in their official mail/personal mail/blog or in any other manner, should be forwarded only after the same has been seen and approved by the Compliance Officer of our company. If an employee fails to do so, he/she shall be deemed to have violated the various provisions contained in SEBI Act/Rules/Regulations etc. and shall be liable for actions. The compliance Officer shall also be held liable for breach of duty in this regard.

MALOO EQUITRADE

Pre- funded instruments / Electronic fund transfers Policy pursuant to SEBI’s Circular No. CIR/MIRSD/03/2011 dated 09/06/2011 and NSE Circular No. NSE/INSP/2011/118, Download Ref. No. NSE/INSP/18024 dated 09/06/2011.

In view of the above Circular of SEBI & Exchanges, we have adapted the following as our policy on Pre – funded instruments / Electronic fund transfers for the purpose of specifying the mode of receipt and payment of funds, has permitted to accept Demand Drafts from their clients.

If the aggregate value of pre-funded instruments is Rs. 50,000/-(Rupees Fifty Thousand Only) or more, per day per client, we may accept the instruments only if the same are accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank. The mode of certification may include the following :-ii. Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument. iv. Authentication of the bank account-number debited and name of the account holder by the issuing bank on the reverse of the instrument.
We may maintain an audit trail of the funds received through electronic fund transfers to ensure that the funds are received from their clients only.
iii. Certified copy of the passbook / bank statement for the account debited to issue the instrument.
i. Certificate from the issuing bank on its letterhead or on a plain paper with the seal of the issuing bank.

MALOO EQUITRADE

POLICY ON ANTI MONEY LAUNDERING MEASURES

PART – A: OVERVIEW

2. Introduction

2. Background

The Central Government passed The Prevention of Money Laundering Act, 2002 (hereinafter referred to as the ‘Act’) and was made public through Gazette of India published by the Department of Revenue under the Ministry of Finance w.e.f. 1^st July, 2005.

The Central Government in consultation with the Reserve Bank of India has framed rules called the Prevention of Money-laundering (Maintenance of Records of the Nature and Value of Transactions, the Procedure and Manner of Maintaining and Time for Furnishing Information and Verification and Maintenance of Records of the Identity of the Clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005 (PMLA Rules).SEBI has specified guidelines vide their circular ISD/CIR/RR/AML/1/06 dated January 18, 2006 for the intermediaries registered with SEBI u/s 12 of the SEBI Act. The guidelines have been framed under Rule 5 of PMLA Rules for maintenance of information in respect of transactions with its client referred to in rule 3 of PMLA Rules.

Since the firm is an intermediary registered with SEBI u/s 12 of the SEBI Act, the Act is applicable to it and the Firm and its representatives have to take steps as set out in guidelines issued by SEBI to discourage and identify any money laundering or terrorist financing activities.

While it is recognized that a “one- size- fits-all” approach may not be appropriate for the securities industry in India, each registered intermediary should consider the specific nature of its business, organizational structure, type of customers and transactions, etc. when implementing the suggested measures and procedures to ensure that they are effectively applied. The overriding principle is that they should be able to satisfy themselves that the measures taken by them are adequate, appropriate and follow the spirit of the measures and the requirements as enshrined in the Prevention of Money Laundering Act, 2002. (PMLA)

The firm thereafter adopted principles in implementing the various provisions of the Act and the Rules framed there under so as to maintain compliance of the same. In order to compile the various activities of the firm in line with the provisions of this Act, this policy has now been framed. The policy will be amended from time to time in line with the amendments made in the Act and the Rules framed there under and any other notifications and/or guidelines issued by SEBI.

As per provisions of Act, the Firm has to maintain a record of all the transactions, which include:

All CASH transactions of the value of more than Rs 10 lakhs or its equivalent in foreign currency.
All series of cash transactions integrally connected to each other, which have been valued below Rs 10 lakhs or its equivalent in foreign currency where such series of transactions take place within one calendar month.
All suspicious transactions whether or not made in cash and including, inter-alia, credits, or debits into/from any non-monetary account such as DEMAT account, security account maintained by the registered intermediary.

It may, however, be clarified that for the purpose of suspicious transactions reporting, apart from ‘transactions integrally connected’, ‘transactions remotely connected or related’ should also be considered.

3. Obligation to establish policies and procedures

In light of the above, the firm and its representatives have to adopt appropriate policies and procedures for the prevention of money laundering and terrorist financing and ensuring their effectiveness and compliance with all relevant legal and regulatory requirements. The Board of the firm or any other person or a group of persons as may be asked by the Board will:

ensure that the content of these Guidelines are understood by all staff members;
c.regularly review the policies and procedures on prevention of money laundering and terrorist financing to ensure their effectiveness.
d. adopt customer acceptance policies and procedures which are sensitive to the risk of money laundering and terrorist financing;
e. undertake customer due diligence (“CDD”) measures to an extent that is sensitive to the risk of money laundering and terrorist financing depending on the type of customer, business relationship or transaction; and
f. develop staff members’ awareness and vigilance to guard against money laundering and terrorist financing.

PART B: DETAILED POLICY

1. CUSTOMER DUE DILIGENCE PROCESS

Policy for acceptance of clients:

The firm’s main business is Stock broking and governed by the byelaws, rules, and regulations of the SEBI and the recognized Stock Exchanges. The authorities have specified minimum documentation and verification required before opening an account of a client, which is quite extensive. Apart from that the authorities have made rules and regulations and issued circulars from time to time for proper governance of securities market. Compliance of these rules and regulations ensures that all the transactions have proper audit trail as well as client verification. However, all representatives of the firm must ensure following while opening an account of a client and doing transaction with them:

Individual Clients

Generally a client isintroduced by another existing client. However, if a client approaches directly, a proper verification of address, occupation and credential must be carried out by the Compliance officer.
b. Know your client (KYC) / Client Registration form must be duly filled up and the information regarding residence/correspondence address, bank details, depository details must be verified with the original documents and if required from any other authentic sources.
c. The Client must provide a recent photograph and necessary identity proof as specified in the KYC form.

Non Individual Clients

The firm will open a trading account for Non-individual entity, if the partner/ director/ karta of Partnership firm/ firm/ HUF of such entity is our client and he/she has beenproperly verified as mentioned for individual clients.
b. Copies of PAN card, financials for last 2 years or from inception of such entity if such entity is not older than 2 years, must be obtained strictly.
c. Shareholding pattern and list of controlling persons must be obtained
d. Photograph of each partner / Whole time Director/Karta/controlling person and details must be obtained as specified by the SEBI and Stock Exchanges.

Risk-based Approach

Each Registration form and Agreement must be reviewed by a senior manager before allowing any client to transact with us and a client may be graded with High risk. All the clients of special category as mentioned below should be marked High risk:

1) Non resident clients

2) High networth clients

3) Trust, Charities, NGOs and organizations receiving donations

4) Companies having close family shareholdings or beneficial ownership

5) Politically exposed persons (PEP) of foreign origin

6) Current / Former Head of State, Current or Former Senior High profile politicians and connected persons (immediate family, Close advisors and companies in which such individuals have interest or significant influence)

7) Companies offering foreign exchange offerings

8) Clients in high risk countries (where existence / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy, Countries active in narcotics production, Countries where corruption (as per Transparency International Corruption Perception Index) is highly prevalent, Countries against which government sanctions are applied, Countries reputed to be any of the following – Havens / sponsors of international terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent.

9) Non face to face clients

10) Clients with dubious reputation as per public information available etc.

The KYC forms of clients marked as High Risk must be verified with the present status of the clients and financial credentials must be monitored by a senior person of the organisation.

Any client who transacts only once or twice in a year, proper verification must be done before doing any transaction with the client.

2. RECORD KEEPING AND RETENTION

The firm is maintaining records as per SEBI Act, 1992, Rules and Regulations made there under, PML Act, 2005 as well as other relevant legislation, Rules, regulations, Exchange, Bye laws and circulars. Record keeping as well as accounting system has to be improved as and when required. We ensure that sufficient information is available to reconstruct individual transactions.

Suspicious Transaction Monitoring & Reporting

The firm has taken appropriate steps to enable suspicious transactions to be recognized and has appropriate procedures for reporting suspicious transactions. The firm has made a list of circumstances, which may be in the nature of suspicious transactions as given below. This list is only illustrative and whether a particular transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances:

Clients whose identity verification seems difficult or where client appears not to cooperate
Clients in high-risk jurisdictions or clients introduced by banks or affiliates or other clients based in high risk jurisdictions;
Substantial increases in business without apparent cause ;
Report generated on monthly basis of transactions valuing more than 10 lacs in individual cases are to be sent for Money Laundering Control Officer or any other designated officer within the firm for his review & counter checking of client’s credentials.

The firm has made a policy to notify any suspicion transaction to the Money Laundering Control Officer or any other designated officer within the firm. The notification is done in the form of a detailed report with specific reference to the clients, transactions and the nature /reason of suspicion. It is ensured that there is continuity in dealing with the client in normal course until told otherwise and the client should not be told of the report/suspicion. In exceptional circumstances, consent may not be given to continue to operate the account, and transactions may be suspended, in one or more jurisdictions concerned in the transaction, or other action taken.

SIGNED BY:

Mr.Vikrant Maloo
(PRINCIPAL OFFICER)