Order receipt and execution.
DealDepot accepts client orders through the following channels:
- The DealDepot app (iOS and Android);
- The MoneyMaker Terminal (desktop);
- Call & Trade with a live dealer on the published phone numbers; and
- In-person walk-in at the registered office.
Before any order is forwarded to the exchange, DealDepot's Risk Management System (RMS) performs a pre-trade compliance check on every order — verifying margin sufficiency, segment authorisation (cash / F&O / commodities, where the client has opted in), surveillance flags (GSM / ASM / T2T / illiquid lists), and any account-level or regulatory restrictions then in force. Orders failing any check are rejected at source with a reason code, intimated to the client through the same channel from which the order was placed.
Call & Trade orders carry an additional charge of ₹50 per executed order, in addition to the brokerage and statutory levies. The Call & Trade charge is published on the tariff sheet and reflected on the contract note. Order execution is on a same-day basis, in line with the timelines set out in the Investor Charter.
Good-Till-Triggered (GTT) orders.
The GTT facility allows a client to place a buy or sell order with a pre-defined price condition that, when met, results in an order being released to the exchange. GTT orders are available only on client-login channels (the DealDepot app, web terminal, or browser-based access) — dealer logins do not have access to this feature.
Each GTT order has a default validity of 364 days from placement, after which the order is auto-cancelled. Three price-condition types are supported: price-below (triggers a market order when last-traded price falls below the trigger), price-above (triggers when LTP crosses above the trigger), and immediate (places a market order on placement). Stop-loss and target legs may be combined under a "one-other-cancel" relation; the main-stat order is independent of either.
Behaviour during corporate actions.
Where a corporate action — stock split, bonus, rights issue, merger, or any action materially affecting the underlying — would otherwise cause the trigger to be met at a stale or distorted price, DealDepot may:
- Cancel the unexecuted GTT order before the corporate action takes effect, to prevent execution at an erroneous price; or
- Retain the order, where the corporate action is unlikely to materially shift price (e.g., a routine dividend).
The decision rests with DealDepot. Clients are notified through the registered email, on-platform notice, and / or SMS before the start of trading on the relevant date. For queries on the status of a specific GTT order during a corporate action, write to backoffice@dealdepot.in.
Risk Management policy and pre-trade controls.
Margin requirements.
DealDepot collects margin per the SEBI / Exchange / Clearing Corporation prescribed norms. We do not, on a routine basis, offer additional intraday or positional leverage on top of the regulator-prescribed margin. The required margin is computed in real-time by RMS using the current Exchange-issued margin file and the prevailing SPAN / VAR / volatility parameters.
Exposure cap.
Trading exposure on each client account is capped daily by RMS at 75% of the client's calculated capital base (free funds plus pledged collateral, valued per the prevailing haircut). The 75% cap is an upstream control on how much exposure a client or dealer terminal can build up against the available capital — it limits position-loading at the order-placement stage. Where a client's capital base changes intra-day (additional pay-in, fresh pledge, or release of collateral), the cap is recomputed accordingly.
Pre-trade controls.
Every order is validated against the parameters described in Section 01 before being routed to the exchange. Orders for securities flagged for caution or short-listed under Exchange surveillance frameworks may be rejected, restricted, or required to meet stricter pre-funding norms (see Sections 07 and 08).
Provisions reserved.
DealDepot does not, as a routine practice, automatically square off intraday positions purely on the basis of mark-to-market loss percentage, nor on a fixed end-of-session timing. RMS retains the right to:
- Square off any position where the client's available margin falls into shortfall (see Section 05);
- Apply a discretionary square-off, including before market close, where in DealDepot's reasonable assessment the volatility of the underlying instrument or the size of the position warrants pre-emptive risk reduction;
- Introduce automated mark-to-market or end-of-session square-off thresholds in future — for example, an MTM trigger at 80% of available margin, or instrument-specific volatility-linked triggers — with reasonable advance notice to clients via email and on-platform notice.
Manual or discretionary square-off by RMS remains available as a risk-management tool, applied on a case-by-case basis as set out in Section 05.
Brokerage and other charges.
Brokerage rates and other transaction charges — statutory levies, Exchange transaction fees, SEBI turnover fee, GST, stamp duty, depository charges, demat AMC, and depository transaction charges — are set out in the DealDepot Tariff Sheet, available as part of the account-opening kit and on the Forms & Downloads page.
The tariff sheet may be revised from time to time. Any such revision is communicated to clients on the registered email at least 30 days in advance of the effective date — being the SEBI / Exchange-prescribed minimum and consistent with clause 47 of the standard Rights & Obligations document.
Brokerage and all transaction charges are reflected on each contract note. Contract notes are issued on T+1 from the head office, and statements (margin, account, securities) are issued in line with the timelines specified in the Investor Charter.
Late-payment penalty.
Where a client's trading-account ledger remains in debit beyond the settlement obligation date, DealDepot levies a delayed-payment charge of 18% per annum, computed on a simple basis on the daily debit balance. The charge is applied at month-end and reflected on the client's monthly ledger statement.
The 18% rate is on par with the standard rate prevailing in the Indian broking industry. It does not represent a debt-collection or punitive intent — it is a charge for the cost of the funds that DealDepot is required to fund into the Clearing Corporation on the client's behalf, and for the time value of the unsettled position.
Square-off and forced position closure.
DealDepot reserves the right to liquidate any open position in a client's trading account, without further notice and without liability for any resulting loss, in any of the following circumstances:
- Margin shortfall — where the client's available margin falls below the maintenance margin and the shortfall is not made good within a reasonable interval, taking into account market conditions and the size of the position.
- Ledger debit — where the trading-account ledger remains in debit beyond the settlement obligation date and the debit is not cleared within a reasonable interval.
- AML / surveillance flag — where a transaction or pattern of transactions in the account triggers an internal AML or market-surveillance flag and the position is judged to require defensive closure pending review (see Sections 07 and 13).
- Regulatory or law-enforcement direction — where DealDepot is directed by SEBI, the Stock Exchanges, the Clearing Corporation, FIU-IND, or any other competent authority to close out the position.
- Voluntary or compulsory account suspension — where the client has elected to freeze the account (Section 11) or DealDepot has elected to deregister the client (Section 12) and there are open positions to be closed.
Client code modification & error account.
Modifications to the client code on an executed trade are permitted only in exceptional circumstances — typically a genuine punching or typing error by the dealer at the time of execution. Modification is not a routine remedy and is not available to branches or Authorised Persons; it can only be effected from the head office.
The procedure is:
- The dealer reports the error to the head office Surveillance Department promptly on realisation.
- Surveillance examines the genuineness of the error — voice-recording review where applicable, time-stamp and audit-log analysis, impact assessment on the client's account.
- Where the error is established as genuine, the trade is transferred to DealDepot's Error Account and the client's code is restored to the original instruction.
- The position in the Error Account is squared off immediately. Any difference and loss arising from the transfer and squaring up is the responsibility of the dealer concerned and is borne by DealDepot, not by the client.
- The Surveillance Department's approval is required for every modification; the decision is ratified by the Director / Senior Management.
Modifications are subject to the Exchange's modification windows and per-day limits as published in NSE / BSE circulars from time to time.
Internal shortages from inter-se client netting.
Pursuant to SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/75 dated 5 June 2024 (opens in new tab) and the direct-payout-to-client-demat framework that took effect on 14 October 2024, securities purchased by clients are credited directly by the Clearing Corporation to the client's demat account, bypassing the broker's pool account. As a result, the legacy class of pool-account-related shortages no longer arises.
In the residual cases where an internal short position arises from inter-se netting between two of DealDepot's own clients on the same security, the shortage is routed through the Clearing Corporation's auction process per the framework specified by NSE Clearing / ICCL. DealDepot maintains real-time monitoring of client positions to identify potential shortage scenarios, and reconciles client holdings and obligations daily.
Charges to the client for an auction-settled shortage.
Standard delivery brokerage applies on the underlying trade. No additional administrative or handling charge is levied by DealDepot on the client for an auction-settled shortage. The client bears only the charges levied by the Clearing Corporation, in line with paragraph 5.2 of SEBI's June 2024 circular which expressly prohibits brokers from levying any charge over and above CC charges. Where charges are applicable, they are itemised on the contract note and the ledger.
Surveillance and processing of alerts.
DealDepot operates a market-surveillance framework covering both stockbroking and depository participant (DP) operations, in line with SEBI Circular SEBI/HO/ISD/ISD/CIR/P/2021/22 dated 1 March 2021 and NSE Circular NSE/SURV/48818 dated 1 July 2021, and the prevailing NSDL surveillance guidelines.
Stockbroking — internal alert criteria.
In addition to processing alerts received from the Stock Exchanges, DealDepot generates internal alerts on the following criteria:
- A single client or group of clients contributing more than 25% of the day's volume in a single scrip or single derivative contract.
- New clients, or clients reactivated after a significant gap, contributing more than 50% of the day's volume in a single scrip or contract.
- A client or group dealing frequently in small quantities in a scrip ("layering" patterns).
- Trading activity disproportionate to the income range or net worth declared at KYC.
- A client submitting modification requests to demographic details (address, email, mobile, bank) twice or more in a single calendar month.
- Clients with direct or indirect connection to a listed company who execute transactions ahead of the dissemination of price-sensitive information.
- A client or group contributing more than 20% of volume in any scrip on the Exchange's "information list" or "current watch list".
- Persistent profit / loss patterns that suggest transfer of profit or loss between connected accounts.
- A client holding more than 5% of the paid-up capital of a listed company who has pledged 100% of that holding for margin and who has significant trading volume in the same scrip.
- Clients matching any of the above criteria whose orders are placed through a dealing office geographically far from the KYC-registered address.
- Clients receiving shares of a listed company through multiple off-market transfers and pledging them.
- Multiple client codes trading from the same IP address.
- Clients connected through key KYC parameters (PAN, mobile, email, bank, address).
Depository Participant — internal alert criteria.
For DP operations (NSDL), the parallel set of alerts includes:
- Multiple demat accounts opened with the same demographic details — same PAN, mobile, email, bank account, or address, against existing demat accounts held with us.
- Bounced communications (email or letter) on the registered contact details.
- Frequent changes in demat-account details — address, email, mobile, authorised signatory, POA holder.
- Frequent off-market transfers in a specified period.
- Off-market transfers or pledge transactions not commensurate with the client's declared income or net worth.
- High-value off-market transfers immediately following a modification of demat details.
- Off-market transfers using reason codes such as gift-with-consideration or gift / donation to unrelated parties, where frequent.
- Newly opened accounts with sudden spike in transaction activity, followed by a quick return to zero or dormant state.
- Any other patterns indicative of market manipulation by the client.
Processing timelines.
Alerts are reviewed on an ongoing basis and processed within the following maximum windows:
| Alert source | Processing window | Reporting |
|---|---|---|
| Exchange-generated stockbroking alerts | 45 days from generation | Quarterly status report to NSE within 15 days of quarter-end |
| Depository-generated alerts (NSDL) | 30 days from generation | Adverse observations reported within 7 days; quarterly status to NSDL within 15 days of quarter-end |
| Internal alerts (broker / DP) | On generation; final disposition within the corresponding Exchange / Depository window | Adverse observations reported within 7 days of identification |
Reasons for any delay in processing are recorded on the alert. Internal escalation is invoked at day 20 (reminder to surveillance team), day 25 (escalation to Compliance Officer), and day 30 (escalation to senior management).
Maker-checker and approval.
A dual-control process is followed: the designated official ("maker") initiates review and analysis of the alert, and a second official — the Compliance Officer or Surveillance Head — ("checker") reviews and approves the disposition. Closures are documented with reasons and supporting evidence; actions taken (including STR filing with FIU-IND, Exchange / Depository reporting, or termination of client relationship) are recorded in the alert register.
Quarterly review.
A quarterly Management Information System (MIS) report is placed before the Board and the Designated Director, summarising alerts generated, closed, referred to the Exchange / Depository, and pending. Where a "NIL" position obtains in any category, a NIL report is filed with the Exchange / Depository within 15 days of quarter-end. The Surveillance Policy itself is reviewed at least once each financial year.
Refusal of orders for penny stocks and illiquid securities.
DealDepot reserves the right to refuse, restrict, or impose stricter margin or pre-funding requirements on orders in:
- Securities listed under the NSE / BSE surveillance frameworks — Graded Surveillance Measure (GSM), Additional Surveillance Measure (ASM short-term and long-term), Trade-for-Trade (T2T) segment, or T-segment;
- Illiquid options series, as identified by the Exchanges from time to time;
- Securities subject to circuit breakers, halts, or suspended for trading;
- Any other securities listed in the surveillance / cautionary lists published by the Exchanges from time to time.
A refusal may be applied at the order-placement stage (real-time rejection by RMS) or as a standing restriction on the security. Where a standing restriction is applied, the client is notified of the restriction and the rationale through email and on-platform notice. Refusal is also one of the dispositions available under the surveillance alert framework set out in Section 07.
Running Account Settlement (RAS).
In line with SEBI norms, DealDepot offers two running-account settlement cycles:
- 30 days (monthly), or
- 90 days (quarterly).
Each client may elect either cycle as part of the account-opening flow, and may switch between the two on subsequent communication. A switch must be communicated by email at least 7 days before the next scheduled settlement run; switches received within 7 days take effect from the following cycle.
If a client has not provided RAS consent — or has revoked it — credit balances in the client's trading-account ledger are returned to the client's registered bank account within 24 hours of pay-out, in line with the Investor Charter.
For trading accounts that have been inactive for more than 30 days during a settlement cycle (per SEBI's January 2025 ease-of-doing-business relaxation), funds are settled in the next monthly RAS cycle.
Inactive accounts.
A trading account is treated as inactive where there has been no qualifying activity for 24 consecutive months, in line with NSE Circular 80/2024 dated 25 October 2024.
Activities that prevent inactivity.
"Qualifying activity" includes any one of the following:
- Trading — purchase or sale of any security across any segment (cash / equity derivatives / currency derivatives / commodity derivatives / debt / online bond platform / EGR / Execution-Only Platform), or participation in OFS / buy-back / open offer through DealDepot;
- Investment activity — successful subscription to an IPO with allotment (not cancelled bids), Sovereign Gold Bond subscriptions, or mutual-fund investments (lump-sum or successful SIP installment) on the Exchange platforms through DealDepot;
- KYC update — a modification to the email ID, mobile number, or address in the KYC record through DealDepot, where uploaded to KRA and confirmed in Validated or Registered status.
Pre-flag communication.
Before flagging an account as inactive, DealDepot may send a courtesy communication to the client noting the upcoming flag. Such communication will not, and may not, ask the client to trade for the purpose of preventing the inactive flag — this is expressly prohibited by the NSE circular and may attract disciplinary action.
Treatment during inactive period.
An inactive account is marked accordingly on the broker back-office and in the UCC database of all relevant Exchanges. There is no other differential treatment of the account beyond this regulatory marking. Demat-account charges (AMC, transaction charges) continue to apply unchanged; the trading-account side has no AMC.
For inactive accounts:
- Where the inactive account holds a NIL balance (no funds, no securities), it is excluded from the daily Holding Statement and the daily Segregation & Monitoring of Collateral submissions to the Exchange / Clearing Corporation.
- Where the inactive account holds funds or securities balances, those balances continue to be reported in the daily submissions notwithstanding the inactive flag, until settled.
Credit balances are settled per the RAS cycle in force for the account (Section 09); pending corporate-action benefits are credited to the linked demat account in the normal course.
Reactivation.
An inactive account can be reactivated on a written request from the client. The request may be submitted by:
- Sending a duly-signed written request to DealDepot's Mumbai head office; or
- Email to compliance@dealdepot.in from the client's registered email ID.
The reactivation procedure includes:
- A fresh e-KYC with in-person or video in-person verification (IPV / VIPV), in line with the SEBI Master Circular on KYC dated 12 October 2023.
- Confirmation of the client's basic details — address, mobile, email, bank / DP account, income range. Where any of these have changed, supporting documents are obtained and the records updated in DealDepot's system and the UCC database.
- Verification of the client's KRA status. If the KRA status is not Validated / Registered (i.e. On Hold, Rejected, or Registered through another intermediary), the basic details are obtained, documents are uploaded to KRA, and trading is permitted only after the validated status is confirmed.
Once reactivated, the 24-month inactivity clock is computed afresh from the date of reactivation. Trading exposure is granted only after reactivation is complete and the client meets prevailing margin norms.
Untraceable clients.
Where DealDepot is unable to settle a client's account due to non-availability of bank details or non-traceability of the client, the unsettled funds are upstreamed to the Clearing Corporation under the SEBI upstreaming framework. DealDepot maintains an audit trail of tracing efforts. On receipt of a claim from such a client, the account is settled immediately, with payment / delivery only to the verified client.
Temporary suspension at client's request.
A client may at any time request a temporary freeze of online access to the trading account — typically in response to suspected unauthorised activity, a compromised credential, or a personal need to halt trading.
The procedure, modes of communication, timelines, treatment of open positions, and re-enablement requirements are set out in detail on the Voluntary Freezing of Trading Account page, in implementation of SEBI Circular SEBI/HO/MIRSD/POD-1/P/CIR/2024/4 dated 12 January 2024.
Client deregistration by DealDepot.
DealDepot reserves the right to deregister any client where any of the following circumstances arises:
- KYC information is found to have been falsified or materially misrepresented;
- The client is found to have engaged in market abuse, manipulative trading, fraudulent activity, money laundering, or any other conduct prohibited by SEBI / Exchange / Depository / FIU-IND or any competent authority;
- The client has remained in persistent default of settlement obligations notwithstanding repeated demand;
- DealDepot is directed by SEBI, the Stock Exchanges, the Clearing Corporation, FIU-IND, or any other competent authority to close the account or terminate the relationship; or
- The client has died (deregistration follows the standard deceased-client process per Exchange / Depository norms).
Notice.
Save in cases of fraud, market abuse, or regulatory direction — where deregistration takes effect immediately — DealDepot will give the client at least 30 days' advance notice of intended deregistration, by registered email and on the registered mobile, identifying the reason and the effective date. During the notice period, the client may close out open positions, withdraw credit balances, and arrange the transfer of demat holdings.
Anti-Money Laundering (AML / CFT) policy.
DealDepot operates an Anti-Money Laundering and Combating the Financing of Terrorism (AML / CFT) framework in line with:
- The Prevention of Money Laundering Act, 2002 (PMLA) and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 (PMLR);
- SEBI Master Circular SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78 dated 6 June 2024 on AML / CFT for SEBI-registered intermediaries; and
- Directions issued by FIU-IND and the Stock Exchanges from time to time.
Designated officers.
Tel: +91 22 6917 5201
The Principal Officer is responsible for day-to-day implementation of the AML / CFT policy, filing of Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) to FIU-IND, escalation of internal alerts, and ongoing employee training. The Designated Director provides board-level oversight and is accountable for the overall compliance of DealDepot with PMLA, PMLR, and the SEBI AML / CFT framework. The Board of Directors retains ultimate responsibility for AML / CFT compliance.
Risk-based approach.
DealDepot follows a risk-based approach to client due diligence, distinguishing between three risk categories:
| Category | Indicative client profiles | Periodic review |
|---|---|---|
| Low | Salaried employees, small retail investors, government departments, listed companies | Every 5 years |
| Medium | Self-employed professionals, medium-sized businesses, recently incorporated companies | Every 3 years |
| High | Politically Exposed Persons (PEPs), non-resident clients, high-net-worth individuals, trusts / NGOs / charitable organisations, companies with closely-held family shareholdings, clients from high-risk countries, non-face-to-face clients | Annually, with enhanced due diligence |
Customer due diligence (CDD).
- Identity is established at account opening using PAN, Aadhaar, photograph, signature, address proof, income proof, and bank-account proof (full list per the e-KYC page).
- Beneficial-ownership identification is performed for non-individual clients — natural persons owning more than 10% of shares / capital / profits, or otherwise exercising control.
- No anonymous, fictitious, or shell accounts are opened. Politically Exposed Persons require enhanced due diligence and senior-management approval before onboarding.
- Sanctions and PEP screening is performed on every onboarding through the integrated KYC platform.
Transaction monitoring and STR filing.
- All transactions are monitored against threshold-based and pattern-based rules in the back-office surveillance system (cross-reference Section 07).
- Anomalous patterns — unusual complexity, no economic rationale, possible ML / TF connection, deviation from client profile — are escalated to the Principal Officer for review.
- Suspicious Transaction Reports are filed with FIU-IND within 7 days of suspicion, with immediate filing for urgent cases. Cash Transaction Reports are filed in line with the prescribed thresholds.
Record retention.
Records of identification, transactions, and reports filed are retained for a minimum of 5 years from the date of the transaction or the closure of the relationship, whichever is later — being the statutory minimum prescribed under PMLR. Investigation-related records are retained for longer where ongoing.
Employee awareness.
AML / CFT awareness training is provided to relevant employees on an ongoing basis — initial training for new joiners, periodic refreshers, and special training for employees in client-facing or surveillance roles. Training records and attendance are maintained by the Compliance Department.
Code of fair dealing & conflict of interest.
Fair dealing.
DealDepot deals fairly and even-handedly with every client, irrespective of size, segment, or volume of business. We do not extend preferential treatment to any client in respect of order priority, margin terms, or access to information. Order routing follows time priority within the relevant segment.
Proprietary trading.
DealDepot does not currently undertake proprietary trading in any segment. We operate exclusively as an agent for client orders. In the event we begin proprietary trading in any segment in future, this disclosure will be updated to identify the segments and the operational segregations and conflict-of-interest controls in place.
Research and advisory.
DealDepot does not hold a Research Analyst (RA) or Investment Adviser (IA) registration, and does not publish research reports, recommendations, target prices, or investment advice. Any communication purporting to be DealDepot research, advice, or recommendation — irrespective of platform or channel — is not from DealDepot. See the Social Media Disclosure page.
No fund-based activities or POA.
- DealDepot does not undertake any fund-based activities. We do not offer Margin Trading Facility (MTF) or any form of broker-funded leverage.
- We do not take a Power of Attorney (POA) from clients. Where a client wishes to authorise limited-purpose access to the demat account for pay-in, this is effected through a Demat Debit and Pledge Instruction (DDPI) — see clause 7 of the MITC.
No referral commission to clients.
DealDepot does not pass on referral commission, rebates, or incentives to any client for referring other clients. This is a deliberate position taken to remain compliant with SEBI's restrictions on inducement-driven onboarding and to keep tariff levels uniform across the client base.
Non-discriminatory access.
All clients are entitled to the same suite of products, segments, platforms, and services subject to (i) the segment authorisations on their own account; (ii) the regulatory requirements applicable to their category of investor (resident / non-resident, individual / corporate, etc.); and (iii) the surveillance and risk-management restrictions described in Sections 02, 07 and 08.
Confidentiality of client information.
The collection, use, sharing, retention, and security of client personal information is governed by DealDepot's Privacy Policy, which complies with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and the SEBI / Exchange / Depository requirements applicable to client KYC and transaction data.
In summary, DealDepot:
- Uses client information only for the purposes set out in the Privacy Policy;
- Does not sell client information to any third party;
- Does not share client information for marketing or advertising purposes;
- Shares client information only with the Stock Exchanges, Clearing Corporations, NSDL, KRA / CKYCR, SEBI, tax authorities, banks and payment service providers, technology vendors under contractual confidentiality, and legal / audit advisors — to the extent required to provide our services and meet regulatory obligations.
The Grievance Officer designated under the DPDP Act, 2023 is the same Compliance Officer (Arjun Shah) — see Section 13 and the Privacy Policy.
Whistleblower mechanism.
DealDepot maintains a formal Whistleblower mechanism in compliance with SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/96 dated 4 July 2024 and NSE Circular NSE/INVG/65921 dated 31 December 2024, together with the SEBI (Stock Brokers) Regulations, 1992 and the SEBI (PFUTP) Regulations, 2003. The policy was approved by the Board on 31 March 2025 and is effective from 1 April 2025.
Who may raise a concern.
The mechanism is available to any person — employees (permanent, temporary, contractual), Directors and Key Managerial Personnel, Authorised Persons and their staff, clients, and any other person having dealings with DealDepot. Anonymous reporting is accepted, subject to the limitations described below.
What may be reported.
"Wrongful conduct" includes, without limitation: fraud, market manipulation, insider trading, front-running, unauthorised trading, creation of mule accounts, violation of SEBI regulations, breach of company policy, financial irregularity, and misuse of company resources or confidential information.
Reporting channel.
Whistleblower Committee.
Complaints are routed per a defined hierarchy — concerns about Board members, MD, CEO, KMPs, the Designated Director, or promoters are routed directly to the Committee (excluding any member who is the subject of the complaint); concerns about other employees or Authorised Persons may be routed via the Compliance Officer or directly to the Committee.
| Chairperson | Mr Piyush Shah |
|---|---|
| Member | Mrs Parul Shah |
| Member Secretary | Mr Arjun Shah (Compliance Officer) |
Handling timelines.
- Acknowledgement of complaint within 2 working days, with a unique reference number.
- Initial assessment within 7 days — determining merit and scope.
- Investigation within 30 days — evidence gathering, interviews, documentation, with strict confidentiality.
- Report and recommendation within 7 days of investigation closure.
- Committee decision and remedial action within a further 7 days.
- Total resolution within 45 days of receipt; complex cases may take longer with Committee approval.
Protection of the whistleblower.
The identity of the whistleblower is kept strictly confidential and disclosed only on a need-to-know basis, except where legally required. The Company prohibits any form of retaliation — termination, suspension, demotion, transfer, discrimination, harassment, denial of promotion or benefits, or any adverse action — against a whistleblower acting in good faith. Disciplinary action may be taken against any individual making deliberately false, malicious, or self-serving allegations.
Record retention and reporting.
Whistleblower records — complaint register, investigation reports, Committee minutes, action-taken records — are retained for a minimum of 8 years. A quarterly summary is placed before the Board / Audit Committee. A half-yearly summary report (or NIL report) is filed with the Stock Exchanges. Suspicious activity meeting market-abuse thresholds is reported to the Stock Exchanges within 48 hours of detection.
Periodic policy review.
This Policies & Procedures document is reviewed periodically by DealDepot's Compliance team and approved at the board level. Reviews are conducted:
- At least once each financial year as part of the standard compliance review cycle;
- On the issuance of any material SEBI / Exchange / Depository circular that requires re-statement of policy; and
- On any material change to DealDepot's products, segments, technology, or organisational structure.
The "Last reviewed" date at the top of this page reflects the date of the most recent review. Material changes are communicated to clients on the registered email and on the trading platform on next login.