Policies and Procedures

This document from DDB is mandatory as per SEBI Circular No. MIRSD/SE/Cir-19/2009 dated 03.12.2009 and requires your utmost care, attention and understanding.

Policy for Penny Stocks: DDB 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 category and any other contracts which as per the perception of DDB are extremely volatile or subject to Market manipulation and/or depending on the market conditions.
DDB shall have the prerogative to place such restrictions, notwithstanding the fact that the client has adequate credit balance or margin available in his account and/or the client had previously purchased or sold such securities/contracts through DDB itself. DDB and/or any of its directors, employees, associates, sub brokers, will not be held responsible due to losses due to such refusal.

Setting up Client’s Exposure Limits: DDB may from time to time vary limits (exposure limits, turnover limits, limits as to the number, value and/or kind of securities in respect of which orders can be placed etc.) on the orders that the client can place through DDB's trading system. The client is aware and agrees that DDB may need to vary or reduce the limits or impose new conditions for limits urgently on the basis of DDB's risk perception and other factors considered relevant by DDB including but not limited to limits on account of exchange/SEBI directions/limits (such as broker level/market level limits in security specific/volume specific exposures etc.), and DDB may be unable to inform the client of such variation, reduction or imposition in advance. The client agrees that DDB shall not be responsible for such variation, reduction or imposition or the client's inability to route any order through DDB’s trading system on account of any such variation, reduction or imposition of limits.
The client further agrees that DDB may at any time, at its sole discretion and without prior notice, prohibit or restrict the client's ability to place orders or trade in securities through DDB, or it may subject any order placed by the client to a review before its entry into the trading systems and may refuse to execute/allow execution of orders due to but not limited to the reason of lack of margin/securities or the order being outside the limits set by DDB/exchange/SEBI and any other reasons which DDB may deem appropriate in the circumstances. The client agrees that the losses, if any on account of such refusal or due to delay caused by such review, shall be borne exclusively by the client alone.
DDB has margin based RMS system. Total deposits of the clients (Funds and Securities lying with DDB either as Margin or in running account) are uploaded in the system and client may take exposure on the basis of margin applicable for respective security as per VAR based margining system of the stock exchange and/or margin defined by RMS based on risk perception. Any failure on the client’s part in payment of margins shall be viewed seriously and DDB is authorized not to allow the client any further exposure and also authorized to square off client’s existing position/s and/or sell the securities lying with DDB as collateral.

Applicable Brokerage Rate :Brokerage will be charged at the rates being agreed between the client & DDB within the limits prescribed by SEBI/exchange. The slab rates of brokerage fixed by DDB are function of the quality and cost of services provided to the client and the volume and revenue expected from an account. It shall be reviewed by DDB from time to time.
The brokerage shall however be exclusive of DP Annual maintenance charges, DP transaction charges/Pledge/Re-pledge/Demat/Remat charges, DP Inter settlement charges, Account Opening charges, Delayed Payment charges, Penalties levied by Exchange, Research advisory charges, Courier charges, Bank charges towards the cheques received unpaid, DP, Bank and other processing charges towards periodic settlement of Funds/Securities on periodic basis, Statutory charges payable to Exchange/SEBI/Govt. Authorities etc., SEBI/Exchange/Clearing Member Turnover charges, Other out of pocket and service related charges.

Imposition of Penalty/Delayed Payment Charges :The client agrees that DDB may impose fines/penalties for any orders/trades/deals/actions of the client which are contrary to this policies/rules/regulations/bye laws of the exchange or any other law for the time being in force, at such rates and in such form as it may deem fit. Further where DDB has to pay any fine or bear any punishment from any authority in connection with/as a consequence of/in relation to any of the orders/trades/deals/actions of the client, the same shall be borne by the client.
DDB is therefore authorized by the client to charge a delayed payment penalty, not exceeding 18% per annum, on account of delays/failure by the client in meeting the pay-in obligations on the scheduled date and also where the clients take exposure in F&O segment by depositing collaterals in a ratio which is disproportionate to the Cash versus collaterals ratios prescribed by the Exchanges. While levying delayed payment charges or interest on the debit balance in the running account of a client, DDB may not consider any credit balance in the other family or group account of the client.
DDB provides exposure against the upfront margin received in the form of cash/collateral from the client and the client also has the prerogative to demand withdrawal of cash and collaterals at his discretion, DDB shall not pay any interest or other benefit to the client for maintaining cash balances or depositing collateral margins with DDB

Shortages in obligations arising out of internal netting of trades:For internal shortages in BSE, the stocks are recovered by self auction at BSE on T+3 day and in NSE they are purchased from the market on T+3 day. The purchase consideration (inclusive of all statutory taxes & levies) is debited to the short delivering seller client.

The right to sell client’s securities or close client’s open positions:Without prejudice to DDB’s other right (Including the right to refer the matter to arbitration), DDB shall be entitled to liquidate/close out all or any of the clients position without giving notice to the client for non payment of margins or other amounts including the pay in obligation, outstanding debts etc. and adjust the proceeds of such liquidation/close out, if any, against the clients liabilities/obligations. The client shall ensure timely availability of funds/securities in form and manner at designated time and in designated bank and depository account(s), for meeting his/her/its pay in obligation of funds and securities. Any and all losses and financial charges on account of such liquidations/closing out shall be charged to & born by the client.

Restrictions/Prohibition to take further position or Closing Existing Position:Under following circumstances, the client may not be permitted to take any further position by DDB and/or DDB shall close existing position without any further intimation to the client:

• Failure      or delay to meet pay-in or margin obligation on time and/or to clear      outstanding dues to DDB.
• Repeated      bouncing of cheques of the client.
• Unnecessary/unwarranted      dispute from client with DDB without any substantial cause/reason.
• Client’s      attitude of not coming to an amicable settlement for any dispute that can      be settled without involvement of Exchange and /or SEBI.
• As      per findings of Risk Management department of DDB.
• Any      direction from SEBI/Exchange or such other authorities.
• Under      any such other circumstances as DDB may think just and proper on case to      case basis.

Temporary Suspending or Closing Client’s Account:Notwithstanding anything to the contrary stated in the agreement, DDB shall be entitled to terminate the agreement with immediate effect in any of the following circumstances:

• As      per Client’s prior written request in prescribed format submitted to DDB      at its Mumbai H.O. (subject to clearance of entire      outstanding/obligations).
• Dormant      or in-active status of client account beyond specified time limit as may      be prescribed by DDB and
• Under      any circumstances mentioned in point no.‘7’

Deregistering a client:Client’s Account may be suspended or closed by DDB from further dealing through DDB in following circumstances:

• As      per specific written request from client submitted to DDB at its Mumbai      H.O.;
• Any      direction from SEBI/Exchange or such other authorities;
• If      the action of the client are prima facie illegal/improper or such as to      manipulate the price of any securities or disturb the normal/proper      functioning of securities or disturb the normal/proper functioning of the      market, either alone or in conjunction with others;
• If      there is any commencement of a legal proceeding, including arbitration      against the client under any law in force;
• On      the death/lunacy or other disability of the Client;
• If      the client being a partnership firm, any steps taken by the Client and/or      its partners for dissolution of the partnership;
• If      the Client suffers any adverse material change in his/her/its financial      position or defaults in any other agreement with the Stock broker;
• If      there is reasonable apprehension that the Client is unable to pay its      debts or the Client has admitted its inability to pay its debts, as they      become payable;
• If      the Client is in breach of any term, condition or covenant of Agreement;
• If      the Client has made any material misrepresentation of facts, including (without      limitation) in relation to the Security;
• If a      receiver, administrator or liquidator has been appointed or allowed to be      appointed of all or any part of the undertaking of the Client;
• If      the Client have taken or suffered to be taken any action for its      reorganization, liquidation or dissolution;
• If      the Client has voluntarily or compulsorily become the subject of      proceedings under any bankruptcy or insolvency law or being a company,      goes into liquidation or has a receiver appointed in respect of its assets      or refers itself to the Board for Industrial and Financial Reconstruction      or under any other law providing protection as a relief undertaking;
• If      any covenant or warranty of the Client is incorrect or untrue in any      material respect;
• Based      on the recommendations made by the Branch Manager /Associate /Sub-broker      (eg., excessive speculations, un-cleared balances,etc.)
• If      the client is unable to fulfill any and/or all obligations towards the      exchange(s), SEBI, DDB on time.
• Non      updation of communications details viz., email id, Mobile no, Land line      details or it is found to be belonging to a third person.
• Client      lodges a compliant either directly with DDB or through Exchange relating      alleged unauthorized Trades being executed in the account.
• On      notices received from statutory, Government or Local authorities and      Income Tax, Service Tax, a Judicial or a Quasi Judicial authority, etc.
• DDB      may also close clients’ account any time at its sole discretion by giving      adequate Notice/intimation in advance.

Policy for Dormant/In-active account:As per DDB’s policy, the account in which no transaction of any nature has taken place during last twelve months shall be considered as Dormant/in-active account. In case DDB treats the account of client as Dormant/in-active account, the funds or securities lying with DDB shall be refunded/returned to clients immediately on demand by the client. In case DDB treats the account of client as dormant/in-active account, and if trade is executed in such account, then it is verified with client over telephone. In order to reactivate the inactive account, client needs to instruct DDB in writing in prescribed format in advance at its Mumbai H.O. Such written request DULY SIGNED BY CLIENT may also be sent by way of Fax on 022-22884564 to Compliance Officer or by e-mail to compliance department at compliance@dealdepot.in from client’s own e-mail account registered with DDB. DDB shall reactivate the said account subject to fulfilment of such conditions as DDB may consider fit and proper.

Policy for Client code modification/Error account :

• DDB      shall have the absolute discretion to accept, refuse or partially accept      the client code Modification requests based on Risk Perception and other      factors considered relevant by DDB; DDB and/or any of its directors,      employees will not be held responsible for Damages/losses due to such      refusal or due to delay caused by such review.
• Client      code modification requests will be strictly accepted only to rectify      genuine error in entry of client code at the time of placing /modifying      the related order; consequently dealers are expected to take utmost      care/precaution while execution of client trades.
• As      per SEBI circular dated July 5, 2011 on client code modifications, penalty      will be levied on all client code modifications w.e.f. August 1, 2011      (including genuine errors).
• DDB      will allow Modifications in the client Codes of Non-Institutional clients only      for the following objective Criteria provided there is no consistent      pattern in such modifications: Error due to communication and/or punching      or typing such that the original client code/name and the modified client      code/name are similar to each other. Modification within relatives      (Relative for this purpose would mean ‘Relative’ as defined under sec. 6      the Companies Act, 1956).
• For      easy identification of “ERROR ACCOUNT”, DDB have registered a fresh client      code No. 1011 & ERROR as “ERROR ACCOUNT” in Back office & same has      been uploaded in the UCC database of the Exchange.
• Any      transfer of trade (institutional or non-institutional) to “ERROR ACCOUNT”      of DDB would not be treated as modification of client code and would not      attract any amount of penalty, provided the trades in “ERROR ACCOUNT” are      subsequently liquidated in the market and not shifted to some other client      code. However operational costs as applicable & Profit/Loss from the      transaction will be transferred to the concerned Dealer/Associate.
• Client      Code Modification requests through “ERROR ACCOUNT” will be accepted only      till 3:30 PM IST.
• All      cases of modification of client codes of non-institutional trades executed      on the Exchange”, shall be liable for a penalty as laid down by regulators      from time to time [As per SEBI Circular No. CIR/DNPD/6/2011 dated July 5,      2011 a penalty of 1% of value of non-institutional trades modified will be      levied if value of non-institutional trades modified as a percentage of      total value of non-institutional trades executed is less than or equal to      5% and penalty of 2% if modification exceeds 5%, in a segment during a      month].
• In      addition to above it is well within rights of DDB to levy additional      penalties in case concerned Dealer/Associate fails to submit any sufficiently      valid reason for client code Modification.
• DDB      will levy Penalties as applicable in relation to client code modification      on next day of the Modification date, though Bills/Files in relation to      same may be provided by exchange on a later date.
• The DDB      shall conduct a special inspection of the concerned Dealer/Associate, if      modification exceeds 1% of the value of trades executed during a month and      take appropriate disciplinary action, if any deficiency is observed.

Policy on Pre-Funded Instruments:With reference to SEBI Circular No. CIR/MIRSD/03/2011 dated June 9, 2011 the drafted Organization policy on Pre-funded Instrument is as given hereunder:

• As a      general policy Prefunded Instruments are not accepted by DDB & clients      are advised to avoid use of pre-funded instruments for making payments.      The clients are also educated about the Exchange and PMLA rules &      byelaws.
• The      instruments received from clients are checked before depositing the same      into bank. If the instrument is identified as Pay Order/DD, then a      suitable Reason/clarification in requisite format is required to be      obtained from the client.
• If      the aggregate value of pre-funded instruments is Rs. 50,000/- or more per      client per day, we may accept the instruments only if the same is 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 either of the following:
      - Certification from the issuing bank on its letterhead or on plain paper      with the seal of the issuing bank.
      - Certified copy of the requisition slip (portion which is retained by the      bank) to issue the instrument.
      - Certified copy of the passbook/bank statement for the account debited to      issue the instrument.
      - Authentication of the bank account number debited and name of the      account holder by the issuing bank on the reverse of the instrument.
• The      details of the instrument must be tallied with the detail provided by the      clients in KYC before entering into back office software. In case of      mismatch is identified, it should be reported to department head/      Management/ key personnel’s for taking appropriate action.

Policy on Unauthentic News Circulation:This policy is made in compliance with the SEBI Circular no. Cir/ISD/2011 dated 23rd March, 2011 in connection with unauthenticated news circulated by SEBI Registered Market Intermediaries through various modes of communication. Accordingly, No Employee /Representative Shall

• Communicate      or counsel or procure, directly or indirectly, any unverified information      or rumors related to securities, to any other person(s).
• Encourage      or circulate rumors or unverified information obtained from client,      industry, any trade or any other source without verification.
• Access      to blogs, chat forum and other sites and if accessed shall either be      restricted under supervision of director/compliance officer or should not      be accessed at all.
• Use      any blogs/chat forums/ messenger sites for divulging any unverified      information or for circulation any kind of rumors in the market.
• Circulate      any market related news received by him/her either in their official      mail/personal mail/blog or in any other manner, and such information      should be forwarded only after the same has been seen and approved by the      Compliance Officer of the company.

However, notwithstanding anything contained in above mentioned clauses will be applicable to any sort of communication required by the employee for/or in relation to any assignment of the Company within ordinary course of business or for pursuing any research for the development or/in the interest of the company.

Other general policies and procedures for dealing through DDB:

• DDB      reserves the right to accept an applicant as a client and is not obliged      to disclose reasons for not accepting the applicant as a client. Once the      account is activated, Client Registration Application Form will be      maintained by DDB.
• DDB      reserves the right to make such changes to policies as may be considered      necessary from time to time. Changes by Stock Exchanges/other Regulators      shall be with immediate effect, other changes shall be effective from the      time the client is notified thereof unless otherwise required by the      Rules, Regulations & Bye - Laws of the Stock Exchange(s) or Rules      & Regulations of SEBI.

TRADING:

• All      the orders placed by client with DDB are on client’s own account and not      on behalf of his clients. The client shall not indulge in any sub-broking      activities or issue bills/contracts/confirmation notes to anyone else for      the trades done by the client. The client therefore will not require split      confirmation memos for orders executed by DDB on his behalf.
• The      securities sold through DDB on client’s account are belonging to client as      legal, rightful and beneficial owner/s. The client takes full      responsibility of any dispute regarding the title of the securities sold      through DDB and state that he will deal only in those securities that      would be rightly owned by him.
• Any      queries related to securities delivered by DDB, would be brought to the      notice of DDB or otherwise it can be presumed that the client has checked      all the securities received by him & in case of physical delivery they      are good as per the prevailing norms.
• The      client shall not sell any securities until he has confirmed clear balances      of holding of the same in his demat account. Further in case he buys      securities in one Exchange and sells the same on another Exchange, or if      he buys securities and sells back the same before having received them in      our demat account, the client hereby confirms that he shall be fully      responsible in the event of any auctions happening of his sale obligation,      due to the deliveries having been received short from the purchasing      exchange and/or due to the operational/procedural delays for inter      depository and time taken by depositories to execute the same and/or for      any reason whatsoever. Also all such consequences, auctions, penalties or      any other financial loss or charges will be purely and entirely on      client’s account and DDB will in no way be responsible and/or liable for      the same.
• The      Exchange may annul a trade suo-moto without giving a reason thereof. In      the event of such annulment, DDB shall be entitled to cancel the relative      contract(s) with the Client.

PAYMENTS OF FUNDS AND SECURITIES:

• In      case of shares purchased being sold the next day or later on the same      exchange or any other exchange it is hereby reconfirmed that the client will      make the payments first and then receive the payments on payout of the      sale transactions.
• Client      agrees that while making payout of the securities, as a RMS Policy DDB      will hold Securities equal to double the value of debit in client's      account(Except Debit up to Rs.50); subject to Exchange Bye Laws relating      to settlement of funds & securities; for this purpose credit in      respect of any non-cleared cheque will not be considered.
• The      client agrees that it will not make any third party payment from any account      (other than what is specified in the Account Opening Form). In case of      such payment being made, the client agrees to intimate DDB, in writing of      the same and provide necessary documents as proof that the client holds      the account in his/its name. The client also agrees that the broker may      reject such third party cheques/payment and the client will not hold the      broker responsible for any loss incurred in such cases.
• The      client hereby agrees that he shall not deposit post dated cheques, excess      payment cheques, if any, received from the associate for any reason      whatsoever and bring it to the notice of associate and DDB. The client      also agrees that he will not initiate legal proceedings against the      associate and DDB in such case.
• DDB      will settle client's accounts in accordance with Exchange/SEBI guidelines      on a Monthly/Quarterly basis as instructed by client; client agrees that DDB      shall retain an amount up to Rs. 10000 towards DP, KRA, ISB2P & to      address the administrative/operational difficulties in accordance with      Exchange rules/Circulars relating to settlement of funds & securities;      Nevertheless client can anytime withdraw amount retained at the time of      settlement by specific instruction to DDB in this regard.
• Stamp      duty, Turnover fees, Service tax, any other charges may be levied by DDB      on contracts. The same is collected by DDB from the clients and paid to      the relevant government agencies, exchanges, the professional clearing      members or to meet any specific expense of the organization. Any      discrepancy regarding the same has to be brought to the knowledge of DDB      within reasonable time.

INVESTMENT ADVICE:

• The      client acknowledges that DDB shall not be liable to provide him with any      legal, tax, investment or accounting advice or advice regarding the      suitability or profitability of a security or investment.
• The      client agrees that in the event of DDB or any employee or official of DDB      providing any information to the client, the client may act upon the same      at the sole risk and cost of the client and DDB shall not be liable or      responsible for the same.
• The      client assumes full responsibility with respect to his investment      decisions and transaction.
• DDB,      its officers, directors, agents and affiliates will have no liability with      respect to any investment decisions or transactions with client.
• DDB      does not intend to give and the client acknowledges that DDB shall not be      liable to provide to the client, any tax, legal or investment advice of      any kind or any advice or opinion with respect to the nature, potential      value or suitability of any particular securities trade, transaction,      investment or investment strategy.
• The      client understands and agrees that in case the client receives or accesses      any investment research reports or any investment or other recommendations      or advice from DDB/any associates/any employee/official of DDB or      associate/ on DDB’s website or that of any associates, the same is on a      no-liability, no guarantee, no-solicitation and no-obligation basis. Any      decision, action or omission thereon by the client shall be entirely at      the client’s risk and should be based solely on the client’s own      verification of all the relevant facts, financial and/or circumstantial      and/or a proper evaluation thereof and/or the client’s investment      objectives. DDB shall not be responsible or liable for the same for any      reason whatsoever.

GENERAL:

• The      client may download his account statement / other documents from DDB's      website www.dealdepot.in on regular basis and retain such records. (The      client should take all the necessary steps to ensure confidentiality and      secrecy of the login name and password. In case of his inability to access      the system the client should lodge a complaint with DDB; else it would be      presumed that all the documents have been properly accessed.) Any      discrepancy in the account statement sent shall be brought to the notice      of DDB by the client in the writing within thirty days of date of receipt      of statements, failing which the account statement appearing in the books      of DDB shall be deemed to be correct and accepted by the client.
• DDB      shall ensure due protection to the clients regarding client’s right to      dividends, rights or bonus shares, etc. in respect of transactions routed      through it and it shall not do anything which is likely to harm the      interest of the clients. DDB shall not be liable for any real/notional      loss suffered by the clients, if the client fails to apply for such      corporate benefits in time for the shares held by DDB on behalf of the      client. In some cases, DDB at the client’s request may apply on behalf of      the client for the Rights issues/Open offer for the shares held by DDB on      behalf of client. DDB shall not be liable for any loss/claim whatsoever      incase such application is rejected by the Registrar/Company Manager to      the issue for any reason.
• DDB      reserves the sole and exclusive right to determine the Channels through      which the client may access/receive the Services. DDB reserves the right      to, from time to time, discontinue the availability of any Channel to the      client without any prior notice and without assigning any reasons      whatsoever for such discontinuance. The client/associate has read,      understood and agrees to comply with the provision of Money Laundering Act      2002 applicable from 01.07.05. DDB PMLA Policy along with self explanatory      presentations is available on our website www.dealdepot.in for your ready      reference & understanding.
• Under      SCHEDULE II of the Securities and Exchange Board of India (Stock Brokers      and Sub-brokers) Regulations, 1992, under CODE OF CONDUCT FOR STOCK      BROKERS [Regulation 7] B. Duty to the Investor, as per Clause (5) Business      of Defaulting Clients: “A stock-broker shall not deal or transact business      knowingly, directly or indirectly or execute an order for a client who has      failed to carry out his commitments in relation to securities with another      stock-broker. The Client understands that he is required to provide DDB      with details of any dispute or default with any other stock broker/trading      member and that he must keep that information updated as and when      developments occur in that regard. In order to be able to fulfill this      statutory requirement as well as to ensure that genuine investors are not      put into increased risk of losing their funds or securities lying with DDB      due to a default by DDB caused by any fraudulent or defaulting client who      may habitually commit fraud or default on DDB, the client hereby expressly      authorizes DDB to disclose/provide to any trade body, association of stock      brokers/trading members including the Association of National Exchanges      Members of India (ANMI), related website(s), or any organization which      maintains such a dispute or default database for the purpose of sharing      the information with stock brokers/trading members, his registration and      identification details, his transactions and accounting details as well as      any other details relating to any dispute with the client (sufficient if      deemed as dispute by DDB), or default by the client, in fulfilling his      obligations to DDB. The Client agrees and confirms that he shall not act      or make any claim against any body or organization or database to whom      such information is furnished and upon settlement with DDB shall have the      information removed through DDB.

Note :  DDB hereby states and informs that it undertakes Proprietary trading in addition to client based trading.

Introduction

This policy outlines the procedures for clients of DealDepot Brokerage Pvt Ltd to voluntarily freeze or block online access to their trading accounts in case of suspicious activity. This functionality empowers you to take control and safeguard your account if you suspect unauthorized access or unusual trading activity.

Communication Channels

You can request a freeze/block on your trading account through two methods:

1. Telephone: By calling from your registered mobile number on our dedicated hotline at +912269175213.
2. Registered Post: By sending a written request to 904, P J Towers, Dalal Street, Fort, Mumbai, Maharashtra, India 

Actions Upon Request

Upon receiving a validated freeze/block request, we will take the following actions within 15 minutes during trading hours (9:15 AM to 3:30 PM) and by the start of the next trading session outside of trading hours:

• Freeze your online access to the trading account, preventing any login attempts.
• Cancel all pending orders in your account.
• Send a confirmation SMS and email notification to your registered contact information, informing you about the freeze, cancelled orders, and the process for reactivation.
• Provide details of your open positions (if any) and their expiry information within one hour of the freeze to eliminate unwanted delivery obligations.

Re-enabling Online Access

To re-enable online access to your trading account, please contact our customer support team. We will perform necessary due diligence to confirm your identity and reactivate your account.

Clarifications

• This freeze/block only applies to your online access. Your underlying investments and positions remain unaffected.
• Our risk management activities will continue to function normally even with a frozen online access.
• A freeze request does not deactivate your Unique Client Code (UCC) with the Exchange.

Disclosure and Communication

This policy is an integral part of our Risk Management Policy.