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Pure Broking (Your Financial Broker)

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Policy Procedure

This document outlines various policies and procedures framed and followed by Pure Broking Private Limited (PURE BROKING) with respect to its dealing with its clients as stock broker on National Stock Exchange of India Ltd. (NSE) and Bombay Stock Exchange Ltd (BSE) (collectively hereinafter referred to as the Exchanges”). The policies and procedures as stated herein below are subject to change from time to time at the sole discretion of PURE BROKING, depending upon regulatory changes, its risk management framework, other market conditions, etc.

POLICY FOR ACCEPTING NEW CLIENTS

  • Collect and verify all original documents from the client.
  • Collect a certified copy of valid documents showing details of his permanent address, current address, PAN , nature of his occupation , financial status and also a recent photograph.
  • The PAN details of the clients shall be verified with Income tax site & then account will be opened as per the name appearing on the PAN card as per the Income Tax department.
  • The client shall be interviewed personally regarding the purpose of opening the account i.e: weather short term or long term investment, prior experience in stock market, income details, and introducer details.
  • On collection of requisite documents and carrying out in-person verification with the appropriate format. Then account will be opened and copy of the complete KYC will be handed over against acknowledgement which must be preserved on record.
  • This will be applicable for all segments including DP.
  • The concern officer who is carrying out in-person verification must put his/her signature on KYC form.

REFUSAL OF ORDER FOR PENNY/ILLIQUID STOCK

Following types of scrips will come under penny/illiquid stock if it falls in anyone category as mentioned below as part of the due diligence and risk management policy of pure broking.

  • Scrip which are quoting at less than Rs.10 /- on any of the Exchanges.
  • Scrips appearing in the list of illiquid securities issued by the Exchanges periodically.
  • Securities forming part of Trade-to-Trade settlement.
  • Securities forming part of Z group.
  • Scrips on which Exchange VaR is more than 50%
  • Scrip whose average daily volume is less than 15000 shares (collectively for all Exchanges) in last seven days.
  • Any Securities which in the opinion of PURE BROKING is likely to be penny Stock.

Trading in Penny stocks may be allowed to clients at the sole discretion of PURE BROKING. Also PURE BROKING may restrict the quantity/amount which a client may be allowed to buy/sell the penny stock. If the client wants to purchase Penny stocks then PURE BROKING may insist up to 100% advance payment! Sufficient clear ledger credit balance and similarly if client wishes to sell Penny stock, then PURE BROKING may insist that shares should be first transferred to beneficiary demat account of PURE BROKING. Under no circumstances, PURE BROKING shall be held responsible for non-execution/delay in execution of such orders and consequential opportunity loss or financial loss to the client.

SETTING UP CLIENT’S EXPOSURE LIMITS

Cash Segments
  • Exposure based and / or Margin based limits will be given to the clients for doing trades in Cash Segment.
  • Limits will be given on the basis of credit balance and / or collateral/securities of the client available with PURE BROKING valued after haircut.
  • Exposure based limit may be given to the client in certain multiples (multiples times may be decided by PURE BROKING at its sole discretion from time to time) on the available credit balance and / or on the collateral/securities of the client available with PURE BROKING valued after hair cut. However, on case to case basis the excess limits may be allowed.
  • Margin based limit may be given to the client on the applicable VaR as may be decided by PURE BROKING from time to time on the available credit balance and / or on the collateral / securities of the client available with PURE BROKING valued after hair cut. However on case to case basis the excess limits may be allowed.
  • Securities shall be valued after appropriate hair cut based on the type of scrips, nature of scrip, liquidity, volatility of scrips, etc. from time to time.

PURE BROKING may at its sole and absolute discretion allow clean exposure limit up to certain amount to the client without insisting for any credit balance and/or margin the quantum of clean exposure limit shall be decided by PURE BROKING. On a case-to­-case basis PURE BROKING may, at its sole and absolute discretion, give higher clean exposure limits to certain set of the clients. PURE BROKING reserves the right to withdraw clean exposure limit granted to the client at any point of time at its sole and absolute discretion. The client cannot and shall not raise any concern/dispute for the same and under no circumstances; PURE BROKING shall be held responsible for alleged / consequential opportunity loss or financial loss to the client.

Derivatives Segments
  • Margin based limits will be given to the clients for doing trades in Derivatives Segment.
  • Limits in Derivatives Segment will be given on the basis of free credit balance and / or collateral/ securities of the client available with PURE BROKING valued after hair cut.
  • Securities shall be valued after appropriate hair cut based on the type of scrips, nature of scrip, liquidity and volatility of scrip, etc. from time to time.
  • A client will be normally allowed limits till the client has free credit balance and /or collateral/ securities valued after hair cut. in case of excess limit is availed, the same will be regularized by the end of trading session / day. However on case to case basis the excess limit may be allowed to be carried forward.

PURE BROKING may from time to time depending on market conditions, profile and history of client, type and nature of scrip, etc., may its sole direction change rate hire cut applicable on the securities/ collaterals, number of times the limits to be given cash and / or derivative segments and take such step as PURE BROKING any deem necessary.

APPLICABLE BROKERAGE RATE

The brokerage rate applicable on clients trades will be as per agreed rates as mentioned in the Tariff Schedule at the time of opening the client trading account. Any higher brokerage will be levied only if agreed in writing between PURE BROKING and the client or by advance notice of 15 days by PURE BROKING to the client. If the client has any grievances’ regarding the rate of brokerage charged then he should intimate the same to PURE BROKING within four hours of receipt of the contract note/confirmation memo/bill.

The brokerage rate at no point of time will exceed the rates as may be specified by the Exchanges/SEBI from time to time.

Unless otherwise agreed the brokerage will be exclusive of the levies / charges as mentioned in The Tariff Sheet.

IMPOSITION OF PENALTY/DELAYED PAYMENT CHARGES BY EITHER PARTY, SPECIFYING THE RATE AND THE PERIOD

In case of delay in payment by the client to PURE BROKING on its due date, PURE BROKING in respect of such delayed payment will be entitled to recover late / delayed payment charges from due date. The said delayed payment shall include amounts payable by the client to PURE BROKING in respect of initial margin, mark to market, shortfall of margin(s) in prescribed modes, and/or other margins and pay in obligations. Late payment charges will be levied up to 2.5% per month or a part of month on delayed payment for the delayed period. The trade of the Client may not be executed by PURE BROKING if the client does not clear dues along with delayed payment charges. The client will not be entitled to any interest on the credit balance / excess margin available/kept with PURE BROKING.

A delayed payment charge is applied to act only as a deterrent measure. The client should not construe it as funding arrangement. The client cannot demand continuation of service on a continued basis citing levy of delayed payment charges.

PURE BROKING may impose fines / penalties for any order/ trades/ deal/ actions of the clients which are contrary to this agreement/ rules/ regulations/ byelaws 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 the PURE BROKING 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 order / trades / deal / actions of the client, the same will be borne by the client.

THE RIGHT TO SELL CLIENTS’ SECURITIES OR CLOSE CLIENTS’ POSITIONS, WITHOUT GIVING NOTICE TO THE CLIENT, ON ACCOUNT OF NON-PAYMENT OF CLIENT’S DUES

The client is required to pay adequate margin pay in obligations in full and that it shall be the clients responsibility to ascertain in advance the margin / pay-in obligations requirement for its order / trades / deals and to ensure that the required margin / pay in obligations is made available to PURE BROKING in such form and such manner as may be required by PURE BROKING from time to time. If the client’s order is executed despite a shortfall in the available margin, the client shall, whether or not PURE BROKING intimates such shortfall to the client, make up for the shortfall on its own immediately. The client shall be responsible for all orders (including any orders that may be executed without the required margin in the clients account) and / or any claim / loss / damage arising out of the non-availability/ shortage of margin / pay-in obligations required by PURE BROKING and / or by Exchange.

The client shall fulfil all its obligations / liabilities / dues to PURE BROKING, failing which PURE BROKING has the right not the obligation to square up all or any outstanding position and /or take offsetting positions and/or sell the margin / securities available with PURE BROKING without giving any notice to the client. PURE BROKING may also square up all or any outstanding position and /or sell the securities / collateral available with PURE BROKING as a part of risk management at any time without giving any notice to the client. In case of purchase on behalf of client, the PURE BROKING may close out its transactions by selling securities, in case the Client fails to make full payment to PURE BROKING for the same before the time intimated by PURE BROKING. In case of sale on behalf of client, the PURE BROKING may close out its transaction by purchasing the securities. The client shall be liable for any losses, costs and be entitled to any surplus, which may result from the above.

SHORTAGES IN OBLIGATIONS ARISING OUT OF INTERNAL NETTING OF TRADES

If a selling client who has sold shares of particular scrip on T day does not deliver shares latest byT+2 (i.e. by pay-in day deadline) and such quantity of shares results in internal shortages, then such quantity of internal shortage will be purchased from the market on pay-in day / or reported for self auction if provided by the Exchange. On T+2 (i.e. pay-in day) provisional debit will be given in client accountant T + 1 day’s closing rate+ adhoc margin as decided by PURE BROKING from time to time.

On payout day of securities purchased in the internal shortage account,-provisional debit bill amount will be reversed and client account will be debited with the amount at which securities are purchased on T+2 day. Fines / penalties / charges may be levied on account of internal shortage to selling client.

Due to internal shortage on account of internal netting of trades, the buyer client shall receive late delivery of securities. Buyer shall have no claims / rights against PURE BROKING for delay in delivery of securities. It may also be possible that PURE BROKING may not be able to obtain the required securities due to market conditions, then in such cases the buyer clients’ account will be credited and seller clients’ account will be debited as per the close out rate provided by the exchange for the relevant Auction settlement. Provisional debit bill amount will be reversed in the sellers client account.

Notwithstanding the above, the selling client who has failed to deliver the sahares by due date and time shall be solely responsible for all cost, charges, penalties, damages, etc. arising out of such non delivery of shares.

Above procedure is subject to change from time to time according to change in settlement procedure of the Exchange.

CONDITIONS UNDER WHICH A CLIENT MAY NOT BE ALLOWED TO TAKE FURTHER POSITION OR PURE BROKING MAY CLOSE THE EXISTING POSITION OF A CLIENT

Under the following conditions PURE BROKING will not allow the client to take further positions or PURE BROKING may close the existing position of a client:-

  • Insufficient / inadequate margin(s) and / or insufficient / inadequate free credit balance available with PURE BROKING.
  • Scrips / stocks falling in Penny Stocks in clause (a) above.
  • Illiquid contracts/options.
  • Trades which apparently in the sole and absolute discretion of PURE BROKING seems to be Synchronized trades/Circular trading / Artificial trading / manipulative in nature, etc.
  • Scrips banned by Regulatory authorities.
  • Where name of the client apparently resembles with the name appearing in the list of debarred entities published by SEBI / Exchanges and other regulatory authorities [where the information available for the debarred entity (other than name) is not sufficient enough to establish that the client and such debarred entity are one and the same].
  • The client fails to furnish documents information as may be called for by PURE BROKING from time to time as per regulatory requirement and/or as per its internal policy.
  • In the event of death or insolvency of the client or the client otherwise becoming incapable of receiving and paying for or delivering or transferring securities which he has ordered to be bought or sold.

In addition to the above PURE BROKING can also close position of the client in case the client fails to pay his/ her obligation / dues before pay in schedule of the exchange and / or as demanded by PURE BROKING.

Depending on the market circumstances if PURE BROKING is of the view that the positions of the clients are / will be at risk then PURE BROKING may close the existing position without waiting for the pay in schedule of the exchange.

TEMPORARILY SUSPENDING OR CLOSING A CLIENT’S ACCOUNT AT THE CLIENT’S REQUEST

Demat accounts

PURE BROKING will maintain client’s securities in a designated account called the client beneficiary / beneficiary account. The securities of PURE BROKING will be kept in a separate demat account termed as PURE BROKING P.L own beneficiary account. The clients and Pure broking’s own securities will not be mixed with each other

Trades

The trades of clients shall be carried out in the respective client code only. The dealers shall take utmost care while executing the trades of the clients regarding the accuracy of client code, Quantity, Price, etc.

POLICY FOR INACTIVE CLIENT

Any Client who have not traded for last 365 days or such period as may be decided in any segment of any exchange with PURE BROKING then that client code will be made in active and will be kept in dormant mode. If client wishes to activate his account then he may have to complete such documentations as decided by PURE BROKING from time to time. After the client is made in active funds and securities lying in trading account if any available with PURE BROKING will be settled at the end of the quarter in which trading account is made inactive.

INFORMATION SECURITY POLICY AND NETWORK SECURITY POLICY

  • The legitimate use of network and reasonable level of privacy is ensured.
  • Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
  • This policy recommends that any information that is considered sensitive is Encrypted.
  • Regular Audit of network system is done on periodic basis to ensure the Compliance of this policy.
  • No visitor is allowed in this area without prior approval and they are not allowed to carry any laptops, pen drives, floppies, cds etc., inside the secured areas.
  • All employees are not allowed to carry any information in any form from the office while leaving the office. No direct access to Internet is provided to anyone other than authorized persons. All the computers are controlled, their activities are frequently viewed by senior officials time and again to ensure that no pilferage of any sensitive information.
  • No third party vendors, contractors are permitted in restricted zone. Any meetings with this person if required are held at non secured zone office at the front office.

FUNDS

System of Payin and payout of funds

Payin: Clients can transfer funds into the trading account only from such bank accounts which are registered with Pure Broking. Any transfer from a non-registered bank account will not be considered and the client doen not get any trading limit for such transaction.

Payout: all payout will have to be compulsory placed on the back office access provided to the clients. All payout request will be processed electronically and the credit shall come to the client’s primary account within 24 hours of having processed the payout request.

Deregistering a client

PURE BROKING may at its sole discretion deregister a client without giving any specific reason. Necessary communication will be done by PURE BROKING to client in writing or by email. On giving the intimation to de-register, the client’s funds and securities, if any, will be settled at the earliest. The client will be given necessary notice period as required by the SEBI / Exchanges from time to time.

Due to de-registration, PURE BROKING shall have the right to close out the existing open positions1 contracts, sell/ liquidate the margin (in any form) to recover its dues, if any, before de-registering the client. Any action taken by PURE BROKING in terms of this policy shall not be challenged by the client, and PURE BROKING shall not be liable to the client for any loss or damage (actual / notional), which may be caused to the client as a result. Also while de-registering the client, PURE BROKING may retain certain amount / securities due / belonging to the client for meeting any future losses, liability, penalties, etc. arising out of dealing of the client with PURE BROKING. In case if any securities retained by PURE BROKING is sold / liquidated to recover any such losses, liability, penalties, etc., PURE BROKING shall have the sole authority to decide the scrip, the mode, manner and the price at which to effect the sale of securities and the client cannot raise any dispute as to the manner, mode and the price at which the securities are sold by PURE BROKING.

In any of the above circumstances, if the client is able to justify his / her, circumstances / reasons either by producing any record, document or otherwise to the full satisfaction of PURE BROKING, then PURE BROKING may reconsider its decision of de-registering the client. However in no circumstances any action taken by PURE BROKING till the date of re-registration shall be challenged by the client and PURE BROKING shall not be liable to the client for any loss or damage (actual / notional), which may be caused to the client as a result.

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Registered/Corporate Office AddressO-402,Milestone Leone,Athwagate,Nanpura,Surat-395001,Gujarat
Pure Broking Pvt. Ltd: Member of NSE & BSE – SEBI Registration no.: INZ000018531
CDSL: Depository services through Pure Broking Pvt. Ltd. – SEBI Registration no.: IN-DP-116-2015
Mutual Fund:Mutual fund services through Pure Broking Pvt.Ltd–AMFI Registration no:ARN-110016
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