Vajraaditya Ventures
Policies & Procedures

Our comprehensive policies and procedures for client trading, risk management, and compliance

A. Funds

System of Payin and Payout of funds

Pay-in

Clients can transfer funds into the Trading Account only from such bank accounts which are registered with Vajraaditya Ventures. Any transfer from a non-registered bank account will not be considered and the client does not get any trading limit credit for such transfers.

Payout

All payouts will have to be communicated to our office through registered email id or registered mobile number. All payout requests will be processed and the credit shall come to the client's primary bank account within 24 hours of having processed the payout request.

The payout window for EQ/Currency is before 7:30 PM every day - requests placed before 7:30 will be honored the next day. Requests placed after 7:30 PM will be honored in two days.

Payout windows are closed on Saturday and Sunday - this means if you place a request on Saturday or Sunday or after 7:30 PM on friday, it will be honored only on Monday.

B. Margins

Client Funding: Vajraaditya Ventures does not engage in the business of Client Funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions. Margin Policy can change at any point of time based on market volatility.

  • Positions which do not have sufficient funds can be cut any time at the discretion of our RMS desk. There will be no margin calls or intimation from our RMS desk.
  • All positions will be subject to square off if your losses exceed 50% of the available funds in your account. This will be done at the discretion of our RMS team and there will be no margin call.
  • Fines levied by the exchange for short margin will be payable by the client.
  • Clients will have to ensure all orders are closed by the EOD.
  • Payments will only be accepted from the client's registered bank account, cash and DD payins are not accepted.

All information mentioned here is subject to change at the discretion of our Risk management team.

C. Debit Balance

Delayed payment charges

Vajraaditya Ventures follows the practice of posting the settlement obligation towards their transaction in the client ledger on the settlement date. All clients are advised to make the payment before the pay-in time on the settlement day, though there are instances wherein client may delay the payment beyond the settlement date. Although, it is obligatory for a broker to meet the settlement obligation in time, therefore, in order to ensure timely receipt of funds from clients towards their payment obligation, "charges for delayed payment" are levied in the client's account. The sum towards "charges for delayed payment" is levied to discourage delayed payment from clients who do not deposit the required sum of money before the payin time on the payin day. "Charges for delayed payment" are levied on the respective ledger debit of the clients at a rate of 0.05% per day of the debit balance in the account. For the purpose of reckoning debit balance, the debit balance in the client ledger is consolidated across all segments of the respective exchange after giving effect to the release of margin.

Charges on F&O position

In the Equity Derivative Segment and Currency Derivative Segment, we accept the approved securities from clients for margin purpose. Exchanges stipulate that for overnight F&O positions, 50% of the margin needs to compulsorily come in cash and the remaining 50% can be in terms of collateral margin. If you don't have enough cash, your account will be in debit balance and there will be an interest charge also called delayed payment charges of 0.05% per day applicable on the debit amount.

D. Contract Notes and Margin Statement

Vajraaditya Ventures will issue contract notes & margin statements to its clients within 24 hours of the trade taking place. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin status.

E. 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.

F. Closing of Accounts / Dormant Account

The Clients account shall be closed upon a specific request from the client. For dormant accounts, we do not close such accounts, but mark the same as "Inactive" till further action by the concerned client.

G. Investor Grievances

The Compliance Officer shall be the designated officer for handling the Investors Grievances and Client Complaints. The email ID you can write to in case you have any grievance is info@vajvt.com or geetha@vajvt.com

The resolution of the Complaint shall be done at the earliest and the same shall be recorded in the register along with the date of resolution.

H. Policy on Business Continuity Plan & Disaster Management

Disconnection from Exchange Terminal - Internet Failure / Power Outage / Other Natural disasters / riots / etc.:

  • We are using NOW terminal for order placement.
  • We have back-up internet service subscriptions in case of internet disconnection.
  • When we are unable to connect on any internet provider, we will be placing orders from any one of our BCP sites.
  • When we are unable to operate from our current office, we will temporarily use one of the BCP sites.

Alternative BCP sites:

  1. 32/1, Ramalinganagar Layout No.4, Alagesan Road No.2, Saibaba Colony, Coimbatore.
  2. 7.2, Theppakulam Street No.3, Coimbatore.
  3. 3-B, 8th Cross, Venkateshwara Layout, SG Palya, Bangalore.

I. Policy on Outsource of Activities

Vajraaditya Ventures has the policy of NOT outsourcing their core and critical activities to third-parties, as per the recommendation from SEBI.

We normally do not outsource any function which can be reasonably executable in house however, there are certain special services which we cannot perform such as lawyers assistance, auditors service, courier services, printing of stationery etc. Such decision of outsourcing is taken by the partners of the firm and conveyed to the working employees.

J. Policy on Unauthenticated News Circulation

Vajraaditya Ventures has the policy of not circulating any unauthenticated news related to Stock market, which will have an impact on the decision of the client's trades.

We do not provide any kinds of tips and unauthenticated news circular to our clients, nor allowed any of our employees to circulate unauthenticated news.

We even do not permit any of our employees to indulge in daily trading activities.

We are very particular to enter the orders as per the instruction of our clients.

Many a times client asks to us about our opinion on market movement & Market forecast but we have instructed all our employees to refrain from giving any kind of stock specific market forecast.

K. Policy on Risk Management and Surveillance

  • We are using NOW terminal for order placement.
  • We have set the limits for each client in NOW-admin.
  • Each user id limit has been set at the corporate admin level.
  • Per order limits:
    • CDS - Per order limit is Rs. 10 Crores
    • NFO – Per order limit is Rs. 5 Crores
  • Each client in NFO segment is given position limits as per the span margin specified by the exchange daily. For CDS segment position limit is set as per span cum exposure margin as specified by the exchange.
  • For Proprietary trades, position limit is set only on the firms' margin money in accounts and not on clients' money.
  • Only authorized employees are allowed to enter our trading rooms.
  • Server room and trading rooms have surveillance cameras and fingerprint access controls to prevent unauthorized entry.
  • Our employees are selected after proper verification of their certificates and with good references only.
  • All our outside trunk phone calls are taped.

L. Policy on Inactive Client / Dormant Account

Any client account which has been inactive for a continuous period of two year shall be classified as Inactive Client Account.

We will notify to the client that his/her account has been classified as inactive. Also further communicate that the funds remaining in the clients account will be paid out within 10 days.

In case of reactivating the inactive accounts, before permitting the said client to trade, we will take all the documents which are required for registration purposes afresh & after satisfying with all angle, we will allow the client to trade further.

M. Vajraaditya Ventures PMLA Policy

Anti Money Laundering Measures

Background

The Prevention of Money Laundering Act, 2002 came into effect from 1st July 2005. Necessary Notifications / Rules under the said Act were published in the Gazette of India on 1st July 2005 by the Department of Revenue, Ministry of Finance, and Government of India.

SEBI vide circular dated 18th January 2006 required Market intermediaries to lay down policy framework for anti money laundering measures to be followed. Vajraaditya Ventures being a Stock Broker needs to adhere to the same. SEBI has also issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT until December 15, 2008

Objective

Money laundering has now become one of the major concerns of international financial community. Money Laundering is not just an attempt to disguise money derived from illegal activities. Rather, money laundering is involvement in any transaction or series of transactions that seek to conceal or disguise the nature or source of proceeds derived from illegal activities, including drug trafficking, terrorism, organized crime, fraud and many other crimes.

The objective is to have a system in place for preventing any money laundering financial transaction through us and also to identify, monitor, report any such transaction to appropriate authorities.

"Know Your Customer"(KYC) is the guiding principle behind the Anti-Money Laundering (AML) measures. It incorporates the "Know Your Customer" Standards & "Anti Money Laundering" Measures, hereinafter to be referred as "KYC Standards" and "AML Measures". The objective of is to "have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the Company from being used, intentionally or unintentionally, by criminal elements". KYC Standards and AML Measures would enable the Company to know/ understand its customers, the beneficial owners, the principals behind customers who are acting as agents and their financial dealings better which in turn will help the Company to manage its risks prudently.

The management of the company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance with respect to all relevant legal requirements.

The regulatory / statutory requirements

An officer of the company will be designated as "Principal Officer" who will ensure proper discharge of all legal requirements with respect to the same Mr. Venu Madhav, Compliance Head is the Principal Officer responsible for:

  • Compliance of the provisions of the PMLA and AML guidelines
  • Act as a central reference point and play and active role in identification & assessment of potential suspicious transactions
  • Ensure that Vajraaditya Ventures discharges its legal obligation to report suspicious transactions to concerned authorities.

The main aspect of this policy is the customer due diligence process which means:

  • Obtaining sufficient information about to the client in order to identify who is the actual beneficial owner of the securities or on whose behalf transaction is conducted
  • Verify the customers identity using reliable independent source document, data or information
  • Conduct on-going due diligence and scrutiny of the account/ client to ensure that the transaction conducted are consistent with the clients' background/ financial status, its activities and risk profile.

The customer due diligence process includes three specific parameters:

  • Policy for acceptance of clients: Each client should be met in person. Complete KYC to be done for all clients. No account to be opened in a fictitious/benami name or on an anonymous basis.
  • Clients Identification Procedure (Risk profiling): All clients to be classified as per the risk into 3 categories Low, Medium and High Risk
  • Suspicious Transaction identification and reporting: Any unusual activity compared to past transactions. Sudden activity in Dormant accounts. Sudden High volume / high value transactions

The principal officer shall report the nature, amount, date and all related details of any and all suspicious transactions recorded.

1. Client identification

Before opening any Trading account with us, the following measures shall be taken:

  • In person verification of the client
  • Identify beneficial ownership and control, i.e., determine the persons who beneficially own / control the account.
  • Collect information about client's background, occupation and also check the name of the introducer.
  • 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.
  • For clients trading in F&O segment, documentary proof of his financial details will be collected.
  • In case of Corporate client, collect copies of certificate of incorporation, Memorandum of association and other documents as required by SEBI
  • In case of Corporate client, collect adequate information of the persons authorised to deal on behalf of the company.
  • The client shall be interviewed personally regarding the purpose of opening the account i.e., whether short term trading or long term investment.
  • Prior experience in stock market
  • Introducer details

2. KYC updation process

All corporate clients must submit annual report every year. In case of individual clients, Client Master details shall be sent to all clients, who will confirm either that the details are updated or shall be advised to submit details if required. He shall also specify his present occupation and financial income details per annum in the same declaration.

The information should be adequate enough to satisfy competent authorities (regulatory/ enforcement authorities) in future that due diligence was observed by us in compliance with the Guidelines.

Failure by prospective client to provide satisfactory evidence of identity should be noted and reported to the principal officer.

Further, we should also maintain continuous familiarity and follow-up with the client where inconsistencies in the information provided are noted.

The account will not be opened where we are unable to apply the above KYC policies, e.g., non co-operation of the client in providing full information etc

3. Client categorisation

Each client will be marked into 3 categories, High Risk, Medium Risk and Low Risk from the point of view of the anti money laundering laws. The categorization will be made based on the following parameters/ factors of risk perception:

  • High Networth Clients
  • Trusts/ NGOs / Charities receiving donations
  • Companies having close family shareholdings (The above are considered of High Risk as per SEBI guidelines)

The other parameters are nature of business activity, trading turnover, manner of making payment etc. Provision will be made in the back office software for noting categorization of each client. The high-risk client will require regular KYC update.

The clients will be placed under low, medium and high-risk category based on their turnover per day. Corporates / HNIs having respectable social and financial standing, Clients who make payment on time and take delivery of shares can be considered as Low

4. Suspended Persons

SEBI and other authorities suspend or debar persons / entities from participating in securities market on several instances. We as a Broker are required to ensure that such persons do not trade through us.

We shall lay down systems for identifying transactions which is not in consonance with the financial status declared/ shown by the client. Also, unusual activities compared to past transactions, sudden activity in dormant accounts, activity inconsistent from declared business activity, should be traced. This shall require appropriate changes in our back office software.

Systems shall be put in place for identifying transactions likely to be market manipulation, and which appears to be insider trading and also any transaction which seems to have no bonafide intention. Regular communications by means of mailers, SMS, Email are sent to clients at various intervals requesting them to update their latest financial and KYC details available with us.

Role of Compliance Team & Internal Audit: The compliance team will play an important role in ensuring compliance of the above policies and procedures. The account opening team will exercise adequate due diligence as stated above. There will be periodic checking by the Principal Officer and the same report will be properly filed

There is a system of concurrent audit, which will also include ensuring compliance of the:

  • Due diligence in KYC norms.
  • Generation of exception reports
  • Trading in dormant client codes
  • Level of awareness of staffs

5. Illiquid Securities

The Exchanges specifies a list of Illiquid Securities where higher due diligence is to be exercised by the Brokers. The list is displayed in our website for client's information. The trade pattern in such scripts by our clients is monitored. In case of high volume in any script compared to Exchange volume, the client is asked to submit clarification.

6. Employee Training

We have policy for ongoing employee training programme so that the total staffs of our company completely aware of the provisions of AML and CFT procedures and amendments thereof. These training programmes are totally focused for frontline staff, back office staff, compliance staff, risk management staff and staff dealing with new customers as it is very crucial that all those concerned fully understand the rationale behind these guidelines, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being misused by unscrupulous elements, if there is any lapse on the part of any staffs of the company.

A register of attendance of participation in such Education/ training program is maintained for the employees, kept secured with the Compliance Department.

As resolved Vajraaditya Ventures shall take adequate measures as per its internal policy to prevent money laundering and shall also put in place a frame work for PMLA policy. The policies and procedures as mentioned above shall not be final as it may adopt additional measures to safeguard its interest with respect to activities associated with PMLA.

N. Vajraaditya Ventures - Conflict of Interest Policy

In order to strive for achieving management of conflict of interests, Vajraaditya Ventures shall endeavor:

  • To promote high standards of integrity in the conduct of business
  • To ensure fairness of dealing with clients
  • To guide for identification, elimination or management of conflict of interest situations
  • To provide a mechanism for review and assessment of the policy (ies) on conflict of interests

Vajraaditya Ventures Conflicts of Interest Policy sets out how:

  • The Company will identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to our Clients' interests;
  • The Company has established appropriate mechanisms and systems to manage those conflicts;
  • The Company maintains systems designed to prevent damage to our Clients' interests through identified conflicts.

Identification of Conflicts of Interests

The Company shall take adequate steps to identify conflicts of interest. In identifying conflicts of interest, the Company will take into account situations where the Company or an employee or a Relevant Person:

  • Is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;
  • Has an interest in the outcome of a service provided to the Client or of a transaction carried out on behalf of the Client, which is distinct from the Client's interest in that outcome;
  • Has a financial or other incentive to favour the interest of one Client over another;
  • Carries out the same business as the Client; or
  • Receives from a person other than a Client an inducement in relation to a service provided to a Client, in the form of monies, goods or services, other than the standard commission or fee for that service.

Measures to avoid or to deal or manage actual or potential Conflict of Interests

Should a conflict of interest arise, it needs to be managed promptly and fairly. The Company puts in place following arrangements to ensure that:

  1. There is a clear distinction between the different departments' operations;
  2. No single person will gather conflicting information, thus counterfeiting or hiding information from investors is minimized;
  3. The Company's employees are prohibited from investing in a financial instrument for which they have access to non-public or confidential information;
  4. Transactions by the Company's employees are neither performed nor executed by themselves.
  5. Employees sign a contract of employment including confidentiality clauses. No associated person may disclose inside information to others, except disclosures made in accordance with the Company's policies and procedures, to other Company personnel or persons outside the Company who have a valid business reason for receiving such information;
  6. Each department will control the flow of information where, otherwise, the risk of conflict of interest may harm the interest of a Client;
  7. Relevant information is recorded promptly in a secure environment to enable identification and management of conflicts of interests;
  8. Adequate records are maintained of the services and activities of the Company where a conflict of interest has been identified;
  9. In certain jurisdictions appropriate disclosure may be made to the Client in a clear, fair and not misleading manner to enable the Client to make an informed decision;
  10. There is a periodic review of the adequacy of the Company's systems and controls.
  11. Employees are required to avoid conflicts of interest with activities they undertake outside Vajraaditya Ventures.

Information barriers

The Company respects the confidentiality of information it receives regarding its Clients and operates a "Need to Know" approach and complies with all applicable laws in respect of the handling of that information. Access to confidential information is restricted to those who have a proper requirement for the information consistent with the legitimate interest of a Client of the Company. The Company operates internal organizational arrangements to avoid conflicts of interest by controlling, managing or restricting, as deemed appropriate, the flow of confidential information between different areas of business or within a specific division or department. In particular, Chinese Walls are a key tool for conflict of interest prevention, avoiding insider dealing and market manipulation risks. Furthermore, Chinese Walls can involve separation of premises, personnel, reporting lines, files and IT-systems and controlled procedures for the movement of personnel and information between the Company and any other part of the Company. The Company maintains permanent information barriers between different departments.

Disclosure to clients of possible source or potential areas of conflict of interest (COI)

  1. Vajraaditya Ventures or its associated persons should, in writing, disclose to a client any COI in respect of that client including:
    1. Measures taken to avoid or mitigate the conflict;
    2. Any ownership interest or financial interest that the provider or representative may be or become eligible for;
    3. The nature of the relationship or arrangements with a third party that gives rise to a COI in sufficient detail to enable the client to understand the exact nature of the COI.
  2. Vajraaditya Ventures or its associated persons should, in writing, inform a client of the policy on Management of Conflict of Interest and how it may be accessed.
  3. Intimation of an actual or potential COI should be made to a person with responsibility for the issue or area, such as the relevant management team, head of the department or key individual.
  4. In accordance with an employee's obligation to act in the best interest of COMPANY, it is not permissible for employees to engage in conduct that would amount to a COI with COMPANY.
  5. Staff that fail to disclose a potential or actual COI in accordance with this policy may be liable to disciplinary procedures.
  6. Where a conflict arises Vajraaditya Ventures or its Associated Persons will, if it is aware of it, disclose it to a client prior to undertaking trading activity for that client or, if the company does not believe that disclosure is appropriate, to manage the conflict, the company may opt not to proceed with the transaction or matter giving rise to the conflict.
  7. Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect Clients' interests, the conflict will be disclosed to allow the Client to make an informed decision on whether to continue using our service in the situation concerned.
  8. Vajraaditya Ventures may decline to act for a Client in cases where we believe a conflict of interest cannot be managed in any other way.

Policies and procedures

The Company has developed and implemented policies and procedures throughout its business to prevent or manage potential conflicts of interest. Our employees receive guidance and training in these policies and procedures, and they are subject to monitoring and review processes.

Internal code of conduct governing operations

Vajraaditya Ventures and Associated Persons shall abide by the Code of Conduct contained in the Schedule II of the Securities and Exchange Board of India (Stock-Brokers and Sub-Brokers) Regulations, 1992, as amended, for accomplishment of the objectives of the SEBI Code.

Standards of appropriate conduct in the performance of the activities

Vajraaditya Ventures and its Associated Persons shall adopt the following standards of appropriate conduct in the performance of the activities:

  1. To place the client's interests first: Placing the client's interests first is a hallmark of professionalism, requiring Vajraaditya Ventures and its Associated Persons to act honestly and not place personal gain or advantage before the client's interests.
  2. To provide business services with integrity: Integrity requires honesty and sincerity in all business matters. Vajraaditya Ventures and its Associated Persons are placed in positions of trust by clients, and the ultimate source of that trust is the Vajraaditya Ventures and its Associated Persons' personal integrity, both in the letter and the spirit.
  3. To provide business services objectively: Objectivity requires intellectual honesty and impartiality. Regardless of the services delivered or the capacity in which Vajraaditya Ventures and its Associated Persons functions, objectivity requires Vajraaditya Ventures and its Associated Persons to ensure the integrity of their work, manage conflicts and exercise sound commercial and professional judgment.
  4. To be fair and reasonable in all business relationships & to disclose and manage conflicts of interest: Fairness requires providing clients what they are due, owed or should expect from a business relationship, and includes honesty and disclosure of material conflicts of interest. It involves managing one's own feelings, prejudices and desires to achieve a proper balance of interests. Fairness is treating others in the same manner that you would want to be treated.
  5. To act in a manner that demonstrates exemplary professional conduct: Professionalism requires behaving with dignity and showing respect and courtesy to clients, fellow business associates, and others in business-related activities, and complying with appropriate rules, regulations and business requirements. Professionalism requires Vajraaditya Ventures and its Associated Persons, individually and in cooperation with peers, to enhance and maintain the Vajraaditya Ventures public image and its ability to serve the public interest.
  6. To maintain the abilities, skills and knowledge necessary to provide business services competently: Competence requires attaining and maintaining an adequate level of abilities, skills and knowledge in the provision of business services. Competence requires Vajraaditya Ventures and its Associated Persons to make a continuing commitment to learning and business services improvement.
  7. To protect the confidentiality of all client information: Confidentiality requires client information to be protected and maintained in such a manner that allows access only to those who are authorized. A relationship of trust and confidence with the client can only be built on the understanding that the client's information will not be disclosed inappropriately.
  8. To provide business services diligently: Diligence requires fulfilling business commitments in a timely and thorough manner, and taking due care in planning, supervising and delivering business services.