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.
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.
All information mentioned here is subject to change at the discretion of our Risk management team.
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.
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.
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.
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.
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.
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 firstname.lastname@example.org or email@example.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.
Disconnection from Exchange Terminal - Internet Failure / Power Outage / Other Natural disasters / riots / etc.:
H. 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 be 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.
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 circulated 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.
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.
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 1 st 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
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.
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
The main aspect of this policy is the customer due diligence process which means:
The customer due diligence process includes three specific parameters:
The principal officer shall report the nature, amount, date and all related details of any and all suspicious transactions recorded.
Before opening any Trading account with us, the following measures shall be taken:
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
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:
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
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
here is a system of concurrent audit, which will also include ensuring compliance of the
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.
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.
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:
i. There is a clear distinction between the different departments’ operations;
ii. No single person will gather conflicting information, thus counterfeiting or hiding information from investors is minimized;
iii. The Company’s employees are prohibited from investing in a financial instrument for which they have access to non-public or confidential information;
iv. Transactions by the Company’s employees are neither performed nor executed by themselves.
v. 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;
vi. Each department will control the flow of information where, otherwise, the risk of conflict of interest may harm the interest of a Client;
vii. Relevant information is recorded promptly in a secure environment to enable identification and management of conflicts of interests;
viii. Adequate records are maintained of the services and activities of the Company where a conflict of interest has been identified;
ix. 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;
x. There is a periodic review of the adequacy of the Company’s systems and controls.
xi. Employees are required to avoid conflicts of interest with activities they undertake outside VAJRAADITYA VENTURES.
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):
i. VAJRAADITYA VENTURES or its associated persons should, in writing, disclose to a client any COI in respect of that client including –
a. Measures taken to avoid or mitigate the conflict;
b. Any ownership interest or financial interest that the provider or representative may be or become eligible for;
c. 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.
ii. 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.
iii. 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.
iv. 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.
v. Staff that fail to disclose a potential or actual COI in accordance with this policy may be liable to disciplinary procedures.
vi. 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.
vii. 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.
viii. 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.
i. 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.
ii. 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.
iii. 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.
iv. 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.
v. 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.
vi. 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.
vii. 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.
viii. 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.