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CLIENT CODE MODIFICATION AND ERROR CODE POLICY
OBJECTIVE
THE MAIN OBJECTIVE OF THE POLICY IS TO DEAL WITH MODIFICATION OF
CLIENT CODE AFTER THE EXECUTION OF TRADE AND TO CREATE AWARENESS
AMONGST THE RELEVANT STAFF SUCH AS DEALERS, BRANCH IN CHARGE,
COMPLIANCE OFFICER, SUB-BROKERS AND AUTHORSIED PERSONS.
TERMS USED IN THIS POLICY
1.GENUINE ERRORS: Errors 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 and
modification within relatives. (‘Relative’ for this purpose
would mean ‘Relative’ as defined under Companies’ Act, 1956)
2. MODIFICATION OF CLIENT CODES: Modification in client codes to
that of ‘ERROR’, which will be subsequently closed
out/liquidated and not shifted to any other client code.
POLICY
Dealers are advised to hear patiently the client code / scrip
code and reconfirm the same to their best possible efforts
before placing order into the system. The dealer should not
yield to any pressure or sense of urgency shown by the client in
placing the order.
CRITERIA FOR GENUINE ERROR
The following instances would be considered as the
genuine errors:
1. Where the Actual Client code and wrongly punched Client code
are similar.
2. Error occurred due to any miscommunication from the
client/authorised representative of the client.
3. Error due to wrong entry of client code among the family
members of the client.
PROCEDURE FOR CLIENT CODE MODIFICATION
1. The occurrence of such incident shall be first reported to
the compliance officer / operations in charge at the Head
Office. The modification shall be carried out only at the
head-office after verifying the SEBI / Exchange directives
issued from time to time.
2. The compliance officer/operations in-charge shall review the
Error Account Trades on daily basis.
3. A separate register has been maintained to record such
occurrences.
4. An error account has been created with code ‘ERROR’ and title
‘ERROR’. The same has been uploaded to the NSE and UCC for it
‘ERROR’.
5. The access for the client code modifications is given only to
the operations in-charge at Head Office. Any deviations from
there shall be escalated to the compliance officer, Ramesh
Bajaj.
6. The client code modification shall be done only in
exceptional cases. For Eg: If the order has been wrongly punched
in “XX02” instead of “XX20” then the same will be modified only
in head office after the board approval.
7. The operations in-charge or the compliance officer shall have
a look at the correct code and the wrong code and satisfy
himself as to the genuineness of the error. He shall further
take immediate steps to avoid the repetition of the incidence.
8. Both, the operations in-charge and the proprietor shall look
at the pattern of incidence and take urgent steps to report to
the exchange, the wrong doings, if any.
REPORTING SYSTEM
1. Client code modifications shall be reported to all the key
personnel in the organisation.
2. The company shall review the Error Account file sent by the
Exchange on daily basis.
3. A separate register is maintained at the Head Office to
record full details of client code modifications.
APPROVAL AND REVIEW
This policy is drafted by the proprietor himself and
shall stand to be reviewed periodically, as per the needs of the
situation.
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