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Customer care : 9841198942  Live Support
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INTERNAL CONTROL POLICY
Policy and Procedure
All internal control points and operating instruction as
specified by NSEand SEBI from time to time will be followed. We
will appoint concurrent and internal auditor to conduct NSE from
time to time.
1.Client Account Opening :
This is on going process and we regularly receive applications
for registration as client for broking business. At HO
experienced persons are entrusted with the work of Registering
New Clients. New Form received to be checked document as per
exchange by one person and is rechecked by another and then
submitted to the authorized person to sign the documents. A copy
of signed form is given to the client. Our client registration
form is a combined form for registration of client NSE Cash and
F&O Segment and Cash Segment. An agreement in the format
specified by NSE SEBI shall be entered into with all the clients
before the trading account is activated.
This ensures that all the updates pronounced by the exchanges
are properly incorporated. These forms when sent to clients are
affixed with the company name and address.
2.Refusal of orders for penny / illiquid stock
The stock broker may from time to time limit (quantity/value) /
refuse orders in one or more securities due to various reasons
including market liquidity, value of security(ies), the order
being for securities which are not in the permitted list of the
stock broker / exchange(s) / SEBI. Provided further that stock
broker may require compulsory settlement / advance payment of
expected settlement value/ delivery of securities for settlement
prior to acceptance / placement of order(s) as well. The client
agrees that the losses, if any on account of such refusal or due
to delay caused by such limits, shall be borne exclusively by
the client alone.
The stock broker may require reconfirmation of orders, which are
larger than that specified by the stock broker’s risk
management, and is also aware that the stock broker has the
discretion to reject the execution of such orders based on its
risk perception.
3.Setting up client’s exposure limits and conditions
under which a client may not be allowed to take further
positions or the broker may close the existing position of a
client
The stock broker may from time to time impose and vary limits on
the orders that the client can place through the stock broker’s
trading system (including exposure limits, turnover limits,
limits as to the number, value and/or kind of securities in
respect of which orders can be placed etc.). The client is aware
and agrees that the stock broker may need to vary or reduce the
limits or impose new limits urgently on the basis of the stock
broker’s risk perception and other factors considered relevant
by the stock broker 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 the stock broker may be unable to
inform the client of such variation, reduction or imposition in
advance. The client agrees that the stock broker shall not be
responsible for such variation, reduction or imposition or the
client’s inability to route any order through the stock broker’s
trading system on account of any such variation, reduction or
imposition of limits. The client further agrees that the stock
broker 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 the stock broker, 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 stock broker / exchange/ SEBI and any other
reasons which the stock broker may deem appropriate in the
circumstances.
a. For Non-Payment or erosion of margins or other amounts,
outstanding debts, etc. proceeds of such liquidation/ close out
if any, against the client’s liabilities/obligations.
b. Any order which is executed without the required margin in
the client’s account or the broker’s exposure is more than 90%
and above so no fresh trade will be taken.
c. The client here by authorizes the stock broker to square- up
all his outstanding positions at the discretion of the stock
broker, which are not marked for delivery, 15 minutes before the
closing time of the normal market or if the client’s margin is
evaporated by 90% in any of the exchange(s), Tradehifi Stock
Broking Pvt Ltd. reserves the right to square off positions.
d. Under certain market conditions, it may be difficult or
impossible to liquidate a position in the market at a reasonable
price or at all, when there are no outstanding orders either on
the buy side or the sell side, or if trading is halted in a
security due to any action on account of unusual trading
activity or stock hitting circuit filters or any other reason as
prescribed or instructed by SEBI.
The client is not entitled to trade without adequate margin /
security and that it shall be his / her / its responsibility to
ascertain beforehand the margin / security requirements for his/
her /its orders / trades / deals and to ensure that the required
margin / security is made available to the stock broker in such
form and manner as may be required by the stock broker. If the
client’s order is executed despite a shortfall in the available
margin, the client, shall, whether or not the stock broker
intimates such shortfall in the margin to the client, make up
the shortfall suo moto immediately. The client further agrees
that he /she / it shall be responsible for all orders (including
any orders that may be executed without the required margin in
the client’s account) & / or any claim /loss/ damage arising out
of the non availability /shortage of margin /security required
by the stock broker & / or exchange & / or SEBI
The stock broker is entitled to vary the form (i.e., the
replacement of the margin / security in one form with the margin
/ security in any other form, say, in the form of money instead
of shares) & / or quantum & / or percentage of the margin & / or
security required to be deposited / made available, from time to
time.
The margin / security deposited by the client with the stock
broker are not eligible for any interest.
The stock broker is entitled to include / appropriate any / all
payout of funds & / or securities towards margin / security
without requiring specific authorizations for each payout.
The stock broker is entitled to transfer funds &/ or securities
from his account for one exchange & / or one segment of the
exchange to his / her / its account for another exchange & / or
another segment of the same exchange whenever applicable and
found necessary by the stock broker. The client also agrees and
authorizes the stock broker to treat / adjust his/ her / its
margin / security lying in one exchange & / or one segment of
the exchange / towards the of another exchange & / or another
segment of the exchange.
The stock broker is entitled to disable / freeze the account & /
or trading facility / any other service. facility, if, in the
opinion of the stock broker, the client has committed a crime /
fraud or has acted in contradiction of this agreement or / is
likely to evade / violate any laws, rules, regulations, a lawful
authority whether Indian or foreign or if the stock broker so
apprehends.
4.The right to sell clients ’securities or close
clients’ positions, without giving notice to the client, on
account of non- payment of client’s due
The stock broker maintains centralized banking and securities
handling processes and related banking and depository accounts
at designated place. The client shall ensure timely availability
of funds/securities in designated form and manner at designated
time and in designated bank and depository account(s) at
designated place, for meeting his/her/its pay in obligation of
funds and securities. The stock broker shall not be responsible
for any claim/loss/damage arising out of non availability/short
availability of funds/securities by the client in the designated
account(s) of the stock broker for meeting the pay in obligation
of either funds or securities. If the client gives orders /
trades in the anticipation of the required securities being
available suquently for pay in through anticipated payout from
the exchange or through borrowings or any off market delivery(s
) or market delivery(s) and if such anticipated availability
does not materialize in actual availability of securities /
funds for pay in for any reason whatsoever including but not
limited to any delays / shortages at the exchange or stock
broker level / non release of margin by the stock broker etc.,
the losses which may occur to the client as a consequence of
such shortages in any manner such as on account of auctions /
square off / closing outs etc., shall be solely to the account
of the client and the client agrees not to hold the stock broker
responsible for the same in any form or manner whatsoever.
In case the payment of the margin/security is made by the client
through a bank instrument, the stock broker shall be at liberty
to give the benefit / credit for the same only on the
realization of the funds from the said bank instrument etc. at
the absolute discretion of the stock broker.
Where the margin /security is made available by way of
securities or any other property, the stock broker is empowered
to decline its acceptance as margin / security & / or to accept
it at such reduced value as the stock broker may deem fit by
applying haircuts or by valuing it by marking it to market or by
any other method as the stock broker may deem fit in its
absolute discretion
The stock broker has the right but not the obligation, to cancel
all pending orders and to sell/close/liquidate all open
positions/ securities / shares at the pre-defined square off
time or when Mark to Market (M-T-M) percentage reaches or
crosses stipulated margin percentage mentioned on the website,
whichever is earlier. The stock broker will have sole discretion
to decide referred stipulated margin percentage depending upon
the market condition. In the event of such square off, the
client agrees to bear all the losses based on actual executed
prices. In case open position (i.e. short/long) gets converted
into delivery due to non square off because of any reason
whatsoever, the client agrees to provide securities/funds to
fulfill the pay-in obligation failing which the client will have
to face auctions or internal close outs; in addition to this the
client will have to pay penalties and charges levied by exchange
in actual and losses, if any. Without prejudice to the
foregoing, the client shall also be solely liable for all and
any penalties and charges levied by the exchange(s).
The stock broker is entitled to prescribe the date and time by
which the margin / security is to be made available and the
stock broker may refuse to accept any payments in any form after
such deadline for margin / security expires. Notwithstanding
anything to the contrary in the agreement or elsewhere, if the
client fails to maintain or provide the required margin/fund /
security or to meet the funds/margins/ securities pay in
obligations for the orders / trades / deals of the client within
the prescribed time and form, the stock broker shall have the
right without to take any one or more of the following steps:
i. To withhold any payout of funds / securities.
ii. To withhold / disable the trading / dealing facility to the
client.
iii. To liquidate one or more security(s) of the client by
selling the same in such manner and at such rate which the stock
broker may deem fit in its absolute discretion. It is agreed and
understood by the client that securities here includes
securities which are pending delivery / receipt.
iv. To liquidate / square off partially or fully the position of
sale & / or purchase in anyone or more securities / contracts in
such manner and at such rate which the stock broker may decide
in its absolute discretion.
v. To take any other steps which in the given circumstances, the
stock broker may deem fit.
The client agrees that the loss(s) if any, on account of anyone
or more steps as enumerated herein above being taken by the
stock broker, shall be borne exclusively by the client alone and
agrees not to question the reasonableness, requirements, timing,
manner, form, pricing etc., which are chosen by the stock
broker.
5. Shortages in obligations arising out of Internal
netting of trades
Stock broker shall not be obliged to deliver any securities or
pay any money to the client unless and until the same has been
received by the stock broker from the exchange, the clearing
corporation/ clearing house or other company or entity liable to
make the payment and the client has fulfilled his / her/ its
obligations first.
a. The policy and procedure for settlement of shortages in
obligations arising out of internal netting of trades is as
under:
The securities delivered short are purchased from market on T+2
day which is the Auction Day on Exchange, and the purchase
consideration (inclusive of all statutory taxes & levies) is
debited to the short delivering seller client.
b. In case, the shares are not purchased from the market for
whatsoever reason, the seller account shall be debited by the
closing price of shares on the date of the auction plus 2% over
and above the closing price or minimum 50 paise per shares on
the date the auction for the settlement which ever is higher.
c. In case, the shares are not purchased from the market for
whatsoever reason, the seller account
shall be debited by the closing price of shares on the date of
the auction plus 2% over and above the closing price or minimum
50 paise per shares on the date of the auction for the
settlement which ever is higher.
d. In cases of securities having corporate actions all cases of
short delivery of cum transactions which
cannot be auctioned on cum basis or where the cum basis auction
payout is after the book closure / record date, would be
compulsory closed out at higher of 10% above the official
closing price on the auction day or the highest traded price
from first trading day of the settlement till the auction day.
6. Temporarily suspending or closing a client’s account
at the client’s request
i. The client may request the stock broker to temporarily
suspend his account, stock broker may do so subject to client
accepting / adhering to conditions imposed by stock broker
including but not limited to settlement of account and/ or other
obligation.
ii. The stock broker can with hold the payouts of client and
suspend his trading account due to his surveillance action or
judicial or / and regulatory order/action requiring client
suspension.
7. De-registering a client
Not with standing anything to the contrary stated in the
agreement, the stock broker shall be entitled to terminate the
agreement with immediate effect in any of the following
circumstances.
i. 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 the market, either alone or in
conjunction with others.
ii. If the action of the Client are prima facie illegal/
improper or such as to manipulate the price of any securities or
disturb the conjunction with others.
iii. If there is any commencement of a legal process against the
Client under any law in force;
iv. On the death/lunacy or other disability of the Client;
v. 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;
vi. 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;
vii. If the Client being a partnership firm, has any steps taken
by the Client and/ or its partners for dissolution of the
partnership;
viii. If the Client have taken or suffered to be taken any
action for its reorganization, liquidation or dissolution;
ix. If the Client has made any material misrepresentation of
facts, including (without limitation) in relation to the
Security;
x. 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;
xi. If the Client suffers any adverse material change in his /
her / its financial position or defaults in any other agreement
with the Stock broker;
xii. If the Client is in breach of any term, condition or
covenant of this Agreement;
xiii. If any covenant or warranty of the Client is incorrect or
untrue in any material respect;
8.Re-activation of an active Account:
A inactive account can be re-activated when the client submits a
format application. After due verification by the Company the
account shall be re-activated.
9.Contract Notes :
As a Trading Member of NSEwe are required to issue Contract
Note/s to all our constituents for all trades executed by them
in the format as prescribed by the NSE. It is ensured that the
Contract Notes are issued within 24 hours of the execution of
the contract and signed by the person authorized for this
purpose. Contract note are time stamped with the time of receipt
of order and the time of execution of order etc.
10.Collection and Release of payments to Clients
The Tradehifi Stock Broking Pvt Ltdvarious Bank Accounts at HO
are operated by the Director/Authorized Signatories.
Collection:- Normally we get payments on due dates from most of
the clients. Person authorized to collect dues from clients
would review outstanding to be received on continuous basis in
record kept made and payment obtained.
11.Release of Payments: - All Clients to be
paid on due date without fail. However those Clients who have
given Running Account Letter and do not want payments for their
convenience are not paid. Extreme care is taken to ensure that
cheque/s issued by the Tradehifi Stock Broking Pvt Ltd very
seriously.
12.Collection and Delivery of Securities to the Clients
Collection:-
In Demat Form – It is ensured that clients provide delivery of
shares from the same DP ID registered with us as mentioned in
the KYC or updated suquently.
Delivery of Securities to the Clients
In Demat Form:- Pay out released from the Clearing House is
deposited in our POOL Account and there from transferred to the
respective clients demat account.
13. Records :
All physical records like Client Registration Forms –
Contract Notes- Bank records is kept at HO/Record Room.
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