Policies

Trading & Demat Policies.
TRADE MODIFICATION & ERROR POLICY

TRADE MODIFICATION & ERROR POLICY

Objective
To frame the guidelines for modification of client codes post trade execution / online trade modification / Client code modification and reporting of such Client Code Modifications.

Brief about Client Code Modification:
Client Code Modification means modification / change of the client codes after execution of trades. Stock Exchanges provide a facility to modify any client code after the trade has been executed to rectify any error or wrong data entry done by the dealers at the time of punching orders. However, such Client Code modification is subject to certain guidelines as to the time limit within which the client code modification is to be carried out, terminal / system on which such modifications can be done etc. The facility is mainly to provide a system for modification of client codes in case genuine errors in punching / placing the orders. It is to be used as an exception and not a routine. To prevent misuse of the facility Stock Exchanges levy penalty / fine for all non-institutional client code modifications.

Scope of the Policy:
This policy covers all the Client Code Modifications carried out / to be carried out in any of the client accounts, subject to the guidelines issued by the SEBI / Stock Exchanges from time to time, in any segment of any exchange for which I Ventures Capital Pvt Ltd. is a member broker.
“Error Trades” means the trades which will be modified / to be modified / allowed, to be modified subject to guidelines of the SEBI / Stock Exchanges and this policy. For the purpose of this Policy, only the following types of trades shall be modified / allowed to be modified:

In Case of NSE:
i) Client code / name and modified client code / name are similar to each other but such modifications are not repetitive.
ii) Family Code (spouse, dependent parents, dependent children and HUF).

In Case of BSE:
i) Punching error / typing error of client codes due to any genuine error or mistake in order entry, while punching the order, by any dealer.
ii) Trade entered for wrong client due to any miscommunication from the client / authorized representative of the client.
iii) Modification within family members.

General Conditions:
(i) The facility for Client Code Modification can be used only in case of Error Trade.
(ii) The Client Code Modification shall be carried out only on the designated system and / or as per the process as may be prescribed by SEBI / Stock Exchange.

Place for Client Code Modification:
Any Client Code Modification shall, subject to compliance of this policy, be carried out by RMS at HO Capital Market Segment of NSE & BSE.

Penalty
The penalty or fine, if any, levied on IVCPL for any wrong trade occurred due to any miscommunication from the client / authorized representative of the client shall be borne by the client.

On Line Modification:
1. Genuine punching errors in client codes while placing orders shall be allowed to be modified.
2. Client code modification facilities shall be disabled from all the dealer terminals. Hence the facility to modify the client codes would be available only at the Corporate Manager level and would not be given to branches/franchises/sub-brokers.
3. Client code modification shall be carried out only after prior permission from the Director of the company.
4. While carrying out code modification, genuineness of the punching errors shall be verified against corroborative circumstantial evidences like similarities of codes, trades in immediately preceding codes, square off trades without holdings or position or any such other evidences shall have to be taken into account.
5. Complete records of daily online trade modifications shall be maintained in soft form.
6. All such Genuine Error code modification shall be carried out through UCC registered ‘ERROR’ account. Any rate difference including transactions costs shall be settled between the concerned accounts by passing JV of appropriate amount.
7. Training programs would be conducted for all dealers on a regular basis and they would be explained how code modifications can be misused and the steps to be taken to avoid the same.
8. The Penalties, if any charged by the Exchange/Any Regulatory authorities shall be passed on to the concerned client/sub-broker if the reason of the error is attributable to any negligence on their part else shall be born by the company.

Off Line back office modification
1. Genuine punching errors in client code, if detected after the end of post closing sessions may be allowed to be modified subject to the verification of genuineness as narrated above.
2. For F&O and CDS segment, as far as possible, the errors would be rectified by reversal trade in next trading session and the rate differences shall be set off by passing a JV entry in the ledgers of affected clients. In case the client do not agrees to keep such wrong trade record in his account, such trades may be rectified by moving both legs of the trades to the UCC Registered account of actual client or ‘Error A/c.’ instead of settling it though JV entry.
3. For Cash segment any such errors would be rectified after verifying genuineness.
4. Any such back office client code modification shall be carried out only by Director of the company/any person duly authorized by the Director in writing.
5. A register containing required details shall be maintained for all such modifications. Concerned dealer/sub-broker shall enter the required details and sign in the register which shall be approved by counter signature of any of the directors.
Resolution of Grievances
The functional heads are responsible for any resolution of complaint/ grievances related to their individual functions/departments. We have a standard 7 days resolution policy for such customer’s complaints. In case of non resolution of grievances within the prescribed timeframe the issue is escalated to the Designated Director. Once escalated, the director would be responsible to examine the same and offer a solution at the earliest.

Interaction with Customer
We have designated an e-mail id (feedback@iventures.in) to solicit any grievances/complaints from our customers which is also displayed on our website as well as all the communication that goes from our side. We realize that customer’s expectations or complaints can be better appreciated through personal interaction with the company’s staff.

Sensitizing Operating Staff on Handling Complaints
Our employees at all branches have been trained to handle complaints, and to deal with them without prejudice. The functional heads ensure that the internal machinery for handling complaints operate smoothly and efficiently at all levels. The staff receives constant feedback on their approach. At the same time, the HR Department is given inputs on the training requirements for the staff at various levels.
CONFLICT OF INTEREST POLICY

CONFLICT OF INTEREST POLICY



I Ventures Capital Pvt Ltd, its Sub-brokers and its Employees shall:

1. At all times maintain high standards of integrity in the conduct of their business

2. Ensure fair treatment of their clients and not discriminate amongst them

3. Ensure that their personal interest does not, at any time conflict with their duty to their clients and client’s interest always takes primacy in their advice, investment decisions and transactions

4. Make appropriate disclosure to the clients of possible source or potential areas of conflict of interest which would impair their ability to render fair, objective and unbiased services

5. Endeavour to reduce opportunities for conflict through prescriptive measures such as through information barriers to block or hinder the flow of information from one department / unit to another, etc.

6. Place appropriate restrictions on transactions in securities while handling a mandate of issuer or client in respect of such security so as to avoid any conflict

7. Not deal in securities while in possession of material non published information

8. Not communicate the material non published information while dealing in securities on behalf of others

9. Not in any way contribute to manipulate the demand for or supply of securities in the market or to influence prices of securities

10. Not have an incentive structure that encourages sale of products not suiting the risk profile of clients

11. Not share information received from clients or pertaining to them, obtained as a result of their dealings, for personal interest
INSIDE TRADING POLICY

INSIDE TRADING POLICY



SEBI has enacted the Prohibition of Insider Trading Regulations, 2002 and subsequent insider trading regulations 2009 which is applicable to all market intermediaries like I VENTURES CAPITAL PVT LTD.

Pursuant to the said regulations and amendments in the said regulations from time to time, it is necessary that I VENTURES CAPITAL PVT LTD being a capital market intermediary do comply and follow the prescribed procedures in order to prevent the misuse of price sensitive information which an employee/client/director/officer of the company may have access to.

For the purposes of implementation of the code for trading in securities by employee/clients, definitions along with explanations where thought necessary are given as under:

II. DEFINITIONS:

“Securities” include-

(i) Shares, scrips, stocks, bonds, debentures, debenture stock or other marketable securities of a like nature in or of any incorporated company or other body corporate;

(ii) Derivative;

(iii) Units or any other instrument issued by any collective investment scheme to the investors in such schemes;

(iv) Government securities;

(v) Such other instruments as may be declared by the Central Government to be securities; and

(vi) Rights or interests in securities.

Explanation: Mutual fund units, derivative products like futures and options are also covered.

“Client Company” means a listed company which has given mandate or proposes to give any mandate in relation to preparation of any research report, credit rating report, appraisal report or valuation report.

“Compliance Officer” means a senior officer(s) of the Company who are appointed as Compliance Officer(s) for overseeing the compliance with Prohibition of Insider trading.

“Price Sensitive Information” means any information which relates directly or indirectly to a company and which if published is likely to materially affect the price of securities of such company and includes-

• periodical financial results of the Company

• intended declaration of interim/final dividend

• issue of securities or buy-back of securities

• any expansion plans or execution of new projects

• amalgamation, mergers or takeovers,

• disposal of the whole or substantially the whole of the undertaking, any significant changes in policies, plans or operations of the Company

III. Basic procedures for personal investments:

Moral conduct: Every employee/client is expected to put the interest of the Company before his/her personal interest.

Prevention of misuse of Price Sensitive Information: Employee/clients should not use price sensitive information to buy or sell securities of any sort, whether for their own account or relatives.

No Speculation or short sales permitted: Employee should not speculate in shares/derivatives. All purchase transactions have to be delivery based. Selling securities for which delivery has not been taken is prohibited.

Front Running transactions are strictly prohibited. Front running means transacting in a security knowing fully well that IVENTURES CAPITAL PVT LTD also intends to transact in the same security if any.

No passing of price sensitive information: Designated Employee/clients/Directors/ Dependent Persons are prohibited from passing on information to anybody inducing him/her to buy/sell securities.

Special Restrictions of Employee/clients in research department:

Designated Employee/clients/Directors working as Research Analysts for preparing research reports of a client company shall disclose their shareholding/interest in such company to the compliance officer and shall not trade in securities of such client company for a period of atleast 30 days from publication/preparation of such report. For this purpose, any employee/client in the research department should inform the company’s name of which is preparing a report and give an undertaking in the format prescribed in Annexure In case any employee/client leaves IVENTURES CAPITAL PVT LTD, he/she shall be required to give an undertaking that he/she will not deal with any transaction on the basis of unpublished price sensitive information.

Penalty for contravention of code of conduct

Any Directors/Designated employee/clients/dependent persons who trades in securities or communicates any information or counsels any person trading in securities, in contravention of this code of conduct may be penalised and appropriate action may be taken against him which may include disciplinary action by the company, which may include wage freeze, suspension, etc.

INTERNAL SHORTAGE POLICY

INTERNAL SHORTAGE POLICY



Shortages in obligations arising out of internal netting of trades:

I Ventures Capital Pvt Ltd shall have the right to adopt a policy of its choice for internal auctions arising out of internal netting of trades and charge to defaulter seller and compensate the impacted purchaser as per the policy. The current procedure for internal auction is displayed on the website, which may be amended from time to time with prospective effect after publishing the same on the corporate website.

The client hereby agrees that if he/she/it has short delivered any securities against his/her/its pay-in – obligation which resulted into internal shortage, i.e. buy position of another client of I Ventures Capital Pvt Ltd, self Auction of Internal short scrip will be carried out by iVentures Capital.

Internal Shortage in NSE:

In case of internal shortage of security in NSE, the securities will be bought in the open market by I Ventures Capital Pvt Ltd in NSE on T+2 day or on settlement day. The seller client will be debited at sale rate or at the rate at which stock bought by I Ventures Capital Pvt Ltd in the open market, whichever is higher. Securities payout will be passed on to the Buyer. The profit, arising on account of buy rate lower than the sell rate, the benefit, if any, will be passed on to buyer. In case of or any other reason whatsoever, if I Ventures Capital Pvt Ltd is unable to buy such quality in NSE as the case may be the outstanding security pay-in obligation of the seller client shall be closed out at the rate of the closing rate of T+3 or on the next settlement day plus penalty calculated as below. The buyer client will be credited at same closing rate at which seller client was debited.

Shortage from Exchange:

In case of short delivery from the exchange, the securities shall be delivered to the purchaser upon deliveries received from the exchange.
INVESTOR GRIEVANCE REDRESSAL POLICY

Investor Grievance Redressal Policy



Introduction

The key to success for any organization is to not only to maintain the current customers but also to widen the base by reaching out to other potential customers and providing them impeccable service.

At iVentures, we train our staff to understand the customer and service them exactly as per their needs. However, in case of complaints, we provide a quick and effective redressal.

Objective of the Policy

The Investor Grievance Redressal Policy was formed with an aim to provide quick amends to customer issues. In case of a complaint, we have a smooth review mechanism to identify our shortcomings and overcome them quickly. This policy also covers issues relating to services provided by the outsourced agency if any.

Principles of the Policy

We have drafted the Grievance Redressal Policy keeping our customer’s needs in mind. The prescribed document is available at all branches and employees are aware about the same. It is based on the following principles:

Fair treatment to the customers at all times.
Customer complaints to be dealt with complete courtesy and priority
Complete information provided to the customers to escalate their complaints, to a higher hierarchal authority.
Company will treat all complaints efficiently and fairly.
Employees work in good faith and in the interest of the customers.
Handling Customer Complaints

At iVentures, we have a Customer Service Committee that is headed by the company’s MD and other senior functional heads. This ensures that every complaint is given due importance and solved at the earliest. The functions of the committee are as follows:

To screen each feedback and complaint received from various quarters and ensure quick redressal and implementation of the valuable comments.
To ensure that the regulatory instructions regarding customer service are followed consistently and constantly with the involvement of all the functional heads.
To offer advice and aid for unresolved complaints referred by the functional heads.
Resolution of Grievances

The functional heads are responsible for any resolution of complaint/ grievances related to their individual functions/departments. We have a standard 7 days resolution policy for such customer’s complaints. In case of non resolution of grievances within the prescribed timeframe the issue is escalated to the Designated Director. Once escalated, the director would be responsible to examine the same and offer a solution at the earliest.

Interaction with Customer

We have designated an e-mail id (feedback@iventures.in) to solicit any grievances/complaints from our customers which is also displayed on our website as well as all the communication that goes from our side. We realize that customer’s expectations or complaints can be better appreciated through personal interaction with the company’s staff.

Sensitizing Operating Staff on Handling Complaints

Our employees at all branches have been trained to handle complaints, and to deal with them without prejudice. The functional heads ensure that the internal machinery for handling complaints operate smoothly and efficiently at all levels. The staff receives constant feedback on their approach. At the same time, the HR Department is given inputs on the training requirements for the staff at various levels.

POLICY REGARDING INACTIVE (DORMANT) ACCOUNTS

POLICY REGARDING INACTIVE (DORMANT) ACCOUNTS



Inactive (Dormant) Accounts

Client Accounts where the client has not traded for 12 months and does not have outstanding position in Derivatives (F&O and CDS) would be treated as inactive (Dormant) accounts. To ensure complete security of client Accounts and assets, iVentures Capital Pvt. Limited would be placing such accounts under temporary suspension. Once the account is under temporary suspension, the client would be demapped from all trading terminals and will not be allowed to login to his account or trade (place orders) either through online mode or by calling/visiting its service branch. Further the client would be disabled in the back office software and his/her web access to the back office would also be disabled.

For example: Client Account XYZ trades on 10th June, 2011 and does not further trade for next 12 months, further he does not have any outstanding position in Derivatives (F&O and CDS) .The account XYZ would be put under temporary suspension on the 9th June, 2012.

Funds/Stock Transfer Request for Inactive (Dormant Accounts):

A client can opt for withdrawal of funds/securities from his/her account. For the same, the client would be required to place a request for reactivation of the account with us. After the completion of reactivation formalities, the client could place request for withdrawal from our ‘Client Payout’ link on our website. Alternatively the client could also mail us at accounts@iventures.in or call us at 011-40571208

Reactivation of client Accounts

Clients can get such accounts reactivated by placing a reactivation request in the desired format and submitting the below mentioned documents:

1. Identity Proof (Any one)
a. Pan Card
b. Voter ID/Aadhar Card
c. Passport/Driving License

2. Income Proof (Any one)
a. Copy of ITR acknowledgement (For last Financial Year)
b. Copy of Form 16 in case of salaried persons (For last Financial Year)
c. Bank Statement for the last 3 months as updated in our records.

The reactivation form along with the requisite documents should be sent directly to our Head Office at the following address:

iVENTURES CAPITAL PVT.LTD.
A-18, SCOND FLOOR, FIEE COMPLEX, OKHLA PHASE-II,
NEW DELHI-110020
Alternatively the documents could also be submitted at our service branch.

For any further queries, the client could also get in touch with our centralized customer care helpline at 011-40947000 or by sending an mail at care@iventures.in.
RISK MANAGEMENT POLICY

RISK MANAGEMENT POLICY



Assumptions :

The proposed RMS policy is in line with market practices for a Broking Model.

The framework is only for Risk Management System (Financial Risks), and other parameters like cost of funds, brokerages etc. do not fall in this preview for e.g. having established that a trade is risk free, RMS should facilitate execution without blocking or questioning on other parameters like cost etc. We assume that efficiency analysis should be by way of periodical MIS & not on case to case basis. The business works on trust and commitments and others have to support the commitments made by business people once risk call is positive.

The framework suggested assumes upload of correct data in terms of client’s assets etc in RMS system.

Actual Framework :

As & when the Client A/c & DP A/c is to be opened the client will have to bring in assets by way of cash and/or securities.

Client Creation and Mapping :

Client Code would be created in default group i.e. HO Group. All the clients would be then mapped to the respective dealers of the location and all the client codes will also be mapped to one user at the HO, which will act as contingency for all the other locations.

Exposure Multiplier :

Generally default upload limits will be 5 times exposure of the deposit value (Composite Ledger + Stock Collateral) in product code MIS (Margin Intraday Square off) for Cash segment. In this product all remaining position will be squared off automatically by the system at 3:15 pm.

All delivery trade to be done on product code CNC.

In FNO and CDS segment client’s limit will be 2 times is based on the actual margin prescribed by the exchange time to time in the product code MIS (Margin Intraday Square off). In this product all remaining position will be squared off automatically by the system at 3:15 pm.

All carry forward position in FNO and CDS segment to be done on product code NRML and is based on the actual margin prescribed by the exchange time to time.

. Trading in Z group & Physical stocks :

Trading in ‘Z’, ‘T’ & ‘TS’ group stocks are prohibited for all the clients. We are considering on case to case bases for the trade to be executed in above mentioned group stocks. We are not dealing in Physical Stocks.

Terminals Limits :

We are not setting the limits terminal wise as we are following the practice setting the trading limits client wise to reduce manual intervention.

Hair cuts :

Haircuts would be set scrip wise in the system as per the calculation after considering various factors i.e. liquidity, price movements etc. which would be made from time to time. Hence the rate of haircut would not remain static and would change with an intimation of a day’s time or even with immediate effect in case of critical situations.

Cheque Dishonour :

In first instance of cheque dishonour the Client’s A/c will be blocked for buying till the cheque is honoured. The client will have to make good first the obligation by providing us a new cheque. In second instance of cheque dishonour the limits to such client will be given only on the basis of clear funds.

Funds & Securities Release :

Funds & Securities release will be approved by the RMS team. In case of fund release request received during the trading hours, RMS will check whether the client has not made any fresh purchases during the day. If there is any purchase made during the day then the release of funds would be done on the balance amount after deducting the current purchase value. In case of no fresh purchases are made then the payment would be processed and the limits for the value of the payment would be reduced from the trading system i.e. reduced from the clients upload limit.

In case of securities release the RMS team would check the clear balance in the ledger and then only securities would be released. Securities Pay-out will be released on clear ledger balance. In case of ledger having debit balance, 300 % of the stock value will be withheld.

Intimation for Bulk/Block Trades :

Prior to execution of any bulk/block deals in any segment, the RMS team has to be informed. The RMS team would check the availability of limits on the respective levels.

Intimation of Exposure Percentage :

RMS would send intimation/messages through the Admin to all the dealers informing the availability of exposure at the firm level for respective exchanges after reaching 70 %.The second intimation will be sent when the level reach 80 %, at this point message will be sent for going slow in trading in case of the respective segment. Third intimation will be sent once the level reach 90 % level wherein fresh position would not be allowed till the time we reduce our exposure or enhance our firms limit with exchange. Only square off for open position will be allowed.

Password Policy :

In case of ODIN, default password would be allotted to the new user created in the system. In case of NOW password would be allotted and sent to the clients registered e-mail id only. If the user fails to log on in three attempts the password would be locked. The user will have to send an email to RMS team at it@iventures.in for resetting the password. Identity of the person requesting to change password will be verified by the RMS team.

The emails to be approved by the respective heads of the department. In case the request for the change in password is received from any person other than the users it will be rejected by the RMS team.

Square off (Close out) positions and De – registering a client Policy:

Right to sell client’s securities or close client’s positions, without giving notice to the client on account of non payment of client’s dues:–

1. Margin collection – Margin is collected upfront from the client’s i.e prior to executing any trades. Based on the margin thus available with iVentures - exposure is given to the client. The applicable margin may vary and the client may be asked to replenish the margin by tendering additional funds or securities.

2. In accordance with Exchange guidelines, iVentures retains the right to square off the position without giving any notice to the client.

3. The client agrees to pay for the shares purchased through iVentures before the pay-in date in order to enable iVentures to make the requisite pay-in to the exchange. In case the client fails to make the payment, iVentures may liquidate the securities in the clients account in order to ensure that adequate credit is received for the shares purchased. This square off may be done on or before the 5th day from the settlement. 4. The client also agrees to maintain adequate margin for the positions taken in any segment. However in case the credit available is lower than the minimum margin required, the client’s positions would be liquidated in a manner that the there is no shortfall of margin.

5. iVentures shall endeavor to ensure that adequate prior information is given to the client for such liquidation. It shall inform the client through the mobile number and or email id registered with iVentures. For clients to whom a login and password is given to access their account on the website www.iventures.in or such other URL that may be provided by iVentures from time to time, where they are required to login and check the limit statement uploaded therein. It shall be the clients’ responsibility to ensure that adequate credit balance is available in the account.

6. The above guidelines may be changed based on the discretion of iVentures and in terms of the market conditions. In cases where the market is volatile and there is a sudden spurt in scrip price then iVentures may square off position without any notice due to the paucity of time and other such circumstances

7. Whenever iVentures endeavors that the positions are to be liquidated, it shall not be responsible for any liabilities in case the same cannot be liquidated.

8. The priority of the positions to be squared off, i.e. which positions to be squared off first, would be at the discretion of iVentures.

iVentures may follow the following priority for squaring-off positions :-

a) Lower Margin scrip’s will be squared off first.
b) Only futures position will be squared off (option position to be square off manually)
c) In case where there is a position in cash and derivative segment, futures positions would be squared off first then cash positions would be squared off in case shortfall still exist.
Shortages in obligations arising out of internal netting of trades

Internal Shortage Policy

BSE has a window wherein internal short deliveries can get auctioned as per the normal auction process. Internal short deliveries are not covered by the Auction conducted on the NSE. It is due to this limitation on the NSE we follow the procedure as mentioned below:

1. The client may not receive shares on T+2 in case there is an internal shortage situation within iVentures, i.e. the buyer and seller are both iVentures clients and the seller defaults in delivery due to which the buyer may not receive the shares.

2. In case of an internal shortage, firstly the defaulting seller would be debited with a value as on the previous day of the payin day + 30 % for the default till such time the auction process can be completed.

3. In case there is an internal shortage in BSE, the exchange conducts an auction through which the shares would be purchased and delivered to the buyer. The seller would be debited at the rate at which the exchange would have purchased these shares. Additionally, brokerage, statutory costs and other incidental charges including penalty for non-delivery may be debited to the client. In case the exchange is unable to purchase these shares, the exchange will inform iVentures of a close out rate, at which the buyer would be allowed credit and the seller would be debited for the same amount.

4. In case there is an internal shortage in NSE, iVentures purchases the shares from the normal market and provides the shares to the buyer, on receipt of delivery. The defaulting seller would be debited with the rate at which these shares were purchased, including the brokerage, statutory charges and other incidental charges including penalty if any. In case of non receipt of delivery to purchase the shares, the buyer would be offered credit at a close out rate applicable on T+4 day + 3% or and the seller would be debited at the same rate. In case where iVentures is unable to purchase the shares on account of the scrip being in buying circuit, the position would then be closed out on the closing price of the exchange on T+2 at the circuit percentage of 2 days.

5. iVentures may also levy charges on the defaulting seller for non-delivery of stocks within the stipulated time.

Conditions under which a client may not be allowed to take further position or the broker may close existing position of a client /Temporary suspending or close a client’s account at the client’s request and Deregistering a client.

1. In the event where overall position in any scrip or derivative contract has reached the limit prescribed by regulators or exchanges. For example, in case of NRI clients where the PIS Limits are prescribed by RBI are breached or in case of Exchange wise, scrip wise limit prescribed by Exchanges for derivative contracts are breached. In all such cases the client may not be permitted to take additional positions

2. iVentures has the right to stop or block the client to trade in case where there is a debit balance in his/her account.
3. iVentures retains the right to block the client to take a position in certain specified scrips basis the risk management systems of iVentures.

4. In case where iVentures is apprehensive the client to be an entity debarred by any regulatory authority, it shall retain the right to stop the trading activities of such a client.

5. In case where iVentures perceives risk with regards to any regulatory action or with regards to delay or non payment of margin or any other obligation iVentures may temporary block or suspend the trades of such clients.

6. In case where the client’s account is dormant for a period of more than 12 months iVentures will mark such clients as inactive, and trades in the futures and options segment / Cash segment will be restricted till the receipt of the request from the clients for activating the account.

7. In case where suspicious transactions are observed, including but not limited to off market transactions.

8. In case where clients are not reachable at their contact details mentioned in the client registration form or in the client master changes form.

9. In case where unprofessional, or unruly behavior of the client is observed.

10. In case of any ongoing dispute with the client, we may not permit the client to take further positions and may even close out his open positions.

11. In the event of death or insolvency of the client, winding up or liquidation or the client otherwise becoming incapable of receiving and paying for or delivering or transferring securities which the client has ordered to be bought or sold, iVentures may close out the transaction of the client and the client or his legal representative as the case shall be would be liable for the same.
SURVEILLANCE POLICY

SURVEILLANCE POLICY



As per the requirement of Regulators Mr. Amarendra Mishra- Head RMS would be in-charge of all surveillance related activities.

He shall download the surveillance alerts from the Stock Exchange system E-BOSS/CONNECT2NSE.COM on daily basis.

The process of Due Diligence & scrutinizing each alert (client-wise/scrip-wise separately) would be carried out & completed within one week.

He shall call for necessary documentation of each Client, scrutinize all documents for necessary analyses and prepare conclusion against each alert.

After reasonable analyses, he will report the conclusion against each alert to the Compliance Officer/ Designated Director. After due discussion, the necessary actions shall be taken under instructions from the Compliance Officer/Designated Director, if required. The same shall be reported to the Exchange within reasonable time.

In case of any suspicious / manipulative undue activities of any Client, the same will be reported to the Exchange immediately.

Proper records of each alert and documents scrutinized would be maintained.

A quarterly MIS shall be put up to the Board of Directors of iVentures Capital Pvt Ltd

a. Number of alerts pending at the beginning of the quarter,

b. Number of alerts generated during the quarter,

c. Number of alerts disposed off during the quarter,

d. Number of alerts pending at end of the quarter, Reasons for pendency shall be discussed and appropriate action taken. Also, the Board shall be apprised of any exception noticed during the disposition of alerts.
UNAUTHENTICATED NEWS CIRCULATION POLICY

UNAUTHENTICATED NEWS CIRCULATION POLICY



All sub-brokers/Authorised persons/Remisiers/Employees of I Ventures Capital Pvt Ltd have been directed as follows:

1. They should not encourage or circulate rumours or unverified information obtained from client, industry, any trade done by other person or any other sources without verification.

2. Access of Blogs, Chats, Forums, Messenger etc apart from what is required for day to day functioning would be allowed.

3. If accessed , logs or any usage of such Blogs, Chats, Forums, Messenger, Websites etc shall be treated as records and the same should be maintained.

4. Be aware that any market related news received in your official mail/ personal mail/ blog or in any other manner, should be forwarded only after the same has been seen and approved by the Compliance Officer. If any employee fails to do so, he/she shall be deemed to have violated the various provisions contained in SEBI Act/Rules/Regulations etc., and strict action shall be taken against him/her.

The Compliance Officer shall also be held liable for breach of duty in this regard.

Policy for Pre funded Instruments

Policy for Pre funded Instruments



Pre-funded Instrument means Demand Draft, Pay Orders, Fund Transfer through Internet, RTGS etc
This policy covers such Pre-funded Instruments of amount exceeding Rs. 50,000/- Per client per day.
Demand Draft and Pay order of amount exceeding Rs.50,000/- will not be accepted by iVentures Capital Pvt Ltd (IVCPL) in the normal course of business. Ho wever in exceptional cases we would accept payments in the form of Demand Draft and Pay order subject to a written undertaking that the said payment has been made from the clients’ registered bank account with us. The Prefunded instruments would be accepted only in following special circumstances:

Bank Holidays
Client having account in other Banks or Co-operative bank
To Meet Immediate Margin/Settlement Shortfall
To take Fresh Position
Client‘s bank or City do not h a ve c l e a r i n g facility / branch.
Such Acceptance is approved by SEBI/Exchange Norms.
Cheque issued by client has bounced.

The payments made by the clients’ would be taken on record only on receipt of any of the following documents:

i. Certificate from the issuing bank on its letterhead or on a plain paper with the seal of the issuing bank.
ii. Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
iii. Certified copy of the passbook/bank statement for the account debited to issue the instrument.
iv. Authentication of the bank account number debited and name of the account holder by the issuing bank on the reverse of the instrument
The Prefunded Instruments would be accepted only in cases mentioned above and not otherwise. Approval for accept ancewould be taken by either the Compliance Officer or the Managing Director.

PMLA POLICY FOR IVENTURES CAPITAL PRIVATE LIMITED

PMLA POLICY FOR IVENTURES CAPITAL PRIVATE LIMITED



1. INTRODUCTION

I Ventures Capital Pvt Ltd (iVentures) has designed this policy of PMLA and effective AML program to prohibit and actively prevent the money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities or flow of illegal money or hiding money to avoid paying taxes. To discourage and identify any Money laundering or Terrorist financing Activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Maintenance of records of the Nature and Value of Transactions. To protect the interests of investors in securities and to promote the development of and to regulate the securities Market.

This policy provides a detailed Account of the procedures and obligations to be followed to ensure compliance with issues related to KNOW YOUR CLIENT (KYC) Norms, ANTI MONEY LAUNDERING (AML), CLIENT DUE DILIGENCE (CDD) and COMBATING FINANCING OF TERRORISM (CFT). Policy specifies the need for Additional disclosures to be made by the clients to address concerns of Money Laundering and Suspicious transactions undertaken by clients and reporting to FINANCE INTELLIGENT UNIT (FIU-IND). These policies are applicable to both Branch and Head office Operations and are reviewed from time to time.

Every possible measures are taken for the effective implementation of the Policy. The measures taken are adequate, appropriate and abide by the spirit of such measures and requirements as enshrined in the PMLA to the best of our satisfaction.

2. BACKGROUND

Pursuant to the recommendations made by the Financial Action Task Force on anti-money laundering standards, SEBI had issued the Guidelines on Anti Money Laundering Standards vide their the notification No.ISD/CIR/RR/AML/1/06 dated 18 January 2006 and vide letter March 2006 had issued the obligations of the intermediaries No.ISD/CIR/RR/AML/2/06 dated 20 registered under Section 12 of SEBI Act, 1992. As per these SEBI guidelines, all intermediaries have been advised to ensure that proper policy frameworks are put in place as per the Guidelines on Anti Money Laundering Standards notified by SEBI.

What is Money Laundering?

Money Laundering can be defined as engaging in financial transactions that involve income derived from criminal activity, transactions designed to conceal the true origin of criminally derived proceeds and appears to have been received through legitimate sources/origins. This is done in three phases - Placement Phase, Layering Phase & Integration Phase.

Prevention of Money Laundering Act, 2002

Prevention of Money Laundering Act, 2002 (PMLA 2002) forms the core of the legal framework put in place by India to combat money laundering. PMLA 2002 and the Rules notified there under came into force with effect from July 1, 2005.
The PMLA 2002 and Rules notified there under impose an obligation on intermediaries (including IVentures Capital Pvt. ltd. brokers and sub-brokers) to verify identity of clients, maintain records and furnish information to the Financial Intelligence Unit (FIU) - INDIA

Financial Intelligence Unit (FIU) – INDIA

The Government of India set up Financial Intelligence Unit-India (FIU-IND) on November 18, 2004 as an independent body to report directly to the Economic Intelligence Council (EIC) headed by the Finance Minister. FIU-IND has been established as the central national agency responsible for receiving, processing, analyzing and disseminating information relating to suspect financial transactions. FIU-IND is also responsible for coordinating and stretching efforts of national and international intelligence and enforcement agencies in pursuing the global efforts against money laundering and related crimes.

The Prevention of Money Laundering Act, 2002 (PMLA)

The Prevention of Money Laundering Act, 2002 (PMLA) has been brought into force with effect from1st July, 2005. Necessary Notifications / Rules under the said Act have been published in the Gazette of India on 1st July 2005 by the Department of Revenue, Ministry of Finance, and Government of India.

As per PMLA, every banking company, financial institution (which includes Chit Fund company, a co-operative bank, a housing finance institution and a non-banking financial company) and Intermediary (which includes a Stock-broker, sub-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, merchant banker, underwriter, Portfolio Manager, Investment adviser and any other intermediary associated with securities market and registered under section 12 of the Securities and Exchange Board of India Act, 1992) shall have to maintain a record of all the transactions, the nature and value of which has been prescribed in the Rules notified under the PMLA. For the purpose of PMLA, transactions include:

All cash transactions of the value of more than Rs.10 Lakhs or its equivalent in foreign currency.

All series of cash transactions integrally connected to each other, which have been valued below Rs.10 Lakhs or its equivalent in foreign currency, such series of transactions within one calendar month.

All suspicious transactions whether or not made in cash and including, inter-alia, credits or debits into from any non monetary account such as demat account, security account maintained by I Ventures Capital Pvt Ltd.

For the purpose of suspicious transactions reporting apart from `transactions integrally connected', transactions remotely connected or related need to be considered.

“Suspicions Transactions” means a transaction whether or not made in cash which to a person acting in good faith –

(a) Gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or
(b) Appears to be made in circumstances of unusual or unjustified complexity; or
(c) Appears to have no economic rationale or bonafide purpose.

The Anti-Money Laundering Guidelines provides a general background on the subjects of money laundering and terrorist financing in India and provides guidance on the practical implications of the PMLA. The PMLA Guidelines sets out the steps that a registered intermediary and any of its representatives, need to implement to discourage and identify any money laundering or terrorist financing activities.

3. POLICIES AND PROCEDURES TO COMBAT MONEY LAUNDERING AND TERRORIST FINANCING

3.1 Essential Principles

These Directives have taken into account the requirements of the PMLA as applicable to the intermediaries registered under Section 12 of the SEBI Act. The detailed Directives in Part II have outlined relevant measures and procedures to guide the registered intermediaries in preventing ML and TF. iVentures shall consider carefully the specific nature of its business, organizational structure, type of client and transaction, etc. to satisfy itself that the measures taken by it are adequate and appropriate and follow the spirit of the suggested measures in Part II and the requirements as laid down in the PMLA.

3.2 Obligation to establish policies and procedures

Global measures taken to combat drug trafficking, terrorism and other organized and serious crimes have all emphasized the need for financial institutions, including securities market intermediaries, to establish internal procedures that effectively serve to prevent and impede money laundering and terrorist financing. The PMLA is in line with these measures and mandates that all intermediaries ensure the fulfilment of the aforementioned obligations.

To be in compliance with these obligations, the senior management of iVentures shall be fully committed to establishing appropriate policies and procedures for the prevention of ML and TF and ensuring their effectiveness and compliance with all relevant legal and regulatory requirements. iVentures shall:

(a) issue a statement of policies and procedures, on a group basis where applicable, for dealing with ML and TF reflecting the current statutory and regulatory requirements;
(b) ensure that the content of these Directives are understood by all staff members;
(c) regularly review the policies and procedures on the prevention of ML and TF to ensure their effectiveness. Further,in order to ensure the effectiveness of policies and procedures, the person doing such a review shall be different from the one who has framed such policies and procedures;
(d) adopt client acceptance policies and procedures which are sensitive to the risk of ML and TF;
(e) undertake client due diligence (“CDD”) measures to an extent that is sensitive to the risk of ML and TF depending on the type of client, business relationship or transaction;
(f) have a system in place for identifying, monitoring and reporting suspected ML or TF transactions to the law enforcement authorities; and
(g) develop staff members’ awareness and vigilance to guard against ML and TF

4. ANTI MONEY LAUNDERING PROCEDURES

The policy framework would cover the following:

(a) To have a proper Customer Due Diligence (CDD) process before registering clients.
(b) To monitor / maintain records of all cash transactions of the value of more than Rs.10 lacs.
(c) To maintain records of all series of integrally connected cash transactions within one calendar month.
(d) To monitor and report suspicious transactions.
(e) To discourage and identify money laundering or terrorist financing activities. (f) To take adequate and appropriate measures to follow the spirit of the PMLA.

Implementation of this Policy

a. Mr. Nirmal Bansal will be the Principal Officer who will be responsible for compliance of the provisions of the PMLA and AML Guidelines. b. He will act as a central reference point and play an active role in identification & assessment of potentially suspicious transactions.

c. Ensure that iVentures Capital Pvt. Ltd. discharges its legal obligation to report suspicious transactions to the concerned authorities.

d. The policy has been designed incorporating the SEBI Circular No: CIR/ISD/AML/3/2010 dated 31st December, 2010 and SEBI Circular No: CIR/MIRSD/1/2014 dated 12th March,2014.

5. CUSTOMER DUE DILIGENCE PROCESS

The first step towards implementation would be the customer due diligence process which has the following parameters:

a. Client Due Diligence
b. Client Acceptance Policy
c. Risk Based Approach
d. Clients of special category(CSC)
e. Client Identification Procedure
f. Reliance on third party for carrying out CDD

5.1 Customer Due Diligence

a. Personal Meeting: iVentures would enrol and accept clients whom we are able to meet personally. Either the client should visit the office/branch or concerned official may visit the client at his residence / office address to get the necessary documents filled in and signed. We would preferably accept clients who live within the jurisdiction of the branch. As far as possible, we would ensure that the new client is introduced by an existing client.

b. Client Acceptance for whom we are able to apply appropriate KYC procedures: iVentures would obtain complete information from the client. It would be ensured that the initial forms taken by the client are filled in completely. All photocopies submitted by the client are checked against original documents without any exception. “Know Your Client‟ guidelines would be followed without any exception. All supporting documents as specified by Securities and Exchange Board of India (SEBI) and Exchanges are obtained and verified.

c. Clients with Criminal Background: iVentures will not accept clients with identity matching persons known to have criminal background. We would check whether the clients identify matches with any person having known criminal background or is not banned in any other manner, whether in terms of criminal or civil proceedings by any enforcement/regulatory agency worldwide.

d. Fictitious Accounts: iVentures would not accept client registration forms which are suspected to be fictitious/ benami or on an anonymous basis.

There would be no compromise on submission of mandatory information/ documents. Client accounts would be opened only on receipt of mandatory information along with authentic supporting documents as per the regulatory guidelines. We would not open the accounts where the client refuses to provide information/documents.

5.2 Client Acceptance Policy

The clients may be of a higher or lower risk category depending on circumstances such as the customer's background, type of business relationship or transaction etc. We would apply each of the clients due diligence measures on a risk sensitive basis. We w o u l d adopt an enhanced customer due diligence process for higher risk categories of customers. Conversely, a simplified customer due diligence process may be adopted for lower risk categories of customers. In line with the risk-based approach, we would obtain type and amount of identification information and documents necessarily dependent on the risk category of a particular customer.

5.3 Risk Based Approach

We would accept the clients based on the risk they are likely to pose. The aim is to identify clients who are likely to pose a higher than average risk of money laundering or terrorist financing. For this purpose, we have classified the clients as low risk, medium risk and high risk clients. By classifying the clients, we will be in a better position to apply appropriate customer due diligence process. That is, for high risk client we have to apply higher degree of due diligence. The factors of risk perception depend on clients location, nature of business activity, turnover, nature of transaction, manner of payment etc.

In order to achieve this objective, all clients have been classified in the following categories:

a. Category A – Low Risk
b. Category B – Medium Risk
c. Category C – High risk

High Risk

Indicative List of clients*

a. Non resident clients
b. High networth clients, ( clients having trade value of Rs. 25 lacs on per day , Annual Income of Rs. 25 lacs and/ or Networth of Rs. 3 crs and above ) also for any off market/market pay in/payout instructions above the prescribed limit have to be verified by confirming with client over phone / by email/ and or trading team.
c. Trust, Charities, NGOs and organizations receiving donations
d. Politically exposed persons (PEP) of foreign origin
e. Current / Former Head of State
f. Current or Former Senior High profile politicians and connected persons
(immediate family, Close advisors and companies in which such individuals have interest or significant influence)
g. Companies offering foreign exchange offerings
h. Clients in high risk countries where existence / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy, countries active in narcotics production, countries where corruption (as per Transparency International Corruption Perception Index) is highly prevalent, countries against which government sanctions are applied, countries reputed to be any of the following – Havens/ sponsors of international terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent. While dealing with clients in high risk countries where the existence/effectiveness of money laundering control is suspect, intermediaries apart from being guided by the Financial Action Task Force (FATF) statements that identify countries that do not or insufficiently apply the FATF Recommendations, published by the FATF on its website (www.fatf- gafi.org), shall also independently access and consider other publicly available information.

Medium Risk

Indicative List of clients*

Individual and Non-Individual clients falling under the definition of Speculators, Day Traders and all clients trading in Futures and Options segment and provided adequate margins / collaterals

Low Risk

Indicative List of clients*

Senior Citizens, Salaried Employees and a major portion of clients who indulge in delivery based trading

**This list is indicative. The risk profile also depends on trading pattern, payment pattern, financial status and background of the client. I VENTURES CAPITAL shall put in place system of periodical review of risk categorization of accounts and the need for applying enhanced due diligence measures in case of higher risk perception on a client. For High Risk Clients, categorization would be carried out at least once in a six month while for Medium and Low Risk Clients, categorization frequency would be once in a year.

5.4 Clients of Special Category(CSC)

CSC clients would include the following:

a. Non-resident clients (NRI);
b. High Net worth clients (HNI) (HNI “means who has a Net worth in excess of Rs.3 crores, Annual income of Rs. 25 lacs and done Trade value of Rs. 25 lacs and more”)
c. Trust, Charities, NGOs and organizations receiving donations.
d. Companies having close family shareholdings or beneficial ownership.
e. Politically exposed persons (PEP) of foreign origin.
f. Current /Former Head of State, Current or Former Senior High profile politicians and connected persons (immediate family, close advisors and companies in which such individuals have interest or significant influence);
g. Companies offering foreign exchange offerings;
h. Clients in high risk countries (where existence / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy. Countries active in narcotics production, Countries where corruption (as per Transparency International Corruption Perception Index) is highly prevalent, Countries against which government sanctions are applied, Countries reputed to be any of the following -- Havens / sponsors of international terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent;
i. Non-face to face clients;
j. Clients with dubious reputation as per public information available etc.;

The above mentioned list is only illustrative and we should exercise independent judgment to ascertain whether new clients should be classified as CSC or not.

5.5 Client Identification Procedure

The objective is to have a mechanism in place to establish identity of the client along with firm proof of address to prevent opening of any account which is fictitious / benami / anonymous in nature. The documents which can be relied upon are:

a. PAN Card: PAN card is mandatory and is most reliable document as only one card is issued to an individual and we can independently check its genuineness through IT website.

b. IDENTITY Proof: PAN Card itself can serve as proof of identity. However, in case PAN card carries an old photograph of the holder, which does not match current facial features of the client, we would take other identity proof in form of Voter Identity card, Passport, Driving Licence or any Government/PSU/Bank issued photo identity card.

c. ADDRESS Proof: For valid address proof we can rely on Voter Identity Card, Passport, Bank Statement (not more than 3 months old) and latest Electricity/telephone bill in the name of the client.

In case of Corporates, certified copies of the following documents would also be obtained:

a. Copy of the Registration/Incorporation Certificate
b. Copy of the Memorandum & Articles of the Association
c. Copy of the PAN card and the Director Index No. (DIN)
d. Copy of the latest audited Annual Statements of the corporate client
e. Latest Net worth Certificate Latest Income Tax return filed.
f. Board Resolution for appointment of the Authorized Person who will operate the account. g. Proof of address and identity of Authorized Person.

In case of partnership firm, certified copies of the following documents would also be obtained:

a. Registration certificate
b. Partnership Deed
c. PAN card of all partners
d. Authorization letter for the person authorized to open and operate the account
e. Proof of identity and address of the authorized person.
f. Annual statement/returns of the partnership firm

In case of a Trust, certified copies of the following documents would also be obtained:

a. Registration Certificate of Trust
b. Trust Deed
c. PAN card of trust
d. Authorization letter for the entity authorized to act on behalf of trust
e. Officially valid documents like PAN card, voters ID, passport, etc of person(s) authorized to transact on behalf of the Trust.

In case of unincorporated association or a body of individuals, certified copies of the following documents would also be obtained:

a. Resolution of the managing body of such association or body of individuals POA in favour of person authorized to transact.
b. Officially valid documents like PAN card, voters ID, passport, etc of the person(s) authorized to transact Any other document required by to establish the legal existence of such an association or body of individuals.

In case of an NRI account - Repatriable/non-repatriable, the following documents would be required:

a. Copy of the PIS permission issued by the bank
b. Copy of the passport
c. Proof of overseas address and Indian address
d. Copy of the bank statement
e. Copy of the demat statement
f. If the account is handled through a mandate holder, copy of the valid POA/mandate

In Person Verification (IPV)

Once the background screening is complete or simultaneously therewith, the team shall conduct an IPV of the prospective Client. IPV of the Client by an IVENTURES employee is mandatory and shall not at any time be outsourced. The employee visiting the Client for IPV must verify the originals of the photocopy documents submitted by the Client as part of KYC documentation. IPV must be conducted at the time of registering the Client under the KYC norms. I V E N T U R E S must be able to satisfactorily identify the Client and must be able to provide Client details to the authorities as and when required. In case of DP Clients, IVENTURES employee shall conduct an IPV of the prospective Client. IPV of the Client by an IVENTURES employee is mandatory and shall not at any time be outsourced. IPV done for opening Beneficial Owner account by the DP arm of IVENTURES shall hold good for opening trading account for the same Client by the stock broking arm of IVENTURES and vice versa. In the case of its DP activities, IVENTURES must also carry out IPV of Beneficial Owners at the time of opening the DP Account. If the Client acceptance process rejects a Client or the Client does not respond to requests for additional information/documents, all documents collected from the Client may be refunded and a clause to this effect be incorporated in the KYC Form.

5.5 Reliance on Third Party for CDD

iVentures would rely on the data uploaded on the portals of CVL, NDML,DOTEX,KARVY and other KYC Registration Agencies for the purpose of:

(a) identification and verification of the identity of a client
(b) determination of whether the client is acting on behalf of a beneficial owner,
(c) identification of the beneficial owner and verification of the identity of the beneficial owner.
However iVentures would not completely rely on the KRAs for the client due diligence and the KYC department would seek fresh and additional documents in cases wherever it finds any suspicion or in cases where there is a noticeable change in the KYC details provided by the client at the time of registarion.

6. RECORD KEEPING

For the purpose of the record keeping provision, we should ensure compliance with the record keeping requirements contained in the SEBI Act, 1992, Rules and Regulations made there-under, PLM act,2002 as well as other relevant legislation, Rules, Regulations, Exchange Bye-laws and Circulars. Records to be maintained should be sufficient to permit reconstruction of individual transactions (including the amounts and type of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of criminal behavior. Should there be any suspected drug related or other laundered money or terrorist property, the competent investigating authorities would need to trace through the audit trail for reconstructing financial profile of the suspect's account. To enable this reconstruction, iVentures would retain the following information for the accounts of their customers in order to maintain a satisfactory audit trail.

a. The beneficial owner of the account;
b. The volume of the funds flowing through the account; and for selected transactions.
c. The origin of the funds;
d. The form in which the funds were offered or withdrawn, e.g. cash, cheques, etc;
e. The identity of the person undertaking the transaction;
f. The destination of the funds;
g. The form of instruction and authority.

Organization should ensure that all client and transaction records and information are made available on a timely basis to the competent investigating authorities.

7. INFORMATION TO BE MAINTAINED

iVentures shall maintain the following information in respect of transactions referred to in Rule 3 of the Rules including all necessary information specified by the regulator to permit reconstruction of individual transactions in respect of transactions referred to in Rule 3 of the Rules:

(a) the nature of the transactions;
(b) the amount of the transaction and the currency in which it was denominated; (c) the date on which the transaction was conducted; and
(d) the parties to the transaction.

8. RETENTION OF RECORDS

The following Document Retention Terms would be observed:

(a) All necessary records on transactions, both domestic and international, should be maintained at least for the minimum period of FIVE YEARS (5) from the date of cessation of the transaction.
(b) We shall maintain and preserve the record of documents evidencing the identity of our clients and beneficial owners (e.g., copies or records of official identification documents like passports, identity cards, driving licenses or similar documents) as well as account files and business correspondence for a period of five years after the business relationship between the client and intermediary has ended or the account has been closed, whichever is later."
(c) Records shall be maintained in hard and soft copies.
(d) In situations where the records relate to on-going investigation or transactions, which have been the subject of a suspicious transaction reporting, they should be retained until it is confirmed that the case has been closed.

9. MONITORING OF TRANSACTIONS

(a) Regular monitoring of transactions is required for ensuring effectiveness of the Anti Money Laundering procedures.
(b) Special attention required to all complex, unusually large transactions / patterns which appear to have no economic purpose.
(c) Internal threshold limits to specify for each class of client's accounts and pay special attention to the transaction, which exceeds these limits.
(d) Should ensure that the records of transaction is preserved and maintained in terms of the PMLA 2002 and that transaction of suspicious nature or any other transaction notified under section 12 of the act is reported to the appropriate authority.
(e) Suspicious transactions should also be regularly reported to the higher authorities / head of the department.

Further the Compliance Department would randomly examine select transaction undertaken by clients to comment on their nature i.e. whether they are in the suspicious transactions or not.

10. SUSPICIOUS TRANSACTIONS IDENTIFICATION & REPORTING

Suspicious transaction means a transaction whether or not made in cash, which to a person acting in good faith gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or appears to be made in circumstance of unusual or unjustified complexity; or appears to have no economic rationale or bona fide purpose.

10.1 Identification

In order to identify suspicious transaction the following parameters would be assessed:

a. False identification documents
b. Identification documents which could not be verified within reasonable time
c. Non-face to face client
d. Clients in high-risk jurisdiction
e. Doubt over the real beneficiary of the account
f. Accounts opened with names very close to other established business entities
g. Receipt back of well -come kit undelivered at the address given by the client.
h. Suspicious background or links with criminals
i. Large number of accounts having common parameters such as common partners / directors / promoters / address/ email address / telephone numbers introducer or authorized signatory
j. Unexplained transfers between multiple accounts.

10.2 Activity in account

a. Unusual activity compared to past transactions
b. Use of different accounts by client alternatively
c. Sudden activity in dormant accounts
d. Activity inconsistent with what would be expected from declared business.
e. Account used for circular trading

10.3 Nature Of Transactions

a. Unusual or unjustified complexity
b. No economic rationale or bonafide purpose
c. Source of funds are doubtful
d. Appears to be case of insider trading
e. Purchases made on own account transferred to a third party through an off market transactions through DP account
f. Transactions reflect likely market manipulations
g. Suspicious off market transactions

10.4 Value Of Transactions

a. Value just under the reporting threshold amount in an apparent attempt to avoid reporting
b. Large sums being transferred from overseas for making payments
c. Inconsistent with the clients apparent financial standing
d. Inconsistency in the payment pattern by client e. Block deal which is not at market price or prices appear to be artificially inflated/deflated

Alerts generated by CDSL based on transactions in Depository Accounts

a. Debit and Credit transactions due to Off-market or Inter-depository transfers, above a threshold quantity, in an ISIN, in a single transaction or series of transactions executed during the fortnight.
b. Details of debit and credit transactions due to demat, remat and pledge above a threshold quantity / value in an ISIN, in a single transaction or series of transactions executed during the fortnight.
c. Details of debit and credit transactions above a threshold quantity/value whichever is smaller, in an ISIN, which exceed a threshold multiple of the average size of the transaction calculated for the previous months transactions.
d. Details of Off-market transactions (within CDSL or Inter-depository) where there are more than a threshold number of transactions in an account, for the past fortnight.
e. Any debit transaction in a dormant account for exceeding a threshold quantity/value whichever is smaller, will be reported as an alert. An account having no Debit Transaction in the last month will be considered as Dormant account for this purpose.

Further the Compliance Department should randomly examine select transaction undertaken by clients to comment on their nature i.e. whether they are in the suspicious transactions or not.

Verification of Clients with Dubious Reputation

For verifying the dubious/suspicious reputation, of people, we regularly receive STR Files from CDSL and appropriate actions are taken against each STR, if any. So adequate care is taken by CDSL also for the DP entries effected on behalf of clients by us. We are also regularly logging on to www.watchoutinvestors.com / NSE/BSE, CIBIL and any other possible sources to get information on any dubious or debarred or suspicious people.

10.5 Reporting

Submission of such reports shall be made within the time limit prescribed as follows:-

a. Suspicious transaction reports shall be submitted in writing or by fax or electronic mail within three working days from the date of occurrence of the transactions.
b. Notifications issued by SEBI require STR to be reported within 7 working days of establishment of suspicion at the level of Principal Officer Suspicious Transaction Reports in Manual Format consists of following forms :


Any suspicious transaction needs to be notified immediately to the “Designated Principal Officer”. The notification may be done in the form of a detailed report with specific reference to the client's transactions and the nature or reason of suspicion. However, it should be ensured that there is continuity in dealing with the client as normal until told other wise and the client should not be told of the report or suspicion. In exceptional circumstances, consent may not be given to continue to operate the account, and transactions may be suspended, in one or more jurisdictions concerned in the transaction, or other action taken.

I Ventures Capital Pvt Ltd shall maintain and preserve the record of information which is reported to the Director FIU-IND for a period of five years from the date of the transaction between the client and the intermediary.

11. LIST OF DESIGNATED INDIVIDUAL/ENTITIES

An updated list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website at http://www.un.org/sc/committees/1267/consolist.shtml.

iVentures would ensure that accounts are not opened in the name of anyone whose name appears in said list. We shall continuously scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list. Full details of accounts bearing resemblance with any of the individuals/entities in the list shall immediately be intimated to SEBI and FIU-IND.

12. PROCEDURE FOR FREEZING OF FUNDS AND ASSETS

Under the Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA) Section, the Central Government is empowered to freeze, seize or attach funds and other financial assets or economic resources held by, on behalf of, or at the direction of the individuals or entities listed in the Schedule to the Order, or any other person engaged in or suspected to be engaged in terrorism. The Government is also further empowered to prohibit any individual or entity from making any funds, financial assets or economic resources or related services available for the benefit of the individuals or entities listed in the Schedule to the Order or any other person engaged in or suspected to be engaged in terrorism. In case, the results of the verification indicate that the properties are owned by or held for the benefit of the designated individuals entities, an order to freeze these assets under section 5 1A of the UAPA would be issued within 24 hours of such verification and conveyed electronically to the concerned depository under intimation to SEBI and FIU-TND and On receipt of this information after verification, iVentures shall act immediately on the same

. 13. REPORTING TO FIU

As per our observations if any, transaction of suspicious nature is identified it must be brought to the notice of the Principal Officer who will submit report to the FIU if required.

14. EMPLOYEES HIRING, EMPLOYEES TRAINING AND INVESTOR EDUCATION

14.1 Hiring of Employees

We shall have adequate screening procedures in place to ensure high standards when hiring employees, having regard to the risk of money laundering and terrorist financing and the size of the business, we ensure that all the employees taking up such key positions are suitable and competent to perform their duties.

The Company HR is instructed to cross check all the references and should take adequate safeguards to establish the authenticity and genuineness of the persons before recruiting. The department should obtain the following documents:

(a) Photographs
(b) Proof of address
(c) Identity proof
(d) Proof of Educational Qualification
14.2 Employees’ Training

We have an ongoing employee training program conducted by our Principal Officer and Senior Management, Participation of all the Key Employees in the Seminars conducted by various Regulatory bodies from time to time, so that the members of the staff are adequately trained in AML and CFT procedures.

All the Circulars issued by various Regulatory bodies including that of PMLA, are circulated to all the staff Members and the same are also being discussed in length, in the Training Program. Training program shall have special emphasis on frontline staff, back office staff, compliance staff, risk management staff and staff dealing with new clients. It is crucial that all those concerned fully understand the rationale behind these directives, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being misused by unscrupulous elements.

Our training will include, at a minimum: how to identify red flags and signs of money laundering that arise d ur i n g the course o f the employees‟ duties; what t o do once the risk is identified; what employees' roles are in the firm's compliance efforts and how to perform them; the firm's record retention policy; and the disciplinary consequences (including civil and criminal penalties) for non- compliance with the PMLA Act.

14.3 Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the Principal Officer. We will also review the AML performance of supervisors as part o f their a n n u a l performance review. The Principal Officer‟s accounts will be reviewed by the Board of Directors.

14.4 Investors Education

As the implementation of AML / CFT measures being sensitive subject and requires us to demand and collect certain information from investors which may be of personal in nature or has hitherto never been called for, which information include documents evidencing source of funds / income tax returns / bank records etc. and can sometimes lead to raising of questions by the client with regard to the motive and purpose of collecting such information. There is, therefore, a need for us to sensitize the clients about these requirements, as the ones emanating from AML and CFT framework. We shall circulate the PMLA Circulars and other specific literature/ pamphlets etc. so as to educate the client of the objectives of the AML/CFT program. The same shall also be emphasized on, in the Investor Awareness Programs conducted by us at frequent intervals of time. The importance of the same is also made known to them at the time of opening the Account.

Review of Policy

The Managing Director or Chief Executive Officer or any other authorized official shall be the authority to give directions for review of the policy and to undertake additions, changes, modifications etc., as directed by SEBI / FIU-IND and all the changes shall be deemed to be incorporated in this policy from their effective date.

Confidential Reporting Of Aml Non-Compliance

Employees will report any violations of the company‟s AML compliance program to the Principal Officer, unless the violations implicate the Compliance Officer, in which case the employee shall report to the Chairman of the Board. Such reports will be confidential, and the employee will suffer no retaliation for making them.

Program To Test Aml Program

The testing of our AML program will be performed by the senior Management of the company. After we have completed the testing, the Internal Auditors will report their findings to The Board of Directors. Each of the resulting recommendations will be addressed by us.

Reporting Of STRs

An important element to the success of the AML process is that the customers should not be informed (i.e. tipped off) that his/her accounts are being monitored for suspicious activities and / or that a disclosure has been made to the designated authority namely Financial Intelligence Unit, India. (FIU-IND) The company can however make normal enquiries to learn more about the transaction or instruction to determine whether the activities of the customer arouse suspicion.

Where it is known or suspected that a suspicion report has already has been made internally or externally, and it then becomes necessary to make further enquiries, care must be taken to ensure that the suspicion is not disclosed either to the client or to any other third party. Such enquiries shall normally be made as directed by the Principal Officer. "Tipping Off' provisions extended not only to the filling of the STR and/or related information but even before, during and after the submission of STR.

All STRs will be reported quarterly to the Board of Directors, with a clear reminder of the need to maintain the confidentiality of the STRs.

Disciplinary Action

A violation of standards, procedures or guidelines established pursuant to this policy shall be presented to Compliance Officer for appropriate action and could result in disciplinary action, including expulsion, dismissal, and/or legal prosecution.

Board Of Directors Approval

We have approved this Anti Money Laundering program as reasonably designed to achieve and monitor for ongoing compliance with the requirements of the PMLA and the implementing regulations under the same.

Principal Officer

In case of any further information or clarification if required in this regard, following are the details of the Principal Officer.

Mr. Nirmal Bansal
12, Vipul Agora, Gurugram, Haryana - 122002
Phone: +91 9810377077
Email ID: nirmal.bansal@iventures.in
Web Address: www.iventures.in


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info@iventures.in· +91-9212255855

iVentures Capital is a professionally managed leading broking house
holding the trust of its clients since 2005.

Address:
12, Vipul Agora, MG Road
Gurugram
Haryana – 122002.
Mobile: (91) 9212255855
Landline: 0124-4634433
Email: info@iventures.in
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