Policies and Procedures

KUNVARJI Finstock Pvt Ltd., is a member of the National Stock Exchange, Bombay Stock Exchange, primary engage in Equity, Equity Derivatives segment, Currency Derivatives segments. KUNVARJI Commodities Brokers Pvt Ltd., is a member of Multi-Commodity Exchange & member of National Commodity and Derivatives Exchange, primary engaged in Commodity segments having its registered office at B-wing, Siddhivinayak Tower, Nr D.A.V.School, Next to Kataria House, Off S.G. Highway, Makarba, Ahmedabad : 380051 Gujarat, India. In this policy documents we will refer both the company as ‘KUNVARJI group”. Our Mobile Trading application TRADESAPP is giving access right to execute trades on NSE, BSE, MCX & NCDEX in the segments specified above.

Funds:-

Procedure of Pay-in & Pay-out

Pay-in: Clients can transfer funds into the Trading Account only from his\her registered Bank accounts given at the time of account opening. Any transfer from a non-registered bank account will not be considered and the client does not get any leverages for such transfers.

The client can transfer funds from online/mobile back office and TradesApp Mobile application and through other gateway facility available. Such transfers will be charged at Rs 5 + GST per transfer. If a client chooses to transfer using NEFT or by means of cheque, there will be no cost.

If the client transfers funds via cheque, the details of the transfer along with a copy of the cheque and deposit slip should be made available to respective companies for the credit entry to be updated in the trading account. The limit will be given subject to clearing of cheque or reflected credit entry in client ledger.

Payout: All payouts request will have to intimate or updated through Mobile back office application\Back office access provided to the clients. All payout requests will be processed electronically and the credit shall come to the client’s primary\registered bank account within 24 hours of having processed the payout request. Any payout request received after 3.30 will be processed on the next working day and client will receive the funds in 48 hours. This will be applicable to equity as well as commodity Segments.

Payout request will not be entertain on Saturday and Sunday – this means if you place a request on Saturday or Sunday or after 3:30 pm on Friday, it will be honored only on Monday.

Margins

Client Funding: KUNVARJI group does not engage in the business of Client Funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions.

NSE/BSE Equity: KUNVARJI Group have a policy of giving up to 1.75 times intraday exposure on a broad spectrum of stocks; no margin is given for delivery trades. The client needs to have enough money in his\her trading account to take delivery of shares failing which our RMS can cut the position. Client can have access the comprehensive real-time margins\live risk through Online Back Office.

For NSE\BSE Futures and Option – Leverage provided in this segment is subject to market conditions. Clients are required to have sufficient balance in their accounts to hold\carry forward positions. Client can access the comprehensive real-time margins\live risk through Online Back Office.

MCX & NCDEX Commodities: Group have a policy of giving upto 5 times intraday exposure in all the base Metals and Agri and Non Agri commodities. Leverage provided is subject to market conditions and changes in its proportion are dynamic. Currently 17% to 20% of SPAN is required to trade intraday. Carry Forward (NRML) positions require 100% SPAN

Risks pertaining to commodity options that devolve into futures on expiry:

Item Equity/Cash Equity derivatives Currency futures       Commodity Commodity
Intraday Margin Time 3:15 PM onwards 3:15 PM onwards 4:50 PM onwards      25 minutes before close 25 minutes before Close

If any intraday position is not squared off on the same day due to any link or system failure or any risks associated with internet/wireless based trading which may occur at the end of the Client, Kunvarji Group or the respective Exchange, it shall be treated as a Cash and Carry (“CNC”) or NRML position and carried forward to the next trading day. In case of such a situation arising, the onus of squaring off the position will be on the Client. Our RMS desk shall square off any such position, without the requirement of a margin call, if the necessary cash is not available in the Client’s account.

Note

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

Collateral margins

Debit balance

Delayed payment charges

KUNVARJI group follows the practice of posting the settlement obligation in client’s ledger on the settlement date. All clients are advised to make the payment before the pay-in time on the settlement day, though there are instances wherein client may delay the payment beyond the settlement date. It is obligatory for a broker to meet the settlement obligation in time, therefore, in order to ensure timely receipt of funds from clients towards their payment obligation, “delayed payment charges” are levied in the client’s account. The “delayed payment charges” is levied to discourage delayed payment from clients who do not deposit the required sum of money before the pay-in time on the pay-in day. “Charges for delayed payment” are levied on the respective ledger debit of the clients at a rate of 18% per day of the debit balance in the account. This will be applicable to all the segments across all the exchanges.

Charges on F&O position

In the Equity Derivative Segment, Currency Derivative Segment, and in commodities exchanges we accept the approved securities from clients for margin purpose. Liquid bees are considered as margin.

Contract notes and margin statement

KUNVARJI group will issue contract notes & margin statements to its clients within 24 hours of the trade taking place. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin status which is also available to be viewed on their respective Mobile Back office\ Ledger.

Demat accounts

Kunvarji group will maintain client’s securities in a Client Beneficiary Account (Demat). A client who wants to fully engage in trading in the Delivery Segment of NSE/BSE, will have to compulsorily open an account with KUNVARJI Group. A client who wants to do delivery base business in commodity segments needs to open COMRIS or NERL account.

Trades

The trades of clients shall be carried out in the respective client code only. The dealers shall take utmost care while executing the trades of the clients regarding the accuracy of Client Code, Quantity, Price, etc.

Closing of accounts/dormant account

The Clients account shall be closed upon a specific request from the client after getting account closing request form. Process will be done by KYC dept after settlement of account.

Settlement of account shall mean that there is no outstanding balance of shares or funds in client’s account. As far as dormant accounts are concerned, we do not close such accounts, but mark the same as “Inactive” till further action by the client.

Investor grievances

The dedicated Customer Care desk is available for handling the investors Grievances and client complaints. The email ID you can write to in case you have any grievance is customercare@kunvarji.com.The resolution of the Complaint shall be done at the earliest or interim response will be given to client.

Brokerage

Brokerage will be charged as per plan opted by client. Client shall receive brokerage charges details at the time on account opening in electronic form.

Kunvarji PMLA Policy

Applicability Kunvarji Finstock Private Limited (KFPL), SEBI Registered Intermediary (Broking/ DP/PMS)

In compliance with – The PMLA Act 2005 and rules thereof -SEBI Circular and Directives including SEBI Master Circular’s ref. SEBI/HO/MIRSD/DOP/CIR/P/2019/113 dated 15-October-20189.

  1. KFPL Policy It is our policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal 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.

2.1. Written Anti Money Laundering Procedures KFPL has adopted these written procedures to implement the anti- money laundering provisions as envisaged under the PMLA. Such procedures shall include inter alia, the following three specific parameters which are related to the overall ‘Client Due Diligence Process’:

  1. a) Policy for acceptance of clients
  2. b) Procedure for identifying the clients

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

The regulatory / statutory requirements

An officer of the company will be designated as “Principal Officer” who will ensure proper discharge of all legal requirements with respect to the same Mr. Atul Chokshi – Compliance Head is the Principal Officer responsible for

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

The customer due diligence process includes three specific parameters:

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

1. Client identification

Before opening any Trading account with us, in KFPL or with KCBPL, the following measures shall be taken:

4. Suspended Persons

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

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

Illiquid Securities

The Exchanges specifies a list of Illiquid Securities where higher due diligence is to be exercised by the Brokers. The trade pattern in such scrips by our clients is monitored. In case of high volume in any scrip compared to Exchange volume, the client is asked to submit clarification.

KUNVARJI – TradesApp…

TradesApp has introduced the concept of discount broking as well as basic   brokerage slab. Trades can avail benefits through technology and easy to operate trading platform.

Other Charges:
Margins:

TradesApp is a web and mobile trading application offered by KUNVARJI group. Special Features of Our Trading application is as under…

  1. Extensive charting with over different indicators and different chart types.
  2. We are equally committed to providing the best possible customer experience through highly personalized service and support. To find out more about us feel free to visit our website. For queries you could write to info@tradesapp.in or call us at 079-6666 9000 Ext : 293

Alternative Means of Communication in Case of L/L Failure in Internet

There are Centralized Dealing Desk functioning at our Registered Office, as trading backup system. All registered can access Centralised dealing room in any eventuality. A dedicated helpline\Dealing number, which is 079-6666 9000 ( Ext : 309/310/311) is available exclusive for online clients. Clients would have to call on these numbers and authenticate their account information before the dealer can place trades.

Additional charges of ₹50 per executed order:
a) For orders placed through our support/dealing desk.
b) Intraday (MIS/BO/CO) positions squared off before market closing by our RMS team.

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