Policy on Running Account Settlement Policy

Introduction

SEBI vide circular no. SEBI circular No. MIRSD/SE/Cir-19/2009 dated December 3, 2009, SEBI circular No. SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 date September 26, 2016, SEBI circular No. SEBI/HO/MIRSD/DOP/P/CIR/2021/577 dated June 16, 2021 has issued wherein specified quarterly/ monthly settlement of running accounts of clients with a new set of compliances for stock brokers to in still greater transparency and discipline in the dealings between the clients and the stock brokers.

As per latest SEBI circular SEBI/HO/MIRSD/DOP/P/CIR/2022/101 dated July 27, 2022, effective from Oct 2022 to Dec 2022 quarter.

The running account of funds shall be settled on the first Friday of October 2022, January 2023, April 2023, July 2023, and so on for all the clients. If the first Friday is a trading holiday, then such settlement shall happen on the previous trading day. However, funds are transferred back to the primary bank account once a month if the client is inactive for 30 calendar days. It will reflect in the funds statement.

Ashlar may retain the funds if a client has an outstanding position on the first Friday of the quarter on which settlement is scheduled and send out an email with the retention statement.
If the settlement of funds with a broker is monthly, the settlement date will be the first Friday of the month.

Objective

Funds lying in the broker's client account are to be cleared/transferred back to the client's bank account.

Purpose

Protect investor funds from misuse or mishappening

Scope

All the Client of Ashlar Securities Pvt Ltd

Policy and Producer

Ashlar has obtained “Running Account Authorisation letter” wherein client specifically agrees to maintain his account on a running account basis i.e. monthly or quarterly settlement basis. Thereby, Ashlar has an obligation to done Actual settlement of fund & securities on their preference i.e. monthly or quarterly basis.

Ashlar conducts its business to ensure the obligations of actual fund & securities, as per SEBI, due to its client’s in routine course of business in a timely manner. The Policy laid down appropriate procedures to settle the obligation of funds and securities of the client on a timely basis as mandated by the client to establish highest standards of ethical and market practice.

Mandatory Quarterly Settlement of Running Account

As per new SEBI circular SEBI/HO/MIRSD/DOP/P/CIR/2022/101, effective from Oct 2022 to Dec 2022 quarter.

Settlement of Funds:-

Settlement of funds is done keeping in view the following points:-

In case of debit on the date of settlement, payout will not be given to the client;
In case of credit balance on the date of settlement with no future debit/credit balances in clients’ ledger, net credit amount on the date of settlement will be transferred to client;
Date of settlement, we consider ledger balance of client on T-1 day (t day) and accordingly, margin obligation of T-1 day (t day)for purpose of settlement of the client accounts then net credit balance (after adjusting retainable margin)will be transferred to client.
It the credit amount is not substantial enough to cover future debit then payout will not be released.
Ashlar will retain an amount of upto Rs. 10,000/- in Equity and Commodity (net amount across segment and across stock exchanges) only after taking written consent of the client.
For operational convenience circular states that accounts with balances less than Rs 10,000 are considered settled without having to transfer funds back to the client: (remove)

In the above settlement Ashlar will settle the fund considering across the segments and across the stock exchange for its clients.

Settlement of Securities:- (remove)

Settlement of securities is done keeping in view of the following points:-

Securities due for pay-in obligation are retained;
On date of settlement, we consider value of securities client on T-1 day and accordingly, margin obligation of T-1 day for purpose of settlement of the client accounts.
In respect of Derivative Market transactions, apart from the margin liability as on the date of settlement, we may retain additional margin requirement of maximum upto 125% of margin requirement on the day of settlement to take care of any margin obligation arising in next 5 days.
In case of clear ledger balances, the stock shall be transferred to the client.

In the above settlement Ashlar will settle the securities considering across the segments and across stock exchange for its clients.

Ashlar will send settlement of accounts for funds & securities along with mentioning retention of funds & securities to the clients just after doing actual quarterly settlement of account.

In case a client has not traded during the quarter / month and the trading member does not hold any funds or securities for the client at any point of time during the quarter / month for which settlement needs to be done, then the member may not issue statement of account to the client.

No inter client adjustment can be done for the purpose of settling client accounts.

RMS & Margin Policy

RISK MANAGEMENT AND SURVEILLANCE POLICY

RISK MANAGEMENT AND SURVEILLANCE POLICY A Risk Management & Surveillance is integral to an efficient risk system. We have put in place a comprehensive risk management system, which is constantly upgraded as per the Exchanges, SEBI & PMLA norms and also as per market movement.

RISK MANAGEMENT POLICY

The Model of RMS is framed for Branches and Authorized Person and clients. All the Staff, Branches, Branch Managers, Authorized Persons, clients need to understand and follow the policy as it is the integral part of company.

RMS Function includes:

• To check capital adequacy for exposure and requirements of the client.

• Monitoring of Clients Order, Patterns of Trade, Order rejections, increasing of Exposure/Limits if required.

• Monitoring MTM profit/loss incurred out of trades and outstanding positions.

• Decision taking with regard to squaring off positions on account of MTM loss or Margin shortfalls or any other reasons that may come across.

Limit construction derived by formula:

Market Limit:

[Combined Ledger Balance as on day across all Segment of NSE, BSE, MCX and NCDEX + Pledge value after appropriate haircut + successful EPI value + online fund transfer on Trading day + 80% value to limit on Sale Stock]

– [MTM Loss (Booked and open both) +Pay out request + unclear chq receipt (if any) + any un settled amount]

Equity segment

We allow exposure in equity market according to below mentioned product wise. We set limit in 2 type of product in equity segment

Product wise Limit Setting:

1. MIS/Cover Order/Bracket Order: Under this category we set limit fix 4 Times or we charged only 25% value of the stock or VAR/100 on the basis of Limit Set. The exposure set or given in this category is on auto squared off mode irrespective of margin available.

2. CNC: The exposure given in the category is fixed 1 time. Exposure set for the product on the basis free credit Ledger balance available. Stock buy in this product will be in nature of delivery.

Derivative and Commodity Segment

Limit setting in All Derivatives segment as per span margin includes all type of margin like initial, exposure, Adhoc, tender, additional and delivery. Exposures are based on product limit setting, mentioned below:

Product wise Limit Setting:

1. Mis/Cover Order/Bracket Order: Under this category limit set on Span Margin. (Means 1 times). The exposure set or given in this category is on auto squared off mode irrespective of margin available.

2. NRML: under this category limit is set 1 time as per the available balances according to span margin. Position can be carried forward only on 100% margin available.

Note-: If you trade in derivative product then you need to maintain 50% cash against collateral.

SQUARE OFF POLICY AND CONDITIONS

• The positions taken for MIS/CO/BO should be cleared within last 15 minutes of respective market close. ASHLAR shall not be responsible for any Loss/uncovered open position on account of any technical failure/ Circuit.

• Once the MTM loss reach 70% of the margin available, Positions will be squared off irrespective of any product.

• If the open position clearance not been initiated from branch and AP, then same would be cleared from RMS department. In this regard, company shall not be responsible for any loss that incur to the client on individual basis.

• Any NEFT/IMPS/RTGS is to be done, and then it should be before 2:00 pm for ignoring the ageing square off Initiated by Branch and RMS.

• T+1+5 (T denotes Trade Day) ageing debit has to be cleared by 2:30 PM by client. If the debit is not cleared by client Compulsory Square off by RMS in the case of non-payment of debit balance in the same day. Cheque would not be considered as payment on same day.

• Debit clients/UCC more than T+1+5 (T denotes Trade Day) will be on square-off mode. No fresh trade will be allowed in such case even if client squared-off his/her position.

• Any probability or guarantee of client cheque receipt/fund transfer request will not be considered on the day of square off.

• In case stock valuation falls below 20% of the total ledger debit, square off can be done even before 5th day of debit.

• If having more than 25 % debit concentration in single stock, stock will be liquidated by RMS.

• All outstanding positions will be squared off and Client will be responsible to pay the Dues to clear the outstanding in his/her ledger.

• In any Circumstances client fails to pay the dues, Company will switch to Legal activities to recover such amount from client.

• Margin Shortfall client’s position may be squared off or reduced up to margin available.

• All Physical Delivery Contract of NSE derivatives will be on square-off mode at its last trading day.

Outstanding Position will square off if client has not sufficient margin towards his delivery obligations.

• All Position in Commodity will be at square-off mode at the first day of their Tender Period.

• The MTM loss arising in F&O positions need to be paid on the same day (Trade day) so that MTM settlement can be performed properly, failing which the positions will be reduced to the available margin level.

• RMS may Square-off the positions in case of: -

1. Script highly volatile

2. Margin /MTM Shortfall

3. Cheque bounce / third party cheque deposit

4. Scrip is banned / not allowed for trading / withdrawal from F&O/ as per exchange

5. Suspicious trade or transaction under PMLA Act

6. Synchronized trading.

7. Regulatory body Prohibits or suspended the client.

8. Circular Trading.

9. Pump and Dump.

• Any type of consideration shall not be given to client, if any instances of cheque bouncing or cheque reversal have taken place in the account.

AMO order (After Market Order)

• AMO order can be placed at after-market hour. AMO orders release is being checked and placed at the time of market open.

• AMO can be cancelled if client does not have sufficient funds/stock balance at the time of order placed.

General Rules and Guideline:

• Trading is not allowed in illiquid stock (declared by Exchange), GSM and SMS stocks (sole discretion).

• Fresh trade is not allowed on any banned script in FO segment.

• Any banned open Position will be on square off mode only.

• Intraday trading is not allowed in banned scrips.

• Client is solely responsible for any loss, shortage and Auction in BTST trades.

• RMS may increase the minimum required margin in any or all product type of trading.

• 20 % Margin will be blocked in T1 Stock Selling.

• Trading in commodity contracts will be banned a day prior to the delivery intention period.

• Trading in Far months contracts in MCX are not be allowed. Only current and next expiry contracts are allowed for trade.

• Option Contracts in commodity segment is subject to open according to open interest and volume in that particular stock.

• If you not maintain 50% cash to collateral will attract up to 18%+GST interest P.A.

• Any delay payment (after T+2) will attract up to 18%+GST interest P.A.

• Any penalty by the exchange on transaction will be debited to the respective client only.

• Any observation like false commitment, fake deposit slip, cheque scanned but not deposited, false receipt of the cheque, cheque reversal instances, cheque bouncing instances and or any such instances come to the notice of Risk department; no further exposure shall be given to the client and strict action shall be taken against respective person.

• No family adjustment of ledger or cheque is allowed.

• No limit or exposure on uncleared cheques.

• No third-party cheque or collateral securities will be accepted.

• For Authorized person, risk will be considered up to the level of available deposit /brokerage • Positions taken as intraday is allow to convert to Delivery Product subject to the availability of credit balance or on confirmation of fund transfer.

• Positions will be squared off immediately, if a cheque bounces (due to any reason).

• Any unethical and unpractical practice seen, observe or done by client or dealer or AP or strict action will be taken and the decision will solely by the department.

• Margin Shortage Penalty shall be levied in case of short reporting by trading/clearing member per instance as per exchange rule and guidelines.

• AP cheques will be treated as confirmed subject to 1 time of his security deposit.

• Defaulter List shall be reviewed on monthly basis and client may be removed from defaulter list on review by APs.

• Payment control Report for debit recovery from the clients is made on daily basis and follow-up for the payment on regular basis done by Concern department.

*Note: Intraday square off timings can change based on the discretion of our risk management department.

• A Call & Trade charge of ?20 + GST will be applicable for all positions squared off by our RMS desk, including auto square off.

• If any intraday position or an MIS trade 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, Ashlar 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.

(position SQR-OFF without the margin call)

• Positions which do not have sufficient funds can be cut any time at the discretion of our RMS desk. There will be no margin calls (with margin call)or intimation from our RMS desk.

• Any open positions can be squared off at the discretion of our RMS desk If the funds available in your account are short of exchange specified margins. There will be no margin call before the position is squared off. During times of extreme volatility, the loss could be more than the funds available in your account before the position is squared off. All resulting charges or debts that might occur from such square offs will have to be borne by the client.

• All BO, CO and MIS positions will automatically be squared off at the end of the each trading day.

• Fines levied by the exchange for (beyong b short margin will be payable by the client.

• All information mentioned here is subject to change at the discretion of our Risk management Team

• Limits can be changed without any prior notice by risk management department in case of expected market volatility.

• Due diligence is being taken by the RMS Department in accordance to the risk of the client due to high leverages. However there is no guarantee or warranty that positions will be auto squared off in time, due to extreme volatility, any loss in such case have to be borne solely by the client. In case client request for pay-out and his/her position gets squared off due to auto squared off mode client will be responsible for his Loss.

New pledging system

If you want to pledge, you will get OTP SMS from NSDL/CDSL. The process of pledge will be completed only after confirming the OTP and only then the shares will be pledged and margin benefit against shares will be given.

Option sell credit can be used only to buy options on the same trading day

When you exit your long/buy option positions or enter new write/short options, the proceeds or credit of option premium can be used for only new long/buy option trades on the same trading day and only within the same segment (proceeds from equity options can’t be used for currency or vice versa). You can use this proceeds or option credit for all other types of trades only from the next trading day.

Password Policy

Password reset for dealers/ clients are through option forgot password. Reset password will be sent on registered mobile number or registered email id.

Policy and Procedure

This document essentially helps curb clients' risk and hence forms an integral part of Ashlar’s internal Risk Management Policy.

FREEZE/BLOCK THE ONLINE TRADING ACCOUNT

Timelines

In line with regulatory requirements, upon the explicit request from a client to block the online access to their trading account through any of the modes mentioned in the forthcoming sections, all efforts will be taken by Ashlar Personnel to fulfil the request as per the below timelines:

. a. For requests received within trading hours, all efforts shall be taken to block the account within 15 min.

b. For requests received after trading hours up until 15 minutes before the market opening time, all efforts will be taken to block the account before the start of the next trading session.

Mediums

Clients can report suspicious activities on their trading account via the following mediums:

a. By mailing on the dedicated email ID: care@ashlarindia.com

b. By calling the number: 0120-6633205/231 (between 8:30 am and 5:00 pm)

SURVEILLANCE POLICY

The objective of this policy is to have in place an effective market surveillance mechanism to ensure investor protection and to safeguard the integrity of the markets. The goal of surveillance is to spot adverse situations in the markets and to pursue appropriate preventive actions to avoid disruption to the markets. The fairness of the markets is closely linked to investor protection and, in particular, to the prevention of improper trading practices. This monitoring is required to analyse the trading pattern of the clients in order to observe whether any transaction (buying / selling) done intentionally, which will have an abnormal effect on the price and / or volumes of any share, which is against the fundamental objective of the Securities Market. It is mandatory under the exchange/regulatory directives to have in place appropriate Surveillance Policies and Systems to detect, monitor and analyse transactions. For the above we have to co‐relate the transaction data with their clients’ information/data and. Detect suspicious/manipulative transactions is an ongoing continuous process with analysis of trades and transactions and carrying out Client Due Diligence (CDD) on a continuous basis.

In‐order to implement the exchange directives, they have provided us alerts which have to be generated by us.

Surveillance Policy

Introduction

In accordance with BSE Notice No 20130307-21 dated March 07, 2013, NSE Circular No NSE/INVG/22908 dated March 07, 2013 and MCX-SX Circular No. MCX-SX/ID/1053/2013 dated March 08, 2013 trading members are required to frame surveillance policy for handling effective monitoring of trading activity of client. The company has laid down policy guidelines which have been framed in the light of above said circular, we are adopting and implementing this surveillance policy applicable to all clients of Ashlar Securities Pvt Ltd.

The policy has been approved by its Board of Directors in Board Meeting held on 18/04/2013 at the Registered Office of the company.

What is Surveillance?

Surveillance is the Process of collecting and analyzing information concerning markets in order to detect unfair transactions that may violate securities related laws, rules and regulations. In order to ensure investor protection and to safeguard the integrity of the markets. It is imperative to have in place an effective market surveillance mechanism. The main objective of surveillance function is to help maintain a fair and efficient market for securities.

Objective

To establish a surveillance mechanisms and controls in the operations /trading activity of Ashlar Securities Pvt Ltd clients.
To put in place appropriate controls for the detection and reporting of suspicious trading activities in accordance with applicable laws/laid down procedures.
To comply with applicable laws and regulatory guidelines.

Policy

Duties and Responsibilities

This Surveillance policy is approved by the Board of Directors of Ashlar Securities Pvt Ltd and A quarterly MIS shall be put up to the Board on the number of alerts pending at the beginning of the quarter, generated during the quarter, disposed off during the quarter and pending at the end of the quarter. Further, reasons for pendency along with appropriate action taken to resolve them shall be discussed. Board shall be apprised of any exception noticed during the disposition of alerts.

Designated directors/ Compliance officer shall be the responsible for all surveillance activities carried out by Ashlar Securities Pvt Ltd, maintenance of record and reporting of such activities.

Internal auditor of Ashlar Securities Pvt Ltd shall review the surveillance policy, its implementation, effectiveness and the alerts generated during the period of audit. Internal auditor shall record the observation with respect to the same in their report.

Receipt of Transaction Alerts from Exchanges

In order to facilitate effective surveillance mechanisms, Ashlar Securities Pvt Ltd surveillance desk shall download Transactional alerts to effectively monitor the trading activity of Client(s) provided by the exchange.

Types of Transactional Alerts provided by Exchange are as follow:

Sr. No.	Transaction Alerts	Segment
1	Significantly increase in client activity	Cash
2	Sudden trading activity in dormant account	Cash
3	Clients/Group of Client(s), deal in common scrips	Cash
4	Client(s)/Group of Client(s) is concentrated in a few illiquid scrips	Cash
5	Client(s)/Group of Client(s) dealing in scrip in minimum lot size	Cash
6	Client / Group of Client(s) Concentration in a scrip	Cash
7	Circular Trading	Cash
8	Pump and Dump	Cash
9	Wash Sales	Cash & Derivatives
10	Reversal of Trades	Cash & Derivatives
11	Front Running	Cash
12	Concentrated position in the Open Interest / High Turnover concentration	Derivatives
13	Order book spoofing i.e. large orders away from	Cash

The Exchanges provides transactional alerts through:

BSE – Alerts can be downloaded by log-in into e-Boss Surveillance System.
NSE – Alerts can be downloaded by log-in into NSE SURVEILLANCE BOARD.
MCX-SX – Alerts can be downloaded through SFTP Root Path\Trading member ID\Data Folder

Suspicious /Manipulative activity identification and reporting process

Suspicious /Manipulative activity identification and reporting process include gathering of client activity, seeking documentary evidences of required, monitoring the trading activates, record maintenance and reporting.

Clients Due Diligence

Ashlar Securities Pvt Ltd shall carry out the Due Diligence of client(s) on a continuous basis and shall update all the KYC parameters as prescribed by SEBI and latest information of the client in Unique Client Code (UCC) database of the Exchange.

Implementing Anti Money Laundering Policy Vis a Vis KYC standard for New Clients Acceptance and implementing high standard of due diligence process.
Periodic updating of client database and having system to do continuous client due diligence.
Identification of Beneficial Ownership
Bank/Demat transaction details
Identification of Multiple Accounts/common Accounts/ group of Clients
Analyzing common emails, mobile numbers, address and other linkages
Other publicly available information

Analysis Client Activity:

Client’s/ Group of Client(s) trading pattern or activity or scrips identified shall be analysed based on Alert received /generated through exchanges system.

Ashlar Securities Pvt Ltd shall require explanation from such identified Client(s) / Group of Client(s) for entering into such transactions as enclosed the Format (Form No. - A).
Ashlar Securities Pvt Ltd shall require documentary evidence such as bank statement / demat transaction statement or any other documents. In case of funds, Ashlar Securities Pvt Ltd shall require Bank statements of the Client(s) / Group of Client(s) from which funds pay-in have been met, to be sought. In case of securities, Ashlar Securities Pvt Ltd shall require demat account statements of the Client(s) / Group of Client(s) from which securities pay-in has been met, to be sought.
Note*
- The period for such statements may be at least +/- 15 days from the date of transactions to verify whether the funds / securities for the settlement of such trades actually belongs to the client for whom the trades were transacted.
Ashlar Securities Pvt Ltd shall analyze the documentary evidences, including the bank / demat statement; Ashlar Securities Pvt Ltd shall record its observations for such identified transactions or Client(s) / Group of Client(s).
In case adverse observations are recorded, Ashlar Securities Pvt Ltd shall report all such instances to the Exchange within 45 days of the alert generation, the alerts shall be disposed off, and in case of any delay in disposition, reason for the same shall be recorded.
In case of extension is required, Ashlar Securities Pvt Ltd shall send a request to exchange for a period of extension.
If explanation on the same shall not satisfactory / reply shall not receive within time period as above mentioned then Ashlar Securities Pvt Ltd suspend the client from trading / report the instance to Regulators (if suspicious).

(Form No. - A)

To,

Client Name :

Client Address :

Sub.: Alert received from (Exchange Name) in respect of your trading during the period from _________ to _________.

Dear Sir,

With reference to above, please note that we have received following alert form the exchange in respect of your trading activity during the period from___________ to _______________.

In this regard you are requested to clarify the following:

Basis of Investment
Objectives of Investment
Source of funds used for making the Investment
Whether such investment is based on any research report if so please provide the detail.
Reason for sudden increase in turnover
Whether you are related party to the Investee Company? If yes, please provide complete details of such relation.

Further you are requested to provide self-attested copy of Bank Account Statement and Demat Account Transaction Statement for the period from __________ to ____________ along with any other relevant document within seven days from the date of this letter.

Please note that your failure to submit reasonable explanation and required documentary evidence within above said time may lead to suspension of trading facility in your account.

INVESTOR GRIEVANCE HANDLING POLICY

Introduction

We at Ashlar Securities Private Limited endeavour to address all complaints regarding service deficiencies or causes for grievance, for whatever reason, in a reasonable time and manner. We realize that quick and effective handling and resolution of client’s/ Investor’s grievance is essential to provide excellent client service.

To achieve this, our company has clearly documented policy for redressal of investor grievances. Through this policy, our company shall ensure that a suitable mechanism exists for receiving and addressing complaints from our clients/investors with specific emphasis on resolving such grievances fairly and expediously.

In accordance with SEBI circular no. SEBI Circular SEBI/HO/MIRSD/DOP/P/CIR/2021/676 dated December 02, 2021, SEBI master circular SEBI/HO/OIAE/IGRD/P/CIR/2022/0150 dated November 07, 2022 and other relevant circular of Exchanges. The Company, has laid down policy guideline which have been framed in the light of above circular, we are adopting and implementing this Investor grievance handling policy to all clients of Ashlar Securities Pvt Ltd to effectively redress the grievances of the investors in a timely manner and facilitate investor awareness.

Scope

This Policy applies to all employees, paid interns, contractors, part-time, full-time employees including Authorised Persons.

Objective

The objective of the Policy is to promote and build prompt Investor Grievance redressal mechanism and investor friendly relations. The Policy thus recognises the investors’ right to always have a contact address available to enable them to query or record a grievance. This also enables the Company use investors’ views as a feedback mechanism.

Policy and Procedure

This policy seeks to ensure that

Grievance, if any that may arise shall be resolved in a proper and time bound manner with detailed advice to the client/investor. In case the resolution needs time, an interim response acknowledging the grievance/complaint shall be issued.

The Compliance Officer shall give quarterly report of the client’s grievance to the Directors of the company with complete details as Name and code of the client, Nature of Complaint, Date of receipt of the complaint and status of resolving the same. For grievances remaining unresolved for a period of more than 15 days from the date of receipt, the Compliance officer shall provide a justification to the Directors.

The Compliance officer shall maintain proper records of all grievances received and resolved.

All personnel/employees at the customer facing channels and other support departments will be periodically trained in handling of client’s complaints.

The Grievance Redress Mechanism with updated contact details and email ID shall be provided to the Clients and uploaded on the Company’s website.

Grievance Handling Mechanism

The Company has an established mechanism for investor service and grievance handling, with ASHLAR and the Compliance Officer appointed by the Company for this purpose, being the important functional nodes.

Some of the key steps undertaken by the Company for handling Investor Grievances are enumerated as follows:

An Investor /Client can make his/her complaint through email or letter to the Company.
The Investor/Client can make a written complaint through letter and sent it or hand delivered to Company’s Head Office.
Handling of all investor grievances is a centralized function and is being handled by Compliance department at corporate office.
The Company has a designated email ID investorcell@ashlarindia.com for handling investor grievances on which investor can send a complaint. This e-mail ID is permanently displayed on company’s website www.ashlarindia.com and is also mentioned on the KYC form.
The client/investor can contact Compliance Officer at her email id- investorcell@ashlarindia.com and Phone No. – 0120-6633229 & 8010934852.Phone No. – 0120-6633229 & 8010934852.
The Compliance Officer has access to the above designated Investor Complaints e-mail ID and is responsible for monitor this e-mail ID on a daily basis.
All the Investor Grievances received in writing at H.O. or at the investorcell@ashlarindia.com would be verified and scrutinize by the compliance department and it would initiate necessary steps to resolve the complaint within 1 -2 working days of the receipt of the complaint by them.
Any course of action which involves the concerned department at Head office it would be informed to the concerned head of the department and Business team. Likewise, if the course of action which involves branch and or associate, business team at the corporate office would be informed/updated.
If there is no response from concerned department or the branch and or associate within 3 working days of the complaint, the same would be escalated to Head Compliance for immediate action and if there no response within 5 working days the same would be reported to the Designated Director as in the form of an MIS reporting
All investor grievances should be resolved within time period of 15-25 days of the receipt of the complaint to the department.
More than 3 complaints received during a month from the same branch (number of complaints is subject to review depending upon the market conditions and volumes generated by the branches and or associates) Head of business would have to seek an explanation from the branch manager and keep the compliance department informed/updated.
All the investor grievances would be handled in the following manner by the compliance department:

All the investor grievances (hard copy or softcopy) would be updated in an excel register (softcopy)/ in complaint register (hardcopy) as in the format specified in Annexure-1 on the same day of the receipt of the complaint. This register would be monitored by the compliance officer.
After verification and scrutiny the appropriate steps would be initiated to resolve the complaint at the earliest.
A monthly MIS of the complaints received, pending and or resolved would be given to the Head of Business and designated Directors of the Company.
As per the exchange/depositary/SEBI directives the complaint register has to be maintained in hardcopy function wise i.e. Broking compliant register, DP complaint register and PMS complaint register as in the format specified in Annexure-1
Therefore, compliance department will ensure that depending upon the type of the complaint, all the information i.e. from the receipt of the complaint till the status of being resolved would be updated in the register as stated in point 10 d

The compliance officer would ensure that it gives its sign-off only after the complaint is resolved.
This policy is to be reviewed as & when management thinks fit or whenever changes are mandated by statutory authorities.

Review/Amendments of Policy:

This policy shall be reviewed as and when needed by Compliance Officer.
In the event of any conflict between the circular or any other statutory enactment and the clause of this policy, the amendment shall prevail over this policy.
Any subsequent amendments/modification in the circulars shall automatically apply to the policy.

Policy communication

A copy of the policy shall be made available to all the relevant staff, dealers branch in-charge, authorise person compliance officer and other stakeholder persons for their information and any change should be communicated to them.

Ashlar Securities Pvt Ltd (ASHLAR) is committed to providing effective and prompt service to its investors. ASHLAR has in place, a designated e-mail address i.e. investorcell@ashlarindia.com for assistance and/or grievance redressal and is closely monitored by the Compliance Officer.

The escalation matrix for complaints relating to the Investors of ASHLAR is as provided below:

Level 1- Customer Care
Level 2- Head of Customer Care:
- In the event, the grievance(s) are not resolved within 3 working days of its submission along with all requisite documents/information or the investor is not satisfied with the resolution provided, he/ she can forward his/her complaint to the next level of hierarchy.
Level 3- Compliance Officer
- In the event, the grievance(s) are not resolved within 5 working days of its submission along with all requisite documents or the investor is not satisfied with the resolution provided, he/ she can forward his/her complaint to the COO/director.
Level 4- Chief Executive Officer/Director
- In case of non-redressal of the complaint to the investor’s satisfaction within a reasonable time frame, the investor may approach the COO/director.

Details of	Contact Person	Contact No.	Address	Email Id	Working Hours
Customer Care	-	0120-6633 231	A-38, Sector-67, Noida-201301,U.P.	helpdesk@wisdomcapital.in	9:00AM TO 5:00PM (Monday to Friday)
Head of Customer Care	-	0120-6633 205		care@ashlarindia.com
Compliance Officer	-	0120-6633 229		compliance@ashlarindia.com
Compliance Officer	-	0120-6633 229/225		dp@ashlarindia.com
Chief Operational Officer (COO)	-	0120-6633 299		deepak@ashlarindia.com

Level 5 –
- In case a complaint is still not redressed to the investor's satisfaction, the investor may approach the Securities and Exchange Board of India and file their grievance through “SCORES”, the centralized online system for lodging and tracking complaints.
- SCORES facility can be accessed through the weblink -
  - SEBI at https://scores.gov.in/scores/Welcome.html
  - Exchange at https://investorhelpline.nseindia.com/NICEPLUS/

Policies

Policy on Running Account Settlement Policy

Introduction

Objective

Purpose

Scope

Policy and Producer

Mandatory Quarterly Settlement of Running Account

Settlement of Funds:-

Settlement of Securities:- (remove)

RMS & Margin Policy

RISK MANAGEMENT AND SURVEILLANCE POLICY

RISK MANAGEMENT POLICY

RMS Function includes:

Limit construction derived by formula:

Market Limit:

Equity segment

Product wise Limit Setting:

Derivative and Commodity Segment

Product wise Limit Setting:

SQUARE OFF POLICY AND CONDITIONS

AMO order (After Market Order)

General Rules and Guideline:

(position SQR-OFF without the margin call)

New pledging system

Option sell credit can be used only to buy options on the same trading day

Password Policy

Policy and Procedure

FREEZE/BLOCK THE ONLINE TRADING ACCOUNT

Timelines

Mediums

SURVEILLANCE POLICY

Surveillance Policy

Introduction

What is Surveillance?

Objective

Policy

Receipt of Transaction Alerts from Exchanges

The Exchanges provides transactional alerts through:

Suspicious /Manipulative activity identification and reporting process

Clients Due Diligence

Analysis Client Activity:

(Form No. - A)

POLICY FRAMEWORK FOR IMPLEMENTATION OF THE PROVISIONS OF PREVENTION AND MONEY LAUNDERING ACT (PMLA) 2002

Introduction

INVESTOR GRIEVANCE HANDLING POLICY

Introduction

Scope

Objective

Policy and Procedure

Grievance Handling Mechanism

Review/Amendments of Policy:

Policy communication