RMS & Margin Policy

Introduction

Margin in trading do excites us a lot to trade more and more. Actually margins are in accordance with the market dynamics and may change from time to time. Below mentioned are some of the points which depict the various margin policies of Ashlar. These will help you out while trading in various segments. Let’s have a look at them:

1. Equity Trading

ASHLAR provides you with an opportunity to trade in both NSE and BSE segment. These are the details for exposure in Intraday and Delivery trading:

• Intraday: Basically it involves opening and closing on the same day itself. In this segment, ASHLAR is providing leverage up to 60 times in Equity. Basically you need to place orders with the product types MIS/MISS/BO/CO. The leverages provided here are as per the brokerage plan selected by you and the segment of the stock you want to trade in.
• Delivery:
  • Delivery trading involves holding stocks overnight. Here in this section, you can expect to have leveraged up to 1 times in Equity.
  • The orders for delivery trades can also be placed in CNC/NRML with 1X leverage.
  • The leverages are provided as per the brokerage plan selected by you and the category of stock you are trading in.
  • You can have a look at our Margin Calculator for leverage in Equity segment here.

2. Future & Option Trading (Equity Stocks and Index)

• Intraday
  • ASHLAR is providing leverage up to 20 times in Future Contracts in Bracket Order (BO) and Cover Order (CO), and up to 30 times in Margin Intraday Square-Off (MIS)/MISS, depending upon the brokerage plan chosen by you.
  • Whereas, in Option Writing/Selling up to 30 times leverage is provided in Margin Intraday Square-Off (MIS)/MISS, depending upon the brokerage plan chosen by you.
  • In Option buying, up to 3 times leverage is available in Bracket Order (BO).
  • As you know, higher leverages for trading in any segment, especially in MIS/MISS (where pre-defined stop loss are not essentially to be placed) has to be used meticulously. Thus, by default up to 10 times leverage in MIS/MISS is being enabled on activation of account, as per the brokerage plan chosen. However, if you are an active trader and scalper, it can be increased further, subjected to consent for MTM Square-Off being sent along with welcome letter on account opening.
• Carry Forward
  • According to the various guidelines mentioned by the exchanges, the full margin, known as the span margin or initial margin plus exposure margin will be required to take overnight position or to carry forward the position till expiry. You need to maintain the stipulated margin as per the exchange on daily basis, to avoid any penalties for short fall.
  • The orders have to be placed in product type NRML.
  • You can check our Margin Calculator for leverage in Futures and Options segment here.

3. Future & Option Trading (Currency)

• Intraday
  • We are providing up to 5 times leverage in currency futures and option writing, as per the brokerage plan selected by the client.
  • The leverages will be available in the product type MIS/MISS.
• Carry Forward
  • As per exchange’s guidelines, the full margin, which is span margin or initial margin plus exposure margin will be required to take overnight position or to carry the position till expiry. The client needs to maintain the stipulated margin as per the exchange on daily basis, to avoid any penalties for short fall.
  • The orders have to be placed in product type NRML.
  • You can check our Margin Calculator for leverage Currency segment here.

4. Future & Option Trading (Commodity)

• Intraday
  • Here you will get leverage up to 5 times in commodity futures and option writing. The leverage basically depends on the brokerage plan selected by you.
  • You need to place orders with the product type as MIS/MISS, to avail the stipulated leverage.
  • However, we are providing leverage up to 6 times in BO/CO type only in Futures.
• Carry Forward
  • As per exchange’s guidelines, the full margin, which is span margin or initial margin plus exposure margin will be required to take overnight position or to carry the position till expiry. The client needs to maintain the stipulated margin as per the exchange on daily basis to avoid any penalties for short fall.
  • The orders have to be placed in product type NRML.
  • You can check our Margin Calculator for leverage Commodity segment here.

5. IMPORTANT

• The positions will be squared off at a MTM loss of 70%*, without the requirement of a margin call in case of volatile market. However margin / intimation call will be given 40% to 60% of total available margin. In case of a loss of 70% of your funds, the positions will be automatically squared off by our RMS Team.
• For this purpose, calls to be made on registered mobile no. / emails sent to the registered mail address.
• *On the subsequent market volatility margin call can be given after square off the outstanding position.
• In case of square off the positions best efforts to be made to leave open positions to the extent that could ordinarily be carried forward as per norms on the available free balance after setting aside the MTM Loss for the day till 3:00 pm.
• While closing out, the positions with highest margin / highest MTM Loss will be closed off first.
• *In case you get a special leverage, the positions will be squared off at 50-70% MTM Loss. This is done to reduce the risk of the client in cases of high volatility in the market. The market is uncertain. It’s better to play a safe game than repenting later on.
• In case of special leverages, separate consent for MTM will be required from you.
• The MIS/MISS/BO/CO trades need to be squared off on the same day, by you, by 3.15 p.m. In case, you have not squared off the position, the same will be done by the RMS Team after the mentioned time. In case of currency, it will be done at 4:45 pm whereas when commodity is concerned, the squaring off is done at 11:15 pm in winters and 11:40pm in summers.
• Thus, generally the squaring off is done at the time 15 minutes earlier than the market closing time.
• *Note: Intraday square off timings can change based on the discretion of our risk management department.
• Although, we square off all MIS/MISS trades automatically after 3:15 pm, the responsibility of squaring off the position lies with you. If the position is not squared off, the same will be converted from MIS/MISS to CNC/NRML. This will be squared off by the RMS Team on the next trading day, without the requirement of margin call, if the required fund is not available in the client’s account.
• Member may transfer the unpaid client securities from pool/unpaid securities Demat account to client’s Demat account in accordance with its Risk Management (RMS) Policy
• As the SEBI circular mandates liquidation of securities in case of non-payment within 5 days from the pay-out date, no pre-order confirmation is required.

Margin of Safety:

The positions cannot be carried forward, in case of loss of 30% of the client’s total fund.

Also, the client has to maintain Margin of Safety/upfront margin, in case of equity delivery. The non-maintenance of the same will lead to squaring off the position/holding automatically by the RMS Team, without the requirement of margin call.

The same is done to maintain risk in case of volatility in the market or in the particular stock taken by the client.

*Margin of safety = (Net Cash Available *100)/ Total Holdings

Net Cash Available = Value of shares after haircut – Debit in Ledger

Margin reporting and Margin Pledge

There are two major regulatory changes from Sep 1st, 2020:

• The method of pledging stocks, and
• Upfront margin requirements (Stocks and F&O on NSE, BSE, MCX)

New pledging system

Until now, when you pledged stocks as collateral to receive margins for trading, you had to move it from your Demat account to the broker and in turn to the clearing corporation. Going forward, the stock will continue to remain in your Demat account and can be directly pledged to the clearing corporation. In the new process of 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.

And for releasing the shares you have to place a upfront request with broker before selling them so that releasing request can further be placed with CM/CC. if request is not placed on time and auction happens then you will have to bear the loss.

Holdings sold can be used to trade F&O

As it is now, you will be able to sell your stock holdings and use the proceeds to enter F&O trades immediately. This is again possible after the clarification from exchanges that Early Pay in (EPI) of stocks sold can be considered as margin, both for new stock and F&O trades.

Sale proceeds from holdings can be used to take new positions

If we debit shares from your Demat and make an early pay in to the exchange on the day it is sold you can continue using the full value of sale proceeds from your stock holdings as soon as you exit them to enter new positions — other stocks or F&O positions. Nothing will change for you as a client

T1 holdings

To sell T1 holdings (stocks bought the previous day and yet to be credited to your Demat) you need VAR, ELM, ADHOC margin. Credit for sell will not be available against T1 selling.

Intraday profits can be used for new positions only after it is settled

Currently, you can use intraday realized profits for taking new positions on the same trading day. Going forward, you will be able to use it only after 2 days (1day) in case of equity/stocks and the next day in case of F&O. This is because the settlement cycle for equity is 2 days and 1 day for F&O, which is when the profits get credited to your account from the exchange only then. So intraday equity profits earned on a Monday can be used to trade more only on Wednesday (Tuesday), and intraday F&O profits earned on Monday can be used to trade more only on Tuesday.

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.

Intraday leverages for now remain the way it was before.

Summary of the changes in the below table:

OTHER

• 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.
• All sticky client codes to be brought in the knowledge of management regularly.

*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.

(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.

• Option Premium benefit is not provided until expiry for trading.
• 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.

Note

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

• All open options contract will be devolved into futures on the expiry date of the options contract.
• The exchange blocks a margin equivalent to 25% of the margin required to hold the devolved future contract 2 days before expiry and 50% of the margin, 1 day before expiry.
• Failure to produce the margin in the trading account can lead to a square-off of open positions at the discretion of the RMS team.
• The margin block will be applicable for contracts part of the exchange’s sensitivity report.
• ASHLAR may also consider imposing additional margins apart from the ones described above from time to time.

If any intraday position or an MIS/MISS 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.

• An order placement charge of Rs.20 plus GST will be levied for all OFS, Buyback and Takeover orders placed through Ashlar.
• Option premium received from writing options will not be considered as Cash/Capital.
• BO/CO not available on currency options.
• BO/CO Order is not available for stock options.
• 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 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.
• Collateral margin will not be considered for equity delivery positions.
• All BO, CO and MIS/MISS positions will automatically be squared off at the end of the each trading day.
• Trading in MCX contracts will be banned a day prior to the delivery intention period.
• Basket /Cover/MIS orders will only allowed in Future listed stocks.
• Fines levied by the exchange for short margin will be payable by the client.
• Clients will have to ensure all CO, MiS/MISS, and intraday products are closed by the EOD.
• Payments will only be accepted from the client’s registered bank account; cash and DD pay-in are not accepted.
• Commodities with staggered delivery will be closed 10 days prior to the delivery date in order to avoid physical delivery, also commodities with compulsory delivery will be closed a day before their respective delivery intention periods.
• On the start of the delivery intention period, clients will not be informed before closing any open positions to avoid compulsory delivery notice. Clients are advised to close their positions well in advance.
• For Commodities, on the start of delivery intention period, no contract will be available under MIS/MISS or CO product type.
• Physical Delivery of Commodities is not allowed.
• Collateral margins
• For all pledge requests placed before 4:00 PM, the collateral margin will be available to trade on T+1 day (next working day). All requests placed after 4:00 PM will be processed only on the next working day.
• Margins will be provided after the applicable haircut. A haircut of 20% would mean that if you pledged stocks worth Rs 1 lakh, Rs 80,000 (80% of 1 lakh) will be added as collateral margin to your trading account.
• You will be able to use this entire margin after haircut for taking intraday or overnight positions in Futures, and for writing Options of equities, indices, and currencies.
• Exchanges stipulate that for overnight F&O positions, 50% of the margin needs to compulsorily come in cash and the remaining 50% can be in terms of collateral margin. If you don’t have enough cash, your account will be in debit balance and delayed payment (interest) charges will be applicable on the debit amount. So, if you take a position that requires a margin of Rs 1 lakh, you will need at least Rs 50,000 in cash irrespective of how much collateral margin you have. Assuming you don’t have Rs 50,000, whatever you are short by will be the debit balance for the day, and delayed payment (interest) charges will be applicable for that amount.
• Reserves the right to liquidate any stock in case debit arises in the client's account and subsequent nonpayment of such debits.
• Option Premium benefit is not provided until expiry for trading.
• 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 payout and his/her position gets squared off due to auto squared off mode client will be responsible for his Loss.

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

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:

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.

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

Introduction

The Prevention of Money Laundering Act, 2002 (PMLA) came in force with effect from 1st July 2005.

As per the provisions of the PMLA, each market intermediary (Reporting Entity) (which includes a stockbroker, sub-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, asset management company, depositary participant, merchant banker, underwriter, portfolio manager, investment adviser and any other intermediary associated with the securities market and registered under Section 12 of the Securities and Exchange Board of India Act, 1992 (SEBI Act) shall have to adhere to client account opening procedures and maintain records of such “transactions” as prescribed by the PMLA and Rules notified there under.

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
	-	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/