POLICIES AND PROCEDURES

This document from SREIL is mandatory as per SEBI Circular No. MIRSD / SE / Cir-19/2009 dated 04.12.2009 and requires your utmost care, attention and understanding.

1. Policy for Penny Stocks: SREIL shall have the absolute discretion to accept, refuse or partially accept any buy or sell order for execution from a client in respect of penny stocks, illiquid stocks, stocks having low liquidity, illiquid “options”, far month “options”, writing of “options”, stocks in S, Z and B2 category and any other contracts which as per the perception of SREIL are extremely volatile or subject to Market manipulation and / or depending on the market conditions.
      SREIL shall have the prerogative to place such restrictions, notwithstanding the fact that the client has adequate credit balance or margin available in his account and/or the client had previously purchased or sold such securities / contracts through SREIL itself. SREIL and / or any of its directors, employees, associates, sub brokers, will not be held responsible due to losses due to such refusal.

2. Setting up client′s exposure limits: SREIL may from time to time vary limits (exposure limits, turnover limits, limits as to the number, value and / or kind of securities in respect of which orders can be placed etc.) on the orders that the client can place through SREIL's trading system. The client is aware and agrees that SREIL may need to vary or reduce the limits or impose new conditions for limits urgently on the basis of SREIL's risk perception and other factors considered relevant by SREIL including but not limited to limits on account of exchange / SEBI directions / limits (such as broker level / market level limits in security specific / volume specific exposures etc.), and SREIL may be unable to inform the client of such variation, reduction or imposition in advance. The client agrees that SREIL shall not be responsible for such variation, reduction or imposition or the client′s inability to route any order through SREIL′s trading system on account of any such variation, reduction or imposition of limits
     The client further agrees that SREIL may at any time, at its sole discretion and without prior notice, prohibit or restrict the client′s ability to place orders or trade in securities through SREIL, or it may subject any order placed by the client to a review before its entry into the trading systems and may refuse to execute / allow execution of orders due to but not limited to the reason of lack of margin / securities or the order being outside the limits set by SREIL / exchange / SEBI and any other reasons which SREIL may deem appropriate in the circumstances. The client agrees that the losses, if any on account of such refusal or due to delay caused by such review, shall be borne exclusively by the client alone.
     SREIL has margin based RMS system. Total deposits of the clients (Funds and Securities lying with SREIL either as Margin or in running account) are uploaded in the system and client may take exposure on the basis of margin applicable for respective security as per VAR based margining system of the stock exchange and / or margin defined by RMS based on their risk perception. Any failure on the client′s part in payment of margins shall be viewed seriously and SREIL is authorized not to allow the client any further exposure and also authorized to square off client’s existing position/s and / or sell the securities lying with SREIL as collateral.

3. Applicable brokerage rate: Brokerage will be charged at the rates being agreed between the client & SREIL within the limits prescribed by SEBI / exchange. The slab rates of brokerage fixed by SREIL are function of the quality and cost of services provided to the client and the volume and revenue expected from an account. It shall be reviewed by SREIL from time to time.
      The brokerage shall however be exclusive of DP Annual maintenance charges, DP transaction charges / Pledge / Re-pledge / Demat / Remat charges, DP Inter settlement charges, Account Opening charges, Delayed Payment charges, Penalties levied by Exchange, Research advisory charges, Courier charges, Bank charges towards the cheques received unpaid, DP, Bank and other processing charges towards periodic settlement of Funds/Securities on periodic basis, Statutory charges payable to Exchange/SEBI/Govt. Authorities etc., SEBI/Exchange/Clearing Member Turnover charges, Other out of pocket and service related charges.

4. Imposition of penalty / delayed payment charges:The client agrees that SREIL may impose fines / penalties for any orders / trades / deals / actions of the client which are contrary to this agreement / rules / regulations / bye laws of the exchange or any other law for the time being in force, at such rates and in such form as it may deem fit. Further where SREIL has to pay any fine or bear any punishment from any authority in connection with / as a consequence of / in relation to any of the orders / trades / deals / actions of the client, the same shall be borne by the client.
     SREIL is therefore authorized by the client to charge a delayed payment penalty, not exceeding 18% per annum, on account of delays/failure by the client in meeting the pay-in obligations on the scheduled date and also where the clients take exposure in F&O segment by depositing collaterals in a ratio which is disproportionate to the Cash versus collaterals ratios prescribed by the Exchanges. While levying delayed payment charges or interest on the debit balance in the running account of a client, SREIL may not consider any credit balance in the other family or group account of the client.
     SREIL provides exposure against the upfront margin received in the form of cash / collateral from the client and the client also has the prerogative to demand withdrawal of cash and collaterals at his discretion, SREIL shall not pay any interest or other benefit to the client for maintaining cash balances or depositing collateral margins with SREIL.

5. Shortages in obligations arising out of internal netting of trades:For internal shortages in BSE, the stocks are recovered by self auction at BSE on T+3 day and in NSE they are purchased from the market on T+3 day. The purchase consideration (inclusive of all statutory taxes & levies) is debited to the short delivering seller client.

6. The right to sell client′s securities or close client′s open positions: Without prejudice to SREIL′s other right (Including the right to refer the matter to arbitration), SREIL shall be entitled to liquidate / close out all or any of the clients position without giving notice to the client for non payment of margins or other amounts including the pay in obligation, outstanding debts etc. and adjust the proceeds of such liquidation / close out, if any, against the clients liabilities / obligations. The client shall ensure timely availability of funds / securities in form and manner at designated time and in designated bank and depository account(s), for meeting his / her / its pay in obligation of funds and securities. Any and all losses and financial charges on account of such liquidations / closing out shall be charged to & born by the client.

7. Restrictions / Prohibition to take further position or closing existing position: Under following circumstances, the client may not be permitted to take any further position by SREIL and / or SREIL shall close existing position without any further intimation to the client:

1. Failure or delay to meet pay-in or margin obligation on time and / or to clear outstanding dues to SREIL.
2. Repeated bouncing of cheques of the client.
3. Unnecessary / unwarranted dispute from client with SREIL without any substantial cause / reason.
4. Client′s attitude of not coming to an amicable settlement for any dispute that can be settled without involvement of Exchange and /or SEBI.
5. As per findings of Risk Management department of SREIL.
6. Any direction from SEBI / Exchange or such other authorities.
7. Under any such other circumstances as SREIL may think just and proper on case to case basis.

8. Temporary suspending or closing Client′s Account: Client′s Account may be suspended or closed by SREIL from further dealing through SREIL in following circumstances:

1. As per Client′s prior written request in prescribed format submitted to SREIL at its Mumbai H.O. (subject to clearance of entire outstanding / obligations).
2. Dormant or in-active status of client account beyond specified time limit as may be prescribed by SREIL and
3. Under any circumstances mentioned in point no.′7′.

9. Deregistering a client:Notwithstanding anything to the contrary stated in the agreement, SREIL shall be entitled to terminate the agreement with immediate effect in any of the following circumstances:

1. As per specific written request from client submitted to SREIL at its Mumbai H.O.;
2. Any direction from SEBI / Exchange or such other authorities;
3. If the action of the client are prima facie illegal / improper or such as to manipulate the price of any securities or disturb the normal/proper functioning of securities or disturb the normal / proper functioning of the market, either alone or in conjunction with others;
4. If there is any commencement of a legal proceeding, including arbitration against the client under any law in force;
5. On the death/lunacy or other disability of the Client;
6. If the client being a partnership firm, any steps taken by the Client and/or its partners for dissolution of the partnership;
7. If the Client suffers any adverse material change in his / her / its financial position or defaults in any other agreement with the Stock broker;
8. If there is reasonable apprehension that the Client is unable to pay its debts or the Client has admitted its inability to pay its debts, as they become payable;
9. If the Client is in breach of any term, condition or covenant of this Agreement;
10. If the Client has made any material misrepresentation of facts, including (without limitation) in relation to the Security;
11. If a receiver, administrator or liquidator has been appointed or allowed to be appointed of all or any part of the undertaking of the Client;
12. If the Client have taken or suffered to be taken any action for its reorganization, liquidation or dissolution;
13. If the Client has voluntarily or compulsorily become the subject of proceedings under any bankruptcy or insolvency law or being a company, goes into liquidation or has a receiver appointed in respect of its assets or refers itself to the Board for Industrial and Financial Reconstruction or under any other law providing protection as a relief undertaking;
14. If any covenant or warranty of the Client is incorrect or untrue in any material respect;
15. Under such other circumstances as SREIL may think just and proper on case to case basis.
16. Based on the recommendations made by the Branch Manager /Associate /Sub-broker (eg., excessive speculations, un-cleared balances,etc.)
17. If the client is unable to fulfill any and/or all obligations towards the exchange(s), SEBI, SREIL on time.
18. DCN failed (Bounced email) on more than 4 instances until client submits and registers new email id.
19. Non delivery of the Statement of Account sent on periodic basis.
20. Non updation of communications details viz., email id, Mobile no, Land line details or it is found to be belonging to a third person.
21. Client lodges a compliant either directly with SREIL or through Exchange relating alleged unauthorized Trades being executed in the account.
22. On notices received from statutory, Government or Local authorities and Income Tax, Service Tax, a Judicial or a Quasi Judicial authority, etc.
23. SREIL may also close client′s account any time at its sole discretion by giving adequate Notice/intimation in advance.

10. Policy for Dormant / In-active account:As per SREIL′s policy, the account in which no transaction of any nature has taken place during last twelve months shall be considered as Dormant / in-active account. In case SREIL treats the account of client as in-active account, the funds or securities lying with SREIL shall be refunded / returned to clients immediately on demand by the client. In case SREIL treats the account of client as dormant account, and if trade is executed in such account, then it is verified with client over telephone. As a risk management measure the telephonic conversations with the clients are recorded at head office.
     In order to reactivate the inactive account, client needs to instruct SREIL in writing in prescribed format atleast 2 days in advance at its Mumbai H.O. Such written request DULY SIGNED BY CLIENT may also by sent by way of Fax on 022-22884564 to Compliance Officer or by e-mail to compliance department at compliance@sre.co.in from client’s own e-mail account registered with SREIL. SREIL shall reactivate the said account subject to fulfilment of such conditions as SREIL may consider fit and proper. However, SREIL may, in its own discretion, reduce / increase the period of 2 days as the circumstances may warrant on case to case basis.

11. Policy for Client code modification / Error account :

1. SREIL shall have the absolute discretion to accept, refuse or partially accept the client code Modification requests based on Risk Perception and other factors considered relevant by SREIL; SREIL and / or any of its directors, employees will not be held responsible for Damages/losses due to such refusal or due to delay caused by such review.
2. Client code modification requests will be strictly accepted only to rectify genuine error in entry of client code at the time of placing /modifying the related order; consequently dealers are expected to take utmost care/precaution while execution of client trades.
3. As per SEBI circular dated July 5, 2011 on client code modifications, penalty will be levied on all client code modifications w.e.f. August 1, 2011 (including genuine errors).
4. SREIL will allow Modifications in the client Codes of Non-Institutional clients only for the following objective Criteria provided there is no consistent pattern in such modifications:
   1. Error due to communication and / or punching or typing such that the original client code / name and the modified client code / name are similar to each other.
   2. Modification within relatives (Relative for this purpose would mean ′Relative′ as defined under sec. 6 the Companies Act, 1956).
5. For easy identification of “ERROR ACCOUNT”, SREIL have registered a fresh client code No. 1011 as “ERROR ACOUNT” in Back office & same has been uploaded in the UCC database of the Exchange.
6. Any transfer of trade (institutional or non-institutional) to “ERROR ACCOUNT” of SREIL would not be treated as modification of client code and would not attract any amount of penalty, provided the trades in “ERROR ACCOUNT” are subsequently liquidated in the market and not shifted to some other client code. However operational costs as applicable & Profit / Loss from the transaction will be transferred to the concerned Dealer / Associate.
7. Client Code Modification requests through “ERROR ACCOUNT” will be accepted only till 3:30 PM IST.
8. All cases of modification of client codes of non-institutional trades executed on the Exchange, shall be liable for a penalty as laid down by regulators from time to time [As per SEBI Circular No. CIR/DNPD/6/2011 dated July 5, 2011 a penalty of 1% of value of non-institutional trades modified will be levied if value of non-institutional trades modified as a percentage of total value of non-institutional trades executed is less than or equal to 5% and penalty of 2% if modification exceeds 5%, in a segment during a month.
9. In addition to above it is well within rights of SREIL to levy additional penalties in case concerned Dealer/Associate fails to submit any sufficiently valid reason for client code Modification.
10. SREIL will levy Penalties as applicable in relation to client code modification on next day of the Modification date, though Bills/Files in relation to same may be provided by exchange on a later date.
11. The SREIL shall conduct a special inspection of the concerned Dealer/Associate, if modification exceeds 1% of the value of trades executed during a month and take appropriate disciplinary action, if any deficiency is observed.

NOTE : SREIL hereby states and informs that it undertakes Proprietary trading in addition to client based            trading.