Internal Policies

The Exchanges have issued guidance relating to Incentive / Referral Schemes. Sankalp Share Brokers Private Limited has framed the following internal policy regarding Referral Incentives.

Background & Relevant Act

This policy complies with the code of conduct prescribed for stock brokers under Regulation 9 of SEBI (Stock Brokers) Regulations, 1992 and all relevant bye-laws, rules and regulations of SEBI / Exchanges with respect to sharing of brokerage, account opening, inducement to trade, sales practices and order placement.

Eligibility

All known persons shall be eligible to receive incentives for referring their friends / relatives / family members / prospective clients to open a client account along with a demat account with Sankalp Share Brokers Private Limited.

Guidelines

1. All referred clients are required to open their Trading cum Demat Account directly with Sankalp Share Brokers Private Limited along with IPV / OSV done directly by the staff of the broking firm.
2. Referring persons are not allowed to undertake any advisory, buy-sell recommendations, or portfolio management to clients. Their role is limited to “Referral” only.
3. All order instructions must be given directly by clients to the staff of the broking firm.
4. All contract notes, daily margin statements, statements of account, annual global statements, STT statements or any correspondence must be sent directly to the clients.
5. All client details shall be maintained confidentially and shall not be disclosed to the referring person.
6. The rate of incentive is fixed at 65% of the total brokerage generated by the stock broking firm from the clients referred.
7. The incentive so paid shall not be recovered from the referred clients and no obligation whatsoever shall be cast on such clients.
8. There shall be no financial transactions between referred clients and referring persons in relation to the transactions undertaken with Sankalp Share Brokers Private Limited.
9. Sankalp Share Brokers Private Limited shall be directly and wholly liable in case of any dispute regarding the referral programme / incentive scheme.
10. The referring persons shall not be forbidden to do any business under the rules and regulations of exchanges / SEBI or any other regulatory authority.

Payout

The eligible referring persons are required to settle their incentives on a periodic basis. The incentive earned will be subject to provisions as per applicable law.

Limitations

1. The amount of incentive shall be calculated as per the calculations given above and in no circumstances shall exceed the maximum amount arrived at.
2. This policy needs to be approved by the Board of Sankalp Share Brokers Private Limited.
3. The policy needs to be reviewed at least once a year.

On the lines of Principle 8 of the IOSCO Objectives and Principles of Securities Regulations, Sankalp Share Brokers Private Limited has put in place comprehensive guidelines for elimination of conflicts of interest.

• We will at all times maintain high standards of integrity in the conduct of our business.
• We will ensure fair treatment of our clients and not discriminate amongst them.
• We will ensure that our personal interest does not, at any time, conflict with our duty to our clients.
• We will make appropriate disclosure to clients of possible sources or potential areas of conflict of interest.
• We will endeavour to reduce opportunities for conflict through prescriptive measures such as information barriers between departments.
• We will place appropriate restrictions on transactions in securities while handling a mandate of issuer or client in respect of such security.
• We will not deal in securities while in possession of material non-published information.
• We will not communicate material non-published information while dealing in securities on behalf of others.
• We will not in any way contribute to manipulate the demand for or supply of securities in the market or to influence prices of securities.
• We will not have an incentive structure that encourages sale of products not suiting the risk profile of our clients.
• We will not share information received from clients for our personal interest.
• There will be an educational programme for Associated Persons every six months for dealing with or avoiding or managing conflicts of interest.
• Our management shall review compliance with this circular every six months.

We, Sankalp Share Brokers Pvt. Ltd., have not outsourced any of our activities to third parties and hence we have not formed any guidelines on Outsourcing of Activities.

In view of SEBI Circular No. CIR/DNPD/6/2011 dated July 5, 2011, the company has formulated the following policy for client code modification to prevent malpractices that could manipulate the capital market.

1. Modification to the client code is to be done only in exceptional cases and not as a routine one.
2. The reason for modification has to be ascertained and analysed; genuineness is to be established and its impact on the clients studied before the modification.
3. As a principle, other than for punching errors, no modification to the client codes shall be allowed.
4. The issue should be reported to the senior level Manager / Director and only with their approval shall the modification be carried out after being satisfied that it is genuine and required to protect the interests of the client.
5. The facility to modify client codes shall be available only at the Corporate Manager level and shall not be given to branches / franchise / sub-brokers.
6. Training programmes shall be conducted for all Dealers explaining how code modifications can be misused and what steps should be taken to avoid the same.
7. Punching / typing errors are to be rectified on the Exchange platform as per SEBI / Exchange rules. Errors not assignable to any client should be transferred to the “ERROR” code, accountable in the books of the Member's own account.
8. A register is to be maintained for recording all code modifications with details including error code, correct code, scrip name, quantity, client name, dealer's name, dealer's explanation and the authorised Manager's analysis and approval/disapproval.
9. The final decision of the authorised Manager should be ratified later by the Director.
10. This policy should be reviewed and necessary changes made by the Directors at least once every financial year.

With reference to NSE Circular No. NSE/INSP/32524 dated 6 June 2016 and BSE Circular No. 20160607-04 dated 7 June 2016.

Definition

Facsimile Signature: Scanned signatures of an authorised person in physical documents, instead of actual signatures of the person, while maintaining the validity of the documents.

Authorised Signatory means any official including the director or compliance officer authorised by the board.

Policy Statement

Sankalp Share Brokers Private Limited sends Electronic Contract Notes to its clients. Clients who have opted for physical contract notes receive them with manual signatures from our authorised signatory.

Maintaining / adopting the facsimile signature policy is not applicable to us. We always strive for a green initiative and send Electronic Contract Notes.

Sankalp Share Brokers Pvt. Ltd. has set the following guidelines for employees and clients:

1. Exercise abundant caution while dealing in low-priced illiquid securities — do not allow large positions in such securities across all user IDs.
2. Ensure that any client taking a large position in any script is not an employee of the company or taking positions on behalf of a promoter / director of the company.
3. Routine enquiries conducted by the Exchange to track any insider trading must be complied with immediately by providing all required details.
4. If any instance of insider trading is observed by the Compliance Officer, SEBI shall be informed by the firm without delay.
5. Employees are strictly prohibited from encouraging or circulating rumours or unverified information obtained from clients, industry, any trade or any other sources without verification. Access to blogs / chat forums / messenger sites is strictly prohibited.
6. Any market-related news received by employees through official or personal mail / blog or in any other manner shall not be forwarded without approval from the Compliance Officer.

Sankalp Share Brokers Private Limited has implemented the following internal controls:

1. Registration of Clients: All clients are allowed to trade only after completing the Registration process including the filling of Account Opening Form & KYC Documents. A receipt is taken from the client as a token of acceptance of all documents.
2. Receiving, Validating & Entering Orders: Client orders are accepted verbally on phone or in person and entered only after the client code is mapped to a dealer in the front-end office.
3. Collection and Release of Payments: Cheques are collected from clients within one working day of the transaction. Payment is made to clients within 24 hours of pay-out, unless the client has authorised a running account.
4. Collection and Maintenance of Margins: Margins are collected from specific clients and kept in separate client margin accounts. Mark-to-Market margins are notified to the client upon receipt from the exchange.
5. Collection and Delivery of Securities: Securities for pay-in are received from the client's demat account only. Pay-out is made to clients within 24 hours of receiving from the clearing corporation subject to realization of funds.
6. Monitoring of Branches / DP Operations: Regular visits to branches for compliance checks. DP Operations are carried out centrally at the head office with properly trained staff.
7. Operation and Compliance: Back-office and compliance requirements are looked after by Back Office Executives and the Compliance Officer respectively.
8. Payment of Dividend: Payments of dividend etc. are made to clients as and when received by the Company on their behalf.
9. Continuity Planning: Multiple lease lines, V-SATs and internet connectivity with exchanges. Back-office data is backed up regularly and a copy is kept at a secure place outside the office premises.
10. Communications and Social Networking: Company employees are prohibited from circulating unauthenticated news, rumours or unverified information. Access to blogs / chat forums / messenger sites is restricted. Any market-related news must be approved by the Compliance Officer before forwarding.

Important Points

1. Self-attested copy of PAN card is mandatory for all clients, including Promoters / Partners / Karta / Trustees and whole-time directors and persons authorised to deal in securities on behalf of a company / firm / others.
2. Copies of all documents submitted by the applicant should be self-attested and accompanied by originals for verification.
3. If any proof of identity or address is in a foreign language, a translation into English is required.
4. Name & address of the applicant mentioned on the KYC form must match the documentary proof submitted.
5. If correspondence and permanent address are different, proofs for both must be submitted.
6. Sole proprietors must make the application in their individual name and capacity.

Proof of Identity (any one)

• Unique Identification Number (UID) (Aadhaar) / Passport / Voter ID card / Driving License
• PAN card with photograph
• MAPIN card
• Identity card / document with applicant's photo issued by Central / State Government, Statutory / Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks, Public Financial Institutions, Colleges, Professional Bodies (ICAI, ICWAI, ICSI, Bar Council), Credit / Debit cards issued by Banks

Proof of Address (any one)

• Passport / Voter ID Card / Ration Card / Registered Lease / Sale Agreement / Driving License
• Utility bills like Telephone Bill (only landline), Electricity bill or Gas bill — not more than 3 months old
• Bank Account Statement / Passbook — not more than 3 months old
• Self-declaration by High Court and Supreme Court judges giving the new address in respect of their own accounts

Additional Documents for Derivatives Trading

• Copy of ITR Acknowledgement / Annual Accounts
• In case of salary income: Salary Slip or Copy of Form 16
• Net worth certificate
• Copy of demat account holding statement
• Bank Account statement for last 6 months
• Any other relevant documents substantiating ownership of assets

As per the latest SEBI circular on KRA Regulations, KYC Registration Agencies (KRA) are responsible for validating clients' KYC details as per their records. If the details are not updated and validated or are “On hold” / “Rejected”, trading and demat shall be blocked for such accounts.

Updation Process

If your KYC details are incorrect in the KRA portal, furnish the following documents at our Office:

1. Duly filled and signed KRA form with photo.
2. Self-attested copy of PAN card.
3. Self-attested copy of Aadhaar card.

Validation Process

After we process your request, we will inform KRA to update their record. You will receive an SMS and email to your registered mobile number and email ID to validate. Check your spam / trash folder if you do not find the email.

Alternative Validation — KRA Portals

• CVL KRA: validate.cvlindia.com
• KARVY KRA: karvykra.com
• NDML KRA: kra.ndml.in
• DOTEX KRA: nsekra.com
• CAMS KRA: qrkra.camsonline.com

Impact if Not Followed

• Clients shall not be allowed to trade on any exchange or manage their open positions until they comply with KYC requirements.
• Clients' trading and demat accounts will remain deactivated till the KRA details are updated and validated.

After validation, records are processed in 5–7 working days to update and activate your trading and demat accounts.

The Prevention of Money Laundering Act 2002 (PMLA) aims to prevent the financing of terrorism and to prevent laundering of money i.e. to legalise or officialise the money generated from illegal activities like drug trafficking, organised crimes, hawala rackets and other serious crimes.

Applicability

This Act is applicable to all SEBI Registered brokers / sub-brokers and other financial institutions who are dealing in any kind of financial assets. It is an obligation of such entities to report certain kinds of transactions routed through them to the Financial Intelligence Unit (FIU-IND) under the Ministry of Finance.

Transactions to be Reported

• Cash transactions above ₹10 lakhs
• Series of cash transactions below ₹10 lakhs aggregating to above ₹10 lakhs in a month
• Equivalent amounts in any foreign currency
• Transactions which may not be in cash but are suspicious in nature
• Attempted or failed transactions of the above types are also required to be reported

Clients of Special Category (CSC)

• Clients whose identity verification seems difficult or clients that appear not to cooperate
• Asset management services for clients where the source of funds is not clear
• Clients based in high-risk jurisdictions
• Clients transferring large sums to or from overseas locations with instructions for payment in cash
• NRI / HNI / Trust / Charities / NGO / Organizations receiving donations
• Companies having close family shareholdings or beneficial ownership
• Politically Exposed Persons (PEP)
• Non-face-to-face clients

Client Obligations

End clients are advised to co-operate with us by providing additional information / documents if asked for during the course of dealings with us to ensure compliance requirements under this Act. As responsible citizens, we must all be vigilant and refrain from knowingly or unknowingly supporting activities that endanger our freedom and cause damage to the nation.

For more information, visit: www.sebi.gov.in and fiuindia.gov.in

As per SEBI Circular SEBI/HO/MIRSD/POD-1/P/CIR/2024/4 dated 12 January 2024, the following policy has been formulated for voluntary freezing / blocking of trading accounts. This policy is effective from 1 July 2024.

How to Request Freezing

If a client notices any suspicious activity or suspects their login credentials have been breached, they can request freezing through either of these modes:

• Option A: Call 9330266651 from your registered mobile number.
• Option B: Send an email to stoptrade@sankalpcares.com from your registered email ID.

The intimation should contain minimum identity details: Trading A/C Code / UCC / PAN / Account Name.

Timelines for Freezing

Unfreeze Procedure

To unfreeze, send an email to stoptrade@sankalpcares.com or a message on 9330266651 from your registered email / mobile. The team will contact you to confirm identity and genuineness of request, reset login credentials and communicate the same to you.

Clarifications

• Freezing / blocking only restricts online access to the client's trading account. There will be no restrictions on the risk management activities of Sankalp Share Brokers Private Limited.
• The request for freezing / blocking does not equate to marking the client's UCC as inactive in Exchange records.

Version 1.0 dated 28 November 2024. As per NSE Circular No. NSE/INSP/62528 dated 21 June 2024 and BSE Circular No. 20240622-2 dated 22 June 2024.

Good Till Date (GTD) Orders

SSBPLTD allows clients to place Good till Date (GTD) orders for Equity Cash products, Index Futures and Index Options.

• GTD orders enable clients to place buy and sell limit orders specifying a validity period within SSBPLTD's maximum allowed date.
• All current and new clients eligible to trade in Equity Cash products and Derivatives can use the GTD facility.
• GTD orders must be placed at a limit price and cannot be submitted at market price.
• A maximum of five GTD orders per scrip is allowed, with a total cap of thirty GTD orders across all eligible scrips.
• Clients may modify the quantity or limit price of GTD orders while in ‘Ordered’ or ‘Requested’ status. GTD orders in ‘Blocked’ status can only be cancelled.
• GTD orders can be placed during the pre-open session for all eligible scrips.
• If the GTD order validity date falls on a non-trading day, the order will expire on the last trading day before that non-trading day.
• Brokerage rates and applicable charges for GTD orders are consistent with those for regular transactions.

Handling During Corporate Actions

Following a corporate action, GTD orders will be validated against the Daily Price Range (DPR) issued by the exchange. Notifications via email and SMS will be sent to clients if GTD orders fall short of funds / securities or are blocked due to price limitations. Clients with unexecuted GTD orders will be notified of all upcoming corporate actions at least one day before the ex-date.

Policy Review

This policy will be reviewed annually.

As per SEBI Notification No. LAD-NRO/GN/2010-11/21/29390 dated 10 December 2010, Associated Persons involved in:

• Assets or funds of investors or clients
• Redressal of investor grievances
• Internal control or risk management
• Activities having a bearing on operational risk

shall obtain the valid certification of NISM Series VII — Securities Operations and Risk Management (SORM) within two years from the date of notification. New employees in the specified categories shall obtain the certification within one year of employment.

Exemption

Associated persons handling basic clerical / elementary functions in the above-specified areas are exempted from obtaining the NISM-SORM certification, provided they are supervised by a person who holds or continues to hold the NISM-SORM certification.

Pre-funded instruments include Demand Drafts, Pay Orders, Banker's Cheques, etc.

• A pre-funded instrument issued by the bank against cash shall not be accepted for an amount of ₹50,000 or more.
• All pre-funded instruments having an aggregate value of ₹50,000 or more per day per client must be accompanied by the name of the bank account holder and the number of the bank account debited, duly certified by the issuing bank.

Acceptable Modes of Certification

1. Certificate from the issuing bank on its letterhead or on plain paper with the seal of the issuing bank.
2. Certified copy of the requisition slip retained by the bank.
3. Certified copy of the passbook / bank statement for the account debited.
4. Authentication of the bank account number debited and name of the account holder by the issuing bank on the reverse of the instrument.
5. RTGS / NEFT / Online bank transfer etc.

Receipt from clients using Electronic Fund Transfer shall be accepted only if the name of the client with the bank name is reflected on our online bank statement, or on receipt of a copy of the instruction to the bank stating the account number debited.

The member reserves the right to reject the payment, post acceptance, if any requisite documents / declarations are unavailable or incomplete, and in such case the member shall refund the money without interest. Such refunds will be marked “A/c. Payee Only” and will be in favour of clients only.

Refusal of Orders for Penny Stocks

SANKALP shall have absolute discretion to term a stock as “Penny Stock”. “Penny Stock” refers to stocks appearing in the list of illiquid securities issued by the Exchange every month and any other stocks which SANKALP might consider to be illiquid. SANKALP at its discretion can accept, refuse or partially accept any buy or sell order in such scripts and may demand appropriate declarations and additional margin from the client before accepting the order.

Setting up Client Exposure Limits

Exposure limit of each client is set based on margin money given by the client including ledger balance after applying appropriate haircut and as per Exchange Regulations. Upfront margin is collected from clients. The exposure limit may be changed based on volatility in the market, quality of collateral and client's existing open position.

Applicable Brokerage

The brokerage rate applicable to clients varies depending on the category of the client (HNI, Institutional, low / medium / high risk client). The brokerage is fixed with the mutual consent of the client. Brokerage charged does not exceed the maximum specified by the Exchange. Changes to brokerage rates are communicated with 15 days' notice.

Penalty / Delayed Payment Charges

Clients are liable to pay delayed payment charges @ 0.07% per calendar day on overdue amounts. Interest in the Derivatives Segment on shortage of cash component is charged @ 0.07% per day including holidays. Penalties may also be levied for bouncing of cheques, non-delivery, auction on failure of payment, and short / non-payment of margin money.

Right to Sell Client's Securities

SANKALP shall be entitled to liquidate client's securities or close out client's open positions without notice for non-payment of margins or other amounts, adjusting the proceeds against the client's liabilities. Any and all losses and financial charges on account of such liquidations shall be borne by the client.

Conditions for Restricting / Closing Positions

• Client unable to meet pay-in obligation as per exchange requirements
• Long pending debit balance in the client's account
• Dishonour of cheque
• Client dealing in “illiquid” stock as declared by SANKALP
• Transactions which appear suspicious in nature
• Failing to provide sufficient margin within the specified time
• Taking further position would violate any circular, rules, regulations or bye-laws of stock exchanges or SEBI

Inactive Accounts

The account of a client who does not trade and remains inactive for 24 months shall be declared an “inactive account” and will be temporarily suspended. Reactivation requires submission of updated KYC documents and margin as required.

Sankalp Share Brokers Private Limited operates the following risk management system:

• Upfront margins are collected from clients before entering into any transaction as per the margining system of the relevant exchange, calculated with exchange-provided software.
• Mark-to-Market (MTM) losses are collected from clients on a daily basis.
• For Capital Market Segment, financial details such as Bank Statement, Demat Statement, Balance Sheet, ITR, and Income Proof are taken to judge the financial health and position of the client. Client limits are allotted based on financial position and soundness.
• Cheques are collected from clients in a timely manner after the client has transacted. Pay-out of securities is made after receiving payment from them.
• If a client fails to make payment within the stipulated time, securities would be squared off and the balance amount paid / recovered from the client.
• Limits for existing clients are updated periodically by assessing their trading history and payment regularity.
• A policy relating to default by the client in making payment of obligations is implemented by reducing or squaring off outstanding positions to the extent of shortfall.
• Client physical addresses are continuously checked by sending quarterly statements of accounts to their registered address.
• Financial documents of clients are updated on a yearly basis to monitor their financial health.

The following transactional alerts are generated by Exchanges and monitored by the Compliance Team on a daily basis:

Action Process

1. Analysis of orders / trades on the basis of financial soundness, past trading pattern, bank / demat transaction details and other publicly available information.
2. If necessary, issue a letter to the client seeking explanation within 7 days of receipt of the alert.
3. Seek documentary evidence such as Bank Statement / Demat Statement / Financial Statements.
4. Bank / Demat Statement period should be at least ±15 days from the date of transactions.
5. Record observations. For Exchange-generated alerts, non-reply or adverse observations shall be reported to the Exchange within 45 days. For internally-generated alerts, report to FIU-IND within 7 days.
6. If alerts cannot be disposed within 45 days, seek extension from the exchanges with necessary reason.
7. Records of all alerts, letters issued and replies received shall be preserved for at least 5 years.

The overall surveillance policy shall be implemented and monitored by the Compliance Officer. A Quarterly MIS report shall be prepared and put before the Board of Directors detailing alerts received, disposed, and pending. The Surveillance Policy shall be updated on a periodic basis based on inputs obtained from Exchanges or derived from within the organisation, after ratification from the Board of Directors.

The SARAL Account Opening Form is the simplified account opening form for resident individuals trading in the cash segment. It includes:

• Section I (KYC): Identity details, Father's / Spouse Name, Gender, Date of Birth, Nationality, PAN, Aadhaar Number, Proof of Identity, Address Details, Contact Details.
• Section II (Other Details): Bank account details, Demat account details, Trading preferences (NSE / BSE / MCX-SX), Mode of receiving Contract Notes / Statements, Standing instructions, Nomination details.
• CDSL Supplementary Form (Annexure 2.8): Additional information including DP ID, holder details, account statement requirements, SMS alert facility, nomination details.

Download the account opening form:

⬇ Download SARAL Account Opening Form (PDF)

Note: This form is applicable for individual investors trading in the cash segment. For trading in segments other than the cash segment and / or for facilities such as internet trading, running account, margin trading, or Power of Attorney, please contact our office for additional forms.