Internal Control Policy

INTRODUCTION

MARKETWOLF SECURITIES PRIVATE LIMITED, formerly known as FNO India Securities Private Limited (MARKETWOLF) as a SEBI registered intermediary is mandated to follow the rules, regulations and circulars issued by the SEBI and exchanges from time to time and operate through well defined procedures and policies. MARKETWOLF has adopted various policies & procedures for internal control measures and tools for compliance with rules, regulations and circulars issued by the SEBI and exchanges from time to time.

CLIENT DUE DILIGENCE

MARKETWOLF exercises due diligence for acceptance of new clients and subsequent continuation of relationship with the clients. MARKETWOLF accepts clients only after due verification of the client’s identity, beneficial ownership, address etc. from reliable, source documents, data or information collected from clients and by applying uniform Know Your Client (KYC) requirements prescribed by SEBI which are followed scrupulously for customer identification and acceptance.

• Name of Client
• Address of Client
• Photograph in case Client is an individual
• For Corporate Clients, Board Resolution, Memorandum of association & article of association of company, Share holding pattern, Details of Authorised Persons and Directors
• PAN Card
• Bank Details
• KYC Form is completely verified and details of clients are uploaded

In person verification (IPV) and completion of KYC procedures is mandatory for all clients without which no client account shall be opened. All KYC Application Forms and supporting documents are checked, including verification of PAN from the Income Tax database.

SYSTEMS AND PROCESS ADOPTED FOR UCC UPLOAD

Vide the Client Registration Form, all mandatory and important details for clients such as Name, PAN, Category, Complete Address including PIN code, Mobile number, Email ID, Income details/range are collected which are then uploaded on the UCC system of the exchange.

From our back-end, we generate file for the client containing data of Market Segment, Client Code, Client Name, PAN, Address in the format prescribed by NSE, CDSL & MCX. The data generated are thereafter verified with KYC. On the data being found fully correct, the client is uploaded on UCC system of NSE & MCX and on CDAS system of CDSL. After uploading, we run a check on the systems by entering the specific client, whether or not the client details are actually uploaded on these systems.

ASSESSMENT OF FINANCIAL CAPABILITY OF CLIENT

We take from clients a signed self-declaration form along with relevant supporting documents, which states their annual income / total net worth in terms of their net assets and liabilities. Such self-declaration has to be mandatorily supported by one of the following documents.

• Copy of ITR acknowledgement.
• Copy of Annual Returns.
• Copy of Form No. 16: In case of salary income.
• Net Worth Certificate from a Chartered Accountant.
• Salary slip duly stamped, signed by employer.
• Bank Account Statement for last six months.
• Copy of Demat Account holding statement.
• Any other document substantiating ownership of assets.

PROCESS OF RECORD KEEPING AND RETRIEVAL OF CLIENT REGISTRATION DOCUMENTS

All client registration documents, once checked, found complete and verified as such and the accounts opened, are digitally stored in a sequential manner. Additionally, all KYCs and supporting documents are scanned and kept in soft form. The same can be retrieved either the physical or the scanned records on an easy basis. Further the record keeping and duration of the same shall be as specified in our policy for record keeping.

UPDATION OF CLIENT FINANCIAL AND OTHER CLIENT PARTICULARS

We send out to all our clients:

• Client Master on annual basis
• Global statements on annual basis
• Self-declaration on annual basis requiring all clients to confirm the details in Client-Master to update their financial particulars
• Self-declaration on half-yearly basis requiring all clients in derivative segment to confirm the details in Client-Master to update the financial particulars.

CLIENT MASTER MODIFICATION

On an annual basis, there is a regular updation happening. However, in between, if the client wants to modify any details, he/she/it is enabled to do so by filling up a Client Master Modification Form and submitting to us the documentary proof of modified detail. Further, any such modification shall also be updated in the KRA and CKYCR Records.

PRECAUTION WITH RESPECT TO DORMANT ACCOUNTS

All dormant accounts i.e., inactive for 12 months in broking and no debit instruction for 6 months in DP are made inactive in our system. Hence it is not possible to execute a transaction in dormant accounts. However, a client can re-activate his/her/its dormant account by giving us in writing in to activate the account and also stating the reason for keeping the account dormant. For more details refer our Inactive policy for this.

CLOSURE OF CLIENT ACCOUNTS

A client account can be closed either by client or in case of an action initiated by MARKETWOLF. MARKETWOLF at its discretion can initiate closure of a client account in following cases:

• if client fails to meet his obligation within stipulated time;
• if clients fails to provide proper documents as required under applicable rules and regulations even after repeated requests;
• if client is declared fugitive under any law in India or abroad;
• if client is declared insolvent under any law in India or any criminal cases are filed or pending and such information is not disclosed at the time of registration with
MARKETWOLF.

On receipt of written request from a client, the compliance team deactivates the client code in its front & back office. On receipt of such request, the account is checked for any outstanding balance either debit or credit. If it is a debit balance, the client is asked to clear it. In case of a credit balance, the same is paid to the client. Similarly, a check is carried out in the settlement department to ascertain:

• the securities lying with us as margin or pending pay-out to the client.
• whether the client has any outstanding position in F&O segment, Currency Derivatives or outstanding pay-in position of securities or a payout from Exchanges in pipeline. In case of any outstanding position, we either let the client pay off the same or wait for the transaction to come to a close so that we can crystallize either the client’s liability for pay-in or our liability to settle the securities due to the client.
• whether any notice issued to the client is pending reply and any liability arises to MARKETWOLF or client as a result of client’s action / inaction for which the notice has been issued. There is a prescribed process sheet, for monitoring the above points before taking a decision whether or not the client’s account can be closed. Once the client is cleared for closure, the client’s account is closed, and an intimation is sent in the format of a letter.

CRF form is marked closed only after proper verification of client’s ledger account & clearance received from accounts department regarding dues & margin. A written communication is also sent to client accompanying closure of his account.

An online facility to close the trading and demat accounts has also been made available to clients.

CLIENT BROKER AGREEMENT

Rights and Obligations of Stock brokers and Clients are executed at the time of client registration. It is as per the format prescribed by the exchange. This will cover all the responsibilities, Rights & Liabilities of client & member.

RISK DISCLOSURE DOCUMENT

Trading in securities market involves risks of various nature. Clients need to be educated and informed about the risks involved and MARKETWOLF as a policy will issue the RDD to all its clients.

TRADING POLICIES

Trades. The trades of clients shall be carried out in the respective client code only. Dealers shall take utmost care while executing the trades of the clients regarding the accuracy of Client Code, lot size, price etc. In case of any mistake in execution of the trade the same shall be intimated to the administrator who shall do the needful to transfer the trade into the correct code using the exchange mechanisms for trade modification. In case the mistake is highlighted or brought to the notice of the HO after the stipulated timelines of the exchange and the Client Code does not exist in the Back Office then the trades shall be transferred to the correct Client Code after the same is approved by the Compliance Officer of MARKETWOLF.

Order Acceptance and Execution. The orders from the client’s shall be promptly executed and the confirmation of the placement of the orders shall be immediately provided to the clients. If there is mistake in inputting the client code while doing the trade, we make the necessary changes in client code within the time allowed by the exchange only after taking the permission of the Compliance Officer

Contract Notes, Margin Statement, Statement of Accounts. Contract Notes, Margin Statement shall be issued to clients within 24 hours from trading date, which shall also be available for viewing on back-office software. Statement of Accounts shall be issued to clients within stipulated timelines.

Demat Account

• MARKETWOLF shall maintain client’s securities in a designated account called the Client Beneficiary Account. The securities of MARKETWOLF shall be kept in a separate demat account termed as MARKETWOLF Beneficiary Account. The clients’ and MARKETWOLF’s own securities will not be mixed with each other.
• a client who wants to engage in trading the delivery segment, will have to compulsorily open a demat account with MARKETWOLF which shall be linked to his trading account. Transfer of shares from a third-party demat account to MARKETWOLF pool account and subsequent selling of such stocks is not allowed.

PAY-IN & PAY-OUT OF FUNDS

Pay-in. Clients can transfer funds into the trading account only from such Bank Accounts which are registered with MARKETWOLF. Any transfer from a non-registered Bank Account will not be considered and the client does not get any trading limit credit for such transfers. Clients can also transfer funds from the instant payment gateway facility as made available from time to time subject to levy of transaction charges as applicable. If a client chooses to transfer using NEFT or by means of cheque, there will be no cost. If the client transfers funds via cheque, the details of the transfer along with a copy of the cheque should be made available to MARKETWOLF for the credit to be updated on the trading account. NO CASH PAYMENT IS ACCEPTED.

Payout. All payouts will have to be compulsorily placed on the mobile application access provided to the clients. All payout requests will be processed electronically and the credit shall come to the client’s primary Bank Account within 24 hours of having processed the payout request. Withdrawal requests for all segments will be processed at 5:30 PM on working days. Any request received by 5 PM, is processed on the same day. If the request is received after 5 PM, it is processed on the next working day.

MARGINS

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

NSE Equity. No margin is given for delivery trades. The client needs to have enough money in his trading account to take delivery of shares failing which MARKETWOLF can cut the position.

NSE Futures and Options. MARKETWOLF does not engage in the business of client funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions. Leverage is provided subject to market conditions and changes in its proportion are dynamic in nature.

MCX Commodities. MARKETWOLF does not engage in the business of client funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions. Leverage is provided subject to market conditions and changes in its proportion are dynamic in nature.

TRANSACTION MONITORING & REPORTING

MARKETWOLF employees are given specific instructions to follow appropriate procedures for recognizing and reporting suspicious transactions. While determining suspicious transactions, MARKETWOLF shall be guided by the definition of a suspicious transaction contained in PML Rules 2005. Whether a particular transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances.

MARKETWOLF shall pay special attention to all complex unusually large transactions/patterns which appear to have no economic purpose. Any suspicious transaction shall be immediately notified to the Designated Director or Principal Officer. The notification may be done in the form of a detailed report with specific reference to the clients, transactions and the nature /reason of suspicion. MARKETWOLF shall specify internal threshold limits for each class of client accounts and pay special attention to transactions which exceeds these limits. The background including all documents/office records/memorandums/clarifications sought pertaining to such transactions and purpose thereof shall also be examined carefully and findings shall be recorded in writing. Further such findings, records and related documents shall be made available to auditors and also to SEBI/stock exchanges/FIU-IND/ other relevant authorities during audit or inspection or as required.

REFUSAL OF ORDERS/RESTRICTIONS ON TRADING IN PENNY STOCKS AND ILLIQUID STOCKS

We define penny stocks as those stocks where the market price is below or close to par, with MARKETWOLF financials being weak with indicators such as loss, accumulated losses, low sales revenue, low or negative net worth, signs of inactivity in MARKETWOLF, which are having very less value. MARKETWOLF may from time to time identify such stocks and put trading restriction on the trades in such penny stocks. In addition to these stocks MARKETWOLF may also include other stocks in the list of restricted stocks such as stocks in Z category, Trade to Trade Settlement or TS category, the scrips which are included in the list of illiquid scrips by the exchange/s or any other scrip which MARKETWOLF deem fit for the purpose of putting trading restriction.

The restriction on above stocks may be as to the price, quantity or mode of placement of orders. Accordingly, MARKETWOLF reserves the right to disable certain scrips for trading on online trading facility/ Authorised Person/branch trading terminals or put quantity or price restrictions while putting trade orders. In such case, client may be allowed to place the trades subject to certain restrictions, through MARKETWOLF’s centralized dealing desk after enhanced due diligence of the orders.

In case of clients using Internet trading facility, they may not find the scrip name or may not be able to place any order in the scrip, if such scrip is one of the restricted scrips. A client can enquire with MARKETWOLF’s dealer or customer service executive about any trading restriction on any scrip.

The above referred restrictions are placed on the trading activities of the client as these stocks are exposed to price rigging and other market manipulative activities. Further, MARKETWOLF as a member of the stock exchanges is expected to have proper surveillance and monitoring mechanism on the trading activities of their clients, particularly on penny and illiquid scrips.

Clients may note that MARKETWOLF shall have right to reject the orders placed by the Client and/or put circuit breakers to discourage trades getting executed at unrealistic prices from the current market price of the security or prohibit the Client from trading in illiquid securities which creates artificial liquidity or manipulates prices or to discourage Client from cross/ synchronized trading and MARKETWOLF shall not be liable for any loss arising out of non-acceptance or rejection of the Client orders for any such reason if the Client fails to give sufficient reason for placing such orders.

SETTING UP CLIENT’S EXPOSURE LIMITS

MARKETWOLF may from time to time at its sole discretion, impose and vary the limits on the orders that client can place through it (including but not limited to exposure limits, turnover limits, limits as to number, value and/kind of securities/ contracts in respect of which buy or sell orders can be placed). MARKETWOLF may need to vary or reduce the limits or impose new limits urgently on the basis of its risk perception and other factors considered relevant and MARKETWOLF will make all necessary attempts to inform clients of such changes.

Further MARKETWOLF may as risk containment measure at any time at its sole discretion and without prior notice, prohibit or restrict the client’s ability to place the orders or trade in all of some of securities/ contracts through member. The exposure limits are generally based on the availability of the margin in the client’s account. Margin may be in the form of funds and /or in the form of securities with MARKETWOLF. The client shall be permitted to trade up to a pre-determined number of times of the margin (the “Multiple”) and the quantum of the Multiple on the margin shall be decided at sole discretion of MARKETWOLF.

MARKETWOLF shall not be responsible for any variation, reduction or imposition or the client’s inability to route any order through the MARKETWOLF website on account of any such variation, reduction or imposition of limits.

APPLICABLE BROKERAGE RATE

Brokerage will be charged to the client based on the brokerage rates specified in the Account Opening Form or as per the product/scheme opted by the client from time to time. Brokerage chargeable to the client will also be communicated to the client at time of account opening. Based on the value of business done by the client and risk perception, MARKETWOLF may reduce the brokerage rate at its sole discretion. Such changed/reduced brokerage terms will be communicated through the relationship manager/e-mail communication and / or amount will be reflected in the contract notes for future trades. However, any increase in brokerage rate either be done with the consent of the client in writing or at the discretion of MARKETWOLF by giving 15 days advance notice to the client. The brokerage rate shall be within the permissible limit set by SEBI/ Exchanges.

IMPOSITION OF PENALTY/INTEREST ON DELAYED PAYMENT

MARKETWOLF requires all its clients to make the payment towards settlement obligation on or before due date. In case of debit balance in cash segment, penal interest will be levied on the client to deter them from delaying the payment in future. Clients are further required to make payment of margin towards their Derivatives segment exposure. While, MARKETWOLF accepts approved securities as margin, however MARKETWOLF is not the beneficial owner of these securities and hence it is unable to pledge the same onwards to the exchange as margin and has to arrange for own funds/securities for payment of margin to the exchange for positions taken by the clients. Clients are requested to make payment of margin in the form of funds to avoid charging of interest in F&O segment. Accordingly, whenever clients provide securities margin (or there is shortfall in payment of securities margin) instead of margin in the form of funds towards exposure in F&O, MARKETWOLF reserves the right to charge interest on the debit balance lying in F&O segment. No ledger credit will be given for margin paid by the client in the form of securities.

Margins provided by the client in the form of funds shall be interest free and the MARKETWOLF shall not be liable to pay any interest on the same. Any amounts which are overdue from the Client towards trading either in the cash or derivative segments or on account of any other reason to MARKETWOLF will be charged Interest on delayed payment at the rate of 24% p.a. compounded on monthly basis or such other rate as may be determined by MARKETWOLF. MARKETWOLF will directly debit the same to the account of the Client at the end of each month. Further, MARKETWOLF will also debit charges for depository services availed from it to the trading account of clients.

RIGHT TO SELL CLIENTS’ SECURITIES OR CLOSE CLIENTS’ POSITIONS, WITHOUT GIVING NOTICE TO THE CLIENT ON ACCOUNT OF NON-PAYMENT OF CLIENT’S DUES (THIS SHALL BE LIMITED TO SETTLEMENT/ MARGIN OBLIGATION/DEBIT BALANCE OF CLIENT)

Without prejudice to other rights (including the right to refer a matter to arbitration), MARKETWOLF would be entitled to liquidate/close out without any notice all or any of the client’s position for non-payment of margins or other amounts, outstanding debts etc. and adjust the proceeds of such liquidation/close out, if any, against the clients liability/ obligations. Any and all losses and financial charges on account of such liquidation/closing out shall be charged to and borne by the client.

MARKETWOLF shall endeavour to inform the client and give him reasonable time for payment. However, it will be the responsibility of client to track his margins/ obligations by going through margin statements sent to the client on daily basis.,/

The client shall be responsible to track his shortfall daily on real time and clear such shortfall, if any, arising in his account. Notwithstanding hereinabove, MARKETWOLF shall be entitled to liquidate/ close out all or any of the client’s positions without any notice to the client during market hours in case the client fails to provide required margin and/or any other payment or if there is any substantial/complete erosion of margin due to volatility in the market. On substantial/complete erosion of margin due to any reason whatsoever, the decision of MARKETWOLF shall be final and binding on the client. The stock broker may exercise all or any of the above rights in such manner as the stock broker thinks appropriate, without demand for additional margin, security or collateral, or advance notice or advertisement, on any exchange or other market where such business can be transacted, at a public auction or by private sale and the stock broker may be the purchaser / seller for its own account. The giving of any prior demand, call or notice shall not be considered as a waiver of the stockbroker’s right to exercise its rights without any such demand, call or notice. The client agrees that in case of high market volatility, the stockbroker may require the client to pay instantaneous margins in addition to the margins that may have already been paid by the client as per margin calls. The client agrees that the stock broker may be compelled to do so in such circumstances of market volatility, in the absence of the payment of the said instantaneous margins by the client, square-off all or any outstanding positions, prevent any new orders from being placed and / or executed by the client or take such other action as the stock broker thinks fit and proper. The client agrees that the stock broker may in exceptional circumstances be compelled to square-off all or any outstanding margin/ positions or prevent any new orders from being placed and / or executed by the client or take such other action as the stock broker thinks fit and proper, even without calling for the payment by the client, of the aforesaid instantaneous margins by the client.

In case the payment of margin/security is made by the client through a bank instrument, MARKETWOLF shall be at liberty to give the benefit/credit for the same only on completion of bank reconciliation and realization of the fund from the said bank instrument etc., at its absolute discretion. Where the margin/security is made available by way of securities or in any other acceptable form, MARKETWOLF is empowered to decline its acceptance as margin/security and/or to accept it at such reduced value as the stock broker may deem fit by applying haircuts at the rate prescribed by Exchange or by valuing it by marking it to market or by any other method as it may deem fit in its absolute discretion

MARKETWOLF has the right but not obligation, to cancel all pending orders and to sell/close/liquidate all open position/securities/ shares at the pre-defined square off time or when mark to market percentage reaches or crosses stipulated margin percentage, whichever is earlier. MARKETWOLF will have sole discretion to decide referred stipulated margin percentage depending upon the market condition. In the event of such square off, the client agrees to bear all the losses based on actual executed prices. The client shall also be solely liable for all and any penalties and charges levied by the exchange(s).

SHORTAGES IN OBLIGATIONS ARISING OUT OF INTERNAL NETTING OF TRADES

MARKETWOLF as member of the exchange delivers/receives securities to/from the clearing corporation on net obligation basis in respect of a settlement. In such a process, if a client, who has sold securities, short delivers the securities, which are to be delivered to another client of MARKETWOLF, who has bought the same security, it is treated as internal shortage of securities. In case of internal shortages on pay in day, MARKETWOLF will endeavor to buy the shares from the market on the pay in day or on the next working day on behalf of the client who has delivered short and deliver the same to the client who has bought them. The client who has delivered short will be debited with the rate at which the shares were purchased or the rate at which the said shares were sold by him, whichever is higher. In case MARKETWOLF is unable to buy the securities as stated above, the transaction shall be closed-out.

CONDITIONS UNDER WHICH A CLIENT MAY NOT BE ALLOWED TO TAKE FURTHER POSITION OR THE BROKER MAY CLOSE THE EXISTING POSITION OF A CLIENT

Under following circumstances, a client may not be allowed to take further position and if required the existing position in his account may also be closed:

• If there is a continuous debit Balance in client’s account.
• If there is insufficient margin in client’s account required to maintain his open position.
• If client is not responding satisfactorily to MARKETWOLF / regulatory enquiry on trades undertaken by him explaining the rationale for transactions or fails to provide documents to prove beneficial ownership of shares, submit proof of income/ Net worth etc.
• If there is an order by SEBI or any other appropriate authority debarring the client from dealing in securities market or an order to suspend/seize client’s account.
• In case the scrip or member limits are breached or likely to be breached in the Derivatives Market Segment.
• In case of dormant/inactive account; and
• At the discretion of MARKETWOLF by giving written notice to the client

TEMPORARILY SUSPENDING OR CLOSING A CLIENT’S ACCOUNT

A client can request for temporary suspending or for permanently closing his account. For permanent closure, client has to give a notice of one month and clear the dues, if any, in his account. Client account may be suspended by MARKETWOLF at any time:

• On directions received from any regulatory authorities.
• If client is not responding to the queries raised by MARKETWOLF related to his trade activities.
• If there is not a single active demat account linked to trading account.
• Due to any other non-compliance observed in the account.

DEREGISTERING A CLIENT

Notwithstanding anything to the contrary stated in the arrangement, MARKETWOLF shall be entitled to terminate the arrangement with immediate effect in any of the following circumstances:

• If the action of the client is prima facie illegal improper or such as to manipulate the price of any securities or disturb the normal/proper functioning of securities either alone or in conjunction with others;
• If there is the commencement of any legal proceedings against the client under any law in force;
• On the death/lunacy or other disability of the client;
• If the client being a partnership firm, steps taken by the client and/or its partners for dissolution of the partnership;
• If the client suffers any adverse material change in his/her/ its financial position or defaults in any other/arrangement with MarketWolf;
• 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;
• If the client is in breach of any terms, condition or covenant of this arrangement;
• If the client has made any material misrepresentation of facts, including (without limitation) in relation to the security;
• 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;
• If the client has taken or suffered to be taken any action for its reorganization, liquidation or dissolution;
• 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 of Industrial and Financial Reconstruction or under any other law providing protection as a relief undertaking;
• If the covenant or warranty of the client is incorrect or untrue in any material respect;
• On the order from the appropriate authority;
• In accordance with the provisions of arrangement entered into with the client.

POLICY ON INACTIVE (DORMANT) ACCOUNT

In order to protect the account of customer, MarketWolf will deactivate the trading accounts of the client, which are identified as “Dormant” on the date of review. Dormant account will be the account where there has been no trade for more than 12 months. However, in case the account satisfies any one of the following conditions, the account will not be marked as dormant even though there has been no trading activity for a period of 12 months before review date.

• Client has brought in Funds/ Stocks in mapped DP account in last 6 months
• Logged into online trading platform in last 6 months (only for online clients)
• Updated any client master detail in last 6 months. Clients will be given advance notice before deactivation of the account. In case any client requests for keeping the account active, deactivation of account will be withheld. Once the account is deactivated, the customer will not be able to place any orders in any trade segments. Client can get his account reactivated by following any of the below process after due authentication:
  • Call / SMS our Customer Service Executive from registered Telephone Number
  • Write an E-mail from registered E-mail ID
  • Submit physical letter of request for reactivation at any of our branches. Funds and securities would be settled as per the settlement frequency chosen by the client. In case of interim request received from the client for release of funds/securities before due date of running account settlement, the funds and/ or securities will be released only after reactivation procedure is completed as mentioned above.

PENAL CHARGES THAT MAY BE DEBITED TO THE CLIENT’S ACCOUNT

MARKETWOLF reserves the right to debit the client's ledger for any penal charges that may be charged by the Exchanges/ depositories on MARKETWOLF on the client level for any default/ violation of Exchange guidelines / requirements occurring due to omission or commission of any act on the part of the client. This may include penalty for:

• Short delivery of securities
• Shortfall in margin payment
• MARKETWOLF shall have the right to recover such charges like any other trade dues payable by the client and recover the same by selling his securities.

THIRD PARTY FUNDS AND SECURITIES

In accordance with SEBI circular dated August 27,2003, MARKETWOLF requires all its clients to make payout of funds and securities from the account held in their name towards their settlement and margin obligation. Similarly, payout of funds will be made in client’s name and securities will be transferred only to demat account held in client’s name and registered with MARKETWOLF. Proofs regarding account being held in client’s name i.e., copy of cheque book/bank statement in case of funds and copy of DP master in case of securities needs to be provided by the client. Receipt of funds/securities will be accepted only from these accounts.

Payment made from any other account will be treated as “third party”. In no circumstance, third party funds and securities will be accepted towards settlement and/or margin obligation. In case, MARKETWOLF observes that payment of funds or securities towards pay in/ margin obligation has been met from third party account, MARKETWOLF reserves right not to give credit of funds/ securities to client/reverse the credit given and return the same to the source account from where funds/securities were received. Client will be solely liable on account of any shortfall in meeting pay in/margin obligation in this regard. Wherever, client gives POA on demat account to MARKETWOLF, MARKETWOLF treats the securities lying in the account as securities margin. Therefore, client needs to ensure that only securities belonging to the client are retained in the account and appropriate proof regarding purchase/gift etc. needs to be provided to MARKETWOLF. In absence of the same, MARKETWOLF reserves right to transfer the securities to source account from where securities were transferred to POA demat account. In case client transfers securities to POA account from third party account and sells the securities, MARKETWOLF reserves the right to withhold the payout till client obtains NOC from the account holder from whose account shares were transferred for sale.

INTERNAL AUDIT

MARKETWOLF shall appoint auditors to carry out internal audit. The Internal Auditor shall submit a report to the Board of Directors which shall be deliberated upon and the suggestions of the auditors shall be implemented in the day to day functioning.

REDRESSAL OF INVESTOR GRIEVANCES

Compliance Officer shall be the designated officer for handling investors grievances and client complaints. In case of any grievance, clients can write at support@marketwolf.com The resolution of the complaint shall be done at the earliest and the same shall be recorded in the register along with the date of resolution.