Before opening any Trading account with us, the following measures shall be taken:

• In person verification of the client Collect information about client’s background, occupation and also check the name of the introducer.
• Collect and verify all original documents from the client.
• Collect a certified copy of valid documents showing details of his permanent address, current address, PAN, nature of his occupation, financial status and also a recent photograph.
• The client shall be interviewed personally regarding the purpose of opening the account i.e., whether short term trading or long term investment.
• Prior experience in stock market Introducer details.

The Clients account shall be closed upon a specific request from the client. The closure shall be effective only after a period of one month has elapsed from the date of application/intimation or the date of settlement of account whichever is later. Settlement of account shall mean that there is no outstanding balance in the books of the client and Great Ventures and the same is confirmed by the client. The date of confirmation shall be the effective date of settlement.

Order Receipt: Most of the times the client is entertained by the dealer who regularly deals with the client. The trades of clients are carried out in the respective client code only. The dealers take utmost care while executing the trades of the clients regarding the accuracy of Client Code, Quantity and Price etc. The orders from the clients are promptly executed by the dealers and the oral confirmation of the placement of the orders is immediately provided to the clients. Moreover, only registered clients are allowed to enter the dealing room for placing the orders. Mechanism for order management and execution: The clients are divided into groups among the dealers and sub brokers at head office level, so that particular dealer can serve a particular group of clients which helps dealer to understand the client investment strategy in a better way & serve them accordingly. The orders are entered instantly by the dealer on the instruction given by the client. On execution of valid order into trade, dealers confirm the trade with the client so as to avoid any future dispute. At the end of the trading hours, the dealer informs the clients about the execution of the orders placed by the clients. Also a trade confirmation SMS message covering details of all the trades executed is forwarded to client after completion of trading hours on registered Mobile No. of the client.

1. 1. In case, client opts to receive the contract note in electronic form, he shall provide an appropriate e-mail id (created by the client) to the Member (Kindly refer _______). Member shall ensure that all the rules/Business Rule/Bye-Laws/ circulars issued from time to time in this regard are complied with. The client shall communicate to the Member any change in the email-id through a physical letter. If the client has opted for internet trading, the request for change of email id may be made through the secured access by way of client specific user id and password.
2. 2. The Member shall ensure that all ECNs sent through the e-mail shall be digitally signed, encrypted, non- tamper able and in compliance with the provisions of the IT Act, 2000. In case, ECN is sent through e- mail as an attachment, the attached file shall also be secured with the digital signature, encrypted and non-tamper able.
3. 3. The client shall note that non-receipt of bounced mail notification by the Member shall amount to delivery of the contract note at the e-mail ID of the client.
4. 4. The Member shall retain ECN and acknowledgement of the e-mail in a soft and non-tamper able form in the manner prescribed by the exchange in compliance with the provisions of the IT Act, 2000 and as per the extant rules/circulars/guidelines issued by SEBI/Commodity exchanges from time to time. The proof of delivery i.e., log report generated by the system at the time of sending the contract notes shall be maintained by the Member for the specified period under the extant rules/circulars/guidelines issued by SEBI/Commodity exchanges. The log report shall provide the details of the contract notes that are not delivered to the client/e-mails rejected or bounced back. The Member shall take all possible steps to ensure receipt of notification of bounced mails by him at all times within the stipulated time period under the extant rules/circulars/guidelines issued by SEBI/Commodity exchanges.
5. 5. The Member shall continue to send contract notes in the physical mode to such clients who do not opt to receive the contract notes in the electronic form. Wherever the ECNs have not been delivered to the client or has been rejected (bouncing of mails) by the e-mail ID of the client, the Member shall send a physical contract note to the client within the stipulated time under the extant Regulations/ Rules, Bye-Laws, Business Rules and Circulars of SEBI/commodity exchanges and maintain the proof of dispatch and delivery of such physical contract notes.
6. 6. In addition to the e-mail communication of the ECNs to the client, the Member shall simultaneously publish the ECN on his designated web-site, if any, in a secured way and enable relevant access to the clients and for this purpose, shall allot a unique user name and password to the client, with an option to the client to save the contract note electronically and/or take a print out of the same.
7. 7. The Electronic Contract Note (ECN) declaration form obtained from the Client who opts to receive the contract note in electronic form must be obtained afresh before 1st April of every financial year by following the same procedure. Thus, such declaration would be valid for that financial year only. Law and Jurisdiction :
8. 8. In addition to the specific rights set out in this document, the Member, Authorized Person and the client shall be entitled to exercise any other rights which the Member or the client may have under the Rules, Bye-laws and Business Rules of the Exchanges in which the client chooses to trade and circulars/notices issued thereunder or Rules of SEBI.
9. 9. The provisions of this document shall always be subject to Government notifications, any rules, guidelines and circulars/notices issued by SEBI and Circulars, Rules, Business Rules and Bye laws of the relevant commodity exchanges, where the trade is executed, that may be in force from time to time.
10. 10. The Member and the client shall abide by any award passed by the Arbitrator(s) under the Arbitration and Conciliation Act, 1996. However, there is also a provision of appeal, if either party is not satisfied with the arbitration award.
11. 11. Words and expressions which are used in this document but which are not defined herein shall, unless the context otherwise requires, have the same meaning as assigned thereto in the Rules, Byelaws and Regulations/Business Rules and circulars/notices issued thereunder of the Exchanges/SEBI.
12. 12. All additional voluntary/non mandatory clauses/document added by the Member should not be in contravention with Rules/ Business Rules/Notices/Circulars of Exchanges/SEBI. Any changes in such voluntary clauses/document(s) need to be preceded by a notice of 15 days. Any changes in the rights and obligations which are specified by Exchanges/SEBI shall also be brought to the notice of the clients.
13. 13. If the rights and obligations of the parties hereto are altered by virtue of change in Rules of SEBI or Bye-laws, Rules and Business Rules of the relevant commodity exchanges where the trade is executed, such changes shall be deemed to have been incorporated herein in modification of the rights and obligations of the parties mentioned in this document.
14. 14. Members are required to send account statement to their clients every month in physical form.
15. 15. The client shall give any order for buy or sell of commodities derivatives contract in writing or in such form or manner, as may be mutually agreed between the client and the Member however ensuring the regulatory requirements in this regard are complied with. The Member shall ensure to place orders and execute the trades of the client, only in the Unique Client Code assigned to that client.
16. 16. The Member shall inform the client and keep him apprised about trading/settlement cycles, delivery/payment schedules, any changes therein from time to time, and it shall be the responsibility in turn of the client to comply with such schedules/procedures of the relevant commodity exchange where the trade is executed.
17. 17. The Member shall ensure that the money deposited by the client shall be kept in a separate account, distinct from his/its own account or account of any other client and shall not be used by the Member for himself/itself or for any other client or for any purpose other than the purposes mentioned in Rules, circulars, notices, guidelines of SEBI and/or Rules, Business Rules, Bye-laws, circulars and notices of Exchange.
18. 18. Where the Exchange(s) cancels trade(s) suo moto all such trades including the trade/s done on behalf of the client shall ipso facto stand cancelled, Member shall be entitled to cancel the respective contract(s) with client(s).
19. 19. The transactions executed on the Exchange are subject to Rules, Byelaws and Business Rules and circulars/notices issued thereunder of the Exchanges where the trade is executed and all parties to such trade shall have submitted to the jurisdiction of such court as may be specified by the Byelaws and Business Rules of the Exchanges where the trade is executed for the purpose of giving effect to the provisions of the Rules, Byelaws and Business Rules of the Exchanges and the circulars/notices issued thereunder.
5. Risk Management Policy

To manage the risk of the company/client from the volatility of the market. RMS works on the following concepts: Cash: The clear balance available in the customers ledger account in our books. Margin: The underlying stake provided by the customer in the form of fund available in the trading account. Setting up client’s exposure limit: In Futures segment, exposure limit of each client is set, based on Margin money given by the client, as per the Exchange Regulations. Upfront margin is collected from client. Great Ventures Right to sell client’s securities or close client’s position, without giving notice to the client on account of non payment of dues. In case of any such sale the client will not be given any notice. Conditions under which a client may not be allowed to take further position Under the following conditions a client may not be allowed to take further position:

1. 1. The client has a due / debit balance Such clients are allowed to close out his open position but is not allowed to take any new position.
2. 2. The client has not able to meet his pay-in obligation in cash by the schedule date of pay-in.
3. 3. The client has not met Market to Market loss in cash.
4. 4. The open positions in a contract exceed or are close to market wide cut-off limits.
5. 5. The clients position is close to client-wise permissible open positions.
6. 6. The client had defaulted in meeting cash obligation leading to compulsory close out of the position.
7. 7. Open position may be squared off by RMS for any client with MTM loss of over 90% of the capital.
6. Liquidation And Close Out Of Position

1. Without prejudice to the Member’s other rights (including the right to refer a matter to arbitration), the client understands that the Member shall be entitled to liquidate/close out all or any of the client’s positions for non-payment of margins or other amounts, outstanding debts, etc. and adjust the proceeds of such liquidation/close out, if any, against the client’s liabilities/obligations. Any and all losses and financial charges on account of such liquidation/closing-out shall be charged to and borne by the client. 2. In the event of death or insolvency of the client or his/its otherwise becoming incapable of receiving and paying for or delivering or transferring commodities which the client has ordered to be bought or sold, Member may close out the transaction of the client and claim losses, if any, against the estate of the client. The client or his nominees, successors, heirs and assignee shall be entitled to any surplus which may result there from. The client shall note that transfer of funds/commodities in favor of a Nominee shall be valid discharge by the Member against the legal heir.

7. Investor Redressal Mechanism
1. 1. The register of complaints is centrally maintained. The Company has a dedicated Customer Relation Team to monitor & redress complaints lodged with branches / sub-brokers. The Complaints received from clients through mail, letter at branches and sub-broker is forwarded to Head office through email, telephone or post to respective Customer Relation Manager where they are redressed on online basis. If the complaint is not resolved at this level, then it is forwarded to Compliance Department. The pending investor complaints and redressal at this level is monitored by the compliance officer. The analysis of such complaints is done by the management and preventive measures are taken and implemented.
2. 2. Complaints registered against the company and received through exchanges are redressed by Compliance Department and are recorded in the Register of Complaints.
3. 3. The Company has designated an exclusive e-mail ID to enable the investors to register their complaints and such ID has been displayed on the companys website and printed on KYC Form, Quarterly confirmation statement of funds and securities, Welcome kit etc.

8. Allotment/Surrender Of Trading Terminals, Opening & Closing Of Branches

Allotment / Surrender of Trading Terminals: The trading terminals are provided to the dealer/s that is/are appointed by the Company or to the registered sub-brokers and authorized persons only. The Exchange compliance requirements regarding allotment of terminals is strictly adhered to while allotment of terminals. In case of any closure of Branch or Sub-broker, the entire user IDs allotted to that location are surrendered. Opening of Branches : While opening a branch, survey is conducted by the marketing team as per evaluation sheet of the company which includes net worth and educational qualification along with experience in the Securities market of the person, infra structure and location of the office etc. Data gathered by the marketing team helps management to determine the credit worthiness of the person for opening a branch/ registering as associate. After the mutual agreement for terms and conditions between the new associate and the company branch is opened. Closing of Branches : Branch closing either initiated at branch level if the branch manager shows his interest to discontinue or initiated by Head office if the performance of the branch is not acceptable to the company. While closing the branch, branch and clients are informed about the closure of branch. Intimation in physical form regarding closure of particular branch is sent to all the clients of that centre. Then as per clients instructions either they are shifted to nearest branch / HO or their accounts are closed. When the procedure is completed for all the clients the branch is closed.

9. PMLA Policy

Anti-Money Laundering Measures Background : The Prevention of Money Laundering Act, 2002 came into effect from 1st July 2005. Necessary Notifications / Rules under the said Act were published in the Gazette of India on 1 st July 2005 by the Department of Revenue, Ministry of Finance, and Government of India. SEBI vide circular dated 18th January 2006 required Market intermediaries to lay down policy framework for anti-money laundering measures to be followed. Great Ventures being a commodity Broker needs to adhere to the same. SEBI has also issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT until December 15, 2008. Objective : Money laundering has now become one of the major concerns of international financial community. Money Laundering is not just an attempt to disguise money derived from illegal activities. Rather, money laundering is involvement in any transaction or series of transactions that seek to conceal or disguise the nature or source of proceeds derived from illegal activities, including drug trafficking, terrorism, organized crime, fraud and many other crimes.

The objective is to have a system in place for preventing any money laundering financial transaction through us and also to identify, monitor, report any such transaction to appropriate authorities. Know Your Customer (KYC) is the guiding principle behind the Anti-Money Laundering (AML) measures. It incorporates the Know Your Customer Standards & Anti Money Laundering Measures, hereinafter to be referred as KYC Standards and AML Measures “. The objective of is to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the Company from being used, intentionally or unintentionally, by criminal elements “. KYC Standards and AML Measures would enable the Company to know/ understand its customers, the beneficial owners, the principals behind customers who are acting as agents and their financial dealings better which in turn will help the Company to manage its risks prudently.

10. Branch/ Authorized persons, Inspection Policy

Branches will be monitored by phone every week on Saturday and their phone calls will be monitored randomly to ensure below listings: No Cash dealings with clients are carried out. No Contract note / confirmation has been issued to clients other than the ones sent by Great Ventures. No Commission, brokerage or fees has been accepted from any client by associate. No funds have been transferred from clients account to the account of associate or from account of one client to the account of another client. No personal trades of the associate have been executed in clients account under any circumstances etc.

11. Fund Management Policy

Pay In : Clients can transfer funds into the Trading Account only from such bank accounts which are registered with Great Ventures. The client can transfer funds from the instant payment gateway facility available on the trading platform or on the backoffice. Such transfers will be charged at Rs 9/- per transfer. If a client chooses to transfer using NEFT or by means of cheque, there will be no cost. Pay Out : All payouts will have to be compulsorily placed on the Backoffice access provided to the clients. All payout requests will be processed electronically and the credit shall come to the clients primary bank account within 24 hours of having processed the payout request. The payout window for Commodities is 9:00 AM every day – requests placed before 9:00 AM will be honored on the same day. Requests placed after 9:00 AM will be honored the next day. Payout windows are closed on Saturday and Sunday – this means if you place a request on Saturday or Sunday or after 7:30 PM on friday, it will be honored only on Monday.

12. Policy on Pre-Funded Instruments

As a general policy Prefunded Instruments are not accepted by Great Ventures & clients are advised to avoid use of pre-funded instruments for making payments. The clients are also educated about the Exchange and PMLA rules & byelaws. some text The instruments received from clients are checked before depositing the same into bank. If the instrument is identified as Pay Order/DD, then a suitable Reason/clarification in requisite format is required to be obtained from the client. 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. If the aggregate value of pre-funded instruments is Rs. 50,000/- or more per client per day, we may accept the instruments only if the same is accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank. The mode of certification may include the either of the following:

1. 1. Certification from the issuing bank on its letterhead or on plain paper with the seal of the issuing bank.
2. 2. Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
3. 3. Certified copy of the passbook/bank statement for the account debited to issue the instrument.
4. 4. Authentication of the bank account number debited and name of the account holder by the issuing bank on the reverse of the instrument.
The details of the instrument must be tallied with the detail provided by the clients in KYC before entering into back office software. In case of mismatch is identified, it should be reported to department head/ Management/ key personnels for taking appropriate action.
13. Daily & Weekly margin statement

Daily margin statement will be sent within 24hrs and weekly margin statement will be sent within 3 working days from the previous weekend.