Our Services Include:

• Capital Market Trading.
• Derivatives Trading.
• Personalized Investment Advice

Systems & procedures.

The objective of this process notes is to explain the Surveillance Process and systems used for Risk Management Surveillance by Surveillance Department. The key points are following:

Dealer ID Creation

Department gets the details of new User ID from the Customer Relationship Department. Details are approved only by Director. The details are uploaded using ENIT to NSE or using FTP to MCX Stock Exchange . Once NSE / MCX Sx approves the User ID, ID is created and details of retail clients (obtained from Back Office) are mapped with the User ID using ODIN Admin. It is communicated to Customer that new User ID has been created.

Retail ID Creation

Retail User id creation form is being collected from the client who desires to have the IBT platform. The user id is created only after the approval of the director. Once the user id is created the user log-on and password is communicated to client. On the first login client has to change the password.

Surveillance

• NSE Cash trading / MCX Sx Trading is done through NEAT/ TWS and NEAT Plus terminal. ODIN Terminals are mapped with ODIN Admin that is provided to set margin limits for retail clients.
• For ODIN server, there is one ODIN Admin (Chief user) that can monitor all the retail clients connected with that particular ODIN. There is only 1 NEAT Corporate Manager and that NEAT server is connected with NEAT manager that manages all the clients attached with the server.
• NEAT Corporate Manager access is restricted to only at HEAD OFFICE.
• Margin Limits are set through ODIN Admin (Chief user) and surveillance department can check rejected orders in ODIN Admin.
• Margin limits are changed only on phone calls / confirmation from designated people of Accounts department / RMS head .
• Capital market surveillance for orders placed on NEAT is done using Odin Admin/Risk Server and
• Surveillance for orders placed in F&O segment / Currency Derivatives Segment is done by Risk Server. Risk Server gives the margin utilized by the client and Mark to Market loss at the current market price of the underlying scrip in which the client or dealer has the positions.

General Points

• Employees follow rules and responsibilities as communicated verbally by Department Manager.
• All User Ids are password protected.
• Manuals for Risk Server are not available readily. These surveillance systems are used to monitor positions but orders that exceed the limits will be rejected.
• We come to know about bulk orders i.e. securities that exceed 0.5% of market cap of a stock, through Back Office report.
• Derivatives that exceed 95% of market wide position limit can be rejected only through odin administrator
• Every week, limits of dealers /Ids are updated based on margins of retail clients handled by the respective dealers.
• Margin Limit is set as zero by default for Retail Clients and dealers.
• Margin is collected from clients even if they want to sell securities.

Passwords for NEAT /TWS , Odin Admin Chief, are available with all members of Surveillance team.

Write-up on Internal Controls

INTERNAL CONTROLS: Internal controls are in place at all levels in the organization. The activity wise details are as under:

Registration of Clients: A KYC policy is already in place and the staff members are instructed to strictly adhere to the rules and regulations framed by various authorities from time to time. All the client registration forms are scrutinized at various levels before final registration of the client. Trading is allowed to the clients only after successful upload of "Unique Client Code". Receiving, Validating & entering orders of the clients in the trading platform: Orders are received on phone. The orders are placed in the trading platform and confirmed immediately on phone itself. Some preferred clients are also informed as and when their order gets executed.

Sales Practices followed by the Trading Member: Not Applicable

Closure of Client accounts/Dormant accounts: On receiving request from clients for closure of accounts the staff members are instructed to verify their accounts and once the client account is clear in all respect the account is closed from our end and the same is intimated to the client.

For dormant accounts, the clients who have not done any transactions for more than six months are temporarily suspended from our end and will be de-activated from back office. The account will be activated only once we receive a written request along with proof of identity from the concerned client.

Collection and Maintenance of Margins: We adhere to strict compliance in maintenance and collection of margins. Our RMS department keeps track of margin requirement of every client on continuous basis. Everyday the margin requirement as per MG13 is matched with margin available in cash as well as collateral received from clients and in case of shortfall duly collected from the respective clients in time and reported accordingly.

Monitoring of debit balances: Accounts departments will send intimation to clients about their debit balances and they do weekly follow up. Clients whose debit balances are for more than six months they are given written letter to settle their account immediately.

Allotment, Surrender of trading terminals: Allotment of terminals will be done strictly on basis of NCFM/BCDE certificates of the user. On expiry of certificate validity the user is instructed to renew the at the earliest. On resignation or in case the user is not renewing the certificate then we will surrender the trading terminals through NSE Enit.

Payment, Receipt of funds from/ to clients: Funds payment to clients will be done on the day of T+2 as per SEBI/Exchange rule. If clients requests for running account then the client account will be settled on every six months.

All clients are requested to make their payments latest by T+1 day. On debit balances weekly reminders will be sent to them.

Receipt, Delivery of Securities from/to clients: Most of the clients are given Auto Payin/ Payout facility. For those not registered for Auto Payin/ Payout delivery of securities will done after considering debit/credit ledger balance in their respective accounts.

Power of Attonery: POA should be taken only for Auto Payin/Payout of securities.

Square off of position/ Liquidation of securities without consent of Clients: We never square off of position/ Liquidation of securities without consent of Clients. If there is any debit balance or violation of margin from client we intimate them and with their consent we square off of their position/ liquidate their securities.

Policy for internal shortages: In case of internal shortages the purchaser will be credited with closing price on T+4 day and the seller will be debited with the same rate.

Transfer of trades: Transfer of trades are not allowed. But in case if trades are to be transferred first we will intimate the exchange about the changes through NSCCL Clearing Management system and on receipt of modification confirmation successfully the trades will be transferred in our back office.

Monitoring of branches/Sub-brokers/DP operations etc: Branches and sub brokers are kept under continuous surveillance through our RMS and Coordination Department. Regular branch visits and internal reviews are carried out to ensure smooth functioning and proper management of the branches. As regards operations at branch level, all the back office related activities have been centralized at the corporate office of the company. The operations at the branch level are restricted to trading and collection of payments only. All other activities are controlled from corporate office only. Feedback from all the branch managers is received on continuous basis to analyze the status of operations at the branch.

Continuity Planning / Alternate plan in case of disasters etc: The Company has a CTCL server located at Head office and another Back up CTCL server is also located at our Head office. If any server is down, users can be shifted to the other server. Back up of the previous day is being restored to Back Up CTCL server which is running live to reduce down time in case of hardware failure. Further the databases are backed up daily & stored at remote location.

Compliance: We are committed to comply with all the requirements issued by exchange and other market intermediaries from time to time. We have compliance department in place for continuous monitoring of various compliances. In the preceding paragraphs, we have elaborated the various internal controls put in place to ensure strict adherence to all the rules and regulations. Department wise allocation of various compliances is also done to ensure day-to-day compliances.

PMLA: It is the policy of the company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Detailed PMLA policies & procedures have been drafted.

Investor Redressal Mechanism: In case of any complaints investors can email their redressal in the e-mail address 'grievances@jjbshares.com'. Complaint Registers are kept at Registered Office & Head Office.

Systems

Capacity of Systems with reference to volume:

NEAT/ODIN/GETS 40MSG Leased line - Capacity Ids 20.

Connectivity to Exchange & /to branches/sub-brokers: We provide connectivity through VSAT/Leased Line.

Back up in case of disruption of connectivity: In case of disruption of Leased Line connectivity full back up of VSAT will be provided.