Policies and procedures

GREEN INDIA COMMODITIES (GC)


GC is a member of the Multi-Commodity Exchange in Commodity segment having its registered office at No. 6, I Floor, 100 Feet Road, Ellaipillaichavady, Pondicherry – 605005, India.

Payment details
Payin
1. Clients can transfer funds into the Trading Account only from such bank accounts which are registered with GC.
2. 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.
3. The client can transfer funds from the instant payment gateway facility available on the trading platform as well as in the back-office. Such transfers will be charged at Rs 9/- per transfer.
4. If a client chooses to transfer using NEFT or by means of cheque, there will be no cost.

Payout
1. All payouts will have to be compulsorily placed on the Back-office access provided to the clients.
2. All payout requests will be processed electronically and the credit shall come to the client’s requested bank account which registered with us within 24 hours of having processed the payout request.
3. The payout requests placed before 12:30 PM will be honored on the same day. Requests made after 12:30 PM will be honored by next working day.
4. Payout windows are closed on Saturday and Sunday – this means if you place a request on Saturday or Sunday or after 12:30 PM on friday, it will be honored only on next working day.

Margins
GC does not engage in the business of Client Funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions.
GC has a policy of giving up to 15 times exposure on commodities trading; no margin is given for carry forward positions. The client needs to have enough money in his trading account to take carry forward positions, failing which GC can cut the position.
Intraday (MIS) trading is allowed in all Non Agri products. Leverage provided is subject to market conditions and changes in its proportion are dynamic. Currently 40% of SPAN is required to trade intraday. Carry Forward (NRML) positions require 100% SPAN

Intraday products square off timings:
Item Commodity
Intraday Margin Time 25 minutes before Close
*Note: Intraday square off timings can change based on the discretion of our risk management department.

Note
a) Positions which do not have sufficient funds can be cut any time at the discretion of our RMS desk. There will be no margin calls or intimation from our RMS desk.
b) All positions will be subject to square off if your losses exceed 50% of the available funds in your account. This will be done at the discretion of our RMS team and there will be no margin call.
c) All MIS positions will automatically be squared off at the end of the each trading day.
d) Trading in mcx contracts will be banned a before the closing hours of the contract prior to the delivery intention period.
e) GC blocks only SPAN margin for overnight positions on commodities. The exchange has offered a provision for brokers to collect an Additional Margin of 5%, which GC has chosen not to collect at its own discretion and passed on the benefit to its clients.
f) Fines levied by the exchange for short margin will be payable by the client.
g) Clients will have to ensure intraday products are closed by the EOD.
h) Payments will only be accepted from the client’s registered bank account, cash and DD payins are not accepted.
i) On the start of the delivery intention period, clients will not be informed before closing any open positions to avoid compulsory delivery notice. Clients are advised to close their positions well in advance.
j) Physical Delivery of Commodities is not allowed.
All information mentioned here is subject to change at the discretion of our Risk management team.

Margin in Debit
Delayed payment charges
GC follows the practice of posting the settlement obligation towards their transaction in the client ledger on the settlement date. All clients are advised to make the payment before the pay-in time on the settlement day, though there are instances wherein client may delay the payment beyond the settlement date. Although, it is obligatory for a broker to meet the settlement obligation in time, therefore, in order to ensure timely receipt of funds from clients towards their payment obligation, “charges for delayed payment” are levied in the client’s account. The sum towards “charges for delayed payment” is levied to discourage delayed payment from clients who do not deposit the required sum of money before the payin time on the payin day. “Charges for delayed payment” are levied on the respective ledger debit of the clients at a rate of 0.05% per day of the debit balance in the account. For the purpose of reckoning debit balance, the debit balance in the client ledger is consolidated across all segments of the respective exchange after giving effect to the release of margin.
Contract notes and margin statement
GC will issue contract notes & margin statements to its clients within 24 hours of the trade taking place. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin status which is also available to be viewed on their respective Back-office Personal Ledger.
Trade – Process
The trades of clients shall be carried out in the respective client code only. The dealers shall take utmost care while executing the trades of the clients regarding the accuracy of Client Code, Quantity, Price, etc.
Closing of accounts/dormant account
The Clients account shall be closed upon a specific request from the client. The closure shall be effective only after a period of six months has elapsed from the date of application or intimation received from the client or the date of settlement of account whichever is later.
Settlement of account shall mean that there is no outstanding balance of funds in the books of the client and GC and the same is confirmed by the client. The date of confirmation shall be the effective date of settlement. As far as dormant accounts are concerned, we do not close such accounts, but mark the same as “Inactive” till further action by the concerned client.
Compliance
The Compliance Officer shall be the designated officer for handling the Investors Grievances and Client Complaints. The email ID you can write to in case you have any grievance is compliance@gicbroking.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.

GC PMLA Policy


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 1st 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. GC being a Stock 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
The management of the company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance with respect to all relevant legal requirements.

The regulatory / statutory requirements
An officer of the company will be designated as “Principal Officer” who will ensure proper discharge of all legal requirements with respect to the same Mr. Senthil Kumar P, is the Principal Officer responsible for
• Compliance of the provisions of the PMLA and AML guidelines
• Act as a central reference point and play and active role in identification & assessment of potential suspicious transactions
• Ensure that GC discharges its legal obligation to report suspicious transactions to concerned authorities.
The main aspect of this policy is the customer due diligence process which means:
• Obtaining sufficient information about to the client in order to identify who is the actual beneficial owner on whose behalf transaction is conducted
• Verify the customers identity using reliable independent source document, data or information
• Conduct on-going due diligence and scrutiny of the account/ client to ensure that the transaction conducted are consistent with the clients’ background/ financial status, its activities and risk profile.
The customer due diligence process includes three specific parameters:

• Policy for acceptance of clients : Each client should be met in person Complete KYC to be done for all clients No account to be opened in a fictitious/benami name or on an anonymous basis
• Clients Identification Procedure (Risk profiling) All clients to be classified as per the risk into 3 categories Low, Medium and High Risk
• Suspicious Transaction identification and reporting Any unusual activity compared to past transactions Sudden activity in Dormant accounts Sudden High volume / high value transactions
The principal officer shall report the nature, amount, date and all related details of any and all suspicious transactions recorded.

1. Client identification Procedure
Before opening any Trading account with us, the following measures shall be taken:
• In person verification of the client
• Identify beneficial ownership and control, i.e., determine the persons who beneficially own / control the account.
• 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.
• In case of Corporate client, collect copies of certificate of incorporation, Memorandum of association and other documents as required by SEBI
• In case of Corporate client, collect adequate information of the persons authorised to deal on behalf of the company.
• Prior experience in stock market
• Introducer details

2. KYC updation process
All corporate clients must submit annual report every year. In case of individual clients, Client Master details shall be sent to all clients, who will confirm either that the details are updated or shall be advised to submit details if required. He shall also specify his present occupation and financial income details per annum in the same declaration.
The information should be adequate enough to satisfy competent authorities (regulatory/ enforcement authorities) in future that due diligence was observed by us in compliance with the Guidelines.
Failure by prospective client to provide satisfactory evidence of identity should be noted and reported to the principal officer.
Further, we should also maintain continuous familiarity and follow-up with the client where inconsistencies in the information provided are noted.
The account will not be opened where we are unable to apply the above KYC policies, e.g., non co-operation of the client in providing full information etc

3.Client categorization
Each client will be marked into 3 categories, High Risk, Medium Risk and Low Risk from the point of view of the anti money laundering laws. The categorization will be made based on the following parameters/ factors of risk perception:
• High Networth Clients
• Trusts/ NGOs / Charities receiving donations
• Companies having close family shareholdings (The above are considered of High Risk as per SEBI guidelines) The other parameters are nature of business activity, trading turnover, manner of making payment etc. Provision will be made in the back office software for noting categorization of each client. The high-risk client will require regular KYC update.
The clients will be placed under low, medium and high-risk category based on their turnover per day. Corporates / HNIs having respectable social and financial standing, Clients who make payment on time and take delivery of shares can be considered as Low

4. Suspended/debarred Persons
SEBI and other authorities suspend or debar persons / entities from participating in securities market on several instances. We as a Broker are required to ensure that such persons do not trade through us.
We shall lay down systems for identifying transactions which is not in consonance with the financial status declared/ shown by the client. Also, unusual activities compared to past transactions, sudden activity in dormant accounts, activity inconsistent from declared business activity, should be traced. This shall require appropriate changes in our back office software.
Systems shall be put in place for identifying transactions likely to be market manipulation, and which appears to be insider trading and also any transaction which seems to have no bonafide intention. Regular communications by means of mailers, SMS, Email are sent to clients at various intervals requesting them to update their latest financial and KYC details available with us.
Role of Compliance Team & Internal Audit

The compliance team will play an important role in ensuring compliance of the above policies and procedures. The account opening team will exercise adequate due diligence as stated above. There will be periodic checking by the Principal Officer and the same report will be properly filed here is a system of concurrent audit, which will also include ensuring compliance of the
• Due diligence in KYC norms.
• Generation of exception reports
• Trading in dormant client codes
• Level of awareness of staffs

5. Employee’s Hiring/Training Programs
We GC have hiring the employees through referral of existing employees and by way of local advertisement through newspapers. All the employees are screened well prior to Personal interview by way of testing their IQ level through questionnaires.
We have policy for ongoing employee training program so that the total staffs of our company completely aware of the provisions of AML and CFT procedures and amendments thereof. These training programs are totally focused for frontline staff, back office staff, compliance staff, risk management staff and staff dealing with new customers as it is very crucial that all those concerned fully understand the rationale behind these guidelines, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being misused by unscrupulous elements, if there is any lapse on the part of any staffs of the company.
As resolved GC shall take adequate measures as per its internal policy to prevent money laundering and shall also put in place a frame work for PMLA policy. The policies and procedures as mentioned above shall not be final as it may adopt additional measures to safeguard its interest with respect to activities associated with PMLA.
All clients on any issue in internet or connectivity failure or in any other difficulty can call on our Head Office.
6. Policy for inactive clients

All that you need to know in case your trading account is not active for more than 6 months.
For reactivating the account we required the following:
a. Required a written confirmation to Reactive the account with client signature and date. If the client is Partenership firm/Corporate required the request should be in letterhead of the company with authorized signature and seal.
b. The client should sign the Mandatory documents in the fresh KYC to reactive his/her account.
c. Required sufficient Address / Bank proofs with fresh KYC if any changes done by the client against the previous KYC which was signed by him.
Once received the said documents, the account will be activated by next working day.

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