Branch Mgt_Manual Ver 1

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Version - DraftVersion - 01Date - March, 12


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Branch Management & Operations Manual Ver-012012

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No part of this document may be reproduced or stored in a retrieval system,

or transmitted in any form or by means, electronic, mechanical, recording or

otherwise without the prior written permission of JRG Legal Department

This manual has been divided into 12 chapters beginning with the introduction

of Branch Structure, and other operational aspects dealing in day to day affairs

of the Brach Functioning. As a Branch Manager, you are required to go

through the same and comply with the various requirements as set out in this

Manual. In the last chapter we have specified various Annexures, which the

Brach Manager has to comply to.


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Contents

1. Introduction to Branch Structure 5-7

1.1 JRG Zonal Structure 51.2 JRG Territories Structure 51.3 JRG Management Structure- Deccan 61.4 JRG Management Structure- Malabar 71.5 JRG Management Structure- Konkan 7

2. Products and Services 8

3. Branch Hierarchy and Management 9-163.1 JRG Branch Hierarchy 9

3.2 Role and Responsibilities of BM 9

3.3 Branch Activities 10

3.4 Client Acquisition 103.5 Account Opening 11

3.6 KYC Requirements 11

3.7 Account Opening 11

3.8 Registration of New Clients 12

3.9 PAN and its Importance 12

3.10 General Account Opening Instructions 12

3.11 Address Proof 13

3.12 JRG Not Accept Certain Clients 13

3.13 Account Opening and other Charged 13

3.14 In Person Verification 143.15 Management of Franking Machine 14

3.16 Account Activation/ Reactivation 15

3.17 Welcome Kit and Calling- DOs and DO NOTs 15

3.18 Introductory Calls by BMs 15

3.19 Updating/ Changes in Client Master 16

3.20 General Dos and DOs and DO NOTs 16

4. Trading and Terminal Management 17-214.1 Terminal Management & Dealing Room 174.2 Dealing Room and Mobile Phones 184.3 Activities that require special Attention of BM 184.4 Dealer Certification 184.5 Order Execution- DOs and DO NOTs 194.6 Password Policy 204.7 Unverified Market Information/ News 204.8 Restrictions on Cash Dealings 204.9 General DOs and DO NOTs 20


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5. Pay In/ Pay Out of Funds and Securities 22-265.1 Funds Pay In 225.2 Funds Pay Out 235.3 Request Based Payout 23

5.4 Auto Payout 235.5 Monthly/ Quarterly Settlement of Funds 235.6 Securities Pay-In 245.7 Securities Pay-Out 245.8 Request Based Pay-Out 245.9 Auto pay-Out 255.10 Monthly/ Quarterly Pay-Out of Securities 255.11 Process to Change DP/ Bank Account Details 26

6. Risk Management and Receivable Managements 27-296.1 Suspicious Transactions 276.2 Grounds of Suspicion 276.3 Trade Modification 286.4 Debit Calls to Clients 296.5 Intimation on Shortages 29

7. Depository Services 30-317.1 DP Service Centres 307.2 DP Drop Box Centres 307.3 DP Account Opening 317.4 DIS Acceptance at DP Centres 31

7.5 Acceptance of DRF/ RRF/ FRF/ URF/ TRF/ PRF 317.6 Changes in DP Service Centre/ Drop Box 31

8. Investor Grievances 32-338.1 Client Queries and Complaints 328.2 Responsibilities of Branch Manager 328.3 Responsibilities of Compliance Officer 33

9. Audio Visual Recorder (AVR) 34-359.1 Requirements of AVR 349.2 Responsibilities of Branch Manager 34

9.3 Responsibilities of IT Department 35

10. Legal and Administration 36-3710.1 Displays and Notice Boards 3610.2 Office Management at Branches 3610.3 Branch Management Expenses 36


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11. References and Abbreviations11.1 References 3911.2 Abbreviations 39

12. Annexures

12.1 Branch Monthly Check List 4012.2 Branch Daily Check List 4712.3 Notice Board JRG Securities 4812.4 SEBI Registration Certificates 5012.4 Notice Board JRG Wealth 5112.5 Pre-Inspection Information Format 5212.6 Policy of Penalties/ Disc. Action for Non Compliance 54


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1. Introduction

The company runs its business

presently spread into three Zon

control over the territories and(ZM). The present Zonal structur

1.1 J.R.G. Zonal Structur

The above said zones are divide

by each Territory Manager (TM).

1.2 J.R.G. Territories Str

Deccan

Malabar

Konkan

Deccan

Aurangabad

Pune

Hyderabad

Vizag

Vijaywada

Branch Management & Operations Manual

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ainly through its branches and franchisees in

es. This has been done in order to have bette

ranches network. Each zone is headed by a Ze is given as under:

into district wise five to seven territories, whi

The present structure of the zones are given a

cture

Malabar

Kozikhode

Kochi City

Pala

Trivandrum

Coimbatore

Trichy

Konka

Bangalo

Hubli

Mangal

Chennai

Nanded

er-012012

etail Broking

r operational

nal Manager

h is headed

under:

n

re

re


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Each of the three territories namely Deccan, Malabar and Konkan are allotted five to seven

branches which are headed by Branch Manager.

The present structure of the JRG Branches is given as below:

1.3 J.R.G. Branch Management Structure- Deccan

Aurangabad

Ahmednagar

Aurangabad

Jalna

Beed

Jalgaon

Nashik

Pune

Pune City

Andheri (Mumbai)

Sakinaka

Borivalli (Mumbai)

Mulund (Mumbai)

Hyderabad

Somajiguda (Hyd)

Dilsuhknagar (Hyd)

Secunderabad

Warrangal

Karimnagar

Nizamabad

Kurnool

Vizag

Vizag

Rajamundry

Srikakulam

Kakinada

Vijaywada.

Nellore

Vijaywada

Khamman

Guntur

Tanuku


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2. Products and Service

JRG maintains network of bra

we offer a wide range of financ

HO are continuously engaged iupon the review newer produ

present structure of JRG produ

2.1 J. R. G. Product & S

The above said products/ serviOffice and Registered Office

Managers are advised to contac

TradingProducts

Equity Cas

Currency D

Commodit

NBFCProducts

Margin Fu

Loan Again

Corporate

Third ParyProducts

Mutual Funds

Insurance Bro

Bonds distrib

Company Fix IPO Distributi

OtherProducts

Depository

Real Estate

Business C


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:

ches and franchisees across India. Through t

ial & investment products and services. The c

reviewing and existing products and servicts/ services are added for the benefit of JRG

cts and services are given as under:

rvices List

es are being provided by a specialized teamho have the domain expert in their fields.

them for the latest services and for any guidan

and Equity Derivatives

erivatives

Derivatives

ding

st Shares

inance

distribution

king Life and General

tion

d Deposits Distributionn

Services

Broking

nsultancy Services

er-012012

his network,

ore group at

s and basedclients. The

at CorporateThe Branch

ce etc.


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3. Branch Hierarchy

The branch hierarchy as discussed above can be better understood with the following diagram.

3.1J.R.G. Branch Hierarchy

3.2 Roles and Responsibilities of Branch Manager

To act as a profit centre head and handle and drive the team to generate desired business.

Planning & Implementing all the marketing, sales and client service related activities.

Responsibilities:

i. Overall monitoring, administration and management of the Branch.

ii. Responsible for participate and delivery of budgets and business targets.

iii. Ensure compliance with regulatory rules and internal requirements.

iv. Liaison with clients and prospects for business development and client service.

v. Achieving branch profitability.

vi. Authorization of Branch expense payments.

vii. Ensures smooth functioning of branch operations and availability of systems.

viii. Set sales targets for the team and ensuring achieving their targets.

ix. Competition tracking and analysis.

x. Provide necessary support to team members.

xi. Manage the training needs of the team.xii. Generate ideas to introduce new products and services.

xiii. Generating MIS as required.

xiv. Attrition management & Retention of talent

National SalesHead

Zonal Heads(3)

TerritoryHeads(XX)

BranchManagers (XX)

Dealers

Support Staff

Sales Staff

Product

Head

Head DealersEquity

HeadCommodity


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3.3 Pyramid of Activities a

The Branch Manager has to undert

servicing the clients, management

various statutory and regulatory co

given hereunder:

3.4 Client Acquisition

Prospects leads are generated t

i. Cross sell across grou

ii. Referrals from existin

iii. Promotional activitie

iv. Corporate events and


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Branch

ke number of activities that range from bringing of

f operations, safe upkeep of branch assets and co

mpliances. The pyramid of the various activities of t

hrough

p entities,

g clients,

, and

marketing campaigns etc.

Clinet Acquisition

Activation of existing clien

Ensuing Compliance

Trading in JRG Products

Pay-in/Pay-out of Funds/Secu

Risk Management

Depository Services

Client Queries & Complain

Branch Administration

Management of Branch Ass

Branch Expenses Managem

er-012012

new clients,

pliance of

he Brach is

s

rities

ts

ets

nt


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The BM has to ensure that the Rights and Obligations, Know Your Client Form, Participant

Beneficiary Agreement and other Mandatory or Voluntary documents are in the latest

formats as prescribed by the H.O. Client Registration Form (KYC) docket for each new client

sent to the H.O. should be complete in all respects with all the mandatory fields/document

duly filled in and signed. Compliance approved latest version of KYC must be used for

account opening and the same can be confirmed in Plum software or check with KYC

department.

3.5Account Opening Process

As an intermediary we are bound to ensure adequate due diligence while dealing with

existing / prospect clients with respect to the requirements prescribed under the Prevention

of Money Laundering Act (PMLA), 2002 and the guidelines issued by SEBI & StockExchanges.

3.6 Know Your Client (KYC)- Why is KYC important?

To avoid regulatory and operational risks.

To help you understand what the law and regulations require of you.

To help you keep down criminals out of your business.

To be confident of the fact that you know your client base.

To be able to identify high risk clients as you take them on.

To make sure that you deal with the authorized and right clients, and above all To help your business continuously growing.

3.7 Account Opening

Account opening involves collecting copies of the clients documents as ID proof,

address proof etc.

The clients photo is an essential KYC requirement.

Recent photo of the applicant is must.

Make sure that client signs across the photograph, and not inside or outside.

Never accept document copies without comparing them with originals.

Documents should be self attested by the client. This means that the client(s) should

sign on the copies.

Photocopies need to be stamped with verified with original.

This stamp should have the verifiers name, employee code, designation and branch

name.


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3.8 Registration of new clients

Client is personally met by the Branch Official i.e. Branch Manager/R.M. Client is explained about various mandatory and non-mandatory clauses/ documents

and advantages of these clauses.

Email addresses and Cell Phone Numbers are obtained from the clients and updated

regularly.

No email is created by JRG employee.

3.9 PAN card and its Importance

PAN card is mandatory ID proof.

The PAN card carries the photograph and the name of the person.

PAN cards are verified and copies are obtained from the clients.

PAN number is verified with the Income Tax website.

For verifying the PAN, in addition to the verified with originals stamp, you also

need to affix the PAN verified stamp and sign. The PAN is really important.

3.10 General Account Opening Instructions

The overall TAT (Turn Around Time), i.e. from the date of client interview to UCC (Unique

Client Code) , to activate a form is fixed as 2 days . In case if any form is found deficient /

rejected due to the absence of required documents / informations , then the same should

be rectified on immediate basis and the account must be coded within 7 days from the date

of deficiency / pendency reporting. All accounts will be activated for trading only after the

clearance of account opening /initial margin cheque.

Form (AOF) fill fully and NA Should be marked wherever Not Applicable.

No column be left blank.

Capital or commodity trading accounts can be opened in single names only.

You cannot have a capital or commodity trading account in joint names.

DP can be opened with Maximum of three Account Holders.

(PAN and Address proof required for All Account Holders, Bank Proof should be in

the name of First Holder).

This stamp should be affixed on all the copies and put his signature on the stamp.

For Participant BO agreement/ any voluntary document is in the name of JRG

Securities Ltd.

Stamping/ franking done for the agreement should be valid for a period of 6 months.

The date of execution of agreement must be after the date of stamping/franking.


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JRG employees should, as far as possible avoid witnessing the Agreement / POA for

the client.

3.11 Address Proof

Obtain self attested any one listed below documents as address proof:

1. Ration Card

2. Passport

3. Voter ID Card

4. Driving license

5. Bank Passbook along with cancelled cheque leaf

6. Bank Statement

3.12TMs/BMs Not to Accept following as JRG Clients

The following entities/ persons will not be accepted as clients by JRG:

Accounts in benami name.

Accounts where sufficient identification documents/ introduction is not

provided.

Accounts of persons with criminal background and/ or having connections

with terrorist organization.

Entities barred by SEBI by way of orders issued by Chairman/Board etc.

3.13 Account Opening and Other Changes

The account opening charges to be collected and deposited with the designated

bank of JRG.

BMs to collect Stamp Duty on Agreements also.

Money to be deposited in JRG Account (i.e. HDFC Bank A/c No.00200130000010).

The details of such cheques should be captured in the KYC Inward /Outward Register

(Physical / Electronic) for audit trail.

No cheque should be kept in branch for more than one working day.

All the stale cheques and cheques not identified should be sent to HO.


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3.14 In Person Verification (IPV)- It is Must

It is mandatory as per regulatory requirement to meet the prospect client in-person and

verify the photograph affixed on the KYC and proof of identity document(s) with the person

concerned, before opening/ on boarding the account.

In-Person Verification of applicant(s) should be carried out immediately.

IPV must be done by the JRG Staff.

It is mandatory to verify the photograph of the client affixed on KYC.

The staff to establish the identity of the applicant by verifying the photograph.

All the documentary evidences must be self attested by the client in the presence of

JRG staff.

Upon the applicant submitting the account opening form, Branch should follow the

procedure as given below:

1. Verify the identity of the applicant.

2. Obtain PAN Card Copy and verify from the original.

3. Address and Bank documents.

4. After due verification, fill the IPV form completely with following;

a. Name of the Employee,

b. Employee Code,

c. Verification Date,

d. Place of IPV,

e. Designation of employee,

f. Sign with Branch Seal)

5. After due verification the staff of should affix Verified in Person stamp on

the proof of identity document(s) collected.

3.15 Management of Franking & KYC Stationary

KYCs would be franked and distributed from HO to branches on their request. Branch has to

maintain the KYC Inward/ Outward Register and all the KYC receipts / issue must be updated

in the Plum software.

In order to ensure proper management of KYC stationary, avoid revenue leakages in terms

of Stamp paper charges and to mitigate reputational risk by restricting the KYC circulation

only to the prospect clients, Branch Manager has to review/ reconcile and certify the KYC

Inward /Outward Register on a monthly basis and gaps, if any, should be highlighted to

respective authorities / stakeholders with immediate effect


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3.16 Account Activation/ Reactivation:

Branch Managers ensure to obtain client codes/ UCC from Client Account

Management System (CAMS).

CAMS to ensure to report of client information to the regulator before activating andrealising to BM.

CAMS should share the UCC and the terminal ID details with with the RMS (Risk

Management and Surveillance) team on a daily basis.

Risk Management and Surveillance will map / create the client on the ODIN terminal

for trading. (Gijo)

3.17 Welcome Kit & Welcome Calling-Dos and Do-Nots for KYC Department:

Ensure to send the Welcome Kit to client within T+1 day of account activation.

Do maintain a Log of Welcome Kit dispatch/ delivery.

Ensure to enclose in kit Client Account information, copy of the Client Registration

form with the KYC and all mandatory and voluntary clauses signed by the client.

Follow up with the welcome call post despatch of kit.

In case of any deficiency found, ensure to correct the within on T+7 days.

Keep the client account in suspended mode till the correction is done.

Do take special care for Internal Clients.

Internet Trading Account password should be mailed separately.

Ensure not to club password PIN mailers with the welcome kit of the client.

In case undelivered/ bounces back kit, call the client over phone. Deactivate the client account temporarily in case of bounces kit.

3.18 Introductory Call by Branch Managers- Dos List

Ensure that concerned dealer makes a call to client and informs him about JRG

products and Services.

This call has to be made within T+1 day once account is activated.

Ensure the authenticity of the client by verifying the profile from the back office.

Ensure to accept orders from the client or duly authorized representative.

Ensure written authorization of the same from the client. Ensure all the calls and interaction with the client is routed through JRG IVR system.

Do keep the adequate audit trail of the same.

Do send the confirmation of the same to HO immediately after such confirmation.


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3.19 Updating/ Changes in Client Master Info / Review of Client Profile- Dos

Ensure to obtain written request from the client for modification in client master.

Obtain separate modification for Depository, Capital Market and Commodity.

Ensure that all the modification request must contain the existing and new details. Ensure that request form and proofs must be signed/ self attested by the client.

BM to verify the copies of documentary evidences, with the originals.

Ensure to put stamp (Verified with Original).

Ensure to put the name, signature, and employee code who verified the documents.

For derivative clients ensure to update their income details with supporting

documentary evidences annually.

For additional information/ understanding the process please refer the KYC manual.

3.20 Dos and Donts

i. The circulation of Client Registration Forms must be restricted to the prospect clients

only and all movements of KYC must be tracked through the KYC Inward / Outward

Register

ii. Branch Manager has to verify the KYC Inward / Outward Register on a monthly basis

and gaps , if any , should be highlighted to concerned authorities

iii. Compliance approved latest KYC only used for account opening and outdated /

expired KYC must be destroyed as per Document Destruction Policy

iv. Branch should ensure account opening charges are collected from clients, wherever

applicable and must be deposited in the specified account for the said purpose.

v. If any employees have provided their mailing addresses as the branch address, these

should be promptly updated on transfer / exit of such employees. CAMS have to

maintain the list of employees accounts and periodically tracked for the above

purpose.

vi. In Person Verification is a must and should be carried out by an employee of the

company. No group company employees/Sub-broker / franchisee employees are

allowed to do In-person verification

vii. CAMS has to verify the details of In-person verification with the employee list and

ensure the authenticity of the same


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4 Trading and Terminal Management

4.1 Terminals Management and Dealing Room Instructions:

In order to ensure timely execution of order instructions / market inquiries of the clientswalk in to the branches or using call and trade facility, all our branches are equipped with

ODIN (Open Dealer Integrated Network) CTCL terminals and experienced Dealers . It is the

duty of the Branch manager to maintain adequate number of terminals with interrupted

connectivity to cater the branchs trading volume.

Terminals are allotted only to the Dealers who are on the rolls of JRG Securities Ltd or its

registered Sub-brokers and have valid NCFM/BCSM/BCDE Certificate. For availing the

terminal, the respective dealer has to forward the application in the prescribed format with

his signature, supported with valid NCFM/BCSM/BCDE certificate and Branch Managers

approval to the Compliance department. Upon receipt of application for new terminal /change of information for the existing terminals, CMP would verify the information with the

same available with HRD and if found satisfactory the terminal ID would be created ad and

released post regulatory reporting and approvals. The TAT for issuance of new terminal /

changes w.r.t. existing terminal is fixed as 48 working hours.

The compliance department has to review the details of active CTCL Terminal Ids with the

information available with HRD and the active IDs available in ODIN manager and gaps if any

should be rectified immediately on identification post reporting to relevant authorities.

As a BCP (Business Continuity Plan) measure, each branchs clients should be mapped to anearest Branch/ Regional Dealing Hub or Centralised Backup Desk and the details like

dealers name, contact number etc should be communicated to the branches to ensure

continued client service and support in case of contingencies. The Branch Managers has to

ensure so as to comply the followings:

All the NEAT/ BOLT Terminals should be supported with valid NCFM/ BCSM or other

certifications.

Branch Managers to ensure to inform Compliance Department about the validity of

NCFM/ BCSM on routine basis.

Branch Managers to ensure that under no circumstances unauthorised terminals are

logged in at the branch.

Terminals to be allotted to the staff of JRG only.

Branch Managers to ensure that terminals are operated by the Dealers only.

BMs to ensure that clients should not have direct access to terminals.

If machines are unmanned, they should be password locked.

BMs not allow unauthorized access to the dealing room.


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BMs to maintain a dealing room register.

BMs ensure that Dealers to follow the code of conduct at all the times.

BMs to ensure to maintain back up connectivity like (VSAT/ VPN/ Leased Line etc) to

meet exigencies.

Ensure that terminals of other brokers are not operated at out branches.

BMs to ensure not to keep documents loose at desks etc.

BMs to ensure that no trades are executed without confirming authenticity of client.

4.2 Dealing Rooms and Mobiles Phones:

Mobile phones are strictly not allowed in the dealing room/ vicinity. The Branch

Managers are advised to ensure the following instructions.

BMs ensure that mobiles are not allowed in the dealing room/ vicinity of trading

areas.

Do not take trade orders through mobile phones.

All mobile calls are forwarded to the Dealing room recorded lines at least 30 minutes

before commencement of Trading Session.

During trading hours, cell phones are deposited with the Branch manager away from

dealing room.

Trade confirmation should be given through recorded lines only.

Obtain clear cut instruction form authorized person only.

No unauthorized trades should be executed.

4.3 BMs to pay special attention to:

In case of any suspicious order like order in illiquid scrip, order of large quantity, etc.

ensure to pass on the information to Risk /Compliance.

Ensure that Dealers do-not do own trading at any time or in any manner which may

have adverse effect on our customers.

NRI clients should not be allowed to trade in restricted securities.

NRI clients should not be allowed to do intra-day trading.

None of the branch staff engage in portfolio management services.

Only authorized sites to be used.

4.4 Dealer Certification

As insisted by regulatory, this has made mandatory that all Dealers should be qualified the

below regulatory certifications and the same to be renewed up on expiry. The HR

department will send a consolidated list of certifications nearing the expiry (i.e. , the expiry

date with in the succeeding 2 months) on a monthly basis to branches / sub-brokers better


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traction. In case the renewal details with the copy of certificate not received at the

Compliance Department up on expiry of certificate such terminals / segments would be

suspended one day prior to the expiry date without any further notice.

NSE Cash Segment : NCFM - Capital Market (Dealers) Module (CMDM)NSE F&O Segment : NCFM - Derivatives Market (Dealers) Module (DMDM)

BSE Cash Segment : BSE Certification in Securities Markets (BCSM)

BSE F&O Segment : BSE Certification in Derivatives Exchange

NSE/ BSE CD Segment : NISM-Series-I: Currency Derivatives Certification Examination

Please refer http://www.nism.ac.in/ or http://nseindia.com/ or http://bseindia.com/ for

more details on the above certifications

4.5 Order Execution- Dos and Do-Nots for Branch Managers and Dealers

Branch Managers to ensure that all orders executed should be confirmed by the

client or his duly authorised representative.

Ensure that all order are executed through Audio Visual Recorder (AVR).

Ensure that all order are routed through the Exchange approved trading system.

All front running/ Dabba Trading/ unauthorised/ unconfirmed dealing are strictly

prohibited.

Ensure that only designated Dealers deal with Client order instructions / market

inquiries.

Ensure that upon execution of trade, the client is confirmed of the same through JRGAVR system.

Dealer has to ensure adequate margin/ clear holdings before execution of orders.

If the client authenticity/ margin / clear holdings is doubtful, then enhanced due

diligence must be done before execution of orders.

Dealers must know that as regulated by SEBI / Exchanges GTC (Good Till Cancelled),

GTD (Good Till Date) are strictly prohibited and not allowed. Trade Confirmation &

Contract Notes.

The Dealers to ensure that EOD Trade confirmation calls should be recorded in a

register maintained for the purpose.

It is to be ensured that trade confirmation should be given to the ultimate clients

only and if the client is not available on call then the same can be given to the POA

/LOA holder.

Branch Manager has to verify the confirmation call once in a fortnight with the Back-

office data minimum for 10 cases and ensure that wrong/ partial confirmations/

misrepresentations of facts are not occurring.


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If client disagree with the trades/ highlights some discrepancy, the same should be

brought to the notice of the Branch Manager and above authorities with

immediately, for further review and resolutions

4.6 Password Policy

Please don't share your password with anyone. Maintain complete secrecy.

Ensure Dealers use their designated user ID.

Ensure Dealers do not share their ID with anyone else.

Ensure to change password of trading terminal at periodic intervals not later than 14

days.

Lock your computer when your are away from your desk.

Compliance of password policy is responsibility of Dealer/ Branch Manager.

4.7 Unverified Market Information/News

All employees especially Dealers not to encourage or circulate rumours or market

information without verification.

Access to Blogs/ Chat forums/ Messenger sites etc. should not be allowed.

Any market related news received should be discussed/ forwarded to clients only

after the same has been seen and approved by the Compliance Officer.

4.8 Cash Dealings Strictly Not Allowed:

Ensure no cash dealing with clients takes place.

Ensure dealings with clients should only be through cheque, draft, pay order, RTGS

and other means as allowed from time to time. Ensure that petty cash is stored in a Safe box in the Branch.

Branch Managers to ensure that petty cash expenses are incurred with proper

approval.

Ensure to send statement of cash expenses if any to HO Accounts on weekly basis.

4.9 Dos & Donts

i. Dealing terminals to be only provided to and operated by those Dealers who are

NCFM certified and under whose name it is registered with the regulators

ii. Terminals should be used only by authorized persons. Under any circumstances,client / third party (i.e., any person other than the person on whose behalf the

terminal is issued) shall not be allowed to operate the terminals.

iii. Terminals should be locked while dealer step away from his/her desk.

iv. In case employees resigned, their terminal ids should be de-activated 1 day prior to

the last working day (LWD)

v. Dealers shall not accept orders from client over non-voice recorded lines and mobile

phones should not be carried to the dealing area


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vi. Dealers not to engage in any trade on behalf of a client without proper prior

instructions received from the client or his / her/its authorised representative

/attorney by POA /LOA

vii. Dealers not to exercise any discretionary authority with respect to any transaction in

a Clients' account.

viii. Dealers not to guarantee against losses by clients in any transaction or agree to

provide any reimbursement of losses or brokerage.

ix. No promises of any sort can be made (stock will definitely perform or equivalent)

x. Dealers shall exercise caution while placing trades in low volume and illiquid

securities.

xi. If the trade / order appear suspicious the Dealer shall not place such trades and shall

bring this to the notice of the Branch Manager / Compliance

xii. Dealers shall be cautious about trades at prices substantially away from the last

closing price/ prevailing touch line prices

xiii. Dealers shall exercise due care and caution when options trades are entered into the

system at prices, which vary considerably than the present intrinsic value at the

given point

xiv. Dealers are advised to monitor dealings of clients closely with respect to correlation

of clients trading activity with their past trading record, including large

concentration in one or few securities, etc.

xv. Dealers not to indulge in trading/arrange trading for Clients outside of the trading

system of the stock exchange (Dabba Trading)

xvi. Employees/Dealers not to accept cash or cash equivalents from Clients, towards

settlement obligations / reward(s) for performance.

xvii. Dealers should not deal or transact business knowingly, directly or indirectly or

execute an order for a client who has failed to carry out his commitments with any

market intermediaries

xviii. Dealers shall not give a view which is contrary to the house view on any security.

xix. Dealers shall not furnish false or misleading quotations or give any other false or

misleading advice or information to the clients with a view of inducing him/her/it to

do business in particular securities and enabling him/herself to earn brokerage

thereby.

xx. Dealers to give recommendations keeping in mind the clients needs and

requirements and should not be driven with the sole objective of generating

revenue.

xxi. Dealers shall not discuss any unverified/unauthenticated market information/ news/

rumours with the clients.

xxii. Dealers shall maintain confidentiality of all data / information of the client.

xxiii. All client codes should be mapped to all terminals within the branch so that in theabsence of a dealer the orders / trades can be executed from other dealers

terminal.


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5 Pay in /Pay out of Funds /Securities

5.1 Funds Pay-in

It is one of the primary duties of the Dealer to inform the pay in responsibilities of the clientand ensure adequate margin/ funds for settlement of obligation on or before T+2 day. This

has to be intimated to the client through voice recorded lines and audit trail should be

maintained as proof of pay in intimation. Branch Manager has to ensure the compliance of

the same.

Branch Manager to ensure that clients pay/ remit their margin/ pay-in obligations by

cheques.

The cheques should be drawn in the name ofM/s JRG Securities Ltd.

Alternately clients can make electronic fund transfer (RTGS/NEFT).

The branch back office to verify the correctness & completeness of all the cheques

received.

In case of any discrepancy (in terms of amount, signature, date, corrections on the

cheque etc), it has to be returned immediately to the client and fresh instrument

received.

Cheques can be accepted only from the designated bank.

Under no circumstances third party cheques to be accepted.

In case client submits the cheque from bank which is not registered with us, ensure

to obtain proof of bank account like Latest Bank statement (not older than 2 months

from the date of submission), Bank Passbook Copy (with latest transaction page),Personalised Cancelled Cheque etc.

Ensure to get the bank account registered with us before submitting Pay in/Margin

Cheques from such accounts.

Branch Manager has to ensure that such cheques are banked/ accounted only after

the mapping of new bank account in the client master.

Under exceptional situations Demand Draft also can be accepted against pay in

obligations.

The B M to obtain the letter from banker stating the details of account from which

the DD is drawn, and submit the same to HO Accounts with a copy of the DD.

BM to not to accept DDs without having such authorisation letter even though the

DD is personalised.

BM to ensure all cheques/ DDs received before banking hours should be banked on

the same day, and received after banking hours on the next day.

Branch has to maintain a Pay in Register to monitor the inward/ outward of

cheques/DDs.


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Acceptance of post dated / blank cheques from clients are strictly not allowed.

In case if branch holds such cheques, necessary approvals from Risk and F&A should

be obtained and the same to be recorded in the Pay in register.

5.2 Funds Pay-out

Funds Payout is processed as

1. Request based pay out,

2. Auto Payout,

3. Monthly /Quarterly Settlement of Funds

5.3 Request Based Payout

Request based payout will be processed for clients who have opted for monthly/ quarterly

settlement of funds through Running Account Authorisation Letter. The branch will send

the request to HO Finance. F&A team to verify the payout requests with the books and ifclear balance available for the requested amount or more the cheques / fund transfer will

be executed for the requested amount. Else the payout will be issued only up to the clear

amount available in the books. Branches have to communicate this to the client while

accepting pay out requests in order to add more clarity in pay out processing and to avoid

further grievances.

The Branch Manager/ Dealer/ F&O should comply with the followings:

Pay out requests should be accepted in writing/ over voice recorded lines.

In case the payout request is received through unrecorded lines, the Dealer/Back

office personnel have to reconfirm the same through recorded lines. All the payout requests received at branches should be forwarded to HO F&A team.

Such requests should be in the prescribed format.

The request should be sent before the cut off time.

If any pay out request received after the payout processing cut off time and can be

processed only on the next day.

In case payout cannot be made same day due to delay, the same should be

communicated to the client through recorded lines.

Do inform to the client that in case the clear fund balance is less than the amount

sought, lesser would be released.

5.4 Auto PayoutAuto payout will be processed for clients not opted for Running Account maintenance. I.e.,

clients not opted for the RAAL , the clear outstanding balance in the statement of funds will

be issued to the client on T+2 day afternoon by way of cheque /electronic transfer. Under

no circumstances, the funds will not hold beyond T+2 for such clients

5.5 Monthly /Quarterly Settlement of Funds


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The monthly / quarterly settlement / flush out of funds will be processed for the clients who

have opted for Running Account maintenance as per the flush out option chosen by the

client through RAAL. This flush out will be processed immediately succeeding calendar day

from the closure of the Month/ Quarter.

5.6 Securities Pay-in

It is the duty of the Dealers and Branch Managers to ensure smooth pay-in of securities. Ut

is the duty of Branch Back office personnel to provide adequate updates or information to

the Dealers on pay in obligations for better traction. Branch Dealer/back office support have

to continuously liaise with the HO Settlement Team, Dealers and track the back office

updates for successful settlement of obligations without any gaps which may leads to

auction/ penalties/ client grievances etc

Dealers/ BMs have to ensure the followings:

The Dealers/ BM to inform the client on Securities Pay in obligation.

To ensure the obligations are settled on or before the cut off time on T+2 day.

The pay in of securities can be accepted only from the designated Demat account of

the client.

Any third party transfer will be reversed on immediate basis and will not be

considered for settlement of obligations.

The clients can execute the securities pay in either by Delivery Instruction Slips (DIS)

or by electronic transfer.

Ensure to have a continuous liaison with HO in order to avoid settlement failures.

5.7 Securities Pay-out

Like the pay out of funds, the securities pay out also will be processed under three methods,

i.e. Request based pay out, Auto Payout, Monthly /Quarterly Settlement of Securities.

5.8 Request Based Payout

Request based payout will be processed for clients who have opted for monthly/ quarterly

settlement of funds through Running Account Authorisation Letter. Settlement team will

verify the securities payout requests with the books and if clear balance of securities

available for the requested quantity, or else lesser of the two will be released. Dealers/

Branch Managers to ensure to comply to the followings:

Ensure to send the request for payout for clients who have opted for monthly/

quarterly settlement of Securities.

Ensure that they have submitted Running Account Authorisation Letter.


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Pay out requests should be accepted in writing/ over voice recorded lines.

All the payout request received at branches should be forwarded to HO Settlement

team for processing.

In case the payout request received through unrecorded lines reconfirm the same

through recorded lines. Ensure that request is in the prescribed format.

Ensure that request is sent before the cut off time.

If any pay out request received after the payout processing cut off time and can be

processed only on the next day.

Ensure to communicate the same to the client through recorded lines.

Ensure that client has the clear balance of securities in the credit of clients.

In case there is no clear balance or insufficient balance, only the lesser would be

released.

BMs to ensure to communicate the same to the clients in order to avoid grievances.

5.9 Auto Payout

Auto payout will be processed for clients not opted for Running Account maintenance. I.e.,

clients not opted for the RAAL , the clear outstanding balance in the statement of securities

will be issued to the client on T+2 day. Under no circumstances, the securities will not be

held beyond T+2 day for such clients

5.10 Monthly /Quarterly Settlement of Funds

The monthly / quarterly settlement / flush out of securities will be processed for the clients

who have opted for Running Account maintenance as per the flush out option chosen by the

client through RAAL. This flush out will be processed immediately succeeding calendar day

from the closure of the Month/ Quarter.

5.11 Process to change the default DP or Bank Account Details

TAT for processing the request for Change / Adding DP or Bank account will be 12

hours from the time of receipt of such request at CAMS.

Ensure Pay in/ Pay out of funds & securities is done only from/to the designated

Bank/ Depository Account which is registered with JRG.

For convenient and smooth operations, Clients can register multiple Bank/

Depository accounts with JRG.

For registering new bank account in client master, client has to submit following:

o Written request for same.

o Proof of bank account,

o Latest Bank statement(not older than 2 months from the date of submission),

o Bank Passbook Copy (with latest transaction page),

o Personalised Cancelled Cheque etc.


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Ensure that request form and the proof of bank account must be signed/ self

attested by the client.

Ensure that Branch official verify all the documents with original.

Ensure that Branch official after verification affix stamp, Verified with Original and

puts his name and designation, employee code and date when verified.

Follow similar procedure for registering/ changing demat account, but obtain the

following documents:

o Written request for same.

o Proof of active demat account,

o Latest holding statement from DP (not older than 2 months from the date of

submission),

o Bank Passbook Copy (with latest transaction page),

o Original / copy of the DIS (Delivery Instruction Slips)


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6. Risk Mgt and Monitoring of Receivables

6.1 Suspicious Transactions

Followings can be termed as Suspicious transaction whether or not made in cash which, toa person acting in good faith-

i. Gives rise to a reasonable ground of suspicion that it may involve the proceeds of

crime; or

ii. Appears to be made in circumstances of unusual or unjustified complexity ; or

iii. Appears to have no economic rationale or bona fide purpose;

iv. Gives rise to a reasonable ground of suspicion that it may involve financing of the

activities relating to terrorism.

The requirement of client identification is not limited to account opening, but also includesexecution of transactions and there by implying that this is a continuous process. Any

suspicion transaction needs to be notified immediately to the Compliance 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. Branches can use the suspicious

transaction reporting file format given in the manual for reporting. Also see Annexure

6.2 Grounds of Suspicion

Opening of account with forged documents,

Transaction in Dormant DP/trading account, Transaction in Penny stocks,

Bulk deal in shares of an illiquid scrip by clients having common introducer,

Trades of significant volumes as a percentage of exchange Turnover,

Transaction at abnormal price in Futures/options,

Payment of substantial amount in trading a/c by DD,

Synchronised trades,

Transaction in excess of clients profile,

Special attention required to all complex and unusual large transaction,

Unusual transaction by Clients of Special Category (CSCs),

Clients whose identify verification seems difficult of client appears to be not

co-operating,

Substantial increase in business without apparent cause,

Doubt over the real beneficiary of the account,

Accounts opened with names very close to other established business entities

Suspicious background or link with known criminals,


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Large number of accounts having a common account holder, introducer or

authorised signatory with no rationale,

Use of different account by client alternatively,

Nature of transaction reflect likely market manipulations,

Suspicious Off market transactions,

Inconsistency in the payment pattern by the client,

Value just under reporting threshold amount in an apparent attempt to avoid

reporting,

Nature of transactions reflect likely market manipulations,

Investment proceeds transferred to a third party,

6.3 Trade Modifications

Error Trades are trades which have to be taken to the books of the company due to errors

on the part of the organization in execution of orders given by the client or in settlement ofobligation of client/ operational errors.

Client facilitation Trades are trades which have been taken to the books in keeping in

mind the business that the client brings to the organization or is capable of bringing to the

organization.

Followings are the most commonly occurring dealing errors are:

i. Quantity Mismatch,

ii. Error on buy/sell and vice versa,

iii. Wrong Punching of Price / Scrip / Strike price/ Premium / Contract,

iv. Error on T to T stocks

All the above cases are grave in nature and happen out of dealers carelessness and

negligence. As per the industry practice, for such cases Dealers try convincing the clients to

accept the executed trade (depending the relationship the dealer shares with the client). At

JRG we do not follow the same industry practice and discourage the Dealers/ Branch

Managers to convince the clients to own such trades.

The Dealers/ Branch Managers to follow the following guidelines for such trades:

a) All Errors have to be squared on the same day, maximum next day.

b) All error trades duly approved by Branch Manager have to be intimated to the TradeProcessing team with client code change request.

c) Trade processing team has to obtain RMS approval before forwarding the requests

to exchange in order to ensure control over price/ scrip manipulation

d) In addition if Loss is more than Rs. 2500/- CMP and F&A approval also to be

obtained.

e) For losses more than Rs. 10,000/- would be intimated by trade processing team to

the management and COO/CEO/MD sign off should be obtained.


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f) Intimations to be compulsorily done by 4 p.m. This is important since the changes

sought have to be informed to the Exchange.

6.4 Debit Call to Clients

Dealers/ Branch Managers to follow the following procedures in case there is debit in the

account of the clients:

i. All clients who have margin/ pay in shortages in account should be intimated by

the Dealers/ BMs from T+1 day onwards.

ii. Dealers/ BMs to ensure collection of dues on T+2 day before the cut off time.

iii. Ensure to intimate branch back office personnel has to intimate the net balance

in Statement of Funds (Ledger) to the clients, during trade confirmation call and

request the client to settle the same on time.

iv. Ensure that client has been informed about the RMS liquidation policy and the

delayed payment charges applicable, if in case the delayed/ failure obligation.

v. Ensure that all debit calls are done through Voice Recorded lines.

vi. Apart from above ensure to maintain must for audit trail and future references in

case of dispute, if any.

6.5 Intimation on shortage of Securities

i. Dealers/ BMs to adhere to the similar procedure as laid down in Debit calls to

clients as given in the above clause.

ii. In case of Pay out shortage of securities, the same to be communicated to

the clients and Dealers has to ensure that adequate holdings are in the client

account before executing any sell orders


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7. Depository Services

JRG has the membership of both the Depository participant i.e. NSDL (National Securities

Depository Ltd) and CDSL (Central Depository Services Ltd). We offer a wide array of

depository services to our clients through network of our Branches/ Authorized Persons (DPService Centre / DP Drop Box Centre)

7.1 DP Service Centre

Depository Service Centres are the centres where the client can avail all the Depository

Services like Dematerialisation/ Rematerialisation/ Pledge/ Hypothecation/Account Opening

etc. Through DP Service centres clients can submit their queries and can get the

acknowledgement of submission/ execution of ____. In order to ensure better control over

the services offered by JRG network, all our DP Service Centres are functioning as a

collection centre where the client can submit their requisitions and can have theacknowledgement from the service centre official. The execution of requests received at

Service Centres will be processed centrally at Registered Office. Normal time taken for

document transition between Service centres & HO and the TAT for execution of the

requests must be communicated to the client

As a regulatory requirement the Service centre official should have the NISMDepository

Operations Module Certification/ NSDL Depository Operations Module Certification/ BSE

Certification of Central Depository as the case may be and must be subsisting at all times.

The copy of NSDL/ CDSL Registration Certificate, DP Dos and Donts, List of Holidays and the

List of Services offered must be displayed at a prominent place in a permanent manner at

all Service Centres.

The HO depository division has to maintain the database of Depository Service Centres

along with the contact person and Service Centre official details and any changes w. r. t the

same must be intimated to CDSL/ NSDL as the case may be. The opening and closure of

Service centres also done with prior approval from respective Depository and must be

intimated to clients 30 days in advance

7.2 DP Drop Box Centre

Depository Drop Box centres are the counters where the client can drop their requests in

the Box installed for the purpose and can get them executed at the respective DP Service

Centres or Central Depository (HO) Division. In this case since the clients are dropping the

requests in the box, they wont get any acknowledgements for the same. The box must be

fire/ tamper proof and the same should be cleared at fixed timing on all working days. The


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time of clearing the Box, List of Holidays, DP Dos and Donts must be displayed at all drop

box centres.

7.3 DP Account Opening

Clients can avail the DP account opening forms from all DP Service Centres / Drop Box

centres and can submit / drop the same at respective Service Centre / Drop Box Centre. The

process to be followed for DP account opening will be the same as the process described

under section 3.3.1

7.4 Acceptance of DIS at DP Service Centres

Clients can submit the DIS at DP Service Centres or can drop the DIS at DP Drop Box centres,

provided the same will be forwarded and processed at HO DP Division. Service Centre has to

affix the Receipt/ Time Stamp and Late Stamp (where ever applicable) before forwardingthe DIS to HO for processing. The acknowledgement of the DIS should be given to the client

with/ Time Stamp and Late Stamp (where ever applicable).

In case DIS dropped at Drop Box centres, the same should be cleared and send to HO for

processing. As advised by regulators, acknowledgements will not be issued to the

documents dropped at Drop Box Centres. However the normal time taken for document

transition should be communicated to the client by way of display of the same at Drop Box

Centres

DP Service Centre/ Drop Box has to maintain an Inward /Outward Register of the documentsand the movement of documents must be recorded on the same

7.5 Acceptance of DRF/ RRF/FRF/URF/TRF/PRF etc

DRF/ RRF/FRF/URF/TRF/PRF received at DP Service Centres must be recorded in the Inward/

Outward Register and should be send to HO DP Division for processing post initial scrutiny of

the documents at Service Centre level. Service Centre should ensure the acknowledgement

of receipt of documents to the client.

DRF/ RRF/FRF/URF/TRF/PRF dropped in the Drop Box must be recorded in the Inward/

Outward Register and should be send to HO DP Division for processing

7.6 Changes in info w. r. t. DP Service Centre / Drop box centre

The HO depository division has to maintain the database of Depository Service Centres

along with the contact person and Service Centre official details and any changes w.r.t the

same must be intimated to CDSL / NSDL as the case may be. The opening and closure of


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Service centres also done with prior approval from respective Depository and must be

intimated to clients 30 days in advance

8. Investor Grievances

8.1 Client Queries & Complaints

Grievances/ Client complaints are handled by the combined efforts of the concerned

Branch, Compliance and Legal team at HO. All complaints received at branch level has to be

uploaded to the Compliance team in the prescribed format along with initial remakes by the

Branch Manager. Clients can also record their complaints in the Investor Grievance Register

which is placed at an easily accessible location at the branch. While the branch may be able

to take corrective action, resolve the issues and pacify the client, the branch manager must

ensure that details of the complaint including the date when it was raised, the issue that

was raised by the client and the resolution offered are recorded in the Investor Grievance

Register and reported to the Compliance department by an email. If the complaint is serious

in nature or not resolved at the branch end, the same is immediately highlighted to the

Compliance Department. TAT for resolution at branch level is 3 working days.

The TAT for resolution of Investor Grievance at Compliance level is 15 working days. The

company has created an Investor Grievance Cell (IGC) along with the dedicated mail id

for the same within the organization located at HO. Only one department i.e. Compliance

department Head is made responsible for all the issues with the Investors Grievances. In

case Compliance Department is not able to resolve within 15 working days, highlight the

same to Legal Department.

8.2 Responsibilities of Branch Manager

The Branch Manager responsibilities with regards to Investors complaints are given

hereunder:

Ensure that each branch/ authorized person of JRG maintains Investor Grievance

Register in the prescribed format. The same must be maintained in perpetuity.

Confirm the maintenance of the register in monthly MIS to Head Compliance.

The register should be placed at easily accessible place in the premises.

Ensure to enter the complaint in the Investor Grievance Register without any delay

when Client approached branches to lodge a complaint.

As soon as a complaint is received at IGC, the same shall be allotted unique id.

All complaints received at branch in any medium (letter, oral, Telephonic etc) must

be recorded in the Investor Grievance Register.

Clients can directly lodge the complaint to HO/ IGC. In that case, a formal

communication would be made by HO to concerned branch.

All the complaints received against the company by whom so ever, would have to

be reported to the compliance department.


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The Compliance Head will only take up the matter with the concerned official of

Corporate Office/ Registered Office/ TM/ Branch etc for collection of the required

information for effective resolution of the complaints.

Ensure to send the complaint through mail to CMP team. In case of written

complaint, scan the document and send to Compliance department.

Ensure to mark a copy of the mail at the dedicated mail id.>>>>>>> .

Branches are required follow-up their complaints that are awaiting resolution

beyond TAT, even of these are pending with Compliance/ Legal Department.

Once the complaint is looked after by Legal Department, no other department/

branch/ AP would communicate with the client.

8.3 Responsibilities of the Compliance Department:

To ensure that each branch maintains the IG register in the prescribed format. Seek

confirmation of the same from each branch.

Maintain similar IG register at HO for recording and processing of the complaints. Enter the complaint with log id in case the complaint id directly lodged at HO.

Ensure that all the complaints received against the company by whom so ever,

have been reported to the compliance department.

It is duty of Compliance Head to take a call based upon predefined criterion when

to treat the complaint as closed.

In case of false and frivolous complaints, the compliance Head would place a note

for initiating of legal case against the client, if warranted.

Once the complaint is closed or referred to Legal Department, record the same in

the IG register.

TAT for the resolution of each complaint is maximum 15 days, unless the same is

forwarded to Legal department.

In case Compliance Department is not able to resolve within 15 working days,

highlight the same to Legal Department.


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9. Audio Visual Recorder (AVR)

9.1 Requirements of AVR

The AVR should be in place at all dealing Branches and all dealing room/ area lines must beconnected to the AVR. Unrecorded telephone lines or mobile phones are strictly prohibited

at the dealing area. All Dealing room/ Area conversations must be routed through the AVR

connected telephone lines. The AVR must be in good condition at all times and is there any

malfunctioning issues noticed, the same must be highlighted to the IT and resolved with

immediate effect. It is the duty of Branch Manager to ensure full compliance of the AVR

system in the week. Territory Manager/ State Head should satisfy the compliance of the

followings:

9.2 Responsibilities of Branch Manager

The Branch Manager has to comply the following guidelines with respect to AVR system:

All orders to be taken thru recorded lines only. It is must.

Proper VRS records to be maintained at all the times.

Ensure that all the communications with the clients should be done through the

Voice Recording System of JRG.

Such communications could be introductory Call to the new clients, Debit Call, EOD

Confirmation Calls , Shortages (Securities/ Margin)

Voice Recording Apparatus is checked on daily basis five times a day, (i.e. before and

after market hours and 3 times during the market hours)

Branch has to test quality of service at least once a day so as to confirm the

recording is audible and all calls are recorded.

BMs to confirm the incoming and outgoing numbers are captured in the system with

time stamp and the date and time of the system is similar to the Market timing.

BMs to ensure that the same is recorded in the register so as to confirm the health

check of the system at least once a week.

BMs to ensure that date and time, record verified and the observations, if any, along

with the signature of the verifying official must be captured on the register.

Branch Manager has to verify at least 20 AVR call logs once in a fortnight in order to

ensure Dealing/ Sales Quality.

BMs to ensure that in case any malfunctioning noticed, the same must be recorded

in the register and information sent to the IT.

In case AVR is not working at any particular point of time, the BMs to seek approval

from Head Compliance w .r. t to alternate mode of communication.

The BMs to ensure that the alternate mode of confirmation is recorded in the

register along with specific approval obtained, if any.


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BMs to confirm the same to HO in weekly MIS w. r. t. health check of the system and

recording of the same in register maintained for that purpose.

Branch Manager verifies the Voice recordings with actual orders placed at least once

a week and report to HO.

Ensure to upload the AVR back up data to HO IT Team on a daily basis as advised.

9.3 Responsibility of IT Department

In case of any requirement of AVR Call logs for regulatory or IG resolution, IT should

arrange the data within a TAT of T+1

of IT Dept, being the custodian of AVR data, has to ensure proper segregation and

control over the AVR call logs.

All the logs should be maintained on Daily basis in such a way so as to make

accessible within 30 minutes of demand.

In case of any down time, the IT has to provide the monthly AVR down time report toHead Compliance.


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10. Legal and Administration:

10.1 Displays and Notice Boards:

The Branch Manager has to ensure that required displays and Notice Boards and displayedat all the times. BM has also to ensure that such displays are correct and as per the

prescribed formats. In order to ensure correct displays, it becomes the duty of BM to

continuously interact with HO compliance.

Shop and Establishment Certificates,

Copy of extract of Minimum Wages Act,

Extract of Payment of Gratuity Act,

Extract of Maternity Act,

Copies of SEBI Registration Certificates,

Notice Board as prescribed by Compliance, DOs and DO NOTs Board as prescribed by Compliance.

10.2 Office Management at Branches

It is the responsibility of the Branch Manager to ensure to keep the safe custody of the

branch assets including furniture & fixture, stationary etc. BM has to ensure that all the

assets of the branch are functioning as per the prescribed requirements. The Branch

Manager has to ensure the compliance of the followings:

I.

All equipments like UPS, VSATs and their IDU units, generators are checked on

daily basis to ensure proper functioning.

II. BMs to ensure that all the assets are under requisite Insurance/ and or AMC.

III. Inventory Register for the stock held being maintained and physical verification

of stock is made every week.

IV. Whether Expiry of stamp paper held as part of inventory Stock is being

monitored, if maintained.

V. BM to maintain inventory Register in the prescribed format.

VI. BM to ensure recording of all the inward/ outward inventory in the register.

VII. BM to maintain the Fixed Assets Register in the prescribed format.

VIII. BM to ensure recording all the assets in the register.IX. BM to send MIS for the inventory and Fixed Assets Register to HO Finance at the

requisite intervals.


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10.3 Branch Expenses Management

For meeting the day to day expenses of the branch, Branch Manager has to ensure that

adequate petty cash is available with the branch. The Petty cash should be managed by the

Branch Manager/ his designated subordinate and a register Petty Cash Register as advisedby Finance & Accounts should be maintained with the branch with up to date information.

The Branch Manager is required to ensure the compliance of the followings:

Petty Cash is stored in a Safe box in the Branch.

Petty Cash expenses are incurred with proper approval,

Statement of petty cash expenses is sent to HO Accounts on weekly basis.

All the expenses to be settled as per guidelines issued by the Corporate Office.

Copy of Petty Cash Register to be submitted to HO F&A team on the prescribed

intervals as advised for reconciliation and to ensure control over expenses. Any petty income should not be used by the branch. The same has to be deposited

to the JRG designated bank account.


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11. References and Abbreviations

11.1 References

1. Internal Code of Conduct policy by HR version No.12. Risk & Surveillance Policy

3. KYC Manual version 1.0 by Operation Department

11.2 Abbreviations

1. JRG JRG Securities Ltd

2. MOM Management and Operations Manual

3. KYC Client Registration Form

4. NEAT National Exchange for Automated Trading

5. BOLT BSE Online Trading

6. CAMS Client Account Management System7. RMS Risk Management and Surveillance

8. TAT Turn Around Time

9. BCP Business Continuity Plan

10.UCC Unique Client Code

11.NCFM NSEs Certification in Financial Markets

12.BCSM BSE Certification in Securities Market

13.BCDE BSE certification in Derivatives Exchange

14.CMP Compliance

15.HRD Human Resources Department

16.F&A Finance & Accounts

17.ORIC Operations Risk and Internal Controls18.AVR Audio Visual Recorder

19.NISM National Institute for Securities Market

20.BCCD BSE Certification on Central Depository

21.DP Depository Participant

22.DRF Dematerialization Request Form

23.RRF Rematerialisation Request Form

24.FRF Freeze Request Form

25.URF Unfreeze Request Form

26.TRF Transfer Request Form

27.PRF Pledge Request Form28.FAR Fixed Asset Register


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12. Annexures

12.1 Branch Monthly Check- List

To be filled in by the Branch Manager and sent to Compliance on the last

working day of every month.

S N Particulars Yes/No/NA

A. Display of Notice Board and registration Certificates.

i. Is the Notice Board as per format approved by Compliance?

ii. Is the Notice Board displayed at a prominent place?

iii. Is the Notice Board correct and updated? When did you last check

with Compliance Dept?

Y/N,

dd/mm/yyyyiv. Are all specified rules prominently displayed - Shop & Establishment

Act, extract of Minimum Wages Act, extract of Labour Act, Gratuity

Act, Maternity Benefit Act?

v. Are valid copies of all registration certificates displayed?

B. Voice Recording System (VRS)

i. Are all the order taken through recorded lines only?

ii. Have you checked daily that VRS has adequate hard disk capacity?

iii. Have you ensured that VRS is recording all conversations?

iv. Have you verified voice recording with actual orders placed (every

dealer, 10% of clients, once every week) - and reported deviations to

Compliance.

v. Are there any deviations in the last month?

vi. Is a back-up of VRS on the PC verified

vii. Has the VRS file been uploaded regularly to Tech? On which days

was it NOT uploaded and why?

C. Dealing Room Instructions

i. Have proper checks been made so to prohibit the entry of

unauthorized persons in the dealing room/ vicinity.

ii. Have proper systems been made so as to prohibit unrealistic/

unjustified orders.

iii. Are dealers educated about this at regular intervals.


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iv. Have proper steps been initiated to discourage communication of price

sensitive information.

v. Are proper systems in place to prohibit JRG staff dealing with the

clients on personal basis.

vi. Have our staff not made any assured returns to clients.

vii. Have you ensured that dealers do not give any stock specific advice of

their own to the clients?

viii. Have proper checks in place to prohibit synchronized trades with other

persons.

ix. Have you made systems so as not to hide losses made, if any?

x. Whether all the order details entered in Order book/ deal sheet

maintained at the branches.

xi. Have you ensured that all the clients codes are mapped to all the

terminals?

xii. Whether orders for walk-in-clients are filled in Order Request Forms.

xiii. Do you ensure that at no point of time dealers do trading outside the

system (Dabba Trading).

xiv. Whether visitor register is maintained and all the records maintained

on daily basis.

xv. Whether you ensured that no trade happens with other members of

the Exchange.

xvi. If such trade has happened, have you informed Compliance Dept.?

D. Restriction on use of Mobile Phones

I. Are you and your staff aware that mobiles phones are strictly not

allowed in dealing room/or near trading terminal?

II. Do you take custody of mobile phones from dealers before start of

trading every day?

III. Do you ensure that all the calls at mobile phones of the dealers are

forwarded to Land line phones before start of the trading day?

IV. Do you ensure that all the trade confirmations are done same day

through the recorded lines and not on mobile phones?

E. As a branch manager, you are required to pay special attention to the tradingpattern of some special category of clients such as NRI, HNI, Trust, charities,NGOs, Politically exposed persons, high profile and well connected persons,non face to face clients to whom you have not met and the clients with dubiousreputation as per the public information available etc.

i. Are the above said clients mentioned above are on your watch list?

ii. Do you keep extra vigil on the trading pattern of above said clients?


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iii. Do you meet the trueness at least once a month in order to verify the

genuineness of the authority?

iv. Have you observed some changes in the trading pattern as compared

to previous month?

v. Have you reported to HO, such activity, if you have observed any

unusual activity?

F. Know Your Client (KYC) is an important document to avoid regulatory andoperational risk, to help you understand what the law and regulations require ofyou, to help you keep down criminals out of your business, to be confident ofthe fact that you know your customer base, to be able to identify high riskcustomers as you take them on, to make sure that you deal with the authorizedand right clients, and above to help your business continuously growing.

i. Whether the accounts opened during the month are as per the

approved company policy.

ii. Whether as a branch manager, you have checked each and everyform including the detailed contents therein.

iii. Have you ensured with the Compliance Dept that your branch is using

the latest KYC form?

iv. Have you ensured that in the account opening form each and every

column is filled in and nothing is left blank?

v. Whether all the documents as required such as Id proof, address

proof, demat account, recent photo, PAN copy obtained.

vi. Whether the documents obtained from the clients have been checked

with original.

vii. Whether the staff who checked with the original documents put his

signature, employee code, with time and date stamp?viii. Whether the staff who verified the documents stamped the documents

with Verified with Originalstamp.

ix. Have you ensured that as address proof only any of the mentioned

documents e.g. ration card, passport, voter ID card, driving license,

bank passbook, bank statement has been obtained?

x. Have you ensured that none of the KYC documents is received in

branch through FAX?

xi. Whether the PAN copy submitted by the clients is verified from the

Income Tax site.

xii. Whether the client has been explained about the mandatory and non

mandatory clauses in the document.

xiii. Whether it is recorded on the documents who in JRG explained the

above to client?

xiv. Whether the email and cell phone number of the clients are

maintained and updated at regular intervals i.e. at least one in three

months.


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xv. Please confirm no email for the client has been created by the JRG

staff. It is must No

xvi. Do you ensure that written request is received from the client in case

of change of any of particulars in KYC etc.

xvii. Do you ensure that the email id and cell phone provided by the clientsare correct and cross verified?

G. In Person Verification. It is must in order to debar benami and unauthorizedand debarred clients in JRG.

I. Do you insist on In Person Verification of the client?

II. Whether in person verification (IPV) of all the clients introduced during

the month has been done by JRG staff.

III. Whether the branch officials who met the client in person, and

recorded, when and where he met the client. It is Must.

IV. Whether the documents submitted by the client are signed, in the

presence of staff, and in whose presence?

V. Whether before accepting any client, proper checks have been made

so as not to entertain SEBI debarred entities.

H. Due Diligence ExerciseSpecial attention to unusual trades and immediatelyreport to HO if you notice.

i. Do you conduct due diligence for the clients if their trades are more

than Rs 5 lacs in equity segment and Rs. 25 lacs in Derivative

segment on any particular day?

ii. If you have observed any unusual activity on same above, have youreported the same to HO?

iii. Do you ensure that financials of all the clients having average daily

delivery position of over Rs. 10. Lacs in equity segment/ and turnover

of Rs. 50 lacs in derivative segment are required to be validated.

iv. If you have observed any unusual activity on same above, have you

reported the same to HO?

v. Whether CA certificate for net worth/ Annual Reports of the clients

have been obtained every six months.

vi. Whether these certificates have been submitted to HO.

vii. Do you ensure that all the unusual trades in illiquid scrips, order of

large quantities etc are reported to HO on routine basis?

viii. Do you monitor if a client has traded more than 25 scrips in a single

day?You must report to HO.

ix. Do you ensure that dealers do not indulge in their own trades that may

have adverse impact on our customers?

x. Do you ensure that NRI clients are not allowed to do intra-day trading?


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xi. Do you ensure that the staff under you and you yourself do not engage

in portfolio management services for any of the client?

I. Terminals/ NCFM Qualification and usage Policy

i. Do you maintain a record of certifications of the dealers and record ofexpiry?

ii. Whether all the NCFM Certificates kept in branches.

iii. Whether the NCFM Certificates are valid and not expired.

iv. Have you ensured that the terminals are operated by the authorized

persons only? No swapping is allowed.

v. Have you ensured that the dealers who operate the terminals are

NCFM certified?

vi. Have you made adequate steps that clients do not have the access to

the trading terminals.

vii. Have you ensured that all the dealers follow the code of conduct at all

the times?

viii. In case dealer has resigned, have you ensured that his terminal id is

de-activated one day prior to his last working day?

ix. Do you ensure that no terminal is operated in the name of resigned

employee?

J. Password Policy

i. Have you ensured that all the dealers in branch are aware of the

password policy?

ii. Do you ensure that Dealers do not share the password of their

terminal with anyone else?

iii. Are all the machines password locked at all the times?

iv. Is the terminal automatically gets locked, if it is not operated for a

particular period of time?

v. Do the dealers change the password every fortnight or earlier? Do you

monitor the same?

vi. As a Branch Manager do you ensure that no terminal is operated by

any unauthorized person including JRG staff at any point of time?

K. Be vigilant at all the times. It is matter of the clients money, our risk andreputation at stake

i. Do you ensure that none of the other brokers terminals are operated

in our premises at any point of t ime?

ii. Do you ensure that at no point of time none of the document is kept

loose at the desks? This may result in great embarrassment to us and

financial loss to JRG/ client.

iii. Do you ensure that the branch keeps records of cheques in hand?


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iv. Do you ensure that at all times the cheques are deposited in the banks

without any delay? Pl quote the instances, if there has been any delay.

v. Do you ensure that the dealers place the orders on behalf of the

clients only after confirming the authenticity of the clients?

vi. Do you ensure that at no point of the time, none of the branch staff

uses any of the unauthorized sites at the official internet?

vii. Mistakes in client master mistakes

L. Investors Grievances

i. Whether the Investors Grievance Register in prescribed format is

maintained at branch?

ii. Do you ensure that you record the complaint when received in the

register without any delay?

iii. Do you ensure that the complainant is replied within 48 hours of the

receipt of the complaint?

iv. Have you forwarded all the complaints to HO within 24 hours of receipt

at the designated email?

M. Legal and Administration

i Have you ensured that office location is registered under Shop and

Establishment Act and copy displayed in office?

Have the registrations under the above said act is valid and not

expired?

ii Have the leave/ license for the branch is subsisting and not expired?

iii In case of expiry, have you sent the renewal of the same to HO at

least three months before expiring?i Have you obtained prior written approval from Compliance before

giving any advertisement in print, radio, TV, pamphlets, flyers,

invitations, or any other instrument/ source of media?

Have you ensured that all the licenses/ approval required for running

the branch are obtained or are in place?

vi Is service tax registration in place for the operations of the branch?

N. Office Management

i. Whether attendance register is maintained at Branch and records

sent to HO at the end of month.

ii. Do you ensure that the new staff is adequately trained in AML (Anti

Money Laundering) and CFT (Combating Financing of Terrorism)

Procedure?

iii. Do you ensure Dos and Do-Nots boards are displayed at all the

branches at prominent place at all the times?

iv. Do you regularly check the proper functioning of UPS, VSATs and

their IDU units, Generators sets etc available at branch?


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v. Do you keep invitatory register with complete details recorded, and

verify at least once in a week with physical quantity? Report the

variance, if any.

vi. Whether expiry of the stamps and other instruments, if any, is

verified?

vii. Whether Fixed Assets Register in prescribed format maintained,

updated and checked with the assets every month?

viii. As a branch manager, do you know the procedure of switching of

connectivity form primary to secondary in case of failure of same?


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12.2 Daily Checklist for Branch Managers

To be sent to HO Compliance at the End of Day (EOD).

Date post:	05-Apr-2018
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