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Policies and Procedures

Policies and Procedures Pursuant to SEBI’s Circular MIRSD/SE/Cir-19/2009

This Policy and Procedure document of CRECER FINANCIAL SERVICES PRIVATE LIMITED (CFSPL) contains important information on trading in Equities and F&O segment(s) of the Exchange(s) through CFSPL.

1. Refusal of orders for penny / illiquid stocks:

Stocks that trade at a relatively low price and market capitalization are called as penny/illiquid stocks. These types of stocks are generally considered to be highly speculative and high risk because of their lack of liquidity, large bid-ask spreads, small capitalization and limited following and disclosure. Therefore depending on the market condition and Risk perception, CFSPL will identify such stocks as Penny stocks or illiquid stocks based on its own criteria or identified by the stock exchanges on periodic basis and may from time to time refuse limit orders in such stocks either based on quantity or value without any reasons given to the client.

2. Setting up client's exposure limits.

Crecer Financial Services Private Limited may from time to time impose and vary limits on the orders that the client can place through stock broker's trading system (including exposure/margin limits, turnover limits, limits as to the number, value and/or kind of securities in respect of which orders can be placed etc..

The client is aware and agrees that CFSPL may need to vary or reduce the limits or impose new limits urgently on the basis of CFSPL risk perception and other factors considered relevant by CFSPL including but not limited to limits on account of Exchange/ SEBI directions / limits (such as broker level / market level limits in security specific /volume specific exposures etc.) and CFSPL may be unable to inform the client of such variation, reduction or imposition in advance. The client agrees that CFSPL shall not be responsible for such variation, reduction or imposition or the client's inability to route any order through CFSPL trading system on account of any such variation, reduction or imposition of limits. The client further agrees that CFSPL may at anytime, at its sole discretion and without prior notice prohibit or restrict the client's ability to place orders or trade in securities through CFSPL or it may subject any order placed by the client to a review before its entry into the trading systems and may refuse to execute / allow execution of orders due to the reason of lack of margin/ securities or the order being outside the limits set by CFSPL / exchange / SEBI and any other such reasons which CFSPL may deem appropriate in the circumstances. The client agrees that the losses, if any on account of such refusal, or due to delay caused by such review, shall be borne exclusively by the client alone.

3. Applicable Brokerage Rates:

CFSPL will charge brokerage to the client according to the brokerage rates specified in the account opening form or as per the scheme opted by the client from time to time. CFSPL is at liberty to charge brokerage within the limits approved by exchanges/SEBI from time to time. The brokerage to be charged by CFSPL shall be exclusive of every statutory levies such as services Tax, Stamp duty, SEBI turnover fees, Securities Transaction Tax and other taxes and transaction expenses as they be present from time to time and as they apply to the account and transactions of the Clients and for the services offered to the Clients. whichever modification in brokerage will be made merely after giving notice by way of communication through email.

4. Imposition of penalty / delayed payment charges:

CFSPL shall reserve the right to levy delayed payment charges, at such rates as may be determined by the CFSPL from time to time, on account of delay / failure by the client in meeting the pay-in / margin obligations / mark-to-market obligation on the scheduled date till the date of payment. The levy is only a penal measure in case of default by the client in meeting settlement and margin obligations and should not be taken as a funding deal by the client ; and the client cannot claim continuation of services on a permanent basis citing levy of delayed payment charges.

CFSPL shall recover penalties / levies imposed by Exchange / regulators from the client which arises on account of dealing with such client viz. penalties / levies on auction resulting from short deliveries, non adherence to client- wise exposure limits in Cash and F & O segment and any other reasons which may be specified by the Exchange / Clearing Corporation / SEBI from time to time.

5. Right to sell client’s securities or close client’s positions without giving notice to the client, on account of non-payment of client’s dues.

In case of client falling short of providing fund / securities CFSPL has the right to close the positions with or without giving prior notice to the client on account of non-payment of dues to the extent of Ledger debit and or to the extent of Margin obligation. CFSPL can liquidate the securities bought or collaterals given or any other securities given in any other form for clearing the clients obligation.

client may take exposure up to the amount of margin available with us and/or collaterals pledged with us.

6. Shortages in obligations arising out of internal netting of trades

Internal shortage arises if one client has failed to give the delivery of securities sold, which has resulted in short delivery to other clients of CFSPL

If a client fails to make timely delivery to CFSPL in respect of the shares or securities sold by him as notified by the Exchange from time to time i.e., in case of short delivery, the said un-discharged obligation on the part of the client shall be subjected to close out or auction in accordance with the rules and regulations of the Exchange. The loss, if any, on account of such close out or auction shall be debited to the account of the client. Under such cases, no further claims shall lie between the client and CFSPL. In case of shares purchased by client where no delivery was timely effected as required under the Rules and Regulations by the Exchange the short delivery will be closed-out by CFSPL in accordance with the Exchange procedure and the credit on account of such close-out or auction shall be made to the account of the client. Under such cases, no further claims shall lie between the client and CFSPL.

7. Conditions under which a client may not be allowed to take further position or the broker may close existing position of a client.

In case overall position in a scrip / derivatives contracts has reached the Regulators prescribed Exchange limit / Market Wide Open interest limit, then CFSPL may not allow clients to take further position, till such time Regulator prescribed limits comes down to create a new position.

Added to that, in case of any delay or failure by the client in meeting any obligation, margin requirements etc. CFSPL, at its discretion, may close the existing position of a client to the extent of Debit balances.

8. Temporarily suspending or closing a client's account at the client's request

On the written request of the client, the client account can be suspended temporarily and can be re-activated on the written request of the client only. During suspension period, the market transaction will be prohibited. However client's pending settlement can take place.

9. Deregistering a client

CFSPL may deregister the client's account in circumstances including but not limited to the following according to its discretion:

a. If the client is debarred by SEBI or any other regulatory authority;

b. If the Client has found to be of unsound mind or of other disability by a competent authority and the findings is in force.

c. as a part of surveillance measure, if a client appears to be indulging in manipulative practices

10. Policy for Dormant Accounts:

A Trading Account shall be classified as dormant account in case there are no transactions ( trading and/ or fund receipts) for a period in excess of 12 months from the last transaction date..

A dormant account can be re-activated on receipt of a request for reactivation along with valid proof of identity..

In such case the surplus funds or securities lying with CFSPL shall be refunded or returned to the client at his last known bank account / DP account for securities or at such other address as mentioned in the Account Opening Form.

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