Firstock Broking Private Limited, is a member of the National Stock Exchange and Bombay Stock Exchange in the Equity and Equity Derivatives segment, having its Registered Office at #46, 1st Floor, 36th F Cross Road, 4th T Block, Jayanagar, Bangalore-560041.

For the purpose of these Policies & Procedures, wherever the context so mentions "Client”, “You" or "Your", it shall mean any natural or legal person who has agreed to open an account or initiate the process of opening an account with Firstock by providing their information while registering on the platform as a user. Firstock allows any person to surf the website without registering on the website. The term "We", "Us”, "Our" and "Firstock" shall mean M/s Firstock Broking Private Limited.

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.

Pay-in: Clients can transfer funds into the Trading Account only from such bank accounts which are registered with Firstock. Payments will only be accepted form of Online Bank Transfers, Payment Gateway transfers, UPI or Cheques. 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.

Payment Gateway: The client can transfer funds from the instant payment gateway facility available on the trading platform.

NEFT/RTGS/Cheque: Clients can add the designated HDFC Bank account of Firstock Broking Private Limited as a beneficiary with their bank and transfer funds through NEFT, RTGS, or cheque at no additional cost. The fund receipt confirmation generally takes 1–3 hours for RTGS and 1–4 hours for NEFT. Once the funds are credited, they will be updated in the client’s account within 10–15 minutes. For cheque transfers, the client must share the transfer details along with a copy of the cheque with Firstock to enable the credit to be updated in the trading account.

UPI Payments: For UPI payments clients should login to Demat/Trading applications, as the SEBI approved UPI IDs are already integrated within the platform. Note that Firstock DO NOT offer the option to make DIRECT UPI payments using any standalone UPI IDs

Pay-out: All pay-outs will have to be placed in the Firstock App. The Pay-Out request will be processed as per the following schedule.

Firstock does not engage in the business of Client Funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions.

When a trading or clearing member utilizes 90% of their available capital or collateral toward margins, risk reduction mode will be triggered and the following conditions will be applicable until restored:

All information mentioned here is subject to change at the discretion of our Risk management team.

Firstock will issue contract notes & margin statements to its clients before the start of the next trading day. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin settlement which is also available to be viewed in the Firstock App.

Brokerage charges will be levied as per tariff

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 pay-in time on the pay in day. “Charges for delayed payment” are levied on the respective ledger debit of the clients at a rate of 0.0329% per day (or 12% per year) 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 giving effect to the release of margin.

Account shall be closed upon a specific request from the client. The closure shall be effective only over a period of one month has elapsed from the date of application/intimation or the date of settlement of account whichever is later. Dormant accounts are concerned, we do not close such accounts, but mark the same as “Inactive” till further action by the concerned client.

Client Account would be treated as INACTIVE if there is no transaction (trade) in the account continuously for 24 Calendar months in any segment

In the event that any discrepancy, unusual activity, or extraordinary trade/transaction is identified during the surveillance review, the Surveillance Team undertakes a detailed examination of the relevant account and transactions. Where further clarification or supporting information is required, the team approaches the respective account holder to obtain additional details regarding the nature, purpose, and circumstances of the identified activity.

If the aggregate value of pre-funded instruments is Rs. 50,000/- or more from client per day per client, we may accept the instruments only if the same are accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank. And the mode of certification may include the following either:

• Certificate from the issuing bank on its letterhead or on a plain paper with the seal of the issuing bank.
• Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
• Certified copy of the passbook/bank statement for the account debited to issue the instrument.
• Authentication of the bank account-number debited and name of the account holder by the issuing bank on the reverse of the instrument. We also maintain an audit trail of the funds received through electronic fund transfers to ensure that the funds are received from their clients only.

The Refund & Cancellation policy for all payments made towards account opening using the payment gateway shall stand as under:

• Pick up of required documents related to the account opening procedure is subject to availability of our representatives, given at any particular time and location.
• In case your account has not been opened by Team Firstock, aver the tenth day passing by from the day of collection of all necessary supporting documents and receipt of all due authorizations from you, you may request for a full refund of the charges as paid by you towards account opening.
• In case you have paid the charges relating to account opening multiple times, please send mail to support team([email protected]) and we will initiate the necessary procedure to refund your money.

Note: The completion of the refund procedure is subject to agencies such as banks, payment gateways.

SEBI vide circular dated 18th January 2006, along with all its updates, requires all ‘Market intermediaries’ to lay down a policy framework for anti-money laundering measures to be followed. EBI has also issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT, last updated on February 3, 2023. Firstock Broking Limited (hereinafter “Firstock”) being a Stock Broker and therefore a market intermediary, is required to adhere to the Master Circular.

The objective of this PMLA policy is to have a system in place for preventing any money laundering financial transactions through Firstock, and to identify, monitor, and 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 to as “KYC Standards” and “AML Measures". The objective is to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent Firstock from being used, intentionally or unintentionally, by criminal elements. KYC Standards and AML Measures would enable Firstock 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 Firstock manage its risks prudently.

The management of the company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance concerning all relevant legal requirements, and undertakes to periodically review the policies.

Ensuring that Firstock discharges its legal obligation to report suspicious transactions to concerned authorities.

This policy is in relation to customer due diligence, which means:

• Obtaining sufficient information about the client to identify who is the actual beneficial owner of the securities or 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 specific parameters:

Before opening any account with us, the following measures shall be taken:
a. In-person or complete online KYC verification of the client .
b. Identify beneficial ownership and control, i.e., determine the persons who beneficially own/control the account.
c. Collect information about the Client's background, and occupation and also determine the introducer, if any.
d. Collect and verify all original documents from the client
e. Collect a certified copy of valid documents showing details of his permanent address, current address, PAN, nature of his occupation, and financial status and a recent photograph,
f. For clients trading in F&O segment, documentary proof of his financial details will be collected, determined by policies from time to time,
g. Corporate clients: Collect copies of the certificate of incorporation, the memorandum of association and other documents required by SEBI, and collect adequate information of the persons authorised to deal on behalf of the company.

a. All corporate clients must submit their annual report to Firstock every year.
b. In the case of individual clients, each Client’s master details shall be sent to the client, who will then confirm that the details are updated correctly, or shall revise or provide details as required. He shall also specify his present occupation and financial income details per annum in the same declaration.
c. No account shall be opened if the client is unable to or refuses to follow the KYC related required.
d. The information shall be adequate to satisfy competent authorities (regulatory/ enforcement authorities) in the future that due diligence was observed by Firstock in compliance with the Guidelines.
e. Failure by a prospective client to provide satisfactory evidence of identity should be noted and reported to the Principal Officer.
f. Further, Firstock should follow up with clients where inconsistencies in the information provided are found, until the client corrects the inconsistencies or provides reasonable proof for the same.

a. 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.

Individuals and entities whose identities and sources of wealth can be easily identified and transactions in whose accounts by and large conform to the known profile may be categorized as low risk.

Customers that are likely to pose a higher-than-average risk to the broker may be categorized as medium or high risk depending on Customer’s background, nature and location of activity, country of origin, sources of funds and his client profile etc.; such as:

FIRSTOCK may apply enhanced due diligence measures based on the risk assessment, thereby requiring intensive “- due diligence‟ for higher risk customers, especially those for whom the sources of funds are not clear. The examples of customers requiring higher due diligence may include: Non-Resident Customers, High Net Worth Individuals, Trusts, charities, NGOs and organizations receiving donations, Companies having close family shareholding or beneficial ownership Firms with sleeping partners, Politically Exposed Persons (PEPs), Those with dubious reputation as per public information available, etc. Companies offering foreign exchange offerings, Clients in high-risk countries

SEBI and other authorities suspend or debar persons / entities from participating in the securities market on several instances. Firstock as a broker are required to ensure that such persons do not trade through us, and shall not be liable for any such blocking or closure of accounts.

a. 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 while onboarding clients. There will be periodic checking by the Principal Officer and the same report will be properly filed by Firstock.
b. 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 among staff.

a. Firstock follows a risk-based approach for mitigation and management of any identified risk. Firstock monitors its policies and may enhance policies if necessary.
b. Client due diligence is undertaken on a risk sensitive basis.

a. Firstock has undertaken measures to understand the normal and standard activities of each client, to be able to understand deviations in transaction and activities.
b. Firstock shall specifically note complex and unusually large transactions / patterns which appear to have no economic purpose.
c. Firstock shall ensure retention of records as required under the PMLA and all other applicable laws.

The Exchanges specifies a list of Illiquid Securities wherein higher due diligence is to be exercised by brokers. The list is displayed on the Firstock website for the client's information. The trade pattern in such scrips by our clients is monitored. We may seek clarifications or justifications from the client in case of a high volume of trades in any scrip compared to the exchange volumes.

Firstock has a policy for ongoing employee training so that the staff of Firstock are always aware of the provisions of AML and CFT procedures and amendments thereof. These training programmes are focused on our customer support 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. A register of attendance of participation in such education and training programs is maintained as records, kept secured with the Compliance Department.

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 [email protected]

The resolution of the Complaint shall be done at the earliest and the same shall be recorded in the register/online along with the date of resolution.

Procedure to file a complaint on SEBI SCORES: Register on SCORES portal. Mandatory details for filing complaints on SCORES: Name, PAN, Address, Mobile Number, E-mail ID. Benefits: Effective Communication, Speedy redressal of the grievances

2. Algo Automations – Policies, Procedures & Operational Guidelines