Internal Control Policy
Objectives: To ensure that the company and its various departments are run in accordance with management policies To ensure that the company does not suffer any losses due to lack of controls To plug the loopholes that could lead to revenue leakages
Policy :
Reporting Authorities:
Company has following functional divisions/ departments. Staff in following departments would report to their respective function heads
Policy :
Reporting Authorities:
Company has following functional divisions/ departments. Staff in following departments would report to their respective function heads
Department | Function/ Department - Head |
BSE | Chanda Khopade / Tushar Karade |
NSE Cash & F & O | Chanda Khopade / Tushar Karade |
Front Office Dealing | Tushar Karade |
Compliance | Chanda Khopade / Tushar Karade |
Account & Finance | Jyoti Solanki |
Back Office | Chanda Khopade / Sakshi Parab |
Back Office Software | Prism Cybersoft Private Limited |
Administration & HR | Geeta Kotian |
All functional heads would report to Board of Director Mr.Ramesh V Luharuka.Maker- Checker Policy:
ll
divisions will have maker-checker system in place
There would be two levels of controls exercised. All transactions would be authorized by respective department heads. High value transactions (above 5 lakhs) would require additional authorization of directors.
Cheque signing authority would be restricted to following persons : Mr. Ramesh Luharuka
Further following activities would require approval of directors :
Registration of Clients
Nariman Point Finance Limited an organisation registered as a Member with National Stock Exchange Limited and Bombay Stock Exchange Limited for the purpose of doing the trading for and on behalf of our customers requires Mandatorily to register all the customers by providing client registration forms. The customers are introduced by the Director, interalia, known for their social and credit worthiness.
Once the customer decides to open an account, client Registration form is filled in with client’s data which is uploaded in NSE system of Uci online and BSE system of WEBEX, which gives an unique customer code (client code) to have absolute control over the systems we have centralized systems.
Receiving, validating & entering the orders of clients in the trading platform
We are operating only at one place on NSE and BSE systems only through Lease Line. These BOLTs are mainly operated by our employees in our offices who operate mainly for their clients.
Since each BOLT operator has its own BOLT and he is required to operate on the same place for his clients, it becomes easy to identify the caller when he calls to get punch an order in the system. As we are issuing the client codes to each client on registration, it becomes easy to identify the client when he makes a call, gives his code number and asks to punch order in the system.
The clients registered with us are provided a fixed limit for their trading activity based on their financial details. According to the exposure limit which is provided to the client, they can trade only up to that amount and beyond this no order will be accepted by the dealer.
Collection and Release of Payments to clients
Collection of funds is the most integral and important part of any stock broker’s office. We have directed all our operators to be punctual in collecting the amount due from each and every client. The clients are required to inform us if they want their pay out cheques whether personally or by courier. On receipt of the request the same is being prepared after approval of Authorised person and the same is being handed over personally or dispatched to client, as the case may be. However, the client’s ledger account is extracted to verify the correctness of the credits lying in the respective accounts. Thereafter the said ledger account is passed on to the accounts Officer who, once again, scrutinizes the ledger and prepares the payout cheque. The cheque along with the ledger is returned back to the originator for scrutiny and initials. The mentioned documents, further is being scrutinized by the accountant for final clearance. Accountant puts his initials and thereafter the cheque is sent to the Director for his signature. This gives the picture of how strict compliance of the clients accounts and the payouts, thereon.
We ensure, before making any payment of the client, we thoroughly scrutinise the ledger account of each and every client and amount of his net credit is being issued, unless otherwise is instructed by the client.
Collection and delivery of Securities to the clients
Pay In :
On opening of the account, we part with all the clients’ information about our Pool account for delivering shares for the pay in. They are being given the relative settlement number for sending shares for pay in.
On the day of the pay in at around 10.00 a.m., an officer takes out the list of all overdue securities pending for pay in. He then finds out the list of probable seller and calls him up for delivering the same on urgent basis as the pay in completes by 10.30 a.m. All the shares undelivered by pay in goes for auction, which is being billed to the respective client.
Pay Out :
The pay out of shares is being made to client depending on his credit worthiness. We normally deliver the shares to client only on receipt of clear credit in our Bank. Till the time the debit is not cleared, the shares are not released to him. Those shares are being hold in beneficiary account till the amount is realized or shares are sold.
Operations & Compliance Requirements :
Whole operations of our NSE and BSE card are done in conformity with the general requirement of Compliance as required by NSE, BSE & SEBI.
Own & Clients Bank accounts are duly opened with AXIS BANK LTD for depositing and issuing cheques for own & client’s use. Each and every client is required to fill the Client Registration Form which is duly registered with the NSE of Uci online and BSE systems of WEBEX and then only client code is being conveyed to the client. Our Client Registration Form is fully comprehensive requiring majority of the details as asked by NSE & SEBI.
Each client shall have his DEMAT account to receive the delivery of shares.
Once the trade takes place, the clients are required to send shares to our Pool account for pay in. In case of pay out the shares are transferred to the DEMAT account of the client after pay out.
The contract Notes of the transactions are being given to clients on the same day by courier as per understanding with each & every client.
Client’s ledgers are being given to them in duplicate for confirmations quarterly as per the compliance requirement. As a policy decision and a compliance requirement, it’s being sent to all the clients.
As a matter of compliance and risk measurement, all the BOLT operators are informed not to execute transaction for any other client’s except its own or of the company and client code should be confirmed if there is any doubt with client or with back office staff. Also, the transactions in oddlot group should be limited and volumes if any to be kept under watch.
We take full care that all kind of compliance requirement is completely followed while doing business operations of the company.
Changes in the Client Code during market hours
Any mistake by the dealer in punching client code number is immediately reported to the Compliance Officer. It is the duty of Compliance Officer to make necessary changes in the Bolt. If any penalty is charged by Exchange on exceeding of limit, which is greater than 1% but less than or equal to 5% after deducting non-institutional modification, then he or she should report to the Director and also to the respective client through email. In order to reduce such wrong punching of client codes we have given a list of our clients along with the code to our dealers.
Payment of Dividend
Many times the dividend payout is received by the company on account of client’s shares which are lying in beneficiary account. The clients on whose account the dividend is received by us are refunded their dividend in normal course on establishing the rightful holder of the dividend.
Internal Audit: The company would be subjected to internal audit. Internal audit would be conducted by independent CA firm Chaturvedi Anand & Company.
Internal auditor would audit as per audit scope agreed mutually with the management.
Internal auditor would directly report to Board of Directors.
Client Registration, Documents maintenance:
KYC are accepted from new client’s through a known source who is very familiar to our Directors. The introductory part of fresh client is accepted after thorough verification of introducer who is other than Directors.
We have a proper & well trained staff that does the entire KYC activity.
divisions will have maker-checker system in place
There would be two levels of controls exercised. All transactions would be authorized by respective department heads. High value transactions (above 5 lakhs) would require additional authorization of directors.
Cheque signing authority would be restricted to following persons : Mr. Ramesh Luharuka
Further following activities would require approval of directors :
Registration of Clients
Nariman Point Finance Limited an organisation registered as a Member with National Stock Exchange Limited and Bombay Stock Exchange Limited for the purpose of doing the trading for and on behalf of our customers requires Mandatorily to register all the customers by providing client registration forms. The customers are introduced by the Director, interalia, known for their social and credit worthiness.
Once the customer decides to open an account, client Registration form is filled in with client’s data which is uploaded in NSE system of Uci online and BSE system of WEBEX, which gives an unique customer code (client code) to have absolute control over the systems we have centralized systems.
Receiving, validating & entering the orders of clients in the trading platform
We are operating only at one place on NSE and BSE systems only through Lease Line. These BOLTs are mainly operated by our employees in our offices who operate mainly for their clients.
Since each BOLT operator has its own BOLT and he is required to operate on the same place for his clients, it becomes easy to identify the caller when he calls to get punch an order in the system. As we are issuing the client codes to each client on registration, it becomes easy to identify the client when he makes a call, gives his code number and asks to punch order in the system.
The clients registered with us are provided a fixed limit for their trading activity based on their financial details. According to the exposure limit which is provided to the client, they can trade only up to that amount and beyond this no order will be accepted by the dealer.
Collection and Release of Payments to clients
Collection of funds is the most integral and important part of any stock broker’s office. We have directed all our operators to be punctual in collecting the amount due from each and every client. The clients are required to inform us if they want their pay out cheques whether personally or by courier. On receipt of the request the same is being prepared after approval of Authorised person and the same is being handed over personally or dispatched to client, as the case may be. However, the client’s ledger account is extracted to verify the correctness of the credits lying in the respective accounts. Thereafter the said ledger account is passed on to the accounts Officer who, once again, scrutinizes the ledger and prepares the payout cheque. The cheque along with the ledger is returned back to the originator for scrutiny and initials. The mentioned documents, further is being scrutinized by the accountant for final clearance. Accountant puts his initials and thereafter the cheque is sent to the Director for his signature. This gives the picture of how strict compliance of the clients accounts and the payouts, thereon.
We ensure, before making any payment of the client, we thoroughly scrutinise the ledger account of each and every client and amount of his net credit is being issued, unless otherwise is instructed by the client.
Collection and delivery of Securities to the clients
Pay In :
On opening of the account, we part with all the clients’ information about our Pool account for delivering shares for the pay in. They are being given the relative settlement number for sending shares for pay in.
On the day of the pay in at around 10.00 a.m., an officer takes out the list of all overdue securities pending for pay in. He then finds out the list of probable seller and calls him up for delivering the same on urgent basis as the pay in completes by 10.30 a.m. All the shares undelivered by pay in goes for auction, which is being billed to the respective client.
Pay Out :
The pay out of shares is being made to client depending on his credit worthiness. We normally deliver the shares to client only on receipt of clear credit in our Bank. Till the time the debit is not cleared, the shares are not released to him. Those shares are being hold in beneficiary account till the amount is realized or shares are sold.
Operations & Compliance Requirements :
Whole operations of our NSE and BSE card are done in conformity with the general requirement of Compliance as required by NSE, BSE & SEBI.
Own & Clients Bank accounts are duly opened with AXIS BANK LTD for depositing and issuing cheques for own & client’s use. Each and every client is required to fill the Client Registration Form which is duly registered with the NSE of Uci online and BSE systems of WEBEX and then only client code is being conveyed to the client. Our Client Registration Form is fully comprehensive requiring majority of the details as asked by NSE & SEBI.
Each client shall have his DEMAT account to receive the delivery of shares.
Once the trade takes place, the clients are required to send shares to our Pool account for pay in. In case of pay out the shares are transferred to the DEMAT account of the client after pay out.
The contract Notes of the transactions are being given to clients on the same day by courier as per understanding with each & every client.
Client’s ledgers are being given to them in duplicate for confirmations quarterly as per the compliance requirement. As a policy decision and a compliance requirement, it’s being sent to all the clients.
As a matter of compliance and risk measurement, all the BOLT operators are informed not to execute transaction for any other client’s except its own or of the company and client code should be confirmed if there is any doubt with client or with back office staff. Also, the transactions in oddlot group should be limited and volumes if any to be kept under watch.
We take full care that all kind of compliance requirement is completely followed while doing business operations of the company.
Changes in the Client Code during market hours
Any mistake by the dealer in punching client code number is immediately reported to the Compliance Officer. It is the duty of Compliance Officer to make necessary changes in the Bolt. If any penalty is charged by Exchange on exceeding of limit, which is greater than 1% but less than or equal to 5% after deducting non-institutional modification, then he or she should report to the Director and also to the respective client through email. In order to reduce such wrong punching of client codes we have given a list of our clients along with the code to our dealers.
Payment of Dividend
Many times the dividend payout is received by the company on account of client’s shares which are lying in beneficiary account. The clients on whose account the dividend is received by us are refunded their dividend in normal course on establishing the rightful holder of the dividend.
Internal Audit: The company would be subjected to internal audit. Internal audit would be conducted by independent CA firm Chaturvedi Anand & Company.
Internal auditor would audit as per audit scope agreed mutually with the management.
Internal auditor would directly report to Board of Directors.
Client Registration, Documents maintenance:
KYC are accepted from new client’s through a known source who is very familiar to our Directors. The introductory part of fresh client is accepted after thorough verification of introducer who is other than Directors.
We have a proper & well trained staff that does the entire KYC activity.
