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M/s Navia Markets Ltd is the Company registered under the Companies Act, having the Corporate Office at Ganga Griha, 4th & 5th Floor, No.9, Nungambakkam High Road, Chennai 600034. Navia is the online brand of Navia Markets Ltd and it is together referred to as “NAVIA”
This page contains important information regarding the terms and conditions which apply to your Trading & Demat accounts with NAVIA, Member of NSE, BSE, NSDL, CDSL and MCX registered with the Securities & Exchange Board of India ("SEBI") as a Stock Broker with SEBI Registration No.INZ000095034, NSE Member code for CM, FAO & CD: 07708, BSE Clearing No for CM, FAO & CD: 6341, NSDL DP ID: IN300378, CDSL DP ID: 12086500 and MCX SEBI Registration No.INZ000077130 with Membership Code: 45345. Client’s access to the account and the use of the account is subject to the compliance with all the terms and conditions set forth herein.
The website is owned, operated and maintained by NAVIA, having the Corporate Office at Ganga Griha, 4th & 5th Floor, No.9, Nungambakkam High Road, Chennai 600034.
Please note that the information contained herein is subject to change without notice.
By selecting and accepting the “Terms and conditions”, during the login process or while applying for any service, the client agrees to be legally bound by these Terms and Conditions. The client agrees that NAVIA may at its sole discretion may vary the terms and conditions from time to time and client agrees to abide by the same.
Before availing of the trading and depository services, the Client shall complete the registration process as may be prescribed from time to time. The Client shall follow the instruction given in the website for registering as a client with Navia.
The Client agrees that all investment and disinvestment decisions are based on the Client's own evaluation of financial circumstances and investment objectives. This extends to any decisions made by the Client on the basis of any information that may be made available on the web site of NAVIA. The Client will not hold nor seek to hold NAVIA or any of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates liable for any trading losses, cost of damage incurred by the Client consequent upon relying on investment information, research opinions or advice or any other material/information whatsoever on the web site, literature, brochure issued by NAVIA or any other agency appointed/authorised by NAVIA. The Client should seek independent professional advice regarding the suitability of any investment decisions. The Client also acknowledges that employees of NAVIA are not authorized to give any such advice and that the Client will not solicit or rely upon any such advice from NAVIA or any of its employees or business associates.
Online account opening using AADHAAR is currently available only for Individual resident and NRO accounts. Joint Account, HUFs, corporate bodies, NRIs, etc. are not eligible for Online Aadhar based account opening.
The Client’s AADHAR number will be used to generate a temporary e-signature which will be used to e-sign the KYC document. The e-signature will be generated using an OTP which will be sent to the client’s mobile number registered with his AADHAR number.
NAVIA will provide the client with a username and password which will enable the client to avail of the facilities of Online Trading through the NAVIA website/ trading platform. Further Navia provides trading over the telephone through Call and Trade services using Telephone Personal Identification number (TPIN) or in any such other manner as may be permitted by NAVIA for availing of the services. NAVIA may also provide the client with the access to its back-office for various reports, etc. All terms regarding the use, reset and modification of such password/TPIN shall be governed by information on the website.
The Client agrees and undertakes to create a strong password immediately on first login. The Client is aware that these passwords are not known or available to NAVIA.
The Client shall be responsible for keeping the Username, Password and TPIN confidential and secure and shall be solely responsible for all orders entered and transactions done by any person whosoever, through NAVIA’s Online Trading System using the Client’s Username and Password or TPIN, whether or not such person was authorized to do so.
The Client shall immediately inform NAVIA of any unauthorized use of the Client’s Username or Password / TPIN with full details of such unauthorized use including the date of such unauthorized use, the manner in which it was unauthorizedly used, the transactions effected pursuant to such unauthorized use, etc.
The Client acknowledges that he is fully aware of and understands the risks associated with availing of online trading services through internet including the risk of misuse and unauthorized use of his Username and/or Password by a third party and the risk of a person hacking into the Client’s account on NAVIA’s Online Trading / Back-office System and unauthorizedly routing orders on behalf of the Client through the System. The Client agrees that he shall be fully liable and responsible for any and all unauthorized use and misuse of his Password and/or Username and also for any and all acts done by any person through NAVIA’s Online Trading / Back-office System on the Client’s Username in any manner whatsoever.
Without prejudice to the provisions mentioned herein, the Client shall immediately notify NAVIA in writing with full details if he discovers or suspects unauthorized access through his Username, Password or Account, he notices discrepancies that might be attributable to unauthorized access, he forgets his password or he discovers a security flaw in NAVIA’s Online Trading System.
NAVIA presently provides 2 kinds of trading platforms – Navia and Navia Plus.
All orders for purchase, sale or other dealings in securities and other instructions routed through the NAVIA’s Online Trading System via the Client’s Username shall be deemed to have been given by the Client.
The client agrees to provide information relating to customer user identification number (TPIN), and such other information as may be required while placing orders on the telephone (Centralized Dealing Desk) to determine the identity of the client.
The orders and instructions and all contracts and transactions entered into pursuant thereto and the settlement thereof will be in accordance with the Exchange Provisions.
NAVIA may from time to time impose and vary limits /leverage on the orders which the Client can place through NAVIA’s online trading System (including exposure limits, turnover limits, single order quantity and value, value and/or kind of securities in respect of which orders can be placed, the companies in respect of whose securities orders can be placed, etc.). The Client is aware and agrees that NAVIA may need to vary or reduce the limits/leverage or impose new limits urgently on the basis of the NAVIA’s risk perception and other factors considered relevant by NAVIA, and NAVIA may be unable to inform the Client of such variation, reduction or imposition in advance. The Client agrees that NAVIA shall not be responsible for such variation, reduction or imposition or the Client’s inability to route any order through NAVIA’s Online Trading System on account of any such variation, reduction or imposition of limits/leverages. The Client understands and agrees that NAVIA may at any time, at its sole discretion and without prior notice, prohibit or restrict the Client’s ability to place orders or trade in securities through NAVIA.
Though orders will generally be routed to the Exchange’s computer systems within a few seconds from the time the order is placed by the Client on NAVIA’s Online Trading System, NAVIA shall not be liable for any delay in the execution of any order or for any resultant loss on account of the delay.
The client agrees NAVIA may impose scrip wise surveillance or such other conditions as to scrip wise limits, etc. The client also understands that NAVIA may impose various surveillances which may differ from client to client on the basis of the NAVIA’s risk perception and other factors considered relevant by NAVIA.
In case of a market order, the Client agrees that he will receive the price at which his order is executed by the exchange’s computer system; and such price may be different from the price at which the security is trading when his order is entered into NAVIA’s Online Trading System.
The client agrees that all orders placed through the trading system shall be forwarded by the system to the Exchange. All orders placed otherwise than through the trading system shall be forwarded by the system to Exchange terminals or any other order execution mechanism at the discretion of NAVIA.
Trade confirmations will be sent to the client by the trading system, email or SMS after the execution of the order and this shall be deemed to be valid delivery thereof by NAVIA. It shall be the responsibility of the client to review immediately upon receipt, whether delivered to him by trading system, email, SMS or any other electronic means all confirmations of order, transactions, or cancellations. It shall be the responsibility of the client to follow up with NAVIA for all such confirmations that are not received by him within a stipulated time.
The client shall bring any errors in any report, confirmation or contract note of executed trades (including execution prices, scripts or quantities) to NAVIA’s notice in writing by an email to [email protected] within twenty-four hours of receipt of the concerned report, confirmation or contract note. Any other discrepancy in the confirmation or account shall be notified by the client to NAVIA in writing via email within twenty-four hours from the time of receipt of the first notice. In all cases, NAVIA shall have a right to accept or reject the client’s objection.
There may be a delay in NAVIA receiving the reports of transaction, status, from the respective exchanges or other persons in respect of or in connection with which NAVIA has entered into contracts or transactions on behalf of the clients. Accordingly, NAVIA may forward to the client late reports in respect of such transactions that were previously unreported to him as been expired, cancelled or executed. The client shall not hold NAVIA responsible for any losses suffered by the client on account of any late reports, statements or any errors in the report / statements computed by or received from any exchange.
The client agrees that if, for any circumstance or for any reason, the markets close before the acceptance of the Order by the Exchange, the order may be rejected. The client agrees further, that NAVIA may reject Orders if the same are rejected by the Exchange for any reason. In case of rejection of an order due to rejection by the Exchange, the client agrees that the order shall remain declined and shall not be re-processed, in any event.
NAVIA may, at its sole discretion, reject any order placed on the trading system / website or in any other manner due to any reason, including but not limited to the non-availability of funds in the trading account of the client, non-availability of securities in the Demat account of the client with a designated depository participant, insufficiency of margin amount if the client opts for margin trading, suspension or blocking of specific security or contracts in any segments or circuit breaker to a scrip in which orders are placed.
The client agrees that, if the order is not accepted on the trading system / website for any reason, NAVIA shall have the right to treat the order as having lapsed or rejected from the trading system.
The client is aware that the electronic trading systems either at the Exchange or in the office of NAVIA offices are vulnerable to temporary disruptions, breakdowns or failures. In the event of non- execution of trade orders or trade cancellation due to the happening of such events or vulnerabilities due to failure / disruption / breakdown of system or link, NAVIA shall be entitled to cancel relative request/(s) with the Client and shall not be liable to execute the desired transactions of the client’s. In such event, NAVIA does not accept responsibility for any losses incurred / that may be incurred by the Client due to such eventualities which are beyond the control of NAVIA.
NAVIA may at its sole discretion partially / completely restrict execution of orders in respect of securities, irrespective of the amount in the balance of the account of the client. NAVIA may allow/disallow client from trading in any security or class of securities, or derivatives contracts or any other trading products and impose such conditions for trading as it may deem fit from time to time.
The client agrees to abide with and be bound by all the rules, regulations and bye-laws of the Exchange as are in force pertaining to the transactions on his behalf carried out by NAVIA and the orders placed by him on the trading system / website or any other manner.
NAVIA shall not be responsible for any order, that is made by the Client by mistake and every order that is entered by the Client through the use of the allotted user name and the security code(s) / password shall be deemed to be a valid order for which the Client shall be fully responsible.
Cancellation or modification of an order pursuant to the client’s request in that behalf is not guaranteed. The order will be cancelled or modified only if the client’s request for cancellation and modification is received and the order is successfully cancelled or modified before it is executed. Market orders are subject to immediate execution wherever possible. Product conversions are available online, and if at any time the client wants to convert the executed order from one product type to another product type for example MIS to CNC or vice versa, it will be carried out, only if the client’s request for the product conversion is received before the stipulated time of intraday auto square off and if sufficient margins are available for product conversion.
The client shall not be entitled to presume an order having been executed, cancelled or modified/product converted until a confirmation from NAVIA is received by the client. However, due to technical other factors the confirmation may not be immediately transmitted to or received by the client and such a delay shall not entitle the client to presume that the order has not been executed cancelled or modified unless and until NAVIA has so confirmed in writing.
The pending orders shall be governed as per the exchange systems, after the market is closed for the day.
NAVIA shall issue contract notes in terms of the SEBI (Brokers and Sub-Brokers) Rules and Regulations, 1992, within 24 hours of the execution of the trade. Such a contract note, if issued in physical form shall be dispatched by NAVIA by post/courier, at the address mentioned in this agreement or at any other address expressly informed to NAVIA by the client. The client agrees that NAVIA to issue the contract note in digital form which shall be sent by way of email to the address provided by the client. NAVIA shall not be responsible for the non-receipt of the trade confirmation due to any change in the correspondence address of the Client not intimated to NAVIA in writing. Client is aware that it is his responsibility to review the trade confirmations, the contract notes, the bills or statements of account immediately upon their receipt. All such confirmations and statements shall be deemed to have been accepted as correct if the client does not object in writing to any of the contents of such trade confirmation/intimation within 24 hours to NAVIA.
Margin is the minimum amount required to buy/sell. Margins are always collected in advance. Various margins applicable are:
1. Span Margin:
SPAN margin is the upfront Margin required by the exchanges in the derivatives segment. It is calculated on a portfolio (a collection of futures and option positions) based approach.
2. Additional/ Exposure Margin:
'Exposure Margin' is the margin blocked over and above the SPAN to cushion for any MTM losses. Both the SPAN and Exposure margins are specified by the exchange. So at the time of initiating a futures trade, the client has to adhere to the initial margin requirement. The entire initial margin (SPAN + Exposure) is blocked by the exchange. Span + Exposure = Initial Margin (Total Margin)
3. VAR Margin: (Value at risk margin):
The VaR Margin is a margin intended to cover the largest loss that can be encountered on 99% of the days (99% Value at Risk). For liquid stocks, the margin covers one-day losses while for illiquid stocks, it covers three-day losses so as to allow the Exchange to liquidate the position over three days. These Margins are collected upfront for the trading in the Equity segments (normal Equity and MTF).
4. GSM / ASM Margin:
GSM stands for 'Graded Surveillance Measure' and ASM stands for ‘Additional Surveillance Measure'. In order to enhance market integrity and safeguard the interest of investors, Securities and Exchange Board of India (SEBI) and Exchanges, have been introducing various enhanced surveillance measures such as reduction in price band, periodic call auction and transfer of securities to Trade to Trade segment from time to time. This additional surveillance initiative is part of SEBI and the Exchanges initiative to enhance market integrity and safeguard the interest of investors. More details and Navia’s risk management policy on ASM framework is found here and GSM framework is found here
The Client agrees and undertakes to immediately deposit with NAVIA such cash, securities or other acceptable security, which NAVIA may require as margin. The Client agrees that NAVIA shall be entitled to require the Client to deposit with NAVIA a higher margin than that prescribed by the Exchange.
The Margin will not be interest bearing. NAVIA shall have, at its sole discretion, the irrevocable right to set off a part or whole of the Margin i.e., by the way of appropriating of the relevant amount of cash or by sale or transfer of all or some of the Securities which form part of the Margin, against any dues of the Client or of a member of the group of the Client (for the purposes of these Terms, "Group" shall mean all the individuals, group companies, firms, entities and the persons as specified in the schedule to the Member Client Agreement) in the event of the failure of the Client or a member of the Group of the Client to meet any of their respective obligations under these Terms.
The client agrees and authorizes NAVIA to determine the market value of securities placed as margin after applying a haircut that NAVIA may deem appropriate. The client undertakes to monitor the market value of such securities on a continuous basis. The client further undertakes to replenish any shortfall in the value of the margin consequents to a fall in the market value of such securities placed as margin immediately whether or not NAVIA intimates such shortfall.
NAVIA may at its sole discretion prescribe the payment of Margin in the form of cash instead of or in addition to margin in form of securities. The Client accepts to comply with the requirement of NAVIA with regards to payment of Margin in the form of cash immediately. Without prejudice to the stock broker's other rights (including the right to refer a matter to arbitration), the stock broker shall be entitled to liquidate / close out all or any of the client's positions for non- payment of margins or other amount, outstanding debts, etc., and adjust the proceeds of such liquidation / close out, if any, against the client's liabilities / obligations. Any and all losses and financial charges on account of such liquidation / closing-out shall be charged to and borne by the client.
The client agrees to abide by the exposure limits, if any, set by the stock broker or by the Exchange or Clearing Corporation or SEBI from time to time.
The client is also aware that NAVIA is required to deposit sufficient margin with the Exchange to enable all its eligible clients to trade subject to such limits as may be imposed by NAVIA on the basis of NAVIAs' Risk perception and other factors considered relevant by NAVIA. However, there may be circumstances when the deposits made by NAVIA with the Exchange may not be sufficient in times of extreme volatility and trading terminals of NAVIA may get temporarily suspended because of the cumulative effect of non-meeting of obligation by various clients as per this agreement. In these circumstances, no client shall have the right to claim any damages from NAVIA for any loss that they might incur on account of such suspension of trading.
The Client agrees that any securities/cash placed by him/her/it as margin may in turn be placed as margin by NAVIA with the Exchanges, clearing corporation or banks or such other institution as NAVIA may deem fit. The Client authorizes NAVIA to do all such acts, deeds and things as may be necessary and expedient for placing such securities/cash with the Exchanges/clearing corporations/Banks/Institutions as margin.
Any reference in these terms to sales or transfer of Securities by NAVIA shall be deemed to include sale of the Securities which form part of the Margin maintained by the Client with NAVIA. In exercise of NAVIA's right to sell securities under the Agreement, the Client agrees that the choice of specific securities to be sold shall be solely at the discretion of NAVIA.
For more elaboration and details on margin requirements clients may review the policies and FAQ’s mentioned on the support portal, the link for which is given below
https://support.tradeplusonline.com/support/solutions/1000086869
Money pay-in to NAVIA - The Client agrees that all payments due to NAVIA will be made within the specified time and in the event of any delay, NAVIA may refuse, at their discretion, to carry out transactions or closeout the position and the costs/losses if any, thereof shall be borne solely and completely by the client. All payments made to NAVIA shall be from the registered bank account of the client and shall not to be from any third party bank account.
The client can transfer funds from the instant payment gateway facility available on the trading platform. Client can also choose to transfer using NEFT/IMPS/UPI or by means of cheque. Such transfers will be charged a fee per transfer plus applicable taxes.
For more details on Funds pay-in visit our support portal at https://support.tradeplusonline.com/support/solutions/folders/1000156094
Money payout to NAVIA - Notwithstanding anything contained in any other agreement or arrangement, if any, between the parties hereto, the client hereby authorizes NAVIA to release all payments due to him from the trading account maintained with NAVIA, against specific request made by the client. All payout requests will be processed electronically and the credit shall come to the client’s primary bank account as per timelines mentioned in the support portal. If at any time the client wants to credit the amount to the Secondary bank, the client must select the same at the time of placing the payout request. If payout processed to Primary Account is rejected by the Bank, Navia shall re-initiate payment to the client’s Secondary Bank account. Payouts will not be processed on Holidays, Saturday and Sunday. For more details on Funds Payout visit our support portal at https://support.tradeplusonline.com/support/solutions/folders/1000156094
Securities pay-in to NAVIA - All delivery to be effected to NAVIA for a trade, must be made within 24 hours from the execution of the sale order or one day before the pay-in date, whichever is earlier. Losses, if any, that may accrue in the event of a default in completing the delivery on the exchange by NAVIA as a result of any delay in the delivery by the client, shall be borne solely and completely by the client. Losses for the purposes of this clause shall include auction debits/ penalty charges/interest if any incurred as a result of non-delivery of securities on the settlement date on the exchange. No third-party shares will be sold through NAVIA or third-party payment should be made to NAVIA and client will be solely responsible for any violation. If the client has sold any securities from the exchange against purchase in previous settlements, such sale shall be at the sole risk as to costs and consequences thereof of the client.
Securities pay-out by NAVIA - NAVIA may directly credit the demat account of the client with the depository participant or maintain the securities in the client unpaid securities pledge Account (CUSPA) of NAVIA until the client has paid for the securities in full. If the client fails to pay for the securities purchased in full then NAVIA reserves the right to sell the unpaid securities and related costs to recover its dues. The client is expected to monitor and pay for his securities purchased in full within settlement date.
Provided that if the order placed by the client through the trading system / website or otherwise is for securities which are in the no-delivery period, such securities shall be credited to the trading account of the client only at the time of settlement of trades, as per the schedule of the Exchange. However, if any sum due from the client, NAVIA may withholds the credit of securities to the demat account of the client. However, the client authorizes NAVIA to withhold the securities to meet liabilities of client to NAVIA under this agreement.
Time of Delivery of shares:
Client agrees to ensure that before selling of any shares, he has the same in the hand. Any loss arising of auction / close out on account of shares not cleared in NAVIA’s account will be borne by the client. The client also agrees to bear any loss arising out of auction due to incomplete/ illegible/ unclear/ instructions and instructions not received on time.
The client shall deliver shares to NAVIA for all sale trades due for settlement, on trade day or before the trade settlement day. The settlement day for all client sales will be the pay in day less one day, where the pay in day is specified by the Exchange /Clearing House, which will be passed on to the client.
Navia shall deliver shares purchased by the client on the trade settlement day, however Navia is not obliged to deliver any securities to the client unless and until the same has been received by Navia from the clearing corporation/ clearing house or other entity liable to deliver securities. The settlement day for all client purchases will be payout day, where the pay-out day is specified by the Exchange/Clearing House for the relevant settlement period.
Navia shall not be obliged to release any securities to the client until the Client has satisfactorily discharged all its payment obligations or other obligations under this Agreement.
Bad Delivery of Shares:
Exchange shortage quantities will be settled after the due auction buy-in process at the Exchange. All auction shortage closeout debits received from the Exchange will be borne by the client. The client shall reimburse Navia for all costs incurred in the auction procedure. Navia shall not be liable for any loss incurred by the client due to wrong transfer of shares. Shortages in obligations arising out of internal netting of trades:
Navia shall not be obliged to deliver any securities or pay any money to the client unless and until the same has been received by Navia from the exchange, the clearing corporation/clearing house or other company or entity liable to make the Payment and the client has fulfilled his/her/its obligations first.
These policies and procedures are for the settlement of shortages in obligations arising out of internal netting of trades as under.
The Short delivering client is provisionally debited 150% of selling value and closed out on auction date 1% higher than the buyer’s traded value. Further, necessary charges, penalties if any, debited by exchange due to short delivery will be pass on to the client at appropriate rates from time to time is debited to the short delivering seller client along with reversal entry of provisionally amount debited earlier.
In cases of securities having corporate actions all cases of short delivery of cum transactions which cannot be auctioned on cum basis or where the cum basis auction payout is after the book closure /record date, would be compulsory closed out on the highest traded price from first trading day of the settlement till the auction day.
As per the SEBI guidelines, the settlement of funds in a client's trading account has to be done within one working day of payout. However, the client can authorize the Broker to retain funds in his Trading Account and maintain it as Running Account. This is called Running Account Authorization. A client can give Running Account Authorization for 30 days or 90 days.
If you have given Running Account Authorization for 90 days:
If you have given Running Account Authorization for 90 days, the settlement will be done after considering the End of the day (EOD) obligation of funds as on the date of settlement across all the Exchanges on first Friday of the calendar Quarter (i.e., Apr-Jun, Jul-Sep, Oct-Dec, Jan–Mar) for all the clients i.e. the running account of funds shall be settled on first Friday of October 2022, January 2023, April 2023, July 2023 and so on. If first Friday is a trading holiday, then such settlement shall happen on the previous trading day.
If you have given Running Account Authorization for 30 days:
If you have opted for Monthly settlement, running account shall be settled on first Friday of each month. If first Friday is a trading holiday, then such settlement shall happen on the previous trading day.
If you have not traded for 30 days:
If you have credit balance and not have done any transaction in the 30 calendar days since the last transaction, the credit balance shall be returned to your Bank Account, within next three working days irrespective of the date when the running account was previously settled. Further, after settlement, if the money is transferred back to your account and no trades are executed during this period, the 30 calendar days for the purpose of subsequent settlement from the day funds were received instead of the last transaction date will be considered.
Check here to know more on Running Account Settlement of Funds.
Navia’s right to change the margins under any conditions without any notice.
Navia reserves the right to increase the margins at any time, during the trading day or on any special day where Navia anticipates higher volatility in the market due to any of the following reasons without any notice
What are the terms for the squaring /close out the Positions/ Stocks etc by Navia?
Navia reserves and retains the right to sell or square off the client’s open positions in any segment of any exchange and the Client Unpaid Securities Pledge Account (CUSPA) stocks/ Pledged Securities / etc. under the following conditions listed below and Navia shall not be held responsible for any loss/charges due to the square off /non- square off of positions as per this policy
1) When there is a Margin Shortfall
It is the responsibility and onus of the client to continuously monitor his positions and bring in additional margin when required. Client may need to bring in additional margins due to MTM loss or margins being increased by the exchange. Client must ensure that there is no Margin shortfall in the account. The Account is said to have a Margin Shortfall if the Available Balance as reflected in the Trading Platform is negative, I.e , the Available Margin is Less than the Margin Required on the open positions.
In event of Margin Shortfall, Navia reserves the right to reduce or completely square off the client’s open positions. Margin Reports are also sent vide email from the back office every day when client has open positions. It is possible for the margin to change after the client has taken the position. Clients are required to monitor the applicable margins on their positions at all times and ensure that there is no margin shortfall to prevent partial or complete liquidation of the open positions
Since liquidation of positions is not a fully automated action in the system, Navia can only square off positions on a best effort basis. It is possible that due to extreme volatility / market freeze or any other conditions, the margin utilized may exceed much beyond the required capital / margin placed by the client before Navia can successfully square off / reduce the positions. In any event Navia cannot be held responsible for such losses or charges incurred. Under no circumstances can the client transfer his/her responsibility of monitoring or squaring up his/her positions to Navia
In the Equity Future /Commodity Future there are possibilities of freezing of contracts at any time during the trading hours. During this freeze period of the contracts, Navia shall not be able to square off the positions as per the RMS policy. Similarly, even in Illiquid options there exists possibility that there are no counter parties available to square off the positions. Hence in this scenario, Navia shall not be held responsible for any losses due to the non-squaring off of the positions
2) MIS / Cover Order (CO) –time based Square off:
Any positions taken under MIS / Cover Order (CO) shall be automatically squared off, at any time within the last half an hour of market close for the respective exchanges and segments if the positions continue to be open at that time. Client has the option to convert a MIS position to normal position (NRML) if adequate margin is available in the trading account. CO positions cannot be converted but can only be exited. Should the client want to convert or exit his/her MIS open positions, he/she should do so before the beginning of auto square off mode of the MIS/CO product. Since these are system-based actions and successful triggering of time based square off may depend on variables which maybe beyond the control of Navia. Navia does not in any manner guarantee the successful triggering of time based square off under MIS/CO product. It is the responsibility and onus of the client to continuously monitor the positions taken under the intraday products and square them off well before the stipulated cut off time for time based square off. In the event of trading system failure during this time, Navia shall on a best effort basis square off clients MIS positions in alternate system, if available and possible. Due to the vast number of such positions that may be required to be squared off manually, it may not be possible for Navia to successfully square off clients MIS/CO positions during times of system failure. Under such circumstances client cannot hold Navia responsible for any losses/charges
3) Margin Call square off – Margin Trade Funding (MTF) account:
Navia shall make the margin Call under the MTF trading account as per SEBI guidelines. As long as there is a MTF position in the client account a MTF report would be emailed to client on daily basis. If there is a margin call it will be reflected in this report. If there is a shortage of funds in the report, it means there is a margin call and client need to immediately bring in the required shortage either in the form of funds or securities. If the client does not bring in the required margins, then Navia can liquidate/sell the shares (funded shares and Pledged shares) if the client fails to meet the margin call requirements.
CLIENT UNPAID SECURITIES PLEDGE ACCOUNT (CUSPA) Policy
Navia shall transfer the clients’ securities received in pay-out (T+1) to clients’ demat account within one working day. But in case if the securities received in pay-out are not paid fully by the client, then Navia may transfer those securities to the client’s demat account and an auto-pledge (without any specific instruction from the client) shall be created in favour of "CLIENT UNPAID SECURITIES PLEDGE ACCOUNT (CUSPA)". The pledge shall be released so that the securities are available as free balance to the client only upon receipt of funds. Further if the client fails to meet the funds pay-in obligation on the settlement day, Navia shall liquidate the securities in the market on the next trading day to recover the debits/dues in the account including the penalty/interest/ accrued interest/DP charges/ any other uncleared charges etc.
Navia shall liquidate these securities in the CUSPA pledge account based on various parameters including but not limited to liquidity, volatility, categorization, concentration, or any single stock or set of stocks that has value close to the amount due, or based on any corporate action that is getting triggered in the stocks held or events that could trigger price fluctuation in any particular sector or a particular company. Navia may at its sole discretion, determine the time of sale and securities to be disposed off (not necessarily based on FIFO method) and or which open position is / are to be liquidated / closed. Further Navia shall not make any pre-order confirmation /margin calls prior to the liquidation of the securities and Navia shall not be held liable for any loss that arise due to the liquidation of securities.
Navia shall not allow the client to initiate any trade for the remainder of that day, immediately after such liquidation of the securities that are lying in the CUSPA Account.
Policy for Penny stock:
It is a stock that trades at a relatively low price and market capitalization. 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. Depending on the market condition and Margin policy of the company, RMS desk reserves the right to refuse to provide the exposure / margin in penny stocks and opportunity losses if any, on account of such refusal shall be borne by the client only
Setting up clients' exposure limits:
Exposures are set in the trading terminal based on the margin deposited by the client to the trading account, and the client can trade based on the margins set in the system. Navia may from time to time introduce various margin exposures/Trading limit policies, including exposure limits, turnover limits, order quantity /Order value and/or any kind of order parameter checks in respect of which orders can be placed in the terminal. Navia may at its discretion vary or reduce the limits or impose new limits urgently on the basis of Navia’s risk perception and other factors considered relevant for the trading 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. On such occasion, Navia may be unable to inform the client of such variation, reduction or imposition in advance and the client agrees that Navia shall not be responsible for such variation, reduction or imposition or the client’s inability to route any order through Navia’s trading system on account of any such variation, reduction or imposition of limits.
Further client agrees that Navia may at any time, at its sole discretion and without prior notice, prohibit or restrict the client’s ability to place orders or trade in securities through Navia, or it may subject any order placed by the client to review before its entry into the trading systems and may refuse to execute / allow execution of orders due to but not limited to the reason of lack of margin/securities or the order being outside the limits set by Navia / exchange / SEBI or any other reasons which Navia 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.
Navia has margin-based RMS system, and the exposure limits are set generally based on the availability of the Margin in the client account. This margin may be in the form of cash and or in the form of securities Pledged with Navia. On a daily basis, Navia shall upload the client’s base capital including ledger balance and the client’s collateral deposits through margin pledge after applying the appropriate haircut. The client can trade up to a pre-determined number of times of the margin (‘’the Multiple’’) for the respective securities as defined in the Risk management policy/FAQ.
Margin benefit based on the Credit For sale.
Navia shall provide the benefit of the “credit for sale” (CFS) after deducting the debits if any, to the Client, for taking the fresh positions. The CFS benefit can be availed on T+1.
Navia, shall suspend a client's Trading Account if there are no trades in the account for a consecutive period of twelve months. This measure is taken to prevent the misuse of dormant accounts and maintain regulatory compliance.
To reactivate a trading account that has been suspended due to inactivity, the client shall be required to resubmit the Know Your Customer (KYC) documents.
Navia, shall conduct due diligence on the updated KYC documents provided by the client. This due diligence includes verifying the client's identity, financial information, and other relevant details.
Upon satisfactory completion of the due diligence process and the verification of the updated KYC information, the Company will proceed to reactivate the trading account. The client will then regain access to their account and be able to resume trading.
As per the SEBI circular No. SEBI/HO/MIRSD/MIRSD2/CIR/2016/95 dated 26th September 2016 Clause 2.6, Stock brokers shall not grant further exposure to the clients when debit balances arise out of client's failure to pay the required amount and such debit balances continues beyond 5 trading days from the date of pay-in.
If the client fails to clear the debit balance beyond 5 working days from the date of pay-in or in other words 6 working days from the date of trade i.e., T+1+5 trading days (excluding Saturday /Sunday and Holidays), Navia shall block such client account and shall not grant any further exposure till the client clears the debit. Further, if the client clears the debit in account, Navia shall unblock the account for further trading on the next working day.
Clients must maintain sufficient margins in the account for the trades and transfer additional funds if there were to be a margin shortfall, which occurs when there is insufficient funds or insufficient margin in the account.
Exchange imposes margin penalty @ 1% or 5% (as per the number of instances of shortfall in a particular month) on the total margin shortfall in the futures and Options segment trades, Navia shall pass this penalty amount to the client's respective trading account.
1. Regulatory conditions under which a client may not be allowed to take further positions or Navia may have to close the existing positions of the client:
In case overall position in a contract has reached the Regulators prescribed Exchange limit/ Market wide open interest limit / then client may not be allowed to take further positions, till such time Regulators prescribed limit comes below the threshold level.
2. PMLA Guidelines:
Clients shall be categorized as High, Medium, and Low risk as per their risk appetite and their current profile as mentioned in Know your client form (KYC). The same will be reviewed at regular intervals.
3. Exposure to clients may be governed by customer profiling mentioned above and as well as by the clients' trading volumes in relation to their stated financial income, as declared to Navia.
4. Suspending Client’s trading account:
Navia may withhold the payout of client and suspend his trading account due to any internal surveillance (if client indulges into manipulative trade practice) or regulatory orders (debarring orders).
5. Dormant Account:
If the client has not traded in any particular segment for a period of 365 days, (not traded for 12 months), the account will be treated as dormant and client trading account shall be suspended from further trading. The client can activate the account by re-submitting the KYC.
6. Additional Surveillance Margin ( ASM)
In order to enhance market integrity and safeguard the interest of the investors, SEBI has introduced additional surveillance margin (ASM) on securities with surveillance concerns based on objective parameters viz. Price / Volume variation, Volatility etc. Navia as a risk containment measure shall allow trading in these shares only on Cash & Carry product (CNC) i.e 100% margin
7.Graded Surveillance Measures. (GSM)
In order to enhance market integrity and safeguard the interest of the investors, SEBI has introduced the Graded Surveillance Measures (GSM) on securities that witness abnormal price rise and do not commensurate with the net worth and fundamentals of the company. Navia as a measure, shall block all these securities as per the GSM list on a regular basis, and shall not allow the clients to take fresh positions but allow the clients to liquidate these securities if client holds the same in the account.
8. Stocks are blocked from trading based on the unsolicited SMS
Navia shall block from trading in the securities for which unsolicited recommendations are being circulated and reported by Exchanges.
9. Expiry Day Trading Policy
As a process, Navia shall block creation of new positions in all the current month derivative contracts under NRML product on the day of expiry. Navia shall closely monitor any physical settlement of the derivative contracts in the future and options segment. Navia shall follow the below actions on the expiry day;
In the event of such square off/ close out of the contracts, the client agrees to indemnify and bear all the losses based on actual executed prices, and hold harmless Navia from any, and against all loss, damages claim, expenses and costs due to the squaring off the entire positions or not squaring off the positions thereby resulting in Physical delivery.
Policy on the Physical settlement of the derivative contracts in the Futures / Options segment.
The physical settlement of stock derivatives takes place by giving or taking delivery of the actual shares. Physical settlement of stock derivatives is allowed on expiry for the clients meeting below requirements:
In case the client fails to meet securities obligation, the given settlement would result in a short delivery. Appropriate penalties to the tune of 20% or more will be applicable. It is the responsibility of client to understand the physical settlement process well.
Conditions under which a client may not be allowed to take further/fresh position, or the broker may close the existing position of a client:
We have margin-based RMS system. Client may take exposure up to the amount of margin available as per our RMS policy of the company. The existing position of the client is also liable to square off/Close out without giving notice due to shortage of margin/non-payment for their pay in obligation/outstanding debts. The following are the condition under which the client is not allowed to trade further:
Navia shall follow the process below and shall square off the entire ITM and CTM contracts before devolving to the futures contract. The Process is given below.
Certain long dated, Deep ITM and Deep OTM options are very illiquid. As a result, they have a very high
Bid/Ask spread, they may have very low or NIL volumes, very low or NIL Open Interest (OI). Regulators
have also introduced guidelines to prevent,
1) Illiquid options from being used to create artificial profit or loss
2) fat finger errors
3) orders being placed far away from their intrinsic values.
To complement the regulatory guidelines and to safeguard our clients' interest, Illiquid Options and
futures are blocked as per Navia’s Risk Management policy to avoid clients being stuck with a position
in the absence of counter parties to cover the same. A risk arises when a client is unable to square off
the position due to non-availability of counter party which is highly common in illiquid contracts. As a
result of this, client would necessarily be required to bring in additional margins, failure of which
would attract penalties. These penalties will be on the broker for not exercising due diligence to
prevent trading in illiquid contracts. To avoid these scenarios, Navia blocks illiquid contracts.
For more details on our Risk Management Policy please refer the FAQ’s
This is a special order type where you can place a buy or sell order at any price and it will stay valid till the time it gets triggered subject to a maximum duration of one year for equities and 1day prior to contract expiry for derivatives
Let’s take an example. HDFC Bank quoting at 1600 and if you want to buy it at 1455 you can place the GTT as explained in the screenshot below.
In the above GTT order form, Order will get triggered once the price touches 1450 and get executed at any price between 1450 and 1455.
GTT order can be placed only as CNC in equity and NRML for Derivatives, which means that necessary margin/ holdings would be required for a GTT order to be sent to exchange when triggered. Also, GTT can be placed only as a limit order with a trigger price. For a buy order, the trigger price should be preferably lower than the limit price and for a sell order, the trigger price should be preferably higher than the limit price for better chance of GTT orders getting traded.
The orders once placed can be viewed only under GTT Order Book and it will not reflect in the normal Order Book. You can also modify or cancel your GTT orders until it gets triggered.
Good Till Trigger order, as the name suggests is valid only till the order gets triggered or for a period of 1 year for Equity and 1 day prior to expiry for Derivatives, whichever is earlier. The moment your GTT order gets triggered, it loses its validity beyond that day (ie., the day of trigger)
GTT order does not assure execution of an order and includes/involves all risks with respect to Internet Based Trading and risks with respect to trading in the Capital Markets segments will extend for trading using the GTT orders as well. All rules and regulations prescribed by SEBI and the Exchanges would have to strictly be followed while placing instructions through Navia. All other laws and regulations as per the Republic of India would be applicable.
Navia, at all times, bears no liability towards clients for any reason whatsoever with respect to using the GTT Feature; including but not limited to, non execution of any order using the GTT Feature / either leg of the order, any opportunity loss for non execution of such orders/trades, any cancellation, rejection or non placement of any orders, and any such other claims which may arise from you with respect to using the GTT Feature.
The terms and conditions of GTT is subject to change from time to time at the sole discretion of
Navia without prior intimation. It is your responsibility to review this Terms of Usage every time
you use the GTT Feature.
To know about the instruments available for trading in GTT, Click here
Margin Trade Funding (MTF) is a funding product offered by NAVIA and in this the stocks are funded as per the SEBI circular, SEBI/HO/MRD/DP/CIR/P/2016/135 dated December 16, 2016, i.e Group 1 stocks. The client can buy the shares by paying the minimum margin as per MTF terms either in the form of Cash margin / Collateral through margin pledge as per the MTF product terms. The shares bought under this product shall be uploaded as positions with cost price to the trading terminal and MTM is monitored during the market. The client’s collateral is also uploaded to the MTF product and cannot sell these collaterals through the MTF product. Further, if the client wants to sell the collateral, the client has to send an e-mail to [email protected] to release the collateral from the MTF product and upload the same to the normal segment. This request will be carried out within one working day and shall allow the clients to sell the collateral through normal product.
Navia shall not allow single scrip funding or accepting it as Collateral for the margin under the MTF product. Further if the client buys and accumulates shares on the single scrip concentration, then Navia shall liquidate these single scrip shares without any prior notice to the client.
If any intraday position or an MIS trade is not squared off on the same day due to any link or system failure or any risks associated with internet/wireless-based trading which may occur at the end of the Client, NAVIA or the respective Exchange, it shall be treated as a Cash and Carry ("CNC") or NRML position and carried forward to the next trading day. In case of such a situation arising, the onus of squaring off the position will be on the Client. Our RMS desk shall square off any such position, without the requirement of a margin call, if the necessary cash is not available in the Client's account.
Navia shall not fund the trading related charges or the booked losses at any time, and if these amounts are not paid by the client, Navia, as a monthly process, shall adjust the cash margin if any to the debits or liquidate the collateral shares in pledge to clear these debits. Check here for more details on MTF
Navia Plus MF is only an order collection platform that collects orders on behalf of clients and places them on BSE Star MF for execution. The Client agrees that NAVIA is not liable or responsible and does not represent or warrant for any damages regarding non-execution of orders or any incorrect execution of orders with regard to the funds chosen by the Client due to, but not being limited to, any link/system failure, sufficient/insufficient funds in the trading account which may occur at the end of the client, NAVIA or the exchange platform.
Policy on the limit setting in the Exchange terminals.
Navia has set limits in Trading Terminals based on the risk mitigation and safe guard mechanism from “fat finger trades” on the following basis:
Further, if at any time if the NEAT terminal set limits exceeds, Navia shall review and reset the limits as per the risk mechanism of the Company and shall allow the clients to trade. But in the meantime, if there are any order rejections or the trading down time, due to exceeding the various set limit, the client agrees that, Navia shall not able to be responsible or liable for any kind of damages / losses / opportunity losses arising out of exceeding the NEAT set limit.
Contract notes and margin statement
NAVIA will issue contract notes & margin statements to its clients within 24 hours of the close of trading. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin status which is also available to be viewed on their respective Back office reports available online.
Policy on hedging the positions:
Client can hedge their open positions to minimize the loss, only if there is full margin available for the current positions. Navia shall allow these hedging, as per the margin policy of the Company.
Delivery Policy in Commodity Futures :
Navia shall not allow the client to mark delivery of open positions of a future commodity contract and the open positions shall be closed before the tender period starts. Tender period starts 5 days prior to expiry day. If an open position of a future contract is not closed on or before the expiry date by the client, depending on the long/short position, Navia shall close out all the open positions, and the client shall be fully liable to indemnify Navia, for any loss/losses that may occur due to the close out of the positions. In case of Natural Gas and Crude Oil contracts, positions are allowed till the expiry date.
Policy on the futures Contracts / products/shares/illiquid option contracts allowed for the trading:
Navia, reserves the right to add or remove any Contracts (Liquid /Illiquid) Commodity/ Equity products from the trading platform without giving any prior notice or by intimating the client in advance. Navia shall not provide the entire commodity products ( Non Agri) / certain Equity Futures & Option Contracts for trading.
Applicable brokerage rate:
The Client agrees to pay the brokerage charges, Exchanges related charges, statutory charges and any other charges (including but not limited to security handling charges on settlement) as it exists from time to time and as it applies to the Client's account in respect of transactions and services that the Client receives from Navia. The brokerage shall be paid in the manner intimated by Navia to the Client from time to time, including as a percentage of the value or the trade or as a flat fee or otherwise, together with the tax as may be applicable from time to time on the same. Brokerage will be charged within the limits prescribed by SEBI/Exchange and other charges are chargeable / payable as per the Tariff Sheet provided by Navia to the client from time to time.
Deregistering a client:
Notwithstanding anything to the contrary stated in the agreement, Navia shall be entitled to terminate the agreement with immediate effect in any of the following circumstances.
Dormant or Inactive account:
Navia as a preventive method to protect the account of customers shall deactivate those accounts that have not traded in the given period of twelve months,( 365 days ). Once the account is deactivated customer will not be able to place any order in any trade segments. As a practice, Navia will exercise due diligence in verifying customer credentials before reactivating a dormant account. The above stated policy may be modified at any time in accordance to the various rules, regulations, byelaws and guidelines that may be prescribed by SEBI, Exchange or any other competent authority or as per the internal policy of the organization from time to time. This policy for dormant account is over and above the transaction monitoring in dormant account as per the Anti-Money laundering policy of the organization. Check here for details of this process.
Recording of Conversations:
The Client agrees and authorizes Navia, at its sole discretion and without prior notice to the Client, to record any conversation between the Client and Navia. Such recording shall be accepted as conclusive and binding for all purpose s including resolving disputes regarding execution of orders subject to these Terms.
Client code Modification policy:
Navia, in terms of the provisions of the Rules, Bye Laws and business rules of the exchange, and as per SEBI, client code modifications in the intraday are allowed for those reasons like, typographical errors, and genuine errors. If at any time, in the event of client code modification, if the exchange imposes/levy penalty to Navia, the same shall be debited to the client account without any intimation. Further, the client agrees to indemnify Navia from all damages/losses arising out of this code modification.
Physical /Digital contract note:
The contract notes are the details of the transactions done by the client on the given day, and as per the guide lines it has to be sent to the clients within 24 hours. If at any time the digital contract note sent to the client returns/bounces due to the various reasons , and the reasons provided by the client does not satisfy/clarify the bounced reasons, then Navia, shall deactivate the client trading account from further trading, until the client submits the fresh e-mail id.
Technical/ Communication issues:
Trading in exchange is in electronic mode based on VSAT, leased line, Broad Band, ISDN, combination of technologies and computer systems to place and route orders. The client understands and agrees that there exists a possibility of communication failure or system problem or slow or delayed response from the system or trading halt or any break down in our back office / front end system, or any such other problems/glitch whereby not being able to establish access to the trading system/network, which may be beyond the control of Navia . This issue may result in delay in processing or not processing buy or sell orders either in part or in full. The client further agrees that, client shall be fully liable and responsible for any such problem/ fault and Navia shall not be held liable on these technical issues and it is being agreed and covered under the internet and wireless based trading agreement.
Authorized Representative:
The instructions issued by an authorized representative of the Client shall be binding on the Client in accordance with the letter authorizing the said representative to deal on behalf of the Client. The Client is aware that authentication technologies and strict security measures are required from the Internet trading through order routed system and undertakes to ensure that the security code(s) of the Client and/or his/her/its authorized representative.
Broker’s Liability:
Under no circumstances shall Navia or anyone involved in creating, producing, delivering or managing the Member's services be liable for any direct, incidental, special or consequential damages that result from the use of or inability to use the service, delay in transmission of any communication, in each case for any reason whatsoever (including on account of breakdown in systems/trading down time ) or out of any breach of any warranty or due to any fraud committed by any person whether in the employment of the member or otherwise.
Communication/Notices:
Client can view details of his ledger, margin, shortfall etc. through his secured login portal on Navia website or by logging to the Mobile App, and the client has to be aware about his position, outstanding balance and Risk on the holding positions. Further, Navia is under no legal obligation to send any separate communication other than the contract note and margin details and these shall be communicated through SMS / Email id’s registered with Navia.
Policy on the client's default or non-settlement of dues:
The Client agrees and authorizes Navia, at its sole discretion and without prior notice to the Client, to record and report the client default status/non settlement of dues/disputes/civil/criminal case details to any agency/regulator/forum/ at any time as and Navia requires and feels.
NAVIA has provided client with a dedicated email ID and telephone numbers for various of its services as given below and as available on the contact us page of the website. https://tradeplusonline.com/Contact-Us
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] and for the escalations [email protected]. The resolution of the Complaint shall be done at the earliest and the same shall be recorded in the register along with the date of resolution.
Notes:
Enrollment: By creating a SIP on a stock Basket, you agree to invest at regular intervals in a predetermined basket of stocks for quantity and price as decided by you.
Frequency: You can choose the frequency of your SIP investments (e.g., Weekly or monthly) as per your convenience.
Investment Amount: You are required to specify the number of shares and the limit or market price of the share that you wish to invest in the selected stock basket for each SIP installment.
Auto-Debit: Funds for the SIP will be auto-debited from your linked ledger account on the scheduled SIP date, once the SIP orders are traded.
Flexibility: You have the option to modify or cancel your SIP conditions anytime through the Online facility provided.
Timings: Your SIP orders would be placed by Navia Markets Limited between 10 a.m, and 2 p.m. on trading day on a best effort basis. We do not guarantee any best price during this period. If SIP date is a trading holiday, then your Stock Basket SIP will be placed on the next trading day.
Execution risk: If any orders in your Stock Basket are placed at limit price, then order execution of such orders are not guaranteed. Market orders may also not be traded if there is a prize freeze. Please ensure to keep sufficient funds available in your trading ledger. The approximate amount required is calculated based on last traded price. However we suggest you to keep atleast 10% more to avoid any possibilities of partial trades or order rejections due to market price fluctuation and insufficient balance
Market Risks: Investing in stocks involves market risks, and the value of your investments may fluctuate. We do not guarantee returns.
Charges: Applicable fees and charges, including brokerage charges, will be deducted from your account.
Legal Compliance: You agree to comply with all applicable laws and regulations related to stock market investments.
Risk Management: Navia shall also at its sole discretion decide to disable or withdraw a particular security from the Stock Basket with intimation to the clients and without assigning any reasons thereof.
Termination: We reserve the right to terminate your SIP in case of non-payment or violation of terms.
Communication: You will be notified via Whatsapp / SMS and Emails once the SIP Orders are Traded on a best effort basis. You consent to receiving communication, statements, and updates via email or other electronic means.
Disclaimer: Navia Markets Ltd. and its representatives are not liable for any losses incurred due to market fluctuations or any other circumstances beyond our control.
Please read and understand these terms and conditions carefully before enrolling in the Stock Basket SIP. If you agree to these terms, you can proceed with your SIP investments.
The Prevention of Money Laundering Act, 2002 came into effect from 1st July 2005. Necessary Notifications / Rules under the said Act were published in the Gazette of India on 1st July 2005 by the Department of Revenue, Ministry of Finance, and Government of India.
As per PMLA every reporting entity (which includes intermediaries registered under section 12 of the SEBI Act, i.e. a stock-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, asset management company, depository participant, merchant banker, portfolio manager, investment adviser and any other intermediary associated with the securities market and registered under Section 12 of the SEBI Act and stock exchanges), shall have to adhere to the client account opening procedures, maintenance records and reporting of such transactions as prescribed by the PMLA and rules notified there under.
SEBI vide circular dated 18th January 2006 required Market intermediaries to lay down policy framework for anti-money laundering measures to be followed. NAVIA being a Stock Broker needs to adhere to the same. SEBI has issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT until December 15, 2008.
SEBI has also issued a Master Circular dated 3 rd February 2023 with Guidelines on Anti-Money Laundering (AML) Standards and Combating the Financing of Terrorism (CFT)/ Obligations of Securities Market Intermediaries under the Prevention of Money Laundering Act, 2002 and Rules framed there under
The objective of the Prevention of Money Laundering Act (PMLA) policy is to prevent and combat money laundering and the financing of terrorism. To combat drug trafficking, terrorism and other organized and serious crimes have all emphasized the need for financial institutions, including securities market intermediaries, to establish internal procedures that effectively serve to prevent and impede money laundering and terrorist financing.
The policy aims to establish a legal framework and regulatory mechanism to prevent the generation of black money and the illegal transfer of funds to promote transparency and accountability in financial transactions that covers:
3.1 PRINCIPAL OFFICER
To ensure proper discharge of legal obligations to report suspicious transactions to the authorities, an officer of the company will be designated as “Principal Officer”.
For the purpose of monitoring the transaction and reporting the same to the FIU-IND, Mr. J Rajesh Kumar is appointed as the principal officer and the same has been reported to the FIU-IND.
Designated Principal Officer: Mr. J Rajesh Kumar
Email id: [email protected]
Tel No:
8037017374
The Principal Officer will be responsible for
3.2 DESIGNATED DIRECTOR
The Company shall nominate the Whole-time Director & CEO who oversees the operations of the Company including implementation of Prevention of Money Laundering Rules, as the Designated Director of the Company under the Prevention of Money Laundering Act, 2002 and Rules framed there under who shall be responsible for ensuring overall compliance with the obligations imposed under chapter IV of the Acts and Rules.
For the purpose of ensuring appropriate systems and processes are in place to prevent money laundering and terrorist financing, Mr. S K Hozefa is appointed as the Designated Director and the same has been reported to the FIU-IND.
Designated Director: Mr. S K Hozefa
Email id: [email protected]
Tel No: 8037017373
The main aspect of this policy is the Client Due Diligence that includes the following four specific parameters:
The CDD measures comprise the following:
5.1 POLICY FOR ACCEPTANCE OF CLIENTS
The Customer Acceptance norms specified herein below shall be applicable to all clients of Navia Markets Limited. All persons sourcing clients on behalf of Navia Markets Limited shall be required to adhere to the requirements specified herein below that are aimed to identify the type of clients.
In normal circumstances, all prospective clients are accepted as client by the company except the clients as per the Debarred Clients.
In-person Verification: In-person verification (IPV) shall be mandatory for all clients. Accounts shall be opened only for those persons whose in-person verification has been done as per the SEBI/Stock Exchange/ Depository or other regulations in this regard.
KYC Procedures : Accept only clients in respect of whom complete KYC procedures have been completed. Clients shall not be opened in case of client fails to submit any required documents as per Customer Identification Policy below:
Debarred Clients : Before opening of clients accounts, check should be done to verify whether the client’s name matches with names in any of the checklist.
Accounts should not be opened of client with known criminal background.
Clients of Special Category (CSC) :
We have maintained the internal management system which reflects the various categories of the clients who have registered and trading with the company. The client category segregation is automated in the system and system will allocate the category as follows:
Designated Individuals / Entities :
An updated list of individuals and entities which are subject to various sanction measures such as freezing of assets, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations Security Council Resolutions.
Navia ensures that accounts are not opened in the name of anyone whose name appears in the said list. Navia shall continuously scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list. Full details of accounts bearing resemblance with any of the individuals/ entities in the list shall be immediately be intimated to SEBI and FIU-IND.
Additional Segment Activation :
For all clients applying for trading rights in the futures and options segments, further details / documents substantiating ownership of Assets would be required. Illustrative list is as follows:
E-KYC Authentication :
No account shall be opened for the client whose E-KYC Authentication or Yes/No Authentication for the Aadhaar number issued by the Unique Identification Authority of India fails.
Treatment of Accounts of Clients of Special Category :
NRI: While opening NRI account utmost care should be exercised. While opening an NRI Repatriable or NRI Non Repatriable inter alia, the following documents should be collected from the clients:
NRE Account – Notarized and Self attested copies of
NRO Cash & Derivatives Account – Notarized and Self attested copies of
High Networth Clients: High networth clients could be classified as such if at the account opening stage or during the course of the relationship.
Trust, Charity and NGOs: Both public as well private, registered as well as unregistered trust will have to be classified in the Special Category. Any Charitable or Non governmental organization or a Non profit organization will also be classified herein.
Close family shareholdings or Beneficial Ownership: In case of close family shareholdings the objective is to understand whether the beneficiaries of two or more accounts, which may also be opened at different times are same, then both need to be marked under this special category.
Politically Exposed Persons: In case of PEPs, the account should be opened only after consent of the senior management and all the required documents are collected and client should be marked as PEP in records. Where a client has been accepted and the client or beneficial owner is subsequently found to be, or subsequently becomes a PEP, registered intermediaries shall obtain senior management approval to continue the business relationship.
Clients in High Risk Country: No accounts shall be opened if received from a client who was residing in a high risk jurisdiction and may have investment proceeds which may have also originated from these countries. The list may be obtained from the Financial Action Task Force (FATF) statements that identify countries that do not insufficiently apply the FATF Recommendations, published by the FATF on its website.
The parameters of risk perception in terms of the nature of business activity, location of clients, mode of payments, volume or turnover, social and financial status etc shall be considered to enable categorization of customers into low, medium and high risk. In case of high risk clients, compliance has to approve the same for onboarding of such clients.
5.2 CLIENT IDENTIFICATION PROCEDURE
The following Client Identification Norms shall be adhered to in respect of all new clients to establish the identity of the client along with proof of address to prevent opening of account which is fictious/ benami/ anonymous in nature.
SEBI / Stock Exchanges / The Depositories and other regulatory authorities under which Navia is governed from time to time specify various KYC norms / guidelines that have to be adhered to in order to be able to identity customers. Such norms and guidelines should be followed scrupulously at the time of customer acceptance.
Basic KYC Norms to be followed for verification / scrutiny
5.3 RELIANCE ON THIRD PARTY FOR CARRYING OUT CDD
Navia may rely on a third party for the purpose of
Such reliance shall be subject to the conditions that are specified in Rule 9(2) of the PML Rules and shall be in accordance with the regulations and circulars / guidelines issued by SEBI from time to time.
5.4 RISK MANAGEMENT
Risk Based Approach shall be applied for mitigation and management of the risk. Clients are categorized Based on the based on the client’s background, type of business relationship or transaction, etc. Corporate and other entities other than the individual clients accounts also scrutinized before opening the trading account in the system. Further individual customers, are categorized, as HNI, HI- Retail customer apart from the net worth of the individual clients and we have segregated clients into the following risk categories based on the risk profile of the clients.
RISK ASSESSMENT - Based on the client profiles, the category is allotted to the client and these profiles are:
Based on the client profile, if the client is politically exposed person(PEP) or Relative of PEP, the necessary checks and balances are carried out prior to registration as client and necessary approvals will be obtained from the TOP MANAGEMENT of the company prior to open an account with the company to these persons. We identify the beneficial owner in a PEP client upon client’s declaration and take supporting document to ascertain the identity of such beneficial owner. Further, the existing client turned to the PEP, or relative of PEP, if any identified the necessary approvals will be obtained from the TOP MANAGEMENT to continue as client of the company.
High Risk Clients
Medium Risk Clients
Low Risk Clients
All clients not dealing with the above criteria are low risk clients.
5.5 MONITORING OF TRANSACTIONS
At regular interval, ongoing due diligence and scrutiny shall be conducted i.e. perform ongoing scrutiny of the transactions and account throughout the course of the business relationship to ensure that the transactions being conducted are consistent with the Organization’s knowledge of the client, its business and risk profile taking into account.
Navia shall apply higher levels of due diligence when an account is operated by a Power of attorney or where an account is opened by an intermediary in fiduciary capacity.
KYC documents will be taken for both the mandate holder / intermediary in fiduciary capacity and the account holder.
The surveillance department of Navia handles this part of the anti-money laundering policy, and surveillance is the one which gives or cuts the exposure or the limit for the purchase or sale of securities. The margin exposure is decided on the credit balances available in the client account and also as per the risk parameters set in the system.
The surveillance department monitors each and every transaction of the clients. If any heavy bulk or suspicious transaction is done by the client, then the same is reported to the Principal Officer of the company.
Suspicious transactions include exchange generated alerts in addition to in-house offline alerts.
An indicative list of suspicious activities:
The Suspicious Transaction (STR) shall be furnished within 7 days of arriving at a conclusion that any transaction, whether cash or non cash, or a series of transactions integrally connected are of suspicious nature. The Principal Officer shall record his / her reasons for treating any transaction or a series or transactions as suspicious. It shall be ensured that there is no undue delay in arriving at such conclusion once a suspicious transaction report is received from surveillance team. Such report shall be made available to the competent authorities on request.
While determining suspicious transactions, Navia shall be guided by definition of suspicious transaction contained in the Rules as amended from time to time. Navia ensures that there is no tipping off to the customer at any level.
Suspicious transaction reporting is to Financial Intelligence Unit-India (FIU-IND)
In terms of the Rules, Navia shall report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) in respect of transactions referred to in Rule 3 at the following address or any address as may be specified by FIU from time to time:
Financial Intelligence Unit – India
6th Floor, Tower-2,
Jeevan Bharati Building,
Connaught Place,
New Delhi-110001, INDIA
Website : https://fiuindia.gov.in/
7.1 Information to be maintained
Navia shall maintain and preserve the following information in respect of transactions referred to in Rule 3 of the Rules including all necessary information specified by the regulator to permit reconstruction of individual transactions in respect of transactions referred to in Rule 3 of the PML Rules:
7.2 Record Keeping
Navia shall ensure compliance with the record keeping requirement as mentioned in the SEBI Act, 1992, Rules and Regulations made thereunder, PMLA as well as other relevant legislation, Rules, Regulations, Exchange Byelaws and Circulars.
In cases of any suspicion of laundered money or terrorist property, Navia shall retain the following information for the accounts of its clients in order to maintain a satisfactory audit trail:
7.3 Retention of Records
Navia shall take appropriate steps to evolve a system for proper maintenance and preservation of account information in a matter that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.
Navia shall observe following document retention terms:
Navia shall maintain and preserve a records for a period of five years from the date of transaction between Navia and the client, all necessary records of transactions both domestic and international which will permit reconstruction of individual transactions so as to provide if necessary evidence for prosecution of persons involved in criminal activity.
Navia shall maintain and preserve the record of documents evidencing the identity of clients and beneficial owners as well as accounts file and business correspondence for a period of 5 years after the business relationship between a client and Navia has ended or the account has been closed whichever is later.
Navia shall maintain and preserve the records of information related to transactions whether attempted or executed which are reported to the Director, FIU-IND as required under Rules 7 & 8 of the PML Rules for a period of 5 years from the date of transaction between the client and Navia or until it is confirmed that the case has been closed.
8.1 Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA), relating to the purpose of prevention of and for copying with terrorist activities was brought into effect through UAPA Amendment Act, 2008. In this regard, the Central Government has issued an Order dated Aug 27, 2009 detailing the procedure for the implementation of Section 51A of the UAPA.
8.2 Under the aforementioned Section, the Central Government of India has outlined a procedure through an Order dated Feb 02, 2021 for strict compliance. These guidelines have been further amended vide a Gazatte Notification dated June 08, 2021
8.3 SEBI communicates the list of designated individuals / terrorists in pursuance to Section 35(1) of UAPA 1967, declared by The Ministry of Home Affairs.
8.4. An updated list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website at https://press.un.org/en/content/press-release.
8.5 All orders under section 35(1) and 51A of UAPA relating to funds, financial assets or economic resources or related services, circulated by SEBI from time to time shall be taken note of Navia for Compliance.
8.6. Navia ensures that accounts are not opened in the name of anyone whose name appears in the said list. Navia will maintain updated designated lists in electronic form and run a check on the given paraments on a regular basis to verify whether individuals or entities listed in the order are holding any funds, financial assets or economic resources or related services held in the form of securities with us.
8.7 In the event, particulars of any of customers match the particulars of designated individuals/ entities, Navia shall immediately not later than 24 hours from the time of finding out such client, inform all particulars of the funds, financial assets or economic resources or related services held in the form of securities, held by such clients on their books to the Central [designated] Nodal Officer for the UAPA, at Fax No.011-23092551 and also conveyed over telephone No. 011-23092548. The particulars apart from being sent by post shall necessarily be conveyed on email id: [email protected].
8.8. Navia shall also send a copy of the communication mentioned above to the UAPA Nodal Officer of the State/UT where the account is held and to SEBI and FIU-IND, without delay. The communication shall be sent to SEBI through post and through email ([email protected]) to the UAPA nodal officer of SEBI, Deputy General Manager, Division of FATF, Market Intermediaries Regulation and Supervision Department, Securities and Exchange Board of India, SEBI Bhavan II, Plot No. C7, “G” Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051. The consolidated list of UAPA Nodal Officers is available at the website of Government of India, Ministry of Home Affairs.
Implementation of KYC procedures requires Navia to demand certain information from Customer which may be of personal nature or which has hitherto never been called for. This sometimes leads to lot of questioning by the client as to the motive and purpose of collecting such information. The Team Leader / Relationship Manager shall explain to the Customers the regulatory requirements and benefits of adhering to the KYC guidelines and seek co-operation of the client.
Employee hiring is processed through three modes. First mode is reference through the existing employee’s; second mode is through the Consultants and third mode of recruitment through search of job portals. All recruitments happen through minimum of two level of interviews one level through HR and second level is through the respective reporting manager. For manager and above positions, Top management also interview and finalize the candidate for the respective position and also does necessary checks based on the reference provided by the candidate and other modes completed before offering the candidates.
Navia has an ongoing employee training program for its staff in relation to AML & CFT procedures. We focus on Frontline staff, back office staff, compliance staff, risk management staff & staff dealing with new clients. Training is Crucial for all staff members in order to fully understand the rationale behind these directives, obligations & requirements; and to implement them consistently and be sensitized to the risks of the systems which may be misused by unscrupulous elements.
Principal Officer & Designated officer shall be the authority to review the policy updated with any amendment etc., as directed by SEBI / FIU-IND and all changes shall be deemed to be incorporated in this policy from their effective date. This AML policy is designed to achieve and monitor our Company’s ongoing compliance with the requirements of the PMLA and implementing regulations under it. The policy is reviewed within half year or as and when any important circulars are issued by any regulatory authority.
Navia may at any time amend these Terms, by modifying or rescinding any of the existing provisions or conditions or by adding any amendment on the web site. Navia shall not be required to communicate any modification or rescission individually to the Client either through physical or electronic form, any separate notice of amendment or modification is deemed to be waived by the Client. The continued use of the services of the member after such notice will constitute acknowledgement and acceptance of such amendment.
The Client hereby warrants that he is capable of executing the present agreement and that the terms of the present are not in contravention of any rights of any party with whom such client has any agreements, at any time prior to the execution of this agreement.
The client agrees to provide and continue to provide all details about themselves as may be required by NAVIA, including but not restricted to PAN Number or Aadhar card or Unique Identification Number (issued by SEBI) , and states all details and facts represented to NAVIA are true.
The Client is aware and acknowledges that trading over the internet involves many uncertain factors and complex hardware, software, systems, communication lines, peripherals, etc., which are susceptible to interruptions and dislocations; and the Online Trading Service of NAVIA may at any time be unavailable without further notice. NAVIA and the Exchange do not make any representation or warranty that the Online Trading Service of NAVIA will be available to the Client at all times without any interruption. The Client agrees that he shall not have any claim against the Exchange or NAVIA on account of any suspension, interruption, non-availability or malfunctioning of the Online Trading System or Service of NAVIA or the Exchange's service or systems for any reason whatsoever.
NAVIA states that it has complied with and will continuously comply and if not proposes to comply with all statutory and regulatory directions to offer the Internet Trading services through the website https://tradeplusonline.com and sub domains of tradeplusonline.com for dealing in cash, Mutual Fund and derivatives segment of the exchange
The Client warrants that all or any of the securities deposited by him with NAVIA in respect of margin requirements or otherwise, are owned by him and the title thereof is clear and free of encumbrances
The Client warrants that all or any of the securities deposited by him with NAVIA in respect of margin requirements or otherwise, are owned by him and the title thereof is clear and free of encumbrances.
The Client/s agree to indemnify and hold NAVIA harmless against any loss that may be suffered by it, its customers or a third party or any claim or action that may be initiated by a third party which is in any way the result of improper use of user ID and password by the Client/s
The Client hereby confirms and warrants that the Client authorises NAVIA to take all such steps on the Client’s behalf as may be required for provisions or to complete or settle any transactions entered into through or with NAVIA or executed by NAVIA on behalf of the Client. However, nothing herein shall oblige NAVIA to take such steps.
The Client agrees to pay to NAVIA brokerage, commission, fees, and the regulatory charges like, Exchange penalties, GST other taxes, stamp charges transaction expenses and clearing charges etc. as they exist from time to time and as they apply to the Client's account and transactions, and for the services that he receives from NAVIA.
A schedule of brokerage, fees and commissions, applicable service and other taxes and other transaction expenses is displayed by Navia on its website through the link given below and shall be provided by NAVIA to the Client from time to time upon request by the Client.
https://tradeplusonline.com/pricing
The Client agrees that none of the services available on the website shall amount to investment advice on the part of NAVIA. The Client agrees that in the event of NAVIA or any employee or official of NAVIA, providing any information, recommendation or advice to the client, the client may act upon the same at the sole risk and cost of the client, and NAVIA shall not be liable or responsible for the same.
NAVIA, and its officers, directors, partners, employees, agents and affiliates will have no liability with respect to any investment decisions or transactions of the client
NAVIA does not warrant that the service will be uninterrupted or error-free. The service is provided in an "as is" and "as available" basis without warranties of any kind, either express or implied, including, without limitation, those of merchantability and fitness for a particular purpose. The client agrees that NAVIA shall not be held responsible for delays in transmission of orders due to breakdown of the system or failure of communication facilities either due to the fault of the systems of NAVIA or of the Exchanges or otherwise or for any other delay beyond the reasonable control of NAVIA due to a breakdown or failure of communication facilities or for any other delay beyond the reasonable control of NAVIA.
All modification to this Agreement shall be made solely at the discretion of NAVIA and shall be intimated to the client by a suitable modification to the terms and conditions or other applicable section on the website or in any other manner.
In the event of death or insolvency of the client, winding up or liquidation, or their otherwise becoming incapable of receiving and paying for or delivering or transferring securities which the client has ordered to be bought or sold, NAVIA may close out the transaction of the client and the client or his legal representative shall be liable for any losses, costs and be entitled to any surplus which may result therefrom.
The client is aware that authentication technologies and strict securities measures are required for internet trading through order routed system and undertake to ensure that the password of the client and /or their authorized representatives are not revealed to any third party. The client also agrees to indemnify NAVIA from any loss, injury, claim or any action instituted against NAVIA arising from the misuse of the password by any party.
NAVIA shall not be responsible for delay or default in the performance of their obligations due to contingencies beyond their control, such as (including but not limited to) losses caused directly or indirectly by exchange or market rulings, suspension of trading, fire, flood, civil commotion, earthquake, war, strikes, failure of the systems, failure of the internet links or government / regulatory action.
In the event of any one or more of the provisions contained in this Agreement becoming invalid, illegal or unenforceable in any respect under any law for the time being in force, the validity, legality and enforceability of the remaining provisions contained herein shall not in any way be prejudiced or affected thereto.
All trades, transaction and contracts are subject to the Rules and Regulations of the respective Exchange on which the trades have been executed and shall be deemed to be and shall take effect as wholly made, entered into and to be performed as per the rules and regulations of the exchanges and the parties to such trade shall be deemed to have submitted to the jurisdiction as per the exchange rules, byelaws and regulations.
Further if the client at any time during the period of trading with Navia or immediately after, any dispute or differences arises between the parties hereto in relation to or in connection with the terms and Conditions or policies and procedures of the Company, shall be referred to the Exchanges investor Grievance Redressal Mechanism. But, if at any time if there are any disputes or differences referred to the Courts, the Jurisdiction shall be the Courts of CHENNAI only.
Notice
All notices, correspondences or communications issued under this agreement shall be served in any one or more of the following modes of communications and such notice or communication shall be served at the ordinary place of residence and/or last known web address / residing address and / or at the ordinary business address of the party to this agreement such as -
By selecting and accepting the “Terms and conditions”, during the login process or while applying for any service, the client agrees to be legally bound by these Terms and Conditions. The client agrees that NAVIA may at its sole discretion vary the terms and conditions from time to time and client agrees to abide by the same.
