APNA GODAM TECHNOLOGIES PRIVATE LIMITED

I. TRADING DAYS, TRADING HOURS AND TRADING HOLIDAYS

Trading Days and Trading Hours

For all commodities and commodity indices, the Platform will have trading session from Monday to Saturday as under and shall remain closed on Sunday, unless it is explicitly stated otherwise.

Session timings are as under.

Members can cancel their outstanding carry forward Good Till Date (GTD)/Good Till Cancelled (GTC) order.

Trading Holidays

• • With regard to trading holidays, Platform shall decide the common holiday list within the broad framework of the Negotiable Instruments Act, 1881. Platform shall also take into consideration Central/State/Local holidays. Platform shall notify the holiday list to the market well in advance under prior intimation on website.
• • For warehouse based trade the holiday of that state will be considered where warehouse situated.
• • For Spot based trade the holiday of that state will be considered where delivery address is situated

Holiday list: Rajasthan

II. TRANSACTION CHARGES

In terms of Bye-laws 3.2.h read with Regulation 6.2.1(e) of the Platform Bye-Laws and Regulations, the transaction charges and classification of commodities falling under Main & Special categories has been revised with effect from April 01, 2022.

The details of the transaction charges under different categories are as under:

The transaction charges for the Main Category commodities.

List of Market Maker and incentive payout report is disseminated on the Platform website.

III. ORDER MANAGEMENT

• • Limit order are priced orders specifying the price at order entry. Limit Orders are matched with counter orders at same (or better than) prices.
• • Market Order, which derives its price based on counter side order.

Order Validity

• • Good till Date order is available for execution till end of the date indicated in the order.
• • Good till Cancel order is available for execution till cancellation of order.

Modification of orders

• • A Member shall be permitted to modify or cancel his orders
• • The order can be modified by effecting changes in the order input parameters in the manner and on such condition as specified by the Platform.

Cancellation of orders

• • A Member shall be permitted to cancel his orders, provided a trade has not already taken place in respect of that order.

IV. TRADING PARAMETERS

Trading Attributes

• • Trading Symbol – The permitted lot size for contracts will be provided in the contract specifications from time to time. Orders can be submitted in the multiple of lot size.
• • Delivery Unit – The permitted delivery lot size for the contract will be provided in the contract specification from time to time. On expiry of contract, open position can be delivered in the multiple of delivery unit.
• • Minimum price tick - Tick size is the smallest price change that can occur for the trades on the Platform. The tick size for contracts shall be the same as provided in the contract specifications from time to time. Orders not in multiple of tick size will be rejected by the Platform.
• • Maximum Order Size - The maximum order size for the contracts shall be the same as provided in the contract specifications from time to time.
• • Quotation / Base Value – ndicates the price unit in which prices are broadcasted. e.g. Rs. Per Quintal (100 kg)

Daily Price Limits (DPL) for Commodity SBT Contracts

• • Base price for DPL: The base price for fixing the DPL slabs shall be the previous day’s closing price of the underlying contract on the respective stock Platform.
• • Breach of slab: A breach of the slab shall be considered when trading in a contract is executed at the upper or lower band of the prescribed slab. This is also called circuit breaker.

DPL for commodity SBT contracts based on agricultural goods

• • DPL for commodity SBT contracts based on agricultural goods is as under. It is 4% of Last Traded Price.
• • Once the initial slab limit is breached in any contract, the DPL for that contract shall be increased further by the ‘Enhanced Slab’ after the cooling off period of 15 minutes in the trading. During the cooling off period trading shall continue to be permitted within the previous slab of DPL. After the DPL is enhanced, trading shall be permitted throughout the day within the enhanced Aggregate DPL.
• • During the cooling-off period of 15 minutes, the trading shall be permitted, within the initial slab limit.
• • After the DPL is enhanced, trading shall be permitted throughout the day within the enhanced Aggregate DPL.

DPL on first trading day of the SBT contract

• • In order to prescribe DPL slabs for the first trading day (launch day) of each SBT contract, base price shall be determined on the basis of market feedback and the Platform will decide.

Modification of Client Codes post execution of trade

The stock Platforms allow modifications of client codes of non-institutional trades only to rectify a genuine error in entry of client code at the time of placing/ modifying the related order.

It is also reemphasized here that this facility is expected to be used more as an exception rather than a routine. For this purpose, the following shall be classified as genuine errors:

• • Error due to communication and / or punching or typing such that the original client code / name and the modified client code / name are similar to each other.
• Modification within relatives (‘Relative’ for this purpose would mean as defined under Companies Act, 2013)
• • Client code modification facility is allowed only for carrying out correction of genuine punching error(s) in the client code.
• • The members will be allowed the facility of client code modifications during regular trading session and end of client code modification session.
• • Proprietary trades are not allowed to be modified as client trade and vice-versa.

V. MATCHING RULES

Price Time Priority

The order matching rules would include the following

• (i) Orders in the Normal market will be matched on price -time priority basis.
• (ii) The best buy order shall match with the best sell order. For trading on price, the best buy order would be the one with the highest price and the best sell order would be the one with the lowest price.

Self-Trade Prevention at PAN level

Platform trading system restricts prevention of self-trades based on Permanent Account Number (PAN) of clients as under;

• • If an active buy / sell order is likely to match with a passive sell / buy order in the same order book belonging to the same client based on PAN details updated by the respective members and as available in Platform records, then such active order (full or partial, as the case may be) shall be cancelled by the Platform with rejection message ‘Expired - The order could have resulted in self- trade’.
• • The active buy/sell order shall be partially executed until it does not result in a self-trade as stated above.
• • Self-trade prevention shall be applicable for all order categories and Account type i.e. Pro and clients
• • In view of self-trade prevention check to be done based on PAN of clients, Members are required to ensure to verify PAN details of clients registered in the Platform’s UCC records as Member will be able to submit orders only for clients where;
  • o The status of Client Id (UCC) is Active (A)
  • o PAN status of client is verified
  • o Correct mobile number is updated for the client
• • The creation of new client code or updating of existing client code shall take effect only after the record has been PAN verified as per Income Tax Records (PAN Database).
• • The Platform shall be carrying out such verification in multiple runs and till such PAN verification is completed, members will not be able to place orders for such client codes.
• • The Platform has put in place a mechanism to verify and check the authenticity of the PAN details of clients that are uploaded on the Platform.
• • Members are requested to enter the names exactly as per Income Tax records (PAN Database) in order to get the client PAN verified.
• • Members should note that initials / abbreviations or changing the order of the first / middle / last names will result in a mismatch.
• • In case of e-PAN, members shall verify the authenticity of e-PAN with the details on the website of IT Department and maintain the soft copy of PAN in their records.
• • PAN would be the sole identification number and mandatory for all entities/persons who are desirous of transacting on the commodity Trading Platform. However, the investors residing in the State of Sikkim are exempted from the mandatory requirement of PAN.

Market Price Protection (MPP)

To strengthen the pre-trade risk control measures for preventing aberrant orders and to ensure orderly trading, the Platform is implementing the functionality of Market Price Protection in the SBT contracts. The Market Price Protection (MPP) feature will function as follows.

• 1) The MPP logic is applicable to normal order.
• 2) Market orders shall be allowed to be traded only up to certain mark-up/down price range above / below the reference price. Reference price in case of MPP would be the Last traded price (LTP) after the first match of the incoming market order.
  • a) Buy market orders shall be allowed to trade till Reference Price + Mark-up %.
  • b) Sell market orders shall be allowed to trade till Reference Price - Mark-down %.
  • c) The mark-up / mark-down percentage for MPP would be set at 10%. The Platform may review the mark-up / mark-down percentage on timely basis based on the internal monitoring and market feedback.
• 3) The remaining order quantity of incoming market order post sweeping the counter orders up to mark-up/down price during matching shall convert into a limit order on the same side at LTP of the said market order, if there are no further counter order present or counter orders are beyond the mark-up/down price range.
• 4) If a reference price for MPP cannot be established as there are no counter orders available, an incoming market order would be converted into a limit price order on the same side as per the following priority;
  • a) Last Trade Price (LTP)
  • b) Previous day Daily Settlement Price
• 5) MPP shall be applicable on order modification request when a limit order is modified to a market order.

Breach of Trade limit

If the CM and/or client exceeds 100% of its margin limit, then system will not accept further orders

VI. CONTINGENCY POOL

Trading Members may be aware that the Platform has provided a facility of contingency pool for the members to trade from the Platform premises, in the event of a contingency where trading member is not able to use own connectivity because of a technical or a power failure. In such cases, trading member can send the request in writing to the Platform asking for permission.

The contingency pool is located at AG Tower, Plot no 16, Sector- 9, Vidhyadhar Nagar, Jaipur, Rajasthan, 302039 and is available during trading hours.

Member shall submit the request on the Member’s letterhead via e-mail to connect@apnagodam.com.

Further, members may note;

• • Maximum two persons from their offices shall be allowed inside the pool at any given point of time.
• • Platform will verify the original identity proof as provided in the request letter details before allowing the representative of the trading member to come and use the trading terminal situated in the contingency pool in its premises.
• • The facility is available on a first come first serve basis.
• • The trading facility in the contingency pool is granted for a particular day only.

Members are requested to strictly follow the procedure stipulated in this regard.

VII. PROPRIETARY ACCOUNT TRADING

Disclosure of proprietary trading by broker to client

With a view to increase the transparency in the dealings between the stock broker and the client, every stock broker shall disclose to his client whether Member does client based business or proprietary trading as well.

• • The stock broker shall disclose this information upfront to his new clients at the time of entering into the KYC agreement.
• • In case of a stock broker who at present does not trade on proprietary account, chooses to do so at a later date, he shall be required to disclose this to his clients before carrying out any proprietary trading.
• • Disclose the information of proprietary trading, if any, to all their existing clients. This may be done through the following modes:
  • o Emails to all your existing clients.
  • o Update the information on your company website (if any)
  • o Mention the same on the Contract Notes issued to the clients.

VIII. USER ID MANAGEMENT

Platform hosted Trading Front End

The Platform offers next-generation trading frontend called SAUDABAHI to its registered Members. SAUDABAHI contains features, including member-level risk management and enhanced information to members and dealers. SAUDABAHI would be available to all members connected through Leased Line, MPLS and Internet and also through Mobile application in Android and Apple.

Type of Users

Each Member will have a ‘Corporate Manager’ User terminal for administration at member firm level and order placement facilities, Dealer User terminal under which the Member can create one or multiple terminal id and Drop-copy User id for online backup.

Member can apply for additional User with AGTPL facility to connect their AGTPL solution to the Platform host system.

Process for User Management

The Platform offers a web-based APNA GODAM module for User id management. APNA GODAM can be used by the Corporate Manager only and the updation done by the corporate manager shall be binding on the Member.

Corporate Manager can send requests to Create, delete, shift user-ids, change of user name and view the status of requests. The member will be responsible and bound by all transactions and activities done and arising out of use of said User ID’s created and issued at the request of Corporate Manager as aforesaid and shall not hold the Platform responsible for any loss/claims or liabilities arising from the use of said User ID/s.

Creation of User

For Corporate Manager User

Corporate Manager’s terminal shall be accessed and operated only by the authorized User of the Member

Annexure I – Application for creation of Corporate Manager User ID and Adapter for Lease Line/Internet. Declaration by the User (to be given separately by corporate manager Users)

Annexure II – Application for accessing Web APNA GODAM portal

Change of User Name

In case of change in the User details, Members are requested not to seek deletion of the User Ids. Members are required to submit an application pertaining to change in User as per the format prescribed by the Platform.

For Corporate Manager

Member is required to immediately inform the change in Corporate User to the Platform in as per the Annexure III format prescribed by the Platform Policy along with a PAN copy of proposed user over the email. Member shall simultaneously place an online request for User name change in APNA GODAM portal.

Change in IP Address

Member are required to submit an online request for change in IP Address mapping of a User through ‘Web APNA GODAM  TRD Member ID  new request  Shift User ID.

Request can be processed during market hours but the member should note that when the IP address is modified or removed, the user would be forcefully logged out.

Connectivity mapping of User Ids

Members intending to get dual connectivity mapped to their user ids are requested to send the request in the format as per Annexure as specified in the Policy.

Process for Password Reset of User

Members should note, the Platform would disable that User id which have been inactive for more than 14 days. In other words, if a user has not logged into the system for a continuous period of 14 days, the user-id will disable for further access.

Members needs to place a request for enablement of inactive user ids. Platform provides an online module through the Web Portal for requesting password reset of Corporate Manager and AGTPL User. SAUDABAHI Corporate Manager can reset password for SAUDABAHI Admin id and Dealer id.

Online password reset functionality in Web APNA GODAM portal can be accessed under Admin  Reset Password menu.

IX. AGTPL SOFTWARE EMPANELMENT AND TESTING OF SOFTWARE

New software or changes to the existing software without proper testing may affect the integrity of the markets, the provisions of the circular are as under:

• a. Testing of Software
• b. Approval of Software of brokers/members
• c. Undertaking to be provided by the brokers/members
• d. Sharing of Application Programming Interface (API) specifications by the brokers/members

With respect to testing of software related to

• (a) Fixes to bugs in the software,
• (b) Changes undertaken to the brokers’ software / systems pursuant to a change to any Platform trading system.

The trading member shall undertake User Acceptance Test (UAT) of the software to satisfy itself that the newly developed / modified software meets its requirements.

Trading members shall also engage system auditor(s) to examine reports of mock tests and UAT in order to certify that the tests were satisfactorily undertaken.

Trading members shall engage a system auditor. While finalizing the system auditor, trading members shall ensure the system auditor does not have any conflict of interest with the Trading member and the directors / promoters of the system auditor are not directly or indirectly related to the current directors or promoters of trading member.

Trading members shall seek approval of the Trading Platform for deployment of the software by submitting necessary details required by Platform including details of software, tests undertaken and certificate / report provided by the system auditor. Platform may seek additional details as deemed necessary for evaluating the application of the trading member.

Testing of Empaneled Software

Testing facility can be availed by the members for familiarization with AGTPL software procured from empaneled vendors before going live. The Platform shall allot two user ids per member on the Platform test environment.

• • User Acceptance Testing (UAT): Member shall undertake UAT of the software to satisfy themselves that the newly developed / modified software meets its requirements.
• • Mock testing: It is mandatory for members to test the new or modification or changes in the existing software in the Platform’s mock trading session before moving it to live.

Testing of In-House Software

• • Testing in a simulated test environment: It is mandatory for the members to test any new software or existing software that has undergone change prior to seeking approval from the Platform. Members must obtain prior approval from the Platform before putting the software to use for connecting to Platform system.

• • User Acceptance Testing (UAT): Member shall undertake UAT of the new or existing software that has undergone change to satisfy themselves that the newly developed / modified software meets its requirements.
• • Mock testing: It is mandatory for members to test the new software or existing software that has undergone change in the Platform’s mock trading session.
• • Demo to Platform: It is mandatory for members to provide a demo of the new or existing software that has undergone changes on Platform’s test environment.

Undertaking

Members/Vendors have to provide one time undertaking as per the format of the Platform, prior to accessing Platform Testing environment.

Trading members shall submit an undertaking to the respective Platform stating the following at the minimum:

• (i) M/s (name of the trading member) will take all necessary steps to ensure that every new software and any change thereupon to the trading and/or risk management functionalities of the software will be tested as per the framework prescribed by Platform before deployment of such new / modified software in securities market.
• (ii) M/s (name of the trading member) will ensure that approval of the Platform is sought for all new/ modified software and will comply with various requirements specified by Platform from time to time with regard to usage, testing and audit of the software
• (iii) The absolute liability arising from failure to comply with the above provisions shall lie entirely with M/s (name of the trading member)

Approval of software

Approval process for all the software shall have following steps:

• • Software Approval Process
• • Software Testing
• • System Audit Reports

Software Approval Process shall be applicable for

• • In-house software and empaneled software vendor
• • New software
• • Any modifications to the already approved software

Members who are seeking approval for new software or change to the existing approved shall be required to;

• • Perform User Acceptance Testing (UAT) and participate in mock drill to certify that the tests were satisfactorily undertaken
• • Submit the auditor’s certificate, as per the specified format to the Platform at the time of seeking approval for the new or modified software

While finalizing the system auditor, trading members shall ensure that the system auditor does not have any conflict of interest with the trading member and that the Directors / Promoters of the system auditor are not directly or indirectly related to the current Directors or Promoters of the trading member.

Trading members shall submit an application, along with system auditor report covering the details mentioned in Annexures issued by the Platform and seek approval from the Platform for deployment of the software.

Sharing of API specification by Platform to the Members/ Brokers/ Vendors

The Platform maintains the API specification for interfacing with its system/s and shares the same with market participants on demand. Platform also intimates to the market in case of any changes in the Existing API specifications through issue of circular followed by email of NNF (person in Non-Natural Form) document to all existing vendors/in-house members.

Members are fully responsible to procure the AGTPL application including procurement of the requisite hardware, software, networking connectivity and to implement the solution at their end.

Risk Management

The brokers should have a system-based control on the trading limits of clients, and exposures taken by clients. Brokers must set pre-defined limits on the exposure and turnover of each client.

The broker systems should be capable of assessing the risk of the client as soon as the order comes in. The client should be informed of acceptance/rejection of the order within a reasonable period. In case system based control rejects an order because of client having exceeded limits etc., the broker system may have a review and release facility to allow the order to pass through.

Reports on margin requirements, payment and delivery obligations, etc. should be informed to the client through the system.

Cross Trades

As in the case of existing system, brokers using Internet based systems for routing client orders will not be allowed to cross trades of their clients with each other. All orders must be offered to the market for Matching. It is emphasized that in addition to the requirements mentioned above, all existing obligations of the broker as per current regulation will continue without changes.

The other criteria’s mentioned deal with Network Security Protocols and Interface standards, Network Security, Standards of Web Interface Protocols and System operations

Additional conditions for Trading using Wireless Technology

Securities Trading using Wireless technology shall include devices such as mobile phone, laptop with data card, etc., that use Internet Protocol (IP).

In addition, the Platform shall ensure that the broker complies with the following

• a) There shall be secure access, encryption and security of communication for internet based trading and securities trading using wireless technology. DOT policy and regulation shall govern the level of encryption.
• b) Adequate measures should be taken for user identification, authentication and access control using means such as user-id, passwords, smart cards, biometric devices or other reliable means, to prevent misuse of facility by unauthorized persons.
• c) Unique identification number as given in case of internet based trading shall be made applicable for securities trading using wireless technology.
• d) In case of failure of the wireless network, alternative means of communication for placing orders should be available.
• e) Additional provisions specifying possible risks, responsibilities and liabilities associated with securities trading using wireless technology should be incorporated as an addendum or by bringing to the notice of clients, who are desirous of availing such facility, and taking their concurrence on the same.

• f) As it may not be possible to give detailed information to the investor on a hand held device e.g. mobile phones, it may be ensured that minimum information may be given with addresses of the Internet web site/web page where detailed information would be available.
• g) Order confirmation should be provided to the user on submitting the order. Order modification / cancellation facilities should also be provided. Trade confirmation should be provided to the user, along with history of trades for the day.
• h) Session login details should not be stored on the devices used for internet based trading and securities trading using wireless technology.
• i) Network security protocols and interface standards should be as per prevalent industry standards and sound audit trails should be available for all transactions conducted using wireless devices.

Member shall arrange for periodic systems audits of their systems to ensure that requirements specified in the circulars are being met.

Additional conditions for Internet Based Trading (IBT)

It has been decided that the Platform shall ensure that the broker comply with the following –

• a. The broker shall capture the IP (Internet Protocol) address (from where the orders are originating), for all IBT orders.
• b. The brokers system should have built-in high system availability to address any single point failure.
• c. There should be secure end-to-end encryption for all data transmission between the client and the broker through a Secure Standardized Protocol. A procedure of mutual authentication between the client and the broker server should be implemented.
• d. The broker system should have adequate safety features to ensure it is not susceptible to internal/ external attacks.
• e. In case of failure of IBT, the alternate channel of communication shall have adequate capabilities for client identification and authentication.
• f. Two-factor authentication for login session may be implemented for all orders emanating using Internet Protocol. Public Key Infrastructure (PKI) based implementation using digital signatures, supported by one of the agencies certified by the government of India, is advisable. Further the two factors in the Two-factor authentication framework should not be same.
• g. In case of no activity by the client, the system should provide for automatic trading session logout. Further to the above, the following practice is advisable –
• h. The back-up and restore systems implemented by the broker should be adequate to deliver sustained performance and high availability. The broker system should have on-site as well as remote site back- up capabilities.

Empanelment of In-House AGTPL and Algo Software by Members

Platform permits the Members to use their in-house developed software or software procured from non- empaneled vendor/s providing AGTPL solutions, run on a suitable hardware/software Platform of their choice in order to trade on Platform trading system.

The facility would enable members to customize the front-end software to meet their specialized needs like information formatting, provision of on-line trade analysis, risk management tools, integration of back- office operations, look and feel of front end, etc. The authorized dealers of the member may trade using the software, subject to approvals from relevant Regulatory Authorities, as may be required in this regard.

The Platform will provide a User ID (User type – Dealer) for the purpose of AGTPL. Members shall not be permitted to use the Corporate Manager User ID for the purpose of AGTPL so developed/procured.

Process for approval of Member developing In-house AGTPL software

Subject to terms and conditions as may be prescribed from time to time, members may develop the AGTPL software in-house

Documentation

Interested members will raise a request to Platform for using the software purchased from Platform empaneled vendor. Member are required to submit following documents and the associated fees. On receipt of the document along with the payment of fees, Platform will initiate the process for empanelment.

• • Application
• • AGTPL undertaking
• • Product and RMS Write-up
• • Prescribed Annexures

Additionally, in case of Algo Software, approval to be taken for each Algo strategy and following additional document to be submitted.

• • Strategy categorization letter

Sharing of API

In case of procuring software from non-empaneled vendors / developing in-house AGTPL software, after submission of the undertaking and upon payment of onetime fee, the Platform shall provide the technical specifications (message formats/protocols etc.) i.e. Application Program Interface (APIs) for interface with the Platform's trading system.

Demo of Software

Platform shall schedule a Demo for the AGTPL Algo product with the members and validates all the required steps as defined by the Platform.

Testing in Test Environment and Mock Environment

The Platform provides a facility to members for testing their AGTPL / Algo software on the Platform's testing environment. The member is required to test the software on the Platform trading test environment, so as to enable the Platform to monitor the same. A distinct User ID on the Platform's test environment shall be provided to the members for the purpose of testing the software. Member shall be required to perform following steps.

• • Testing in a simulated test environment
• • User Acceptance Testing (UAT)
• • Mock testing

Approval for Software

On successful completion of demo and documentation, Platform shall issue approval / intimation through email to the member. Platform will also allocate AGTPL Id to the members after successful approval and authorization.

Additional Compliance for Testing of Algo Software

• • Members shall ensure that all user-ids approved for Algorithmic trading, irrespective of their algorithm having undergone change or not, shall participate in all the mock trading sessions conducted by the Platform.
• • Member shall submit half yearly system audit report by specified system auditor to the Platform for compliance of regular participation in the Platform conducted mock sessions.

Version Upgrade of AGTPL Software

Member shall submit an application for version upgrade indicating the nature of change and details.

• o Version upgrade with changes in Risk Management System (RMS)
• o Version upgrade without changes in Risk Management System (RMS)

• • Application shall be submitted along with note on the product and RMS, duly filled checklist / audit report and other relevant documents.
• • The Member is required to develop and test their software in Test and Mock environment meeting all the requirements of the Checklist shared by the Platform while testing the software.
• • After successful development, Member shall demonstrate the software to the Platform in case version upgrade is with changes in Risk Management System (RMS).
• • If version upgrade is without any changes in RMS, demo is not required and Member shall submit ‘No change letter from Auditor’ as required by the Platform.
• • The Member is required to complete the process of Demo to the Platform and submission of above documents within 30 calendar days from the date of submission of Application.
• • If the Member fails to submit the complete documents within completion of 30 days from the date of submission of application, then the Member is required to submit fresh Application with revised date and re submit all the relevant documents.

Empanelment of Tick by Tick (TBT) data Software

Platform trading engine will provide low-latency Tick-by-Tick (TBT) market data feed. The Tick-by-Tick data feed will enable members to build the outstanding order book at their own end.

The Tick by Tick trading market data will be available free of cost to provide to the members for development or testing of their Algorithmic trading (Algo) strategies using Tick By Tick trading market data. However, the connectivity charges and standard port charges shall be applicable as prescribed.

• • Members of the Platform or empaneled AGTPL vendors desirous of developing a software to read the TBT data, can apply as per format prescribed by the Platform.
  • • Application for development of TBT software for Members planning In-house development
  • • Application for development of TBT software for AGTPL vendors
  • • Enablement of TBT data – (In house development or procured from AGTPL vendor) for Members interested in consuming TBT data

• • Members developing an in-house software for using Tick-by-Tick trading market data are required to provide demonstration of their software and seek approval from the Platform before using the same in production environment.
• • Similarly, AGTPL empaneled vendors who are developing the software for Tick by Tick trading market data are required to demonstrate the software and take approval from the Platform before deploying it at member’s environment.
• • To enable the Tick by Tick trading market data in live environment using an empaneled or in-house software, members are required to apply to the Platform in the format prescribed by the Platform.

Conditions

• • The Tick by Tick trading market data will be provided to members on a dedicated point to point leased line with minimum bandwidth of 2 Mbps.
• • Members who wish to subscribe to this service would need to apply for a separate P2P link.
• • Members may please note that order routing will not be allowed on the leased lines enabled for Tick by Tick trading market data.
• • Members are also advised to provide for two different links from separate service providers which will connect to corresponding two instances of the low latency TBT Feed servers.

Process for using TBT from Empaneled Vendor / In-house developed software

• • Members who wish to avail TBT feed are required to apply to the Platform.
• • Member is required to upload the Application and vendor confirmation letter for using empaneled vendor TBT product.
• • Member is required to provide the Application and Product write-up for using in-house developed TBT product.
• • Once the above documents are submitted, Member has to place a User Id request (Member has to select the TBT IP only while placing the request)
• • Post successful testing, Member is required to submit test reports / Acceptance certificate and requesting the Platform to enable the User id.
• • If the Member had submitted the completed documents post completion of 30 days from the date of submission of application, then the Member is required to submit fresh Application with revised date and re submit all the relevant documents.

System Audit

By Member of the Platform

The members using AGTPL trading software / having Platform approved Algo Trading Software (ATS) shall be required to carry out System audit of their trading facility on frequency of Half-yearly, Annually and Bi-Annually basis as per the applicability criteria.

Miscellaneous Provisions for AGTPL

• • Display of Brokerage, Statutory & Regulatory Levies

  To bring more transparency to investors on the brokerage and other charges being levied by the members, the details of the brokerage and charges applicable for the order to be placed shall be prominently displayed on the “Order placement window/screen” under the separate tab called “Charges” on their applications.

• • Implementation of Two Factor Authentication

  Two-factor authentication for login sessions is mandatory for Portal of the platform. In case of Biometric authentication additional one more factor out of the below is required to be implemented.

  • • Knowledge factor (password, PIN)
  • • Possession factor (OTP, Security token)

In case of non-biometric case both above factor to be introduced

X. AGTPL TERMINAL REPORTING

Advisory for operations of trading terminals

The trading terminals of the Member which are enabled / activated for trading shall be operated / accessed only by the approved Users / approved Persons namely – the Employee of the Member, Partner / Proprietor / Director(s), approved Authorized Person (AP) or an Employee of an approved Authorized Person (AP). No other person shall operate and / or place an orders from such trading terminals. Trading Members shall not entrust the AGTPL terminals to their clients or to any unregistered intermediary other than Approved Persons.

Further, where a User ID is enabled for Internet Based Trading (IBT), orders must be placed by the clients only and not by anybody else or for anybody else. In case of any exigencies, where a client is not able to trade through internet, then the orders on behalf of such clients must be placed by any approved User / approved Persons of the member through the trading terminal as stated above, but not using the Login ID and password of the client.

Members are advised to a take note of the above and abide by Platform Policy, relating to usage and operation of the User ID and AGTPL terminals.

In view of the above, the Trading Members are directed to report appropriate relationship of the approved User / approved Persons with the member as an Employee or Partner/ Proprietor/ Director(s) or approved Authorized Person (AP) or an Employee of an approved Authorized Person (AP) in the “Relationship with TM” attribute, at the time of application or while modification of the User Id or AGTPL Terminal in relevant modules of portal interface. In an event where the relation of the Approved User / Approved Person with the Trading Member has changed, the Member is required to update the same on an immediate basis by placing a request through portal.

XI. AUTHORIZED PERSON

Regulatory Framework for Market Access through Authorized Persons

Authorized Persons - Any person - individual, partnership firm, LLP or body corporate – who is appointed as such by a member (including trading member) and who provides access to trading Platform of a stock Platform as an agent of the member.

A Member may appoint one or more authorized person(s) after obtaining specific prior approval from the Platform concerned for each such person. The approval as well as the appointment shall be for specific segment of the Platform.

Eligibility Criteria

An individual is eligible to be appointed as authorized person if he:

• • is a citizen of India;
• • is not less than 18 years of age;
• • has not been convicted of any offence involving fraud or dishonesty;
• • has good reputation and character;
• • has passed at least 10th standard or equivalent examination from an institution recognized by the Government;
• • The approved users and/or sales personnel of Authorized Persons shall have the necessary certification of the respective segments at all points of time.

Procedure for Appointment

Member are required to submit application to the Platform for registration of authorized person as per the Platform Policy.

Documents required to be submitted along with application have been mentioned as enclosure to the above-mentioned Policy

Authorised Person’ (AP) are also permitted to use the option of e-Signature/Digital Signature for signing the documents. In such cases, members are required to provide an Undertaking along with the AP application which has to be uploaded on the online AP-module through portal for Registration. On receipt of the aforesaid application, the Platform.

• • May accord approval on satisfying itself that the person is eligible for appointment as authorised person, or
• • May refuse approval on satisfying itself that the person is not eligible for appointment as authorised person.
• • A partnership firm, LLP or a body corporate is eligible to be appointed as authorized person
  • o If all the partners or directors, as the case may be, comply with the requirements mentioned in the eligibility criteria.
  • o The object clause of the partnership deed or of the Memorandum of Association contains a clause permitting the person to deal in Securities/Commodities business.
• • The person shall have the necessary infrastructure like adequate office space, equipment and manpower to effectively discharge the activities on behalf of the member.

Conditions of Appointment

The following are the conditions of appointment of an authorised person:

• • The Member shall be responsible for all acts of omission and commission of the authorised person.
• • All acts of omission and commission of the authorised person shall be deemed to be those of the member.
• • The authorised person shall not receive or pay any money or securities in its own name or account. All receipts and payments of securities and funds shall be in the name or account of Member.
• • The authorised person shall receive his remuneration - fees, charges, commission, salary, etc. - for his services only from the Member and he shall not charge any amount from the clients.
• • A person shall not be appointed as authorised person by more than one Member on the same Trading Platform.
• • A partner or director of an authorised person shall not be appointed as an authorised person on the same Trading Platform.
• • The Member and “Authorised Person” shall enter into written agreement(s) in the form(s) specified by Platform. The agreement shall inter-alia cover scope of the activities, responsibilities, confidentiality of information, commission sharing, termination clause, etc.

Withdrawal of Approval

Approval given to an authorised person may be withdrawn by the Trading Platform:

• • On receipt of a request to that effect from the Member concerned or the authorised person, subject to compliance with the requirements prescribed by the Trading Platform, or on being satisfied that the continuation of authorised person is detrimental to the interest of investors or the authorised person at a subsequent date becomes ineligible as above.

Obligations of Member

• • The member shall be responsible for all acts of omission and commission of his authorised person(s) and/or their employees, including liabilities arising there from.
• • If any trading terminal is provided by the member to an authorised person, the place where such trading terminal is located shall be treated as branch office of the member.
• • Member shall display at each branch office additional information such as particulars of authorised person in charge of that branch, time lines for dealing through authorised person, etc., as may be specified by the Platform.
• • Member shall notify changes, if any, in the authorised person to all registered clients of that branch at least thirty days before the change.
• • Member shall conduct periodic inspection of branches assigned to authorised persons and records of the operations carried out by them.
• • The client shall be registered with Member only. The funds and securities of the clients shall be settled directly between member and client and all documents like contract note, statement of funds and deliveries would be issued to client by member. Authorised person may provide administrative assistance in procurement of documents and settlement but shall not issue any document to client in its own name. No fund/deliveries of clients shall go to account of authorised person.
• • On noticing irregularities, if any, in the operations of authorised person, member shall seek withdrawal of approval, withhold all moneys due to authorised person till resolution of investor problems, alert investors in location where authorised person operates, file a complaint with the police, and take all measures required to protect the interest of investors and market.

Disclosure by the Platform

• • Details of the broker with whom the authorised person is registered.
• • Locations of branch assigned to authorised person(s).
• • Number of terminals and their details, given to each authorised person.
• • Withdrawal of approval of authorised person.
• • Change in status or constitution of authorised person.
• • Disciplinary action taken by the Platform against the authorised person.

Online Submission of Applications for Authorised Person(s)

Platform has facilitated Online Authorised Person Registration module through portal, which includes following features.

• • Real time report to check the status of AP submissions made online.
• • Option to “edit and resubmit” an application in case of rejections.
• • Online report to view AP code and date of Registration
• • Option to download the entire data of AP entered into the new online system by the members. Members may use this data to upload in their back office system and avoid duplication of manual data entry

XII. CUSTOMER SERVICE GROUP CONTACT DETAILS

Members can contact during working hours on all working days for all trade related queries on Toll Free Number: 7733901154.

Members can also email us on connect@SaudaBahi.com

Additionally, “Connect with us” window has been provided on website for Member/Client /Others to register query/feedback/complaints.

XIII. ANNEXURES

(On the letter head of trading member)

Permission for Trading from Platform premises using Contingency Pool

Declaration: I hereby declare that the details furnished above are true and correct to the best of my knowledge and belief and I undertake to inform you of any changes therein, immediately. In case any of the above information is found to be false or untrue or misleading or misrepresenting, I am aware that I may be held liable for it.

Further we accept the terms and conditions as mentioned below:

• 1. I/We, hereby authorise Platform, to reset the User password, if requested by trading member/ above listed User.

• 2. I/We hereby understand that Platform shall not be responsible for any delay/error during the activity.
• 3. The said process may take more time than anticipated for any reason whatsoever and I/We hereby unconditionally agree that Platform and the directors, managers, officers, employees and agents of Platform shall not be liable in any way to me/us and/or to my/ our customers or to any other third person, for any such delay.
• 4. I /We undertake to adhere to the rules and regulations/ circulars issued by Platform any other statutory authority from time to time and agree that I/we have complied with all statutory provisions applicable to me/us under law.

Yours faithfully,

For (TM Name)

Authorized Signatory

Name:

Designation:

Date:

Mobile:

Application for creation of Corporate Manager User

Annexure I

(On the letter head of trading member)

Application for creation of Corporate Manager User Id and Adapter for Lease Line/Internet

To,

Trading Operations Department
Apna Godam Technologies Private Limited
Plot. No. 16, Sector-9,
Vidhyadhar Nagar, Jaipur

I/We(Name of the Member) do hereby request you to permit Mr. / Ms. (Name of Corporate Manager User) to act as our Approved User for trading on my/our behalf through Leased Line/Internet terminals.

Date:

Place:

Stamp & Signature of the authorized signatory of

the Trading Member

Declaration to be given by Trading Member

• I/We hereby agree and bind myself/ourselves to be responsible for all acts, quotations made and transactions done or effected by the said Mr. / Ms. As our Approved User on the Trading System of the Platform.
• ● I/We shall ensure that he/she will not execute any order on his/her own account or on account of anyone without such order having my/our prior approval. I/We further agree that I/We shall be responsible for any risks, loss or claims/actions arising out of use of the said User ID and shall not hold Platform responsible for any such risk, loss, claims or liabilities arising from the use of the said User ID.
• ● I/We shall ensure that the proposed Approved User Mr. / Ms. Will not function / place orders / deal on the trading system in any manner that would represent that the trades have been placed as an Authorised Person or a sub-broker.
• ● In case of the said Mr. /Ms. ceasing to be associated with me /us as an employee, agent on commission basis, trainee, client, Approved User or in any other capacity, I/we shall communicate to you the same along with related details and seek change in the User ID so allotted against this application, as prescribed.
• ● I/We also confirm that the Approved User shall clear such certification as may be prescribed by the Platform from time to time and within such period as may be prescribed by the Platform. The User ID so allotted may be withdrawn by the Platform at its discretion on the expiry of such period within which such Approved User fails to obtain the certification.
• ● I/We certify that I/we have not applied for any other User ID in the name of the said Mr. /Ms. . The User ID so allotted would be used by the said Mr. / Ms. Only to access the Platform trading system.
• ● I/We hereby confirm that necessary infrastructure as mentioned below has already been installed by us for running the SAUDABAHI application for which this permission is being sought:

Date:

Place:

Stamp & Signature of the authorized signatory of

the Trading Member

Declaration by the user (to be given separately by Corporate Manager Users)

I hereby declare that I am aware and shall update myself about the Platform Policy. I agree to become an Approved User of M/s (name of Trading Member). I would intimate the Platform upon ceasing to be an employee, agent on commission basis, trainee, client, Approved User of or ceasing to be associated in any other capacity with M/s (name of the trading member). I hereby agree to abide by the Platform Policy that may be in force from time to time. I understand that appropriate action may be initiated against me by the Platform in case of violation of the Platform Policy. I certify that I have not applied for any other User ID on the same segment for which this User Id is now being applied for. I will not allow anybody else to access / use the Platform Trading System using the User ID so allotted to me.

I shall keep complete secrecy of the password.

Date:

Place:

Signature of User

Annexure II

(On the letter head of the member)

Application for accessing portal

To,

Membership Department
Apna Godam Technologies Private Limited
Plot. No. 16, Sector-9,
Vidhyadhar Nagar, Jaipur

Dear Sir,

I/We ( , the ‘Trading Member’) have appointed Mr. /Ms. (Name of Corporate Manager User) son/daughter/wife of as our Corporate Manager and at our request you Apna Godam Technologies Private Limited have created/agreed to create and issued/agreed to issue Corporate Manager User ID accordingly.

I/We want to avail online facility made available by the Platform for creation of new User Id’s, Change in the name of User ID, User Id deletion, change in User Id location and other related activities.

I/We confirm that the above said Corporate Manager is authorised to appoint person/s to act as Approved User/s for the Trading Member and to apply online to the Platform for creation new User ID’s, change in the name of User ID, User Id deletion, change in User Id location and for other related activities on behalf the Trading Member on the terms and conditions as may be stipulated by the Platform.

I/We undertake and confirm that I/we shall be responsible and bound by all transactions and activities done and arising out of use of said User ID’s created and issued at the request of Corporate Manager as aforesaid and shall not hold the Platform responsible for any loss/claims or liabilities arising from the use of said User ID/s.

All requests submitted online by use of Corporate Manager User ID and the related password shall be deemed to be done by me/us for all purposes and all transactions, actions, activities done by use of any User ID created and issued pursuant to online requests as aforesaid and related respective password/s shall be deemed to be done by me/us and I/we shall be responsible and liable for all such transactions, actions, activities etc. and liabilities/obligations arising there from.

Date:

Place:

Stamp & Signature of the authorized signatory

Of the Trading Member

Annexure III

(On the Letterhead of the Trading Member)

Application for change in user name of Corporate Manager User ID

To,

Trading Operations Department
Apna Godam Technologies Private Limited
Plot. No. 16, Sector-9,
Vidhyadhar Nagar, Jaipur

Dear Sir,

Sub: Change in the user name of existing Corporate User ID/s.

I / We request you to kindly change the name of the following User ID/s entirely at our risk and responsibility.

• User ID No.
• Existing User Name
• Proposed User Name
• Reason

Declaration to be given by Trading Member

• ● I/We hereby agree and bind myself/ourselves to be responsible for all acts, quotations made and transactions done or effected by the said Mr. / Ms. As our Approved User on the Trading System of the Apna Godam Technologies Private Limited.
• ● I/We shall ensure that he/she will not execute any order on his/her own account or on account of anyone without such order having my/our prior approval in writing. I/We further agree that I/We shall be responsible for any risks, loss or claims/actions arising out of use of the said User ID and shall not hold Platform responsible for any such risk, loss, claims or liabilities arising from the use of the said User ID.

• ● I/We shall ensure that the proposed Approved User Mr. / Ms. Will not function / place orders / deal on the trading system in any manner that would represent that the trades have been placed as an Authorised Person or a sub-broker.
• ● In case of the said Mr. /Ms. ceasing to be associated with me /us as an employee, agent on commission basis, trainee, client, Approved User or in any other capacity, I/we shall communicate to you the same along with related details and seek change in the User ID so allotted against this application, as prescribed.

● I/We also confirm that the Approved User shall clear such certification as may be prescribed by the Platform from time to time and within such period as may be prescribed by the Platform. The User ID so allotted may be withdrawn by the Platform at its discretion on the expiry of such period within which such Approved User fails to obtain the certification. I/We certify that I/we have not applied for any other User ID in the name of the said Mr. /Ms. . The User ID so allotted would be used by the said Mr. / Ms. Only to access the Platform trading system.

Date:

Place:

Stamp & Signature of the authorized signatory

Of the Trading Member

Declaration by the user (to be given separately by different users)

I/we hereby declare that I am aware and shall update myself/ourselves about the Platform Policy. I agree to become an Approved User of M/s (name of Trading Member). I would intimate the Platform upon ceasing to be an employee / an employee, agent on commission basis, trainee, client, Approved User of or ceasing to be associated in any other capacity with M/s (Name of the trading member). I hereby agree to abide by the Platform Policy that may be in force from time to time and understand that appropriate action may be initiated by the Platform in case of violation of the Platform Policy. I certify that I have not applied for any other User ID on the same segment for which this ID’s now being applied for. I will not allow anybody else to access / use the Platform Trading System using the User ID so allotted to me.

Date:

Place:

Name and signature of User

Thanking You

Yours faithfully,

Authorized Signatory

Authorised Person

Annexure I

(On the Letterhead of the Member)

REQUEST FOR APPOINTMENT OF AUTHORISED PERSON

To,

Apna Godam Technologies Private Limited
Plot. No. 16, Sector-9,
Vidhyadhar Nagar, Jaipur

Dear Sir,

Sub: Request for appointment of Authorised Person

• 1. I/We intend to appoint

  *Mr. /Ms

  *M/s (*strike off whichever is not applicable) As my/our Authorised Person as per the policy of Platform.

  Details of the above named person/entity (hereinafter referred to as the ‘said Authorised Person’) are as contained in Annexure II, III, IV & V hereto.

• Details of the above named person/entity (hereinafter referred to as the ‘said Authorised Person’) are as contained in Annexure II, III, IV & V hereto.
• 3. I/We further confirm that all acts, deeds, omissions and commissions done by the said Authorised Person as such shall be deemed to have been done by me/us under the Policy of the Platform .I/We shall be bound by all such acts, deeds, omissions and commissions done by the said Authorised Person.
• 4. I/We and the said Authorised Person comply and shall continue to comply with and be bound by all the terms and conditions as per the Policy of the Platform but not limited to the following:
  • a. The said Authorised Person is not an Authorised Person of any other member of Platform
  • b. The said Authorised Person is not a director or a partner of any other member of Platform
  • c. I/We shall intimate to the Platform, any change in the constitution, shareholding and partners/directors of the said Authorised Person at least 30 days in advance
  • d. I/We hereby confirm that the said Authorised Person or any of its partners/directors has/have not been suspended or barred by any Stock or Commodity Platform for a period of more than six continuous calendar months.
• 5. I/We hereby confirm that the information submitted herein is true to the best of my/our knowledge and if at a later date any contrary material information comes to my/our knowledge subsequent to the submission of this application, I/We undertake to keep the Platform informed about the same.

I/We Mr. / M/s. (Name of member), TMID of the Platform hereby recommend the registration of the above mentioned applicant as Authorised person.

(Name, Signature & Stamp of Member)

Enclosures:

• 1. Copies of PAN Card of the said Authorised Person and all Directors and Partners of the said Authorised Person (in case of Partnership/LLP/Company)
• 2. Copy of any one of the following as evidence of address of the said Authorised Person and all Directors and Partners (in case of Partnership/LLP/Company)
  • • Bank statement/passbooks (last entry should not be older than 3 months)
  • • Electricity Bill (not more than 3 months old)
  • • Landline Telephone bills (not more than 3 months old)
  • • Voter ID Card/ Driving License/ Passport /Ration Card/Aadhar Card (If the said Authorised Person is individual)
• 3. Copy of School/College Mark sheets or degree/diploma certificate of the said Authorised Person (if individual) / all Directors and Partners of the said Authorised Person
• 4. Copy of the Registered Partnership Deed/ Memorandum of Association of the said Authorised Person containing the clause permitting them to deal in commodities/ Securities derivatives contracts

(All the above enclosures are to be certified by the Authorised Signatory of the Member)

Annexure II

Details of Authorised Person

(On the letterhead of the Member)

** In case the Authorised Person operates from more than one location, similar details to be provided location-wise in separate annexure.

(Name, Signature & Stamp of Member)

Annexure III

Details of the Individual / Details of Directors/Partners of M/s (Applicant Authorised Person)

Photographs of the Individual or each of the Directors/Partners of M/s (Applicant Authorised Person)

(To be signed across and pasted below)

Confirmed

(Name, Signature & Stamp of Member)

Annexure IV

For Corporates

(On the letter head of Authorised Person)

Shareholding Pattern of (name of Authorised Person) as on (Date)

Paid up Rs.

Face value of each equity share Rs.

Signature(s)

Name of Director(s)

Stamp of the Authorised Person

CERTIFICATE

This is to certify that the Shareholding as given above, based on my/ our scrutiny of the books of accounts, records and documents is true and correct to the best of my/our knowledge and as per information provided to my/our satisfaction. Further, we confirm that there is no foreign shareholding in the said entity.

Chartered Accountant

Membership Number

For Firms/LLP

(On the letter head of Authorised Person)

Shareholding Pattern of (name of Authorised Person) as on (Date)

Signature(s)

Name of Partner(s)

Stamp of the Authorised Person

CERTIFICATE

This is to certify that the Capital and Sharing Pattern as given above, based on my/ our scrutiny of the books of accounts, records and documents is true and correct to the best of my/our knowledge and as per information provided to my/our satisfaction. We confirm that there is no foreign holding in the said entity.

Chartered Accountant

Membership Number

Annexure V

Undertaking

(On the letterhead of Authorised Person)

I/we, Mr./Ms./M/s. age residing at having its registered office address at had applied for appointment as Authorised Person of the Platform for trading in the Platform Platform through trading member, M/s.

In this regard I/we hereby confirm/undertake that;

• 1) Neither I/we nor our directors/partners have been convicted for any offence in the past and presently not under trial for any offence involving fraud and dishonesty.
• 2) I/We will-deal with investors on behalf of Trading Member only and that we would not engage in any activities with investors which could result in unauthorised intermediations
• 3) Neither I/we nor our directors are Authorised Person of any other member of the Platform nor have applied for appointment as Authorised Person with any other member of the Platform.
• 4) Neither I/We nor any of our directors/partners is a partner or a director in/with any of the Member of the Platform.
• 5) I/We are not defaulter/expelled on any Platform.
• 6) I/We shall be governed by the PLATFORM Policy.

Stamp & Signature of Authorised Person:

[(Individual/ All the Director(s)/All the Partner(s)] Name of Authorised Person:

Date:

Place:

Stamp & Authorised Signatory of Member: