Policies & Procedures – AUM Securities Compliance Framework

Policies & Procedures Of AUM Securities Pvt. Ltd.

AUM Securities Pvt. Ltd. has specific Operational Policies & procedures in place for smooth operations & Risk management which are listed as follows:

1. Refusal of orders for penny stocks:

A stock that trades at a price which is less then than Face or paid-up value is considered as penny stock. AUM Securities Pvt. Ltd. does not encourage trading in penny stocks or securities falling in T2T or Z group or illiquid stocks & reserves its right to refuse, prohibit or restrict or impose or vary limits on the orders that the client can place in all or some of the penny stocks and filiquid Stocks. Exchange provide the list of illiquid securities on a periodic basis & the same is available at the website of exchange.

Under exceptional circumstances and considering merits on case to case basis, trading in penny stocks/T2T/Z GROUP/Eliquid Stocks may be allowed to clients subject to stringent verifications of the client's intentions and bona fide reasons given by intending clients. further trading limits will be allowed subject to history and financial details of the client, Intention of doing the trades and 100% upfront payment. The said trading limits may not be allowed to clients on a regular basis.

AUM Securities Pvt. Ltd. reserves its rights to suspend the client account if it is observed that the client is indulging in trading activities only in penny stocks/T2T/Z GROUP/liquid stocks or carrying on any insider trading activity, without any reasons being given to the client.

2. Setting up client's exposure limits:

AUM Securities Pvt. Ltd. uses trading software provided by BSE LTD/NSE LTD, where feature of setting up individual client limit is not available hence AUM Securities Pvt. Ltd. will setup client exposure limits manually based on the relationship, track record, financial detail & credit worthiness of the client. Compliance officer of the AUM Securities Pvt. Ltd. will continuously monitor the limit & incase of any increase in the limit required then compliance officer would first check the need for doing so & would then increase the limits on the case to case basis at his own discretion. The exposure limit will defer from client to client at the discretion of the AUM Securities Pvt. Ltd..

AUM Securities Pvt. Ltd., may need to vary or to reduce the limits or impose restrictions urgently on the basis of AUM Securities Pvt. Ltd.'s risk perception and other factors consider relevant by AUM Securities Pvt. Ltd., AUM Securities Pvt. Ltd. may be unable to inform the client of such variation, reduction or imposition in advance. AUM Securities Pvt. Ltd. shall not be responsible for such variation, reduction or imposition or loss of opportunity by client or client's inability to place orders.

3. Applicable brokerage rate:

AUM Securities Pvt. Ltd. will charge brokerage to client at a rate mutually agreed between them subject to minimum brokerage of Rs. 50/- per scrip or minimum Rs. 100/- per contract which ever is higher, however brokerage will always be charged within the limit prescribed by SEBI/exchange, AUM Securities Pvt. Ltd. may specify different brokerages for executing transaction for different clients.

In addition to brokerage AUM Securities Pvt. Ltd. will charge other charges like Transaction charges, stamp duty, service tax, security transaction tax (STT), SEBI tumover charges etc. as may be applicable from time to time.

4. Imposition of penalty/delayed payment charges by either party:

AUM Securities Pvt. Ltd. reserves its right to pass on any penalty charged by SEBI/Exchange as a result of any violation or non-compliance Committed by the client with respect to submitting wrong KYC information, trading & position violations, indulging in price rigging, abnormal & circular trading, creating artificial market, doing financial transactions using trading systems of the exchange etc.

After the introduction of T+1 settlement pay-in & pay-out takes place much faster then it used to take place. As per rule though AUM Securities Pvt. Ltd. needs to collect at least 10% upfront margin before execution of trade but for sake of convenience AUM Securities Pvt. Ltd. is not collecting margin but will collect 100% payment on execution of trade or maximum by next day evening. Simultaneously AUM Securities Pvt. Ltd. will release pay-out cheques (unless otherwise requested by client to withheld the same) on day of pay-out or maximum within one working day of pay-out or as per applicable rules from time to time.

AUM Securities Pvt. Ltd. will charge delayed payment charges (DPC) @ 15% p.a. (subject to minimum of Rs. 50/- per scrip) on a daily basis on a sum due from date of trade to cheque realization date. The client understands that such DPC is deterrent in nature and as such AUM Securities Pvt. Ltd. can not be assumed to be financing/funding the client's settlement obligations.

AUM Securities Pvt. Ltd. reserves its right to change the DPC rate at its sole discretion without assigning any reason thereof. any change in DPC shall be communicated to client from time to time.

5. The right to sell clients' securities or sell clients' positions, without giving notice to client, on account of non-payment of clients'dues

The client shall ensure timely availability of funds/securities in form & manner at designated time & in designated bank & depository account for meeting his pary-in obligation of funds/securities.

AUM Securities Pvt. Ltd. reserves its rights to liquidateldose out all or any of the cilents' position without giving notice to the client for non- payment of margins or other amounts including the pay-in obligation, out standing debts etc & adjust the proceeds of such liquidations/close-out, if any against the client's liabilities/obligation, all such liquidations/closing out shall be done by AUM Securities Pvt. Ltd. on the best effort basis & while doing so, if any surplus left, the same will be credited to the client's account & any losses & financial charges on account of such liquidations/closing out shall be charged to & bome entirely by client.

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

Internal shortages arises when both the buyer & seller of a scrip (Other then T2T & Z group) is clients of AUM Securities Pvt. Ltd. & the seller fails to deliver scrip to fulfill his settlement obligation.

In such case, AUM Securities Pvt. Ltd. will purchase the said scrip on T+3 day, which is the auction day on the exchange, on behalf of seller to make available the delivery of the said securities to the buyer.

If securities can not be purchased from the market due to any force majeure condition, then all shortages not bought-in are deemed to be closed out and short delivering seller client will be debited at the higher of highest price recorded in the scrip from the trading day on which the transaction took place up to a day prior to the day of auction i.e. pay-in day or 20% above the closing price on the day prior to the day of auction ie. pay-in day.

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

The AUM Securities Pvt. Ltd., may at its sole discretion may reduce/restrict client to take further position or may close the existing position of client without any prior intimation/notice due to all or any of the following:-

a) Shortage of margin amount

b) Any restrictions in relation to volume of trading/outstanding business or margin stipulated by the exchange, clearing corporation/clearing house and/or the AUM Securities Pvt. Ltd..

c) Delay by clients in meeting his obligations/dues to AUM Securities Pvt. Ltd. and/or the clearing house

d) Observing/discovery any abnormal behavior/action/deed/trading pattern of the clients dealing with AUM Securities Pvt. Ltd., for example repeated cheque bouncing, frequent non-fulfillment of sell obligation etc

e) Any regulatory action taken by any regulatory authority on client

f) Abnormal volatility in the market or political/financial instability in the country

g) In view of impending price sensitive announcements by the exchange listed company

h) Scrip which is re listed and where the circuit filters are not applicable on the day of re listing

i) Any extra ordinary event warranting such action

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

1. Client account will be temporarily suspended if a client fails to submit details pertaining to KYC or any other details sought by AUM Securities Pvt. Ltd. also AUM Securities Pvt. Ltd. will withheld funds and securities pay-out if AUM Securities Pvt. Ltd. has a reason to take such action which may arise due to the alerts generated by the surveillance system of the AUM Securities Pvt. Ltd.. The account of such clients will remain

2. Client's account will be temporarily closed at client's request when client will intimate the AUM Securities Pvt. Ltd. to do so in writing

9. Deregistering a client

Client will be debarred from doing a business or client will be deregistered due to all or any one of the following:

a) If client fails to meet his financial obligations/dues to AUM Securities Pvt. Ltd.

b) The client become un-discharged insolvent

c) The client applies to be adjudicated as an insolvent

d) The client being declared a defaulter by any of the regulatory bodies of the country or under any law being in force

e) The client has found to be of unsound mind by a court of competent jurisdiction and the findings is in force

f) The client has been convicted by a court of any offence involving turpitude.

g) If client is found to be indulging (directly or indirectly) in to any act or carry out any transaction or any transactions which are in violation of Acts, Rules, Regulations, Bye-laws & circulars governing security transactions

h) If client fall to give any information which is elther required by the AUM Securities Pvt. Ltd./exchange/SEBI on the specific written direction of any statutory legal authority/regulatory authority

i) In case of dispute with any client due to any reason, AUM Securities Pvt. Ltd. will hold payments /securities of the client till AUM Securities Pvt. Ltd. satisfies itself or til arbitration award is awarded by arbitration bench of exchange/any court & such dient's account will not be reactivated by AUM Securities Pvt. Ltd.

j) If particulars/information/statements given by client in KYC are found to be Incorrect or false or untrue or misleading or misrepresenting or any particulars/ information/statements have been suppressed or omitted there from

k) The client makes voluntary written request to de-register himself

l) The death of the client

10. Treatment of inactive dormant account

AUM Securities Pvt. Ltd. will treat client account as inactive if client has not executed a single trade in a year. Such dient's alc will be reactivated after due verification and on receiving a request letter from client to restart the business along with his/her latest financial details & a full cheque for the purchase he/she wants to make.

As AUM Securities Pvt. Ltd. makes payments to clients on T+1 basis and client being a known entity, AUM Securities Pvt. Ltd. will not hold payments of such clients.

11. Disclosure-Pro-Account Trading

As required by SEBI Circular No. SEBI/MRD/SE/Cir-42/2003 dated 19/11/2003, AUM Securities Pvt. Ltd., hereby discloses that it undertakes proprietary trading as well as client based trading from time to time.

The above policies & procedures are adopted by AUM Securities Pvt. Ltd. & are Subject to change/updation from time to time & cdients are requested to abide by the same

FOR AUM Securities Pvt. Ltd.

sd/-

Director/Authorised Signatory

I/WE hereby acknowledge that I/WE have received, read & understood policies & procedures of AUM Securities Pvt. Ltd. with respect to dealing with them in security markets and state that I'we will strictly abide by the conditions laid in this policy.

Also I/We agree not to call in to question the validity, enforceability & applicability of any provisions/clauses of this policy These policies & procedures may be amended unilaterally by AUM Securities Pvt. Ltd., provided the amendment is inform to melus These policies & procedures shall always be read along with the agreement & shall be compulsorily referred to while deciding any disputes or claim between melus & AUM Securities Pvt. Ltd. before any regulator or arbitrator or court of law

Customer's signature (if partner. corporate or other signatory then attest with company seal)

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