SURVEILLANCE POLICY

SURVEILLANCE POLICY FOR DP

The objective of this policy to have effective surveillance frame work for DP’s. It will also help identify adverse situation in markets and pursue appropriate preventive action thereby providing Investor protection.

CDSL has issued a circular in regard to this: CDSL/OPS/DP/SYSTM/2021/309 DATED: JULY 15, 2021.

The alerts will be provided by depository (CDSL) all such alerts will be verified by the compliance officer and due diligence of such clients will be undertaken once again.

DP shall maintain a record of all alerts provided by the Depository (CDSL) and will also record the action taken against such alerts.

Any adverse observation in the alerts will be reported to CDSL. This policy was place before the board the director and approved by the boards on the 1st August 2022.

This policy shall be reviewed once in a year and shall be revised as and when required. Following alerts will be generated by DP.

  • Client has opened several multiple accounts that is account open with same PAN /mobile number / email id/ bank account no. / Address Etc. all such account shall be closed with immediate effect record thereof will be kept by DP.
  • Any mail getting bounced for any BO account the records thereof will be kept by the DP.
  • Frequent changes in details of demat account such as, address, email id, mobile number, Authorized Signatory, POA holder etc.
  • Any BO making frequent off market transactions in a month shall be examined by DP and due diligence of such client and reason of such off-market transaction will be recorded by the DP.
  • Off-market transfers not commensurate with the income/Net worth of the client.
  • Any pledge transaction not commensurate with the income/Net worth of the client. The new net worth shall be obtained by the DP.
  • Off-market transfers (High Value) immediately after modification of details in demat account
  • Review of reasons of off-market transfers provided by client for off-market transfers vis-à-vis profile of the client e.g., transfers with reason code Gifts with consideration, frequent transfers with reason code Gifts/Donation to unrelated parties, frequent transfers with reason code off-market sales
  • 9. Alert for newly opened accounts wherein sudden Increase in transactions activities in short span of time and suddenly holding in demat account becomes zero or account becomes dormant after some time.
  • Any other alerts and mechanism in order to prevent and detect any type of market manipulation activity carried out by their clients.

In point 8,9,10 all such cases DP shall conduct due diligence of the client and shall ensure there is no adverse observation and if found shall be reported to CDSL.

DP will report to CDSL in the prescribed format at the end of every quarter the status of alerts.

The compliance officer shall be responsible for supervision and surveillance of policy.

The data of alerts provided by CDSL and generated by the DP and the action taken against such alerts shall be placed before the board.

Compliance officer shall ensure the internal audit of such all alerts and shall further ensure the any adverse observation are submitted to DP.

registration nos:

Kalpataru Multiplier Ltd.: SEBI Regn. No. INZ000259437 Member: Bombay Stock Exchange Ltd.(BSE):MEMBER ID:3016, National Stock Exchange Ltd., MEMBER ID:11152

Member : Multi Commodity Exchange(MCX): 16020, National Commodities Exchange of India(NCDEX): MEMBER ID:00921

Depository Participant of CDSL DP-ID 12031600 SEBI Regn No. IN-DP-CDSL-221-2003

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