Terms and conditions - TRADEPLUS

General terms and conditions

Before availing of the trading 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 himself 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.

Security precaution and password

NAVIA will provide the client with a username and a trading password which will enable him 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 username and password for accessing 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 is aware that NAVIA’s Online Trading system Rocket, does not generate the initial password. The Client agrees and undertakes to create a strong new 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 and Password / 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/or Password whether or not such person was authorised to do so.

The Client shall immediately inform NAVIA of any unauthorised use of the Client’s Username or Password / TPIN with full details of such unauthorised use including the date of such unauthorised use, the manner in which it was unauthorisedly used, the transactions effected pursuant to such unauthorised 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 unauthorised 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 unauthorisedly 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 unauthorised 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 above, the Client shall immediately notify NAVIA in writing with full details if: he discovers or suspects unauthorised access through his Username, Password or Account, he notices discrepancies that might be attributable to unauthorised access, he forgets his password or he discovers a security flaw in NAVIA’s Online Trading System.

Orders

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 scripwise surveillance or such other conditions as to scripwise 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.

Margin

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 authorises 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 authorises 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/agreements/terms & conditions mentioned on the support portal, the link for which is given below:

http://support.tradeplusonline.com/support/solutions/folders/1000137625-downloads

Running Account settlement of funds and Securities.

Navia as per the rules and regulations of the Exchanges shall settle the funds and securities of the client, on a monthly/quarterly basis and this may lead to the insufficient account balances or margins for trading. Further, the client agrees that, Navia shall not be responsible for any loss due to order rejections or for the non execution of the orders on time due to the settlement of the funds and securities.

Suspension of trading account

The client is aware that, if there are no trades in the trading account for a period of twelve months, Navia shall suspend the trading account from further trading as per the rules and regulations of the exchanges. Further if at any time if the client wants to login to the online trading platform, the client has to send an e-mail to support@tradeplusonline.com to activate the account for the trading or use the facility provided in the mobile APP for activating the suspended account. Navia upon receipt of the client e-mail may activate the trading account within two workings days, and shall reset the password for the client login and trading. The client further agrees that, Navia shall not be responsible for any kind of loss due to the suspension of the trading account.

Margin Trade Funding (MTF)

Navia offers the Margin Trade Funding facility to its clients, to buy the securities with the limited margin as approved by SEBI, and can hold the shares for a long period in the MTF account by making the margin short falls in the form of cash or in securities. This MTF facility is offered online to the client’s and the client’s can trade on the MTF approved securities by transferring the margin as cash or approved securities. The terms and conditions will apply to this MTF trading and the client has to execute a separate agreement as approved by SEBI to transact in the shares and securities of the MTF segment.

Representations and warranties

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://tradeplusoline.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.

Investment or any other advice

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

Indemnity

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.

Severance

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.

Jurisdiction

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.

Policies and Procedures

M/s Navia Markets Ltd is a Company registered under the Companies Act of 1956, having its corporate office at No.9, Ganga Griha, 4th & 5th Floor, Nungambakkam High Road, Chennai 600034. Tradeplus is the online brand of Navia Markets Ltd and together it is referred to as “NAVIA”

This page contains important information regarding the Policies and Procedures (Including the Risk Management Policy) which apply to your trading & Demat account with NAVIA, Member of NSE, BSE, NSDL 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: IN-DP-311-2017 an MCX SEBI Registration No.INZ000077130 with Membership Code: 45345. Your access to your account and the use of your account is subject to your compliance with all the policies and procedures set forth herein. Please read this page carefully and retain it for future reference.

The website www.tradeplusonline.com is owned, operated and maintained by NAVIA.

These Policies and Procedures are in addition to the other terms and conditions and documents signed/accepted by me from time to time including but not limited to “Do’s and Don’ts, Risk Disclosure document, Rights and Obligation, Internet and wireless based trading disclosure,etc.

By clicking on the "I agree" button, you agree to be legally bound by these policies and procedures. I agree that NAVIA may at its sole discretion vary the Policies and Procedures from time to time and I agree to abide by the same.

Please note that the information’s contained herein are subject to change without any notice.

For the purpose of these Policies & Procedures, wherever the context so mentions "Client", "I” or "We" or “You”, it shall mean any natural or legal person who has agreed to open an account or initiate the process of opening an account with NAVIA by providing their information while registering on the platform as a user. NAVIA allows any person to surf the website without registering on the website. The term "We", "Us" and “Our” shall mean NAVIA as defined earlier.

Introduction:
Navia’s intention for publishing the Policies & Procedures is not to impose restrictions that are contrary to the Navia’s established culture of openness, trustworthy and integrity but to strictly follow the Rules/Regulations/Bye-Laws of SEBI and the Exchanges to facilitate a Trading Platform and process to transact with more transparency and to maintain good business relationship with the Clients, and Business Associates.

Purpose of this Policy:
The purpose of this policy is to outline business operations and procedures being followed by Navia. These procedures are introduced in line with the Rules / Regulations / Bye-Laws of the exchange and are in place to protect the Clients, Investors, and Navia, from all kinds of risks. This document has been designed to understand the margin policies of the company in the Equity/Commodity/Currency trading segments. Risk Management is an integral part of any organization. Various risks include credit Risk, Market Risk, default Risk, liquidity Risk and other risk. Navia has devised a comprehensive Policy to make sure that customers are aware of the criteria based on which Navia monitors risk and initiates actions to safeguard the interest.

Scope of the Policy:
This policy applies to clients, Investors, Sub-brokers, and other Business Associates/ Partners of Navia, and it covers all the business activities that are being performed through and by Navia

Funds
System of Payin and Payout of funds:
Payin: Clients can transfer funds into the Trading Account only from such bank accounts which are registered with NAVIA. Any transfer from a non-registered bank account will not be considered and the client does not get any credit of the amount / trading limit for such transfers.
The client can transfer funds from the instant payment gateway facility available on the trading platform or through the back office. Client can also choose to transfer using NEFT/IMPS/UPI or by means of cheque. Such transfers will be charged at Rs 9/- per transfer plus applicable taxes.
For more details on Funds payin visit our support portal at http://support.tradeplusonline.com/support/solutions/1000097588

Payout:
All payouts will have to be compulsorily placed through the access provided on the trading platform. All payout requests will be processed electronically and the credit shall come to the client’s primary bank account as per timelines mentioned in our support portal. If at any time if 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. Payouts will not be processed on Holidays, Saturday and Sunday.

Transfer of funds :
The funds updated by Navia on the trading system is the sum total of debit and credit balance of clients across all market segments (except MTF). Using this single consolidated capital client can trade in any segment. Navia has also provided an online utility on the trading portal for clients to transfer their the clear credit amount to MTF segment. Such transfer requests shall be processed by Navia at the end of the day and shall effect the transfer only if there are clear credit balances available in the trading accounts segments.
For more details on funds payout visit out support portal at:
http://support.tradeplusonline.com/support/solutions/1000097588

MarginsMargin is the minimum amount required to buy/sell derivative instruments. Margins are always collected in advance. Various margins applicable are:

1. Span margins : SPAN Margin is the minimum requisite margins blocked for futures and option writing positions as per the exchange's mandate.

2. Additional/ Exposure Margins : 'Exposure Margin' is the margin blocked over and above the SPAN to cushion for any MTM losses

3. VAR Margin: (Value at risk margin) These Margins are collected upfront for the trading in the Equity segments of MTF and Equity Cash.

4. GSM / ASM Margins : The entire initial margin (SPAN + Exposure) is blocked by the exchange. (This varies from stock to stock).
Use our Margin calculator published in our website to find out the margins for various securities & commodities.

Navia offers the following Trading Platform's and exchange segments for trading.

Trading platform	Exchange & Segments offered
ROCKET BASED ON BSE BOW API’S	ALL SEGMENTS
ITS (INFINI TRADING SOLUTIONS) BASED ON REFINITV API	ALL SEGMENTS

Listed below are the products available for the trading and the Exposure / margin required for trading in various segments of the exchanges for both delivery / carry forward & Intraday.

Products	Type	Exposure / Margins -Equity	Margin – Equity Futures / Options selling	Margin - Currency Derivatives	Margin – Commodity Futures/ options selling	Margin – Equity / Commodities options BUY
MIS(Margin intra-day square off)	Intraday with auto square off	50% of (VAR+ELM+ADDHOC) on derivative stocks	33% SPAN +33% ADDITIONAL MARGIN FOR INDEX (Only for ITS) AND 50% SPAN + 50% ADDITIONAL MARGIN FOR STOCKS	50% SPAN +50% Additional margin	50% SPAN +50% Additional margin	100% of Premium Value for Equity and Commodity
NRML(Normal)	Delivery / carry forward	1 X	100% SPAN +100% Additional margin	100% SPAN +100% Additional margin	100% SPAN +100% Additional margin	100% of Premium Value
CNC(cash and carry)	Delivery	1 X	NA	NA	NA	NA
CO / BO (Cover order) / Bracket Order	Intraday with auto square off	Based on Stop loss. Upto 10 X	Based on Stop loss. Upto 23 X for index and 10 X for stock futures/options selling	NA	Based on Stop loss. Upto 55 X	NA
MTF	Delivery	VaR + 4 times applicable ELM on Group I stocks available for trading in the F&O segment and VaR + 6.5 times applicable ELM on other approved stocks	NA	NA	NA	NA

Any order placed under MIS and CO & BO will automatically be squared off within half an hour before the market closes for respective exchange segments or the Intraday MTM reaches 80% whichever is earlier.

Navia offers trading only in the non agri products in MCX exchange and agri products are not allowed for trading in the Commodities trading platform offered by Navia. Further in the non agri segment Navia does not allow for delivery of contracts and the same is restricted in the system.

Navia’s right to Change the margins under any conditions without any notice.
Navia shall withdraw /reduce the intraday (MIS/CO/BO) leverage /margin 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,

• Exchange policy changes or regulation
• Government policy changes or regulation
• Stock broker internal policy changes
• Excessive or abnormal market movement / turnover / volatility in the domestic & Global markets.
• Any upcoming election results/ any other political changes.

What are the terms for the squaring /close out off 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 Secutities Account (CUSA) account stocks/ collaterals / demat account stocks with POA 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 positions as per this policy.

1. When Mark-to Market (MTM) loss breaches 80% or more of Capital/Margin
Once the MTM loss exceeds 80% of more of Capital/margin (which means that client has lost 80% or more of his capital/margin) for both Intraday (MIS/CO/BO products) and carry forward positions (NRML product), Navia shall cancel all open/ Pending orders and shall square off the entire positions of client at market. Further, the client shall be put in square off mode and shall not be able to place any fresh orders. Since some of these actions are not automated in the system, Navia can only square off positions on a best effort basis. It is possible that due to extreme volatility / high leverages used by the clients / market freeze or any other conditions, the MTM loss may exceed even 100% of capital / margin placed by the client before Navia can square off the positions. In all / any events Navia cannot be held responsible for such losses or charges incurred. It is the responsibility and onus of the client to continuously monitor his positions and bring in additional margin required as when the MTM loss is incurred so as to ensure that MTM loss does not exceed 80% of capital/margin placed where in the above square off condition is triggered. Under no circumstances can the client transfer his/her responsibility to monitor his/her positions to Navia. In the event that MTM loss exceeds 100% of the capital / margin, Navia reserves the right to liquidate the client DP stocks in any manner and at any time it deems fit.

2. When the Margin Shortfall exceeds 40% for the Carry forward positions (Trading terminal it is calculated as 140%).
Once the margin shortfall exceeds 40% of more of the required margins (for example the margin required is Rs. 1 Lakh and client has only Rs. 60,000 of margins left – this means that client has a deficit of Rs. 40,000 or 40% of required margins – client margins could have reduced due to MTM loss incurred or increase of exchange margins required on carry forward positions - NRML product), Navia shall reduce or completely square off the clients open positions to reduce the margin shortfall deficit. Please note that in the trading system the margin shortfall % is calculated by adding 100% to the shortfall. Hence a margin shortfall of 40% and 50% would reflect as 140% and 150% in the trading terminal respectively. (Margin shortfall is computed as = Span + additional margin + Realized MTM P&L and unrealized MTM Losses divided by Ledger Balance + Collateral + Pay in if any and then the result multiplied by100). Since some of these actions are not automated in the system, Navia can only square off positions on a best effort basis. It is possible that due to extreme volatility / high leverages used by the clients / market freeze or any other conditions, the Margin shortfall may exceed much beyond 40% of the required capital / margin placed by the client before Navia can successfully square off / reduce the positions. In all / any events Navia cannot be held responsible for such losses or charges incurred. It is the responsibility and onus of the client to continuously monitor his positions and bring in additional margin required as when client may incur MTM loss or margins are increased by the exchange so as to ensure that margin shortfall does not exceed 40% of the required capital/margin placed where in the above square off condition is triggered. Under no circumstances can the client transfer his/her responsibility to monitor his/her positions to Navia. In the event that margin shortfall exceeds 100% of the capital / margin, Navia reserves the right to liquidate the client DP stocks in any manner and at any time it deems fit.
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 in a position to square off the positions as per the RMS policy. Hence In this scenario, Navia shall not be held responsible for any losses due to the non-squaring off the positions.

MIS / Cover Order (CO) and Bracket order (BO) –time based Square off:
Any positions taken under MIS / Cover Order (CO) and Bracket order (BO) product 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. The clients when taking such positions under the MIS / Cover Order (CO) and Bracket order (BO product for availing higher leverages is aware of the risks involved in such time based square off. Client has the option to convert a MIS position to normal position (NRML) if adequate margin is available in the trading account. BO and CO positions cannot be converted but can be exited. This client should convert his/her MIS open positions or exit his/her BO/CO open positions before the beginning of auto square off mode of the MIS/Co/BO product. Since these are system based actions and successful triggering of time based square off may depend 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 product. It is the responsibility and onus of the client to continuously monitor his positions taken under the MIS product 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 thousands of such positions to be squared of manually it may not be possible for Navia to successfully square of clients MIS/CO/BO positions due to system failure. Under such circumstances client cannot hold Navia responsible for any losses/charges.

Margin Call square off – MTF funding 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 the Shortage / Excess value in the report below is a debit then 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 collateral) if the client fails to meet the margin call requirements.
For more information and FAQ’s related to MTF margining and risk management guidelines click on the link below.
http://support.tradeplusonline.com/solution/folders/1000228571

Liability clause due to square off / non square off the positions
Navia shall not be held liable for any loss that arise due to the above intraday square off the positions/ Close out of the positions/ squaring off the positions/ selling of the stocks due to the Nonpayment/ margin shortfall/ Mark to Market loss breaching the risk level etc. Further, the client agrees that Navia shall not be held responsible and liable for any loss /damage that arise in case where Navia has not squared off / not closed out the positions / covered the positions on time as per the above square off policy, due to any reason.
Navia reserves the right to change the above policies at any time in general or in particular case within the Exchange guidelines.
For more details and FAQ’s related to Navia’s risk management guidelines for various products and markets segments click on the link below.
http://support.tradeplusonline.com/solution/folders/1000137625

*Note: Intraday square off timings can change based on the discretion of our risk management department.
*Call & Trade charge will be applicable for all the positions squared off by our surveillance admin desk, including auto square off.

Handling of the Client securities – Policy on Client unpaid Securities Account (CUSA):
With respect to SEBI Circular No. CIR/HO/MIRSD/DOP/CIR/P/2019/75 dated June 20, 2019 on Handling of the clients Funds and Securities by Trading Members/ Clearing members ( TM /CM), the following changes have made to the RMS Policy.
Navia based on the above SEBI circular shall require to transfer the client's securities received in pay-out (T+2) 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 retain those securities in "CLIENT UNPAID SECURITIES ACCOUNT (CUSA)" and these securities will be transferred to the client’s respective demat account upon the fulfillment of funds obligation in the account. Further if at any time if the client fails to meet the funds pay-in obligation within five trading days (5) from pay-out day(T+2) then Navia shall liquidate the securities in the market 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 CUSA 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 outstanding, 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 in its sole discretion, determine the time of sell and securities to be disposed off (Not FIFO Method) and or which open position is / are to be liquidated / closed. Further Navia shall not take 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 buy trade immediately after the liquidation of the securities due to debit balances in the client account on 5th day. It is because further exposure is disallowed as the old debit is not realized and it will be allowed only on the realization of the debits in the account. Further, Navia at its discretion ought to liquidate the securities, if any taken immediately after the liquidation of the unpaid securities on 5th day and shall not held liable for any loss out of this liquidation.

https://naviamarkets.freshdesk.com/a/solutions/articles/1000282782

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. Depend 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 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 kind of limit 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. In 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 any 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 and 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.

Exposure Margin based on the shares lying in the Collateral account/ Client Unpaid Securities Account (CUSA).
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 deposited with Navia. On a daily basis, Navia shall upload the client’s base capital including ledger balance and the client’s collateral deposits after applying the appropriate haircut to the client trading account as trading margin and CUSA account shares / shares lying in the client’s depository account as holding to trade in shares and securities. 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 margin table presented above and the quantum of the multiple shall be decided at the sole discretion of Navia from time to time. Further, Navia shall consider the POA shares for the margin reporting to the exchange, only if there are no sufficient cash margins available in the trading account to meet the required margin on the Trade day. The margin for the POA shares will be calculated after applying the necessary exchange hair cut and it will be considered for reporting only to the Equity Derivative segment and not to the Currency derivative segment.

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 sale of share/securities value will be added to the client’s base capital/Cash margin, during the trading hours, after adjusting the debits if any, to the client account as per the CFS percentage decided and fixed by Navia. The client can trade based on the cash Margin as well as the securities margin, but in both the cases, the client has to make the payment on or before the exchange pay in date i.e. (T+2) otherwise, these shares shall be liable to be squared off, immediately after the pay in time or any time due to the shortage of margin.

Trading benefit based on Futures Credit
Navia shall provide the benefit of the “Futures credit” in the derivative segments i.e the booked MTM credit, premium credit, credit due to the close out of the positions etc. after deducting the debits if any, for taking the fresh positions in the market. But as per the rules and regulations of the derivatives trading, these credits are settled only on the T+1 day by the exchange. Hence, there is a possibility of short margin reporting to the exchange on the open positions and Navia shall not be responsible for any penalties charges debited by the exchange. The client agrees to bear the losses or penalties if any on account of such trading.
Navia reserves the right to sell or square off the client’s positions in securities and derivatives or the Client Unpaid Securities account stocks/ collaterals / demat account stocks etc. under the following conditions

Margin Call square off – Margin Trade Funding Account: ( MTF)
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 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 support@tradeplusonline.com 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.

Further, if there is a margin shortfall in the MTF account, Navia shall make the margin Call to the client by e-mail / SMS / Call to transfer funds or securities to cover the margin shortfall. But if at any time if the client fails to meet out the margin shortfall for Five consecutive trading days, Navia shall square off / sell the positions either Fully or Partially to the extent of margin shortfall. Navia shall not be liable or responsible for any kind of losses incurring out of this squaring off action.

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 to clear these debits.

Navia shall withdraw /reduce the intraday (MIS/CO/BO) leverage margin/ Exposures 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,

• Exchange policy changes or regulation
• Government policy changes or regulation
• Stock broker internal policy changes
• Excessive or abnormal market movement / turnover / volatility in the domestic & Global markets.
• Any upcoming election results/ any other political changes.

Blocking of the Debit accounts as per the Enhanced Supervision:

The following is the extract of 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 the fifth trading day, as reckoned from date of pay-in.”

Based on the above it is inferred that when clients fail to clear their debit balance beyond 4 days from the date of pay-in or in other words 6 days from the date of trade i.e T+2+4 trading days, excluding Saturday /Sunday and Holidays. Navia shall block such client accounts and shall not grant any further exposure till the client clears the debit. Further, if the client sell the share or transfer the amount on the blocking day, Navia shall not allow the client to trade on the same day.

Imposition of Penalty/ Delayed payment charges ( Interest) / Cheque bounce charges:
NAVIA follows the practice of posting the settlement obligation towards their transaction in the client ledger on the settlement date. All clients are advised to make the payment before the pay-in time on the settlement day, though there are instances wherein client may delay the payment beyond T+1 or o the settlement date. Further the clients are required to maintain 100% SPAN + Additional margin for carry forward positions in the Equity Derivative Segment/ Currency Derivative Segment and Commodity futures segment.
In the above scenario not making the payment on time, the clients will be liable to pay late pay in/ delayed payment charges ( interest) for non-making payment of their pay in/margin obligation on time as per the exchange requirement/schedule at the rate of up to 2% per month or as per the applicable rate decided by NAVIA from time to time. Navia shall charge the interest on the shortfall margin amount in the Equity derivatives, Currency derivatives and Commodity future segment, without considering the value of the Collateral shares provided for the trading margin. The client further agrees that Navia may impose fines/penalties for any orders/trades/deals/actions of the client which are Contrary to this agreement rules / regulations/bye laws of the exchange or any other law for the time being in force. At such rates and in such form as it may deem fit.
Further, if at any time where Navia has to pay any fine or bear any punishment from any authority in connection with/ as a consequence of in relation to any of the orders/ trades/ deals/ actions of the client, the same shall be borne by the client.
Navia shall transfer the demat account debits including the Annual fees, transactional charges or any other debits related to the bank charges/margin penalties/ short delivery debits/ etc to the client’s trading account. Further, if at any time if the client dishonors/bounces the given cheque, Navia shall debit the client account with the bank charges and the penalty that may be decided by Navia from time to time.
Exchange Margin shortfall Penalty/ Provisional margin Penalty:
If at any time, the Exchange impose margin penalty @ 1%or 5% (as per the number of days) on the total margin shortfall in the futures and segment trades, Navia shall pass this penalty amount to the client‘s respective trading accounts. Further, Navia on a daily basis shall calculate the provisional margin penalty amount as per the exchange rates @ 1% or 5% respectively and shall debit the provisional margin penalty amount to the client’s respective trading ledger. This provisional margin penalty amount will be reversed in the client’s trading ledger upon debiting the actual margin penalty amount to the respective client’s trading ledger.

Exchange Margin shortfall Penalty & Margin Provisional penalty debit process:
If at any time, the Exchange impose margin penalty @ 1% or 5% (as per the number of days of shortfall) on the total margin shortfall in the derivatives segment, Navia shall pass this penalty amount to the client‘s respective trading accounts. In view of the above penalty , Navia shall debit the respective clients accounts with Provisional margin shortfall penalty on the day of margin shortfall, and shall reverse and debit the actual margin shortfall penalty amount upon the receipt of the penalty file from the Exchange.

Other Surveillance Actions:
1. Regulatory conditions under which a client may not be allowed to take further position or Navia may close the existing position 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 down to create a new position

2. PMLA Guidelines:
2. Client will be categorized as High, Medium and Low risk customer 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. For more details on PMLA and Navia’s policy click on the links below
http://support.tradeplusonline.com/solution/articles/1000266642-faq-s-on-pmla
https://tradeplusonline.com/Terms_And_Condition.aspx

3. Exposure to client may also be governed by customer profiling mentioned above as well as clients financial income made available to Navia from time to time.

4. Suspending Client’s trading account:
4. Navia may withhold the payout of client and suspend his trading account due to any internal surveillance (if client indulges into manipulative trade practice) / regulatory orders (debarring orders).

5. Dormant Account:
5. 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 sending an e-mail to support@tradeplusonline.com or from website of Navia or using the Mobile APP.

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 that witness abnormal price rise, which not commensurate with the net worth and fundamental’s of the company. Navia as a risk containment measure shall allow trading in these shares only on Cash & Carry product (CNC) i.e 100% margin. Exchange also levies Additional Surveillance Margin (ASM) in Equity Derivatives Segment on all gross open positions on Future Contracts and on Short Positions in Options Contract. The above mentioned ASM shall be added to the applicable exposure margin of the respective index/stock futures and options contracts. For more details on ASM refer the link below.


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, which not commensurate with the net worth and fundamental’s 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 clients holds the same in their account. For more details on GSM click on the link mentioned below.
http://support.tradeplusonline.com/solution/articles/1000249307-graded-surveillance-measure-introduction-and-faq-s

8. Stocks are blocked from trading based on the unsolicited SMS
Navia shall block the securities for which unsolicited messages are circulated and reported by Exchanges from trading.

9. Policy on the do not exercise option in the Equity derivative segment
Navia shall monitor and square off the in the money option contracts, where the possibilities of the STT is more than the total margin amount ( i.e. premium + cash available) without giving any intimation to the clients. Further, if at any time, if the client has not squared off the in the money option contract and allowed to exercise, Navia shall calculate the STT after the market hours and if the STT is more than the total cash available (cash+ premium), then Navia without any notice to the client shall upload the client position to the Exchange for the do not exercise option.

Policy on the Physical settlement of the derivative contracts in the future/ Option segment.
Navia shall not allow any physical settlement of the derivative contracts in the future and options segment and as a process Navia shall block all the current month derivative contracts under product NRML on the day of expiry. Navia shall follow the below actions on the expiry day;

• Fresh positions in current month expiry contracts in NRML/MIS/CO/BO will be allowed upto 1 day prior to the expiry of the contract. On the expiry day all overnight NRML positions would be uploaded as MIS positions which would be compulsorily auto squared off by the risk management system (RMS) upto 30 minutes prior to the market closing, if not closed by the client. Call N Trade charges would apply if the position is auto closed by the RMS
• Such MIS positions cannot be converted to NRML for expiry day contracts.
• Navia shall not allow any scrip to be settled for physical delivery on the expiry day.
• Since margins are applied and increased on a graded manner for In the money (ITM) contracts from 4 days prior to expiry, penalty and interest charged on margin shortfall, if any would be debited to client account.
• Delivery margin imposed on the physical delivery of the contracts during the expiry period ( 4 days) , will be debited to the client ledger but shall not be applied to the trading terminal during the trading day,( except NEST/ITS trading system) hence there can be a difference in the shortfall of margin amount reported from the ledger and trading day margin in the trading terminal. ( Please follow the back office ledger margin shortfall report)

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 claims, expenses and costs due to the squaring off the entire positions or non –squaring off the positions and resulting Physical delivery.

Settlement of the Commodity options Contracts on the expiry day & Devolvement Process.
The term Devolvement means conversion of a commodity option In the money (ITM) / Close to money (CTM) contract to commodity futures contract on expiry day. If the options contracts are not covered / closed by the client, then exchange will charge the devolvement margin @ 25% (on T-2 day) and @ 50 % (on T-1 day) on the ITM/ATM/CTM Contracts. ’T’ refers to the expiry day of the contract. Further, if the client has not closed the ITM contracts on the expiry day, these particular option contracts will be devolved /Converted to the current month future contract based on the strike price of the option contract, and all the out of money (OTM) contracts will be closed automatically with zero price. In case of CTM contracts, if the same is not squared off by client prior to expiry then an explicit instruction need to be placed in the Trader work station (TWS) terminal provided by the MCX exchange to convert this contract to future contract.
In the view of the above devolvement process, Navia shall not allow any option contract to be devolved to the future Contract. Further, if there is any margin short fall in these 2 days (T-2 day and T-1 day), due to increase in devolvement margins, the client position will be closed as per the margin shortfall policy as stated above and any margin shortfall penalty will be debited to client. Navia shall not be responsible for not debiting/ collecting the devolvement margin upfront in the trading terminal.
For more details on the devolvement process and risk management policy for such option contracts click on the link below:
http://support.tradeplusonline.com/solution/articles/1000271465-navia-s-policy-process-on-the-mcx-option-settlement-devolvement
What are the Risk Parameters measured by the RMS for monitoring & squaring off the Positions.

1. Navia shall square off all intraday positions within the last half an hour session of the trading of the respective exchange segments, if not squared off by the clients.
2. Navia shall not allow carry forward of the positions taken under the MIS/CO/BO intraday products.
3. Navia shall not provide any intraday adhoc margin other than the credit balance uploaded as base capital.
4. Clients are permitted to convert the product from MIS to NRML with the available margin before the start of the time based auto square of period of the respective segments of the exchanges.
5. Navia has set restrictions on single order quantity and single order value on various exchange segments. This is done to prevent “fat finger errors” and is also a mandatory exchange requirement. The values set by Navia are based on Navia’s assessment of risk/ Navia’s net worth /trading turnover of Navia in various exchange segments etc. It is possible for client orders to get rejected due to these limits getting hit. On the best effort basis Navia will review these limits and re-adjust them to allow client orders. However this is at the sole discretion of Navia and Navia will not be responsible for any loss / opportunity loss as a result of orders being rejected by the trading terminal due to these limits being hit. To see the exact limit set click on the link given below
   http://support.tradeplusonline.com/solution/articles/1000271428-what-are-the-overall-limits-set-in-various-trading-platforms-as-per-exchange-regulations-and-to-be-pr
6. Navia shall square off the Client Unpaid Securities Account position on 7th day (on T+2+5 ) if debit in client account is not cleared by that time or the credit coverage ratio reduces to 110%, whichever is earlier. Credit coverage ratio is Total value of stocks held with Navia in Client Unpaid Securities Account plus open and un-settled positions divided by total debit in client ledger.
7. Navia shall not allow trading in the illiquid scrips as specified by the exchange / or at its own discretion in the Options segment.
8. Navia shall not allow the physical settlement of the Futures and options Contracts in the equity derivative segment
9. Navia shall not allow the delivery of the commodities in the Commodity segment.
10. Navia shall not allow to devolve the commodity option contracts in the Commodity segment unless and until the clients specifically writes to Navia to devolve the contract and also should have the sufficient margins.
11. Navia shall not be responsible or held liable for the losses/ damages/ opportunity claims etc that arises due to the technical issues in the trading system / malfunction of the trading software during the trading hours or after the trading hours.

Policy on the limit setting in the NEAT terminals.
Navia with reference to the NSE circular reference No. 80/2012 issued on October 2012 directing the Trading member to set limits at various levels in their respective trading terminals. Navis has set such limits based on the risk mitigation and safe guard mechanism from “fat finger trades” on the following basis, 1. Quantity limit for each order 2. Value limit for each order,3. User value limit for each user ID,4. Branch value limit for each branch ID and 5. Spread order Quantity and Value Limit. 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 client’s to trade. But in the mean time, 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.

Tender Period:
It is the period, that starts few days before the expiry, and since Navia shall not allow to give/take delivery of the Commodities this period will not be applicable for open positions.

Delivery Policy in Commodity
Navia shall not allow the client to mark delivery of open positions of a future contract and the open positions shall have to be closed out before the tender period starts. If at any time an open position of a future contract is not closed out 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.

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) / Equity Futures & Option Contracts for the trading and shall not allow the product “ NRML” on the expiry day to trade on the option contracts. Further, Navia shall not allow any illiquid option Contracts and these contracts shall be blocked from trading in the market. The Client agrees on the blocking of these illiquid contracts from trading and shall not claim any loss /damage /opportunity loss for trading or not trading in the illiquid futures and options contracts.

Base Package(s) and Add On package(s).
Navia to make the trading simple has offered the base packages and Add On package facilities for its clients. The clients can subscribe these packs online by logging to the Subscription Management portal in the web site, or by calling or sending e-mail from the registered e-mail to Client service Desk. Add On packages includes, Call & Trade, trade instant SMS, Infini trading solution etc. Navia shall maintain a separate ledger in the client subscription Management Portal for managing these packages subscribed by the client. Navia shall auto debit these subscription amount on a monthly basis, and the client’s are responsible to keep sufficient amount in the client’s ledger in the Subscription management Portal by recharging the account. If at any time, the client’s ledger in the subscription Management Portal, does not have the sufficient amount to renew these subscribed packages by auto debit, Navia shall transfer the required amount from the Clients trading account ledger to the clients ledger in the subscription Management Portal.



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 exist from time to time and as it apply 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.

The right to sell securities or close out client’s positions without giving notice to the client, on account of non- payment of client’s dues.
Without prejudice to Navia’s other right (including the right to refer the matter to arbitration), Navia shall be entitled to liquidate/close out all or any of the clients position without giving notice to the client for non-payment of margins or other amounts including the pay in obligation, outstanding debts etc. and adjust the proceeds of such liquidation/close out, if any, against the clients liabilities /obligations. Navia has the right but not the obligation, to cancel all pending orders and to sell/close/liquidate all open positions/securities/shares at the pre-defined square off time or when Mark to Market (M-T-M) percentage reaches or crosses stipulated margin percentage, whichever is earlier. Navia shall have the sole discretion to decide referred stipulated margin percentage depending upon the market condition.
Further the Client authorizes Navia to sell /dispose the shares lying in the depository account or square off all or some of the positions as Navia deems fit in its discretion without any intimation/reference to the client for the non-receipt of the payment/ mark to market Loss/ Margin shortfalls/ Penalties/Charges etc. for the trades that are carried out through the depository account margin provided by Navia.
In the event of such square off, 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 claims, expenses and costs due to the squaring off the entire positions or non –squaring off the positions.

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.

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/shortage of margin 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 making of payment for their pay in obligation/outstanding debts.
The following are the condition under which the client is not allowed to trade further

1. If the cheque bounces with the insufficient funds or any other reason
2. if the client’s debit on the T+2+5 days is not settled,
3. If the client’s welcome kit/contract note returns to the sender.
4. If the client is being debarred by the SEBI/ or any of the regulator.
5. If the client’s Mark to Market loss reaches at the risk level and shall not provided the extra margin to meet the mark to market loss/ margin shortfall.
6. If the client’s transaction is reported as suspicious and identifies under PMLA.

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.

• If the action of the client are prima facie illegal/improper or such as to manipulate the price of any securities or disturb the normal/proper functioning of securities or disturb the normal/proper functioning of the market, either alone or in conjunction with others.
• If there is any commencement of a legal process against the client under any law in force;
• On the death/lunacy or other disability of the client.
• If the client being a partnership form, has any steps taken by the client and/or its partners for dissolution of the partnership.
• If the client suffers any adverse material change in his/her/its financial position or defaults in any other agreement with the stock broker.
• If there is reasonable apprehension that the client is unable to pay its debts or the client has admitted its inability to pay its debts as they become payable.
• If the client is in breach of any term, condition or covenant of this agreement.
• If the client has made any material misrepresentation of facts, including (Without limitation) in relation to the security;
• If a receiver, administrator or liquidator has been appointed or allowed to be appointed of all or any part of the undertaking of the client;
• If the client have taken or suffered to be taken any action for its reorganization, liquidation or dissolution;
• If the client has voluntarily or compulsorily become the subject of proceedings under any bankruptcy or insolvency law or being a company, goes into liquidation or has a receiver appointed in respect of its assets or refers itself to the board for industrial and financial reconstruction or under any other law providing protection as a relief undertaking.
• If any covenant or warranty of the client is incorrect or untrue in any Material respect;
• If the client is not able to adhere to the policies and procedures of the Company, Navia shall terminate the client with one month notice as per the clause no. 28 of the rights and obligations of the stock broker, sub-broker and clients.

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.Client can get their account reactivated by either login into the web portal of the company or writing an email to registered email id or calling our customer support desk from registered phone number.Further, if the client becomes inactive, Navia will settle the funds and securities based on the Running Account Authorization provided by the clients on a quarterly/monthly basis based on the client’s instruction.

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, andas 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 understand 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 clients 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.

Customer support:
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.aspx

Investor grievances
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 compliance@naviamarkets.com and for the escalations ig@naviamarkets.com
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.

Note:

• Please be advised that a Call & Trade charge will be applied for all OFS, Buyback and Takeover orders placed through NAVIA.
• Call & Trade charge is applicable for positions squared off due to insufficient funds / intraday (MIS/ CO/ BO ) square off through admin terminal.
• Option premium received from writing options will not be considered as Cash/Capital.
• MIS/ Co /BO is not available on currency options.
• CO/BO is not available on Currency /Cross Currency futures.
• CO/BO is not available for stock options& Index options.
• Positions which do not have sufficient funds can be cut any time at the discretion of our RMS desk. There will be no margin calls or intimation from the surveillance admin department desk.
• Any open positions can be squared off at the discretion of the surveillance (RMS) desk, If the funds available in your account are short of exchange specified margins. There will be no margin call before the position is squared off and margin short fall percentage will be sent via SMS to the client registered mobile number.
• During times of extreme volatility, the loss could be more than the funds available in your account before the position is squared off. All resulting charges or debts that might occur from such square offs will have to be borne by the client.
• Leverages may vary between Rocket and ITS with the latter allowing higher exposure.
• All BO, CO and MIS positions will automatically be squared off last half an hour before the close of market for the respective segments.
• Trading in MCX contracts will be banned a day prior to the delivery intention period.
• Fines levied by the exchange for short margin will be payable by the client.
• BO and CO is not allowed in pre open for Equities.
• Navia shall square off all intraday positions within the last half an hour session of the trading, if not squared off by the clients.
• Navia shall not allow carrying forward the positions taken under the MIS intraday product.
• Navia shall not provide any intraday adhoc margin other than the credit balance uploaded as base capital.
• Clients are permitted to convert the product from MIS to NRML with the available margin on or 30 minutes before the market closes.
• Navia has limited the single order value to 10 Crores in the F&O segment and the single order quantity in the equity cash segment is 20000 shares. This is subject to change based on market conditions.
• Navia shall square off the Client Unpaid Securities Account position on 6th (T+2+4) day, if the payments are not received or the credit coverage reduces to 110%, whichever is earlier.
• Navia shall make a margin call if the daily MTM loss is not paid by the client in the Margin Trading Funding account, and shall square off accordingly.
• Navia shall not allow trading in the illiquid securities as specified by the exchange in the Options segment.
• Navia shall upload the client option position to the exchange for the do not exercise option, if the client has not closed the position allowed to exercise, and the STT will be more than the receipt of the premium amount.
• Payments will only be accepted from the client’s registered bank account, cash and DD payins are not accepted.
• For Commodities, on the start of delivery intention period, no contract will be available under MIS/NRML or CO/BO product type.
• Physical Delivery of Commodities are not allowed.
• Instruments available for trading at NAVIA are subject to the discretion of the risk management team, and these may change from time to time for various reasons.

Navia has prepared detailed FAQ’s on margin policies and the same can be accessed from the link below:
http://support.tradeplusonline.com/support/solutions/folders/1000137625

NAVIA PMLA Policy

Anti-Money Laundering Measures
Background
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.

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 also issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT until December 15, 2008

Objective
Money laundering has now become one of the major concerns of international financial community. Money Laundering is not just an attempt to disguise money derived from illegal activities. Rather, money laundering is involvement in any transaction or series of transactions that seek to conceal or disguise the nature or source of proceeds derived from illegal activities, including drug trafficking, terrorism, organized crime, fraud and many other crimes.

The objective is to have a system in place for preventing any money laundering financial transaction through us and also to identify, monitor, report any such transaction to appropriate authorities.

“Know Your Customer “(KYC) is the guiding principle behind the Anti-Money Laundering (AML) measures. It incorporates the “Know Your Customer” Standards & “Anti Money Laundering” Measures, hereinafter to be referred as “KYC Standards” and “AML Measures ". The objective of is to “have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the Company from being used, intentionally or unintentionally, by criminal elements ". KYC Standards and AML Measures would enable the Company to know/ understand its customers, the beneficial owners, the principals behind customers who are acting as agents and their financial dealings better which in turn will help the Company to manage its risks prudently

The management of the company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance with respect to all relevant legal requirements.

The regulatory / statutory requirements
An officer of the company will be designated as “Principal Officer” who will ensure proper discharge of all legal requirements with respect to the same. For the purpose of monitoring the transaction and reporting the same to the FIU-IND, Mr. Francis Kurian is appointed as the principal officer and the same has been reported to the FIU-IND.

Designated Principal Officer: Mr. Francis Kurian
Email id: franciskurian@naviamarkets.com
Tel No: 044- 39189422

The Principal Officer will be responsible for

• Compliance of the provisions of the PMLA and AML guidelines
• Act as a central reference point and play and active role in identification & assessment of potential suspicious transactions
• Ensure that NAVIA discharges its legal obligation to report suspicious transactions to concerned authorities.

The main aspect of this policy is the customer due diligence process which means:

• Obtaining sufficient information about to the client in order to identify who is the actual beneficial owner of the securities or on whose behalf transaction is conducted
• Verify the customers identity using reliable independent source document, data or information
• Conduct on-going due diligence and scrutiny of the account/ client to ensure that the transaction conducted are consistent with the clients’ background/ financial status, its activities and risk profile.

Client Acceptance Policy:
In normal circumstances, all prospective clients are accepted as client by the company except the following categories.

1. Client’s who don’t have SEBI prescribed basic KYC documents
2. SEBI banned entities
3. Documents suspected to be non genuine
4. Clients who is having criminal back ground
5. Client who is having direct relationship with the criminal back ground person
6. Unable to ascertain the identity of the clients through information provided
7. Perceived non-cooperation of the client for complete details
8. Client being defaulter and have cases filed against him

Confirmation of Client’s Address at HO:

In addition to the in person verification carried out, at the head office where the centralized account opening takes place, the address of the client is confirmed by way of phone call. Whenever the client is submitting the application form through any of the branches/sub-brokers, the client will be called on their landline/mobile phone to confirm whether the client has given the application form opening the account or a benami account is opened. This reduces not only the risk of opening any benami account but also reduces the chance of the welcome kit, contract notes being returned.

It is also stated that if the address that is mentioned in the application is same as confirmed by the client then the account is further taken for processing, else the same will be returned by the client registration department to the respective branches/sub-brokers. Also once the account is opened, the welcome letter to the client is sent mentioning his client code, brokerage structure,his/her bank account number and all other KYC related details. On a daily basis, contract notes of the clients sent directly to their mailing address if the client not opted for digital contract notes. If it is returned, the separate policy on contract note returned is followed.

Clients of Special Category (CSC) shall be read as under:
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:

Non Resident Clients:
While opening NRI account utmost care is being exercised. While opening an NRI Repatriable or NRI Non Repatriable we collect the following documents from the clients:

1. Pan Card Copy
2. Passport Copy
3. Indian Address Proof
4. Cancelled Cheque copy of NRE A/c
5. PIS Permission issued from RBI.
6. NRI Address Proof
7. Bank Statement Copy.

All transactions of NRI clients are scrutinized before executing the transaction in the system for the source of funds and securities. Upon satisfying the origination of the funds and securities, the trading account of this category is allowed to trade

High Net worth clients
High net worth clients could be classified if at the account opening stage or during the course of the relationship, it is realized that the client’s investments or the appetite for investment is high. The High net worth clients are basically categorized as the clients having Net worth of Rs.10 Crores or more.

Trust, Charities, NGOs and organizations receiving donations:
Both public as well private, registered as well non registered trust will have to be classified in the special category. Any Charitable or Non-governmental organization or a Non Profit Organization will be also classified herein.

Companies having 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 have been opened at different times, are same, if yes, then both need to be marked under this special category.

Politically exposed persons (PEP):
PEP are the individuals who are or have been entrusted with prominent public functions in a foreign country, e.g. Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. PEPs may be identified in below mentioned manner:

• The client himself provides the details of being PEP
• Through publicly available information
• According to the database available.

In case of PEPs an extra care is taken while opening the account. We open such accounts only after informing senior management.

Client Identification Procedure under PEP:
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 and take supporting document to ascertain the identity of such beneficial owner. Further, the existing client turned to the PEP, or relative of PEP, the necessary approvals will be obtained from the TOP MANAGEMENT to continue as client of the company.

The above categories are segregated based on the status and trading pattern of the clients which covers the identification of the special category of the clients as per the PMLA. . 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.

1. High Risk Client
2. Medium Risk Client
3. Low Risk Client

Based on the client profiles, the category is allotted to the client and these profiles are

High Risk Clients

1. Clients who are refusing to provide their financial details / source of income.
2. Clients against whom any action has been taken by SEBI/Stock Exchanges or any other regulatory authority in the past
3. Individual clients whose employer is a politician, Income tax / custom department or any other sensitive government department.
4. Clients residing in sensitive areas. For example, Naxalite region, areas where dealing in narcotic drugs, immoral traffic, corruption etc is highly prevalent.

Medium Risk Clients

1. Client whose account is operated by POA holder other than NAVIA.
2. Client’s who have given trading authorization in some other person’s name (excluding Authorized person)
3. Clients whose trading pattern is not in line with their declared Income.

Low Risk Clients
All clients not dealing with the above criteria are low risk clients.

Suspicious Transaction Reporting:
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.

Dormant Accounts:
Any trading client is not traded continuously with the Company; the said client account is suspended from trading in the system. Whenever the client wants to start trading the client has to send an e-mail to support@tradeplusonline.com from the registered e-mail id to activate the account before initiating the trade. Further, if the trades are executed, offline, our Client Dealing department will call and provide the trade confirmations at the end of the trading day to avoid the unauthorized transaction if any.

Off-Market Transfer between client accounts in NSDL system:
Any off market instruction submitted by the clients are scrutinized before processing the same in the NSDL system. Any transaction value Rs.2 Lac or more, the DP staff will call and verify the sanctity of the instructions and processed the same in the system. Any alerts are noticed, the same is reported to the appropriate officials for further action.

Retention of Records:
The process flow of maintain the application and KYC documents submitted by the clients are as follows

All the KYC documents will be indexed and will be sent to the godown where the same will be packed in the polythene bag and stored in carton box which is fire proof. Further, the KYC forms and other requests and other requests submitted by the client towards updating/modification of the details also attached to the respective client’s KYC form are scanned and made available for verification at any point of time.

Funds Pay-in & Pay-out to the Clients:
All funds pay-out made by the company to the clients only to the respective client name only with crossed cheque or fund transfer to the respective client’s registered bank account only. All funds pay-in received from the clients are verified and validated with the registered bank details of the clients before crediting the amounts to the client account. Further, we have clear policy on not to entertain any cash transaction from/to the clients.

Employee Hiring and Training:
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.

Review of Policy
Principal Officer & Compliance officer shall be the authority to review the policy updated by DP Team 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.

The principal officer shall report the nature, amount, date and all related details of any and all suspicious transactions recorded.

Amendment / Modification of the Terms:
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.

Client Acceptance of policies and procedures stated herein above:
I/ we have fully understood the same and do hereby sign the same and agree not to call into question the validity, enforceability and applicability of any provision/clauses this document any circumstances what so ever. These policies and procedures may be amended/ changed unilaterally by the broker. I/ We agree never to challenge the same on any grounds including delayed receipt/ non receipt or any other reasons whatsoever. These policies and procedures shall always be read along with the Agreement, Terms and Conditions and shall be compulsorily referred to while deciding any dispute or difference or claim between I/we and Navia before any court of law/judicial/adjudicating authority including arbitrator/mediator etc.

By clicking on the "I agree" button, I/We agree to be legally bound by these Policies and Procedures of the Company Navia Markets Ltd.