P.H. Financial and Investment Consultants Private Limited was founded by Late Mr. Ranchhor Hariram Hemdev, Late Mrs. Rani Ranchhor Hemdev and Late Mr. Prakash Ranchhor Hemdev. At the outset, they began this organization as one of the key players in Inter Bank Call Money Market. However after the Reserve Bank of India intervention the business model transitioned to being Intermediaries for Inter Corporate Deposits and which still continues to be an integral part of our business. In these many years, PH Financial and Investment Consultants Private Limited branched out in several arenas of Corporate Finance. In 1994, we became members of National Stock Exchange of India Limited for their Cash Segment as well as the Future & Option Segment. In 1996, we also branched out as Distributors of Mutual Funds by getting our own ARN Code – 0266. We are and strive to continue to be Specialists in several areas of Corporate Finance like Placement of Commercial Paper, Non Convertible Debentures, Promoter Funding, Loan against Shares, Bills Discounting and Short Term Loans. We believe that Corporate Finance is the area of Finance dealing with monetary decisions that business enterprises make and the tools and analysis used to make these decisions. The Primary Goal of Corporate Finance is to maximize Shareholder value while managing the firm's financial risks. As Arrangers of Finance, we realize that each Client is unique and so is their financial requirement. Over this period, PH Group has found its feet by making several Large and Mid Cap Companies along with a number of Banks and NBFC’s a part of the PH Family as clients by providing them customized services to suit all their needs. Our bouquet products are non-standardized and structured to meet the specific financial objectives of our Clients.
022 - 668118 01
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Jaisingh Business Centre,
Sahar Road, Parsiwada, Andheri (East), Mumbai - 400099, India
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P. H. FINANCIAL & INVESTMENT CONSULTANTS PRIVATE LIMITED (hereinafter referred
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The underlying document outlines various policies and procedures P H Financial and
Investment Consultant Private Limited (PHFIC) framed with respect to its dealing
with clients to ensure transparency and facilitate understanding on various aspects
related to service delivery.
Kindly note that the below stated policies and procedures are subject to change from time to time; depending upon our internal risk management framework, market and external environment;
Procedure for Client Registration and Documents maintenance
Procedure for UCC Upload
From our back-end, we generate file for the client containing data in KYC of market segment, client code, client name, PAN, address in the format prescribed by NSE. The data generated are thereafter verified with KYC. On the data being found fully correct, the client is uploaded on UCC â€“ site of NSE . The PAN card is verified through income tax website.
Procedure for Sales Practices followed by us
Procedure for Customer Category & Exposure Limits
|a.||High Net Worth Individual (HNI) Client accounts||This category of clients will be the client Having specified Minimum margin in form of Cash or approved securities as described by the company from time to time.|
|b.||Retail Client Accounts||All other clients, not falling with in above category are provided with minimum limit as described by the company from time to time.|
Procedure for Brokerage Rates
At present SEBI permits maximum brokerage @2.5%. The Company charges brokerage to their clients at the rate below this maximum limit. Each client will be intimated the rate at which brokerage will be charged to him. This rate will be revised by the Company based on volume of the Clientâ€™s business/ market conditions / other relevant factors. Any change in the rate of brokerage will be intimated to the client in writing in advance.
We follow the following Procedure for Order Receipt and Execution
Procedure for sending Contract Notes, Daily Margin statement, Quarterly Statement of Accounts to clients
Policy for Client Code Modification
Procedure for Payment, Receipt of funds from / to clients
Procedure for Receipt, Delivery of Securities from /to Clients
Procedure for Penalty / Delayed Payment Charges
PHFIC may levy late payment charges to the clients who have not cleared their dues towards settlement / margin obligations within the time prescribed by the exchanges from time to time at specified rate as decided from time to time, till the dues are cleared. Further where the Company 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.
Procedure for Policy for internal shortages
Procedure for Shortages in obligations arising out of netting
If the client defaults on its existing obligation and in the event the trade has been internally netted off by PHFIC , PHFIC shall have the right to square off the position of the client to make good the shortages arising thereof. PHFIC shall not be responsible for losses to the Client on account of such square off. All losses to the Client on this account shall be borne solely by the Client and the Client shall indemnify.
Procedure for refusal of order for Penny Stocks:
Although the term â€˜Penny Stockâ€™ has not been defined by NSE/ SEBI, a penny stock generally refers to a stock which has the below mentioned characteristics:
PHFIC Pvt. Ltd. acknowledges that it is a clientâ€™s privilege to choose the shares/
scripts in which he/ she wants to trade. However, the company would like to pay
special attention, when it comes to dealing in penny stocks. To this end: The
may refuse the request of the client to deal in penny stocks, without assigning
any reason for the same.
Any large order of purchase or sale of such stocks should be referred to the head of the Dealing Department, and subsequently may or may not be placed for execution.
Clients must ensure that trading in such stocks does not result in creation of artificial volume, or false or misleading appearance of trading. Further, clients should ensure that trading in such stocks does not operate as a device to inflate or depress or cause fluctuations in the prices of such stocks.
Clients are expected not to place orders in such stocks at prices, which are substantially different from the prevailing market prices. Any such order is liable to be rejected at the sole discretion of the company.
In case of sale of such stocks, the client should ensure that the delivery of shares to the company before the pay-in date.
Procedure for Collection, maintenance & reporting of margins
Right to sell clients securities or close clients positions, without giving
to the client on account of non payment of dues. (Limited to settlement/margin
PHFIC would have the discretion to square off the position of the Client, with no obligation of communicating the same to the Client, in following circumstances:
The Client accepts to comply with requirement of payment of Margin/settlement
of the Client, immediately, failing which PHFIC may sell, dispose, transfer or deal
in any other manner the securities/margin already placed with it as Margin or
all or some of the outstanding positions of the Client as it deems fit at its sole
discretion without further reference to the Client and any resultant or associated
losses that may occur due to such square -off/sale shall be borne by the Client
and PHFIC shall be fully indemnified and held harmless by the Client in this behalf
at all times.
Any reference in the terms to sale or transfer of securities by PHFIC shall be deemed to include sale of securities which form part of the Margin maintained by the Client. In exercise of PHFIC right to sell securities, the Client agrees that the choice of specific securities to be sold shall be solely at PHFIC discretion without any reference to client. Such liquidation or close out of positions shall apply to any segment in which the Client does business with PHFIC.
The provisions specified herein do not confer any liability on PHFIC to square off the clients positions. It shall be the responsibility of the client to pay to PHFIC any due payable to PHFIC irrespective of whether PHFIC exercises its right to square off the positions of the client in accordance with the provisions given herein above. However, in the event of extreme volatility and / or clientâ€™s open (outstanding) position resulting in mark to market losses beyond PHFIC, threshold limit any time during a trading session, and /or clients positions or collateral being not saleable, thereby forcing PHFIC to liquidate any position of the respective clientâ€™s available positions and collateral, same shall be done by PHFIC during the course of a trading session without recourse to the client.
Conditions under which client is not allowed to take further positions or PHFIC may close existing positions
PHFIC shall have the right to refuse to execute trades/allow the client to take further positions in the following circumstances:
PHFIC shall also have a right to close existing positions of the clients in the
abovementioned circumstances and PHFIC shall not be responsible for any loss
by the Client due to any of aforesaid conditions of refusal or closure of positions
and the client shall keep PHFIC indemnified at all points of time in this
Procedure for Temporarily suspending or closing of clientâ€™s account at the clientâ€™s request
PHFIC may at any time, temporarily suspend the account of the client in following circumstances:
Trades in the account of the client during the period of such temporary suspension
shall not be permitted. The account shall be reactivated on submission of a written
request for reactivation by the client.
Procedure for Monitoring of debit balances
Procedure for Investor Redressal Mechanism
Procedure for Suspicious Transactions
The organization has a proper PMLA policy and the same has been implemented within the organization. Any transaction that is done by a client specified under High risk category or done by an NRI client or trades done in scripts which are found to be illiquid or manipulative nature are tracked. If such transactions are found to be problematic then further scrutiny or enquiry is made by the principal officer and if found to be suspicious then the same is informed to the FIU.
Trading Member has maintained and preserved all such records of transactions which are prescribed under Rule 3 of PMLA and has ongoing Training program for staff members and investors. Any transaction that gets covered under the requirement of PMLA transactions, the information regarding any trade of such nature can be enquired and found out as and when required.
Procedure for NEAT Terminal
Procedure for Closure of Client accounts/ Dormant accounts
P H Financial & Investment Consultants Pvt. Limited (PHFIC) as a matter of policy accepts and realizes that the investor community is made of traders as well as investors. Whereas traders trade frequently, the investors trade with long gaps. The inactive client policy is framed keeping the same in mind.
Procedure for Deregistration of a client
Deregistration/Termination of the client may be with mutual consent of the parties or by giving Notice. Such deregistration / termination shall not effect the rights and liabilities of the parties in respect of the transactions executed before the date of such deregistration/termination.
PHFIC may at any time, at its sole discretion and without prior notice to the Client, prohibit or restrict or block the Clientâ€™s account or related services and the Clientâ€™s ability to trade due to regulatory requirements, prevention of money laundering regulations, market conditions and other internal policies. Further PHFIC may Freeze the Client Account in following Scenario:
The account shall be reactivated under the following circumstances:
In addition, PHFIC may interalia terminate/freeze trading facilities due to
requirements and to comply with provisions of Prevention of Money Laundering
or due to suspicious activities observed by surveillance department or due to
risk perception. Such Clients may be re-admitted on submission of fresh KYCâ€™s and
supporting documents/explanation resolving the earlier observations for
Conflict of Interest Policy:
M/s P H Financial & Investment Consultants Pvt Ltd was incorporated on 08.02.1994 under The Companies Act, 1956. Presently M/s P H Financial & Investment Consultants Pvt Ltd is registered as a Stock Broker with National Stock Exchange of India Limited (NSE) & Bombay Stock Exchange of India Limited (BSE), for providing financial services in Indian Capital Markets to the individual, corporate, financial institutions etc. SEBI vide its Circular No. CIR/MIRSD/5/2013 dated 27.08.2013 has laid down the guidelines required registered intermediaries to establish and implement a conflict of interest policy. To adhere to the SEBIâ€™s guidelines, the company is required to take all reasonable steps to identify or manage conflicts of interest of its clients. We are presently governed by the provisions for avoidance of conflict of interest as mandated in the respective regulations along with relevant circulars issued from time to time by SEBI. Our associated persons are educated for the compliance of these guidelines. Guidelines for dealing with Conflict of Interest are as follows:
Policy on pre-funded instruments â€“ Mode of payment
With reference to NSE Circular No. NSE/INSP/2011/118 dated June 9, 2011 on the
drafted policy on preâ€funded Instrument which has been approved by
Board/Management/Key Personnelâ€™s are given hereunder. The Policy is subject to the
Rules and Regulation of the Exchange from time to time.
Pre-funded Instrument includes Demand draft, Pay Order, Bankerâ€™s Cheque, etc. A pre-funded instrument issued by the bank against cash shall not be accepted for amount of INR 50,000 or more.
All Pre-funded instruments having aggregate Value of Rs. 50,000/- or more, per day per client must be accepted if the same are accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank.
The mode of certification may include the following:
RTGS/NEFT/Online bank transfer etc
Receipt from clients using Electronic Fund transfer shall be accepted only if the name of client with the bank name is reflected on our online bank statement or on receipt of copy of the instruction to the bank stating the account number debited must accompany the purchase application.
The member reserves the right to reject the payment, post acceptance and/or processing of the same without any recourse to the Client, if any of the requisite documents/declarations are unavailable or incomplete, and in such case the member shall refund the money without interest. Such Refunds will be marked "A/c. payee only" and will be in favour of clients only.
Internal control policy with respect to broking operations
Client Due Diligence:
We apply the usual client due diligence measures prescribed under KYC norms. Additionally, we also take reference of a client or person known to us in respect of walk-in clients. The format in which we conduct the client due diligence is part of our KYC form.
Assessment of financial capability of client:
We take from clients a self-declaration, which states their total networth in terms of their net assets and liabilities. Such self declaration has to be generally supported by one of the following documents:
Process of record keeping and retrieval of client registration
All client registration documents, once checked, found complete and verified as such and the accounts opened, are stored in locked cabinets in a sequential manner. We can retrieve either the physical records on an easy basis.
Updation of client financial and other client particulars:
We have now started on an annual basis the process of sending out,
Client Master Modification:
On an annual basis, there is a regular updation happening. However, in between, if the client wants to modify any details, he/she/it is enabled to do so by submitting to us the documentary proof of modified detail.
Systems and Process adopted for UCC upload:
From our back-end, we generate file for the client containing data of market segment, client code, client name, PAN, address in the format prescribed by NSE. The data generated are thereafter verified with KYC. On the data being found fully correct, the client is uploaded on UCC â€“ site of NSE. After uploading, we run a check, on the UCC-site, by entering the specific client, whether or not the client details are actually uploaded on UCC-site.
Precaution with respect to dormant accounts:
All dormant accounts (inactive for six months and more) are made inactive in our system. Hence it is not possible to execute a transaction in dormant accounts. However, a client can re-activate his/her/its dormant account by giving us in writing in prescribed format to activate the account and also stating the reason for keeping the account dormant.
Investor Redressal Mechanism:
It is not our policy to record complaints received through telephone call. However, complaints received through letter, e-mail and personal representation (we urge upon client to put it in writing and give it to us) are duly recorded by us.
System in place to generate alerts for suspicious transaction:
Alerts are based on following factors:
If a client is always indulging in one or all of the above in an ongoing manner, we put him/her/it under special watch.
NISM-Series-VII: Securities Operations and Risk Management Certification Examination (SORM)
SEBI issued Notification no. LAD-NRO/GN/2010-11/21/29390 dated December 10, 2010 , according to which, following categories of associated persons associated with a registered stock broker/trading member/clearing member in any recognized stock exchanges, who are involved in, or deal with any of the following:
It is further decided by SEBI, the requirement of passing NISM Series VII certification would be optional for those associated persons handling the basic clerical or elementary functions in the above stated areas and whose work is supervised by NISM Series VII Securities Operations and Risk Management Certification certified personnel. The activities that can be classified as basic elementary level / Clerical level are as follows:-
However, any of the works (as stated herein above) being performed by such persons,
obtaining, NISM-SORM Certification shall be optional provided that they are
supervised by his / her supervisor who shall have to obtain / continue to have NISM
â€“ SORM Certification or such other prescribed certification at all times.
Compliance to above circular issued by the SEBI will be ensured from time to time.
Identification of Beneficial Ownership
The identification of beneficial ownership is done by the compliance department for all existing clients and all new clients shall be accepted only after verifying the beneficial owner of the client account which is either individual or non individual whether company/partner/unincorporated association/body of individuals on parameters stated below:
The intention is to identify the identity of the natural person, who, whether acting
alone or together or through one or more juridical person exercises control through
ownership or who ultimately has controlling ownership interest. However, where the
client or owner of controlling interest is a company listed on a recognized stock
exchange or is a majority-owned subsidiary of such a company identification of the
beneficial owner of such companies is not required.
Client Due Diligence Process
The Prevention of Money-Laundering Act, 2002 (as amended) was notified onJuly 1, 2005. Subsequent to this Securities and Exchange Board of lndia has, on18th January 2006, required market intermediaries to adopt a policy, frameworkwith respect to anti-money laundering measures to be followed by the intermediaries. M/s. P.H. Financial &investment Consultants Private Limited is covered under market intermediaries and adhere to the same.
Money laundering has now become one of the major concerns ofinternational financial community. Money Laundering is not just an attempt todisguise money derived from illegal activities. Rather, money laundering is involvement in any transaction or series of transactions that seek to conceal ordisguise the nature or source of proceeds derived from illegal activities, includingdrug trafficking, terrorism, organized crime, fraud and many other crimes.
Know Your Customer "(KYC) is the guiding principle behind the Anti-MoneyLaundering (AML) measures. lt incorporates the " Know Your Customer "Standards & " Anti Money Laundering " Measures. The objective of is to â€œhaveinplace adequate policies, practices and procedures that promote high ethical andprofessional standards and prevent the Company from being used, intentionallyor unintentionally, by criminal elements".
KYC Standards and AML Measures would enable the Company to know/understand its customers, the beneficial owners in case of non-individual entities, 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 main objective of the Client Due Diligence Process is to obtaining sufficientinformation in order to identify persons who beneficially own or control securitiesaccount. Verify the customer's identity using reliable, independent sourcedocuments, data or information. Conduct ongoing due diligence andscrutiny, i.e.perform ongoing scrutiny of the transactions and account throughout the courseof the business relationship to ensure that the transactions being conducted areconsistent with the established knowledge of the customer, its business and riskprofile, taking into account, where necessary, the customer's source of funds
It is generally recognized that certain customers may be of a higher or lower riskcategory depending on circumstances such as the customer's background, typeof business relationship or transaction etc. As such, customer due diligencemeasures should be applied on a risk sensitive basis. The basic principleenshrined in this approach is to adopt an enhanced customer due diligenceprocess for higher risk categories of customers. Conversely, a simplifiedcustomer due diligence process may be adopted for lower risk categories ofcustomers.
ln line with the risk-based approach, the type and amount of identificationinformation and documents that should obtain necessarily depend on the riskcategory of a particular customer.
The major factor to properly understand their risk profile inter alia includes:
Client Due Diligence process is broadly categorized as:
Client Due Diligence process include the below mentioned guidelines:
All necessary records should be maintained at least for the minimum period prescribed under the relevant Act (PMLA, 2002as well SEBI Act, 1992) and other legislations, Regulations or Exchanges bye-laws or circulars.
Transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances.
Any suspicion transaction to be immediately notified to the Money
Laundering Control Officer or any other designated officer. The
notification may be done inthe form of a detailed report with
specific reference to the clients, transactionsand the nature
/reason of suspicion.
However, it should be ensured that there is continuity in dealing with the client asnormal until told otherwise and the client should not be told of thereport / suspicion. ln exceptional circumstances, consent may not be given tocontinue to operate the account, and transactions may be suspended, in one ormore jurisdictions concerned in the transaction, or other action taken.
Clients of special cateqorv (CSC):
Client of special category should be separately classified also same needs to be Reviewed on periodic basis. Such clients include the following:
The above mentioned list is only illustrative.
RISK MANAGEMENT POLICY
For Cash Segment & Future & Option
The objective of the Risk management function is to ensure that all risks, which threaten the business of Stock and Share Markets, are recognized, controlled and reduced to an acceptable level while all applicable regulatory requirements of the various regulatory authorities are complied with.
Risk based approach:
Classification of both the new and existing clients into high, medium or low risk category depending on parameters such as the customerâ€™s background, type of business relationship, transactions etc. Application of each of the client due diligence measures on a risk sensitive basis and adoption of an enhanced customer due diligence process for high risk categories of customers and vice -Ã¡-versa.
Limits shall be monitored on periodic basis, taking following criteriaâ€™s: Turnover, Exposure, past trends, Location, Deposit/Collateral.
Margins & Trading:
Margin must be collected on all derivative trades. Client level margin will be at management discretion in cash segment. Trading in illiquid scrip shall not be permitted.
Pay-in Of Fund & Stock:
Third party pay-in of securities & fund will not be accepted. Same way pay out of shares and fund will be directly done to client account only. No securities belonging to one client be used/transferred for Own purpose or for other client.
Cash will not be accepted under any circumstances. Collection of cheques from clients must be done by T+2 days except clients who have authorized us to have running account balance.
Periodic settlement of Fund and Securities:
As per the SEBI guidelines, the balances of clients will be settled, as per their specification either once in a month or once in 3 months.
With respect to the transactional alerts being downloaded from the Exchange/ Exchanges /generated by the Company, the following activities will be carried based on UCC parameters:
Due Diligence of its client(s) will be carried out on a continuous basis. It will also be ensured that key KYC parameters are updated on a continuous basis as prescribed by SEBI and latest information of the client is updated in UCC database of the Exchange/ Exchanges. Based on this information, the Company will establish groups / association amongst clients to identify multiple accounts / common account / group of clients.
In order to analyze the trading activity of the Client(s) / Group of Client(s) or scrips identified based on above alerts, Company will:
Monitoring and reporting
Following procedure will followed for monitoring and reporting of alerts:
Limit Setting & Risk Management Structure
Limit Setting & Risk Management Structure is initiated to assure that the cumulative value of all unexecuted orders placed from the terminals is below a threshold limit set and manage the risk of the Company / clients from the volatility of the stock market. It has the course of pre-defined limits / checks such as and Single Order Value Limits, User Order value Limit, Order Price limit and value limit, Cumulative open order value check (unexecuted orders) are in place and only such orders which are within the specified parameters are allowed to be pushed into exchange trading engines.
No user in the system is having unlimited limits on the above parameters. When client limits are exceeded, prior approval is required before allowing the client to execute further trades.
Due to certain incidents of erroneous orders being executed on the Exchange Platform, SEBI has come out with directions to put checks and balances by the Stock Brokers. To prevent aberrant orders or uncontrolled trades, Minimum Pre-Trade Risk controls for all categories of orders placed on Stocks, Exchange Traded Funds, etc. order level checks shall be placed in the Trading terminals as per the Exchange directions which is periodically reviewed.
A. Below limits have been set:
Turnover and Obligation Limits for new clients is based on the Income Range, Category of Clients, etc. Such Limits fixed for clients shall be subject to review depending upon their turnover, payment pattern, background, references etc. The risk identification and assessment processes reviewed periodically to review existing risks and identify new risks.
P.H. Financial and Investment Consultants Pvt. Ltd.
Policy on Prohibition & Circulation of Unauthenticated News