Jamnadas Virji Shares and Stocks Pvt. Ltd.

Jamnadas Virji introduces Forex Trading & Mutual Funds

Bombay Stock Exchange

Top Gainers

Top Volume

Top Losers

Company	Price	Change
JUBILANTFOOD	1147.95	6.26
IFCI	41.85	5.68
PANTALOON	153.00	5.34
TTK PRESTIGE	2954.95	5.32
HPCL	298.00	5.13

Company	Price	Change
SUZLON	25.65	-1.91
HDIL	85.90	4.56
LANCO INFRA	18.10	4.02
ADANI POWER	68.20	1.26
IFCI	41.85	5.68

Company	Price	Change
MUTHOOT FIN	127.90	-3.07
INDIABULLS	205.00	-1.75
SUZLON	25.75	-1.53
CAIRN INDIA	331.50	-1.04
APOLLO HSPT	639.90	-1.01

About Us

Established in 1919 as Jamnadas Virji & Sons, ours is one of the oldest broking concerns on the Bombay Stock Exchange. The legacy is running through four generations in the family. Presently, Jamnadas Virji Shares & Stock Brokers Pvt Ltd is a corporate entity having 100% shareholding within the Shah family. Mr. Pravinchandra N Shah, Mr. Bhavyesh P Shah, Mr. Pruthesh P Shah and Mr. Divyesh P Shah are the promoter Directors of the Company.

Our company has been servicing a wide client base consisting of individuals, corporates and high networth entities over the last ninety years and counting….. We have a network of Sub-brokers and business associates. We are also a member on the Capital Market segment of the National Stock Exchange of India Limited since its inception in 1994 and a member of its Derivatives segment since February 2002. Also we are currently on the panel of financial institutions such as Unit Trust of India, Life Insurance Corporation of India, LIC Mutual Fund, Principle Mutual Fund, Tata Mutual Fund & a few Banks.

At Jamnadas Virji, investment philosophy is rooted in the belief that financial markets reward the knowledgeable. Our approach to investment management is to follow a consistent investment strategy designed to produce above average & consistent, long term returns for our clients. Although being one of the oldest firms, Jamnadas Virji follows unorthodox and advanced gen-next methods of servicing and promises total customer satisfaction.

We are also a Depository Participant with CDSL and are also registered with AMFI for marketing of all mutual fund financial products.

Mr. Pravinchandra Narandas Shah has an experience of 38 years including handling of line business with Associates in Calcutta and Madras Stock Exchanges and handling Institutional business with Unit Trust of India, New India Assurance, L.I.C and G.I.C during the 70’s and 80’s. He has served as a Member of the Arbitration Committee, Settlement Committee and Defaulter’s Committee of the Bombay Stock Exchange.

Mr. Bhavyesh P. Shah handles the day-to-day administration & compliance for the company. He is presently the Joint Secretary of the Arbitration Committee of the Bombay Stock Exchange. He is also proficient in handling Leasing, Hire-purchase, Bill-discounting and Loan Syndication activities.

Mr. Pruthesh P. Shah has been an active jobber, dealing in shares of major pharmaceutical and tea companies during the previous outcry system of the Trading ring and is currently handling portfolio of high-networth individuals of the company. He is also actively involved in educating our clientele about the nitty-gritty and varied benefits of Derivatives trading.

Mr. Divyesh P Shah oversees the Clientele business (local and upcountry), Market operations, financial management and also Mutual Fund & Financial Institutions business.

PAN Check | RBI | SEBI | NSE | BSE | FM | MCX | CDSL

BSE CASH : INB010996236 | BSE F & O : INF010996236 | BSE Currency :INE011183733

NSE CASH : INB231183733 | NSE F & O : INF231183733

CDSL DP ID : IN-DP-CDSL-244-2004 | MCX – SX CURRENCY : INE261183733

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Internal Control Procedure

Acceptance of Client

• No Walk-in clients should be registered as client or allowed to trade. Only those new clients would be accepted and allowed to trade with us, who would be referred to us by any of the following:
1) Directors;
2) Relatives or Family Members of the Directors;
3) Sub Brokers & Authorised persons;
4) Existing Clients.
• On expression of wish for becoming a client by any person, a copy of Client Registration Form along with other documents and forms will be forwarded to the client. The copy of the CRF will also be accompanied with the list of documents and additional documents or proofs required.
• Client Registration Form after being signed and filled by the Client will be received at our Client Registration department.
• At the client registration department, the documents are checked and only after they are found proper they will be counter signed by us. The client code generated will be communicated to the client after completion of entire procedure.
• A prospective client will be allowed to trade only on satisfactorily submission of required documentary proof and proper signing of documents.

Client Identification

The following procedure should be adopted for identification of Client:
• As far as possible, no clients will be registered without personal contact.
• In addition to personal contact, for client identification, proper address and identity proof as prescribed by SEBI as per Uniform Documentary Requirement will be obtained from the client.
• PAN number and a Copy of PAN card will be compulsorily obtained from the client. No trading will be allowed unless the proof of PAN proof is submitted by the client.
• All the documents collected will be verified with original by the Client Registration Department

Registration of Intermediateries

• The procedure as prescribed for registration of Approved Person’s will be followed.
• Brokerage will be shared with the respective Approved person only after the Approval of Registration by the Exchange.

Issue of Trading Terminal

• The Terminal User should be BCSM/BCDE/NCFM certified. Before allowing the user to operate the terminal, the copy of BCSM/BCDE/NCFM certificate will be collected and verified with the original.
• The user will be asked to renew the BCSM/BCDE/NCFM certificate on its expiry. If the user fails to renew the certificate then he would not be allowed to operate the same any further. The renewed copy of the certificate will be re-obtained and verified with original.
• The guidelines laid down by the Exchange for Approved User and Location of trading terminal will be strictly followed. It would be made sure that there is no issue of trading terminals to unauthorized persons or at unauthorized locations.
• The data regarding new user as well as modification in existing user should be immediately uploaded and documented on modification or issue to the new user as the case may be.

Margin Collection

• Any exposure to the client will be subject to the collection of adequate margins from the clients.
• The margins collected would be as per the requirements of the Exchange.
• Margins collected would be in the form of Shares, Cash or Credits.

Transactions of Clients

• Transactions of all major clients would be monitored, if required and in case of any suspicion from our side of possibility of any malfunctioning y the client. If required the client will be asked to stop such kind of malfunctioning or may be even asked to stop trading.

Pay-in & Pay-out of funds & Securities

• All payments shall be received/made from/to the clients strictly by account payee crossed cheques/ demand drafts or by way of direct credit into the bank account through EFT, or any other mode allowed by RBI.
• We shall accept cheques drawn only by the clients and also issue cheques in favour of the clients only, for their transactions.
• In case of securities, we shall give/ take delivery of securities in “demat mode” should be directly to/ from the “beneficiary accounts” of the clients except delivery of securities to a recognized entity under the approved scheme of the stock exchange and/or SEBI.
• We shall make the clients pay-in from the securities purchased by him in the previous settlements & are lying with us.
• In case of internal shortage of shares the stock is recovered from the market on behalf of defaulting client (seller) and delivered to the buyer on receipt of the stock from the clearing corporation.

Monies & securities deposited with the exchange towards margin

• Adequate margin in the form of monies/securities/ collaterals shall always be kept with the exchange.
• The form and mode of the margin shall be as per the guidelines of the clearing corporation issued from time to time.
• In case the client’s shares/monies are utilized for depositing margin with the exchange the same shall be utilized only with the specific written consent of the clients.

Payment of Dividend

• Dividend/ other corporate benefits shall be paid/ credited to customers account within a reasonable time but not exceeding 30 days.
• In case of delay beyond 30 days the matter shall be reported to compliance officer
• The dividend/ corporate benefits of client shall be kept in a separate client bank/ client beneficiary account till the time the said is passed on to the customer.

Placement of Order

• The orders will be placed by the respective Dealer as per the instructions from the clients.
• However, it should be made sure that the priced put up should not be unrealistic or not representing the correct market price.
• Everytime before execution of order a final confirmation of the entire order should be made to the client.
• The clients should not be induced to either Buy or sell.

Other Areas

• Complete confidentiality of Client information should be maintained. No client information would be given except if required by law.
• Proper records as required by various statues will be maintained.
• Customer complaints should be immediately attended by the concerned department and in case the complain remains unresolved within 1 week the same should be escalated to the Compliance officer. If the complain remains unresolved for a further period of 1 month the same should be reported to the Director-Operations who shall personally look into the customer’s complain. A specific (designated) email ID is created for customers complain and shall be regularly monitored by the compliance officer.

Brief risk management and margining policy

Over the years, there hasn't been much change in our RM policy primarily because we are very conservative and cautious in our client’s selection. Since May 2005, there has been clear relaxation from the regulators in terms of enabling brokers to use their prudent decision in terms of collection of margins and settlement funds from the clients as the T+2 environment demands an entirely fresh thinking in terms of risk management compared to older environment of longer settlement cycle. We take margin deposit from trading clients and also deposit the same with BSE as Additional Base Capital which goes towards meeting their margining requirements. For clients delivery based transactions, wherever necessary we take advance shares or funds as the case may be. In many instances we have done pre pay-in of large quantity of shares sold by clients in order to meet high margins. Another good feature that has been put in place by regulators is to bring the CM segment margining in line with FO segment i.e. advance margining system. That has brought a great relief to us brokers and reduced the risk of bad debts. However in our case in almost all Cash Market transactions we either receive the shares and funds (in some cases even advance delivery) on T+1 basis. So the risk is very well controlled. For our NSE F&O segment we strictly follow the rule of advance margining system and have collected sizeable margins from our clients in the form of shares and cash as applicable. Our margin files for NSE F&O segment are regularly being uploaded to the exchange and reflect the true picture of margins lying with us for those respective clients. Also since we are ourselves a DP with CDSL, having most of our client’s demat accounts with us; it becomes easier for us to monitor their financial capabilities. Further, in cases of new clients & clients wherever we feel necessary, we hold back their shares till payment is received.

CODE OF CONDUCT

1.0 Compliance Officer

1.1 Mr Bhavyesh P Shah & Mr Divyesh P Shah the Directors are the Compliance Officer for the organization, reporting to the Board of Directors.
1.2 The Compliance Officer shall be responsible for setting forth policies and procedures and monitoring adherence to such policies and procedures and also for the preservation of “Price Sensitive Information” and implementation of the Code of Conduct under the overall supervision of the Managing Director.
1.3 The Compliance Officer shall also guide the Company and all the employees/ Directors in addressing any clarifications regarding SEBI (Prohibition of Insider Trading) Regulations, 1992 and the organization’s Code of Conduct.
1.4 The Compliance Officer shall maintain a record of the designated Directors and changes made in the list of designated Directors.

2.0 Preservation of “Price Sensitive Information”

2.1 Employees/Directors shall maintain the confidentiality of all Price Sensitive Information. They shall not pass on such information directly or indirectly by way of making a recommendation for the purchase/sale of securities.
2.2 Need to know:
2.2.1 Price Sensitive Information is to be handled on a "need to know" basis, i.e. Price Sensitive Information should be disclosed only to those within the organization who need the information to discharge their duty and whose possession of such information will not give rise to a conflict of interest or appearance of misuse of the information.
2.3 Limited access to confidential information:
2.3.1 Files containing confidential information shall be kept secure. Computer files must have adequate security of login and pass word, etc.
2.4 Chinese Wall:
2.4.1 To prevent the misuse of confidential information, the organization shall adopt a "Chinese Wall" policy which separates those areas of the organization which routinely have access to confidential information, considered “inside areas” from “public areas” which deal with sale/investment advice or other departments providing support services.
The dealing room shall be separated from the back office and other departments.
2.4.2 The employees in the ‘inside areas’ shall not communicate any Price Sensitive Information to anyone in ‘public areas’.
2.4.3 The employees in the ‘inside areas’ shall be physically segregated from employees in ‘public areas’.
2.4.4 In exceptional circumstances, employees from the ‘public areas’ may be brought "over the wall" and given confidential information on the basis of "need to know" criteria, under intimation to the Compliance Officer.

3.0 Prevention of misuse of Price Sensitive Information

3.1 Employees/Directors shall not use Price Sensitive Information to buy or sell securities of any sort, whether for their own account, their relative’s account, organisation/firm's account or a client's account. The following trading restrictions shall apply for trading in securities:

4.0 Other restrictions

4.1 To avoid speculative activities by employees, it is necessary that they shall hold their investments for a minimum period of 30 days after purchase in order to be considered as being held for investment purposes.
4.2 The holding period shall also apply to purchases in the primary market (IPOs). In the case of IPOs, the holding period would commence when the securities are actually allotted.
4.3 In case the sale of securities is necessitated by personal emergency, the holding period may be waived by the Compliance Officer after recording in writing his/her reasons in this regard.
4.4 Analysts, employed with the organization while preparing research reports of a client Company(s) shall disclose their share holdings/ interest in such Company(s) to the Compliance Officer.
4.5 Analysts who prepare research report of a listed Company shall not trade in securities of that Company for thirty days from preparation of such report.

5.0 Reporting Requirements for transactions in securities

5.1 All employees in the “inside area” of the organization shall be required to forward following details of their Securities transactions including the statement of dependent family members to the Compliance Officer:-
(a) all holdings in securities at the time of joining the organization.
(b) periodic statement of transactions in securities during a financial year, if the aggregate trade value exceeds Rs. 25000/- (twenty five thousand only) within three months from the end of the financial year.
(c) annual statement of all holdings in securities as on 31st March of every year
5.2 The Compliance Officer shall maintain records of all the declarations given by the Directors / designated employees in the appropriate form for a minimum period of three years.

6.0 Information to SEBI in case of violation of SEBI (Prohibition of Insider Trading) Regulations

6.1 In case it is observed by the Company / Compliance Officer that there has been a violation of these Regulations, SEBI shall be informed by the organization / Compliance Officer.

POLICIES AND PROCEDURE FOR PREVENTION OF MONEY LAUNDERING (Issued as per the requirements of the PMLA Act 2002)

1. Firm Policy

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.

2. Principal Officer Designation and Duties

The firm has designated Shri. Bhavyesh P Shah, Director as the Principal Officer for its Anti-Money Laundering Program, with full responsibility for the firm’s AML program. The duties of the Principal Officer will include monitoring the firm’s compliance with AML obligations and overseeing communication and training for employees. The Principal Officer will also ensure that proper AML records are kept. When warranted, the Principal Officer will ensure filing of necessary reports with the Financial Intelligence Unit (FIU – IND)

The firm has provided the FIU with contact information for the Principal Officer, including name, title, mailing address, e-mail address, telephone number and facsimile number. The firm will promptly notify FIU of any change to this information.

3. Customer Identification and Verification

At the time of opening an account or executing any transaction with it, the firm will verify and maintain the record of identity and current address or addresses including permanent address or addresses of the client, the nature of business of the client and his financial status as under

Constitution of Client	Proof of Identity	Proof of Address	Others
Company	4.PAN Card 5.Certificate of incorporation 6.Memorandum and Articles of Association 7.Resolution of Board of Directors	8.As above	9.Proof of Identity of the Directors /Others authorized to trade on behalf of the firm
Individual	PAN Card	Copy of Bank Statement,etc	3. N.A.
Partnership Firm	PAN Card Registration certificate Partnership deed	13. As aboves	Proof of Identity of the Partners /Others authorized to trade on behalf of the firm
Trust	PAN Card Registration certificate Partnership deed	13. As aboves	Proof of Identity of the Partners /Others authorized to trade on behalf of the firm

25. If a potential or existing customer either refuses to provide the information described above when
requested, or appears to have intentionally provided misleading information, our firm will not open the new account.
26. All PAN Cards received will verified form the Income Tax/ NSDL website before the account is opened
27. The firm will maintain records of all identification information for ten years after the account has been closed.

4. Maintenance of records

The Principal Officer will be responsible for the maintenance for following records
• all cash transactions of the value of more than rupees ten lakhs or its equivalent in foreign currency;
• all series of cash transactions integrally connected to each other which have been valued below rupees ten
lakhs or its equivalent in foreign currency where such series of transactions have taken place within a month;

1)all cash transactions where forged or counterfeit currency notes or bank notes have been used as
genuine and where any forgery of a valuable security has taken place;
2)all suspicious transactions whether or not made in cash. Suspicious transaction means a transaction
whether or not made in cash which, to a person acting in good faith -
o gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or
o appears to be made in circumstances of unusual or unjustified complexity; or
o appears to have no economic rationale or bonafide purpose; or
o gives rise to a reasonable ground of suspicion that it may involve financing of the
activities relating to terrorism
records shall contain the following information: • the nature of the transactions;
• the amount of the transaction and the currency in which it was denominated;
• the date on which the transaction was conducted; and
• the parties to the transaction."

5. Monitoring Accounts For Suspicious Activity

The firm will monitor through the means of Back Office Software for unusual size, volume, pattern or type of
transactions. The following kinds of activities are to be mentioned as Red Flags and reported to the Principal Officer. • The customer exhibits unusual concern about the firm's compliance with government reporting requirements and the
firm's AML policies (particularly concerning his or her identity, type of business and assets), or
is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspicious
identification or business documents.
• The customer wishes to engage in transactions that lack business sense or apparent investment strategy,
or are inconsistent with the customer's stated business or investment strategy.
• The information provided by the customer that identifies a legitimate source for funds is false,
misleading, or substantially incorrect.
• Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her
funds and other assets.
• The customer (or a person publicly associated with the customer) has a questionable background or is
the subject of news reports indicating possible criminal, civil, or regulatory violations.
• The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
• The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant,
without legitimate commercial reasons, to provide information or is otherwise evasive regarding
that person or entity.
• The customer has difficulty describing the nature of his or her business or lacks general knowledge of
his or her industry.
• The customer attempts to make frequent or large deposits of currency, insists on dealing only in
cash, or asks for exemptions from the firm's policies relating to the deposit of cash.
• The customer engages in transactions involving cash or cash equivalents or other monetary instruments
that appear to be structured to avoid the Rs.10,00,000 government reporting requirements, especially
if the cash or monetary instruments are in an amount just below reporting or recording thresholds.
• For no apparent reason, the customer insists for multiple accounts under a single name or multiple
names, with a large number of inter-account or third-party transfers.
• The customer engages in excessive journal entries between unrelated accounts without any apparent
business purpose. • The customer requests that a transaction be processed to avoid the firm's normal documentation requirements.
• The customer, for no apparent reason or in conjunction with other red flags, engages in transactions
involving certain types of securities, such as Z group and T group stocks, which although legitimate,
have been used in connection with fraudulent schemes and money laundering activity.
(Such transactions may warrant further due diligence to ensure the legitimacy of the customer's activity.)
• The customer's account shows an unexplained high level of account activity
• The customer maintains multiple accounts, or maintains accounts in the names of family members or corporate
entities, for no apparent purpose.
• The customer's account has inflows of funds or other assets well beyond the known income or resources of
the customer.
Broad categories of reason for suspicion and examples of suspicious transactions for an intermediary are
indicated as under:
Identity of Client
- False identification documents
- Identification documents which could not be verified within reasonable time
- Non-face to face client
- Doubt over the real beneficiary of the account
- Accounts opened with names very close to other established business entities
Suspicious Background
- Suspicious background or links with known criminals
Multiple Accounts
- Large number of accounts having a common account holder, introducer or authorized signatory with no
rationale
- Unexplained transfers between multiple accounts with no rationale
Activity in Accounts
- Unusual activity compared to past transactions
- Use of different accounts by client alternatively
- Sudden activity in dormant accounts
- Activity inconsistent with what would be expected from declared business
- Account used for circular trading
Nature of Transactions
- Unusual or unjustified complexity
- No economic rationale or bonafide purpose
- Source of funds are doubtful
- Appears to be case of insider trading
- Investment proceeds transferred to a third party
- Transactions reflect likely market manipulations
- Suspicious off market transactions
Value of Transactions
- Value just under the reporting threshold amount in an apparent attempt to avoid reporting
- Large sums being transferred from overseas for making payments
- Inconsistent with the clients apparent financial standing
- Inconsistency in the payment pattern by client
- Block deal which is not at market price or prices appear to be artificially inflated/deflated

Reporting to FIU IND

• For Cash Transaction Reporting
• All dealing in Cash that requiring reporting to the FIU IND will be done in the CTR format and in the
matter and at intervals as prescribed by the FIU IND
For Suspicious Transactions Reporting
We will make a note of Suspicion Transaction that have not been explained to the satisfaction of the Principal
Officer and thereafter report the same to the FIU IND and the required deadlines. This will typically be in cases
where we know, suspect, or have reason to suspect:
• the transaction involves funds derived from illegal activity or is intended or conducted in order to hide
or disguise funds or assets derived from illegal activity as part of a plan to violate or evade any the
transaction reporting requirement,
• the transaction is designed, whether through structuring or otherwise, to evade the any requirements of
PMLA Act and Rules framed thereof
• the transaction has no business or apparent lawful purpose or is not the sort in which the customer
would normally be expected to engage, and we know, after examining the background, possible purpose of
the transaction and other facts, of no reasonable explanation for the transaction, or
• the transaction involves the use of the firm to facilitate criminal activity.
We will not base our decision on whether to file a STR solely on whether the transaction falls above a set threshold.
We will file a STR and notify law enforcement of all transactions that raise an identifiable suspicion of criminal,
terrorist, or corrupt activities.
All STRs will be reported quarterly to the Board of Directors, with a clear reminder of the need to maintain
the confidentiality of the STRs
We will not notify any person involved in the transaction that the transaction has been reported,
except as permitted by the PMLA Act and Rules thereof.

7.Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under
the supervision of the Principal Officer. We will also review the AML performance of supervisors, as part
of their annual performance review. The Principal Officer’s accounts will be reviewed by the Board of Directors

8.Confidential Reporting of AML Non-Compliance

Employees will report any violations of the firm’s AML compliance program to the Principal Officer, unless
the violations implicate the Compliance Officer, in which case the employee shall report to the Chairman of
the Board, Shri Pravin Shah. Such reports will be confidential, and the employee will suffer no retaliation
for making them.

9.Board of Directors Approval

We have approved this AML program as reasonably designed to achieve and monitor our firm’s ongoing compliance with
the requirements of the PMLA and the implementing regulations under it.

Dormant Account

In case of dormant accounts i.e. clients who have not traded for more than six months, all the transactions are confirmed over telephone with clients if such transactions are executed after a gap of six months.
In addition to above, if any delivery based sell trades are executed in any account which is inactive for more than nine months, there is a pro active calling from head office to check the authenticity of the client and trade.

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