Policies & Procedures
Updated 25th March 2024
Firstock Broking Private Limited is a member of the National Stock Exchange and Bombay Stock Exchange in the Equity and Equity Derivatives segment, having its registered office at No. 350, 1st Floor, 36th A Cross, 7th Main Road, 5th Block, Jayanagar, Bengaluru, KA 560041.
For the purpose of these Policies & Procedures, wherever the context so mentions "Client," "You," or "Your," it shall mean any natural or legal person who has agreed to open an account or initiate the process of opening an account with Firstock by providing their information while registering on the platform as a user. Firstock allows any person to surf the website without registering. The terms "We," "Us," "Our," and "Firstock" shall mean M/s Firstock Broking Private Limited.
Trades
The trades of clients shall be carried out in the respective client code only. Dealers shall take utmost care while executing the trades of the clients regarding the accuracy of client code, quantity, price, etc.
Product
  • CNC (Cash and Carry): If you want to buy for delivery (buy stocks and hold them overnight) in the CM segment, you must place your orders under the product type “CNC.”
  • NRML (Normal): If you wish to carry forward your derivative positions to the next trading day, you must place your orders under the product type “NRML.”
  • MIS (Margin Intraday Square-off): If you wish to trade for intraday purposes in any exchange and segment (CM or F&O), you must place your orders under the product type “MIS.”
Funds
System of Pay-in and Pay-out of Funds:
Pay-in: Clients can transfer funds into the trading account only from bank accounts registered with Firstock. Payments will only be accepted in the form of online bank transfers, payment gateway transfers, UPI, or cheques. Any transfer from a non-registered bank account will not be considered, and the client will not receive any trading limit credit for such transfers.
  • Payment Gateway: The client can transfer funds using the instant payment gateway facility available on the trading platform or the back office. Such transfers will be charged at ₹9 plus 18% GST per transfer.
  • NEFT/RTGS/Cheque: If a client transfers funds using NEFT or cheque, there will be no cost. Customers can use the fund transfer facility from their bank by registering Firstock Broking Private Limited’s HDFC Bank account for transfers. Fund receipt confirmation typically takes 1–3 hours for RTGS and 1–4 hours for NEFT.
If the client transfers funds via cheque, the details of the transfer, along with a copy of the cheque, should be provided to Firstock for the credit to be updated in the trading account.
Pay-out: All pay-outs must be requested through the back-office access provided to clients. Firstock approves pay-out requests as follows:
  • Pay-outs are processed once a day and credited to the primary bank account linked to the client’s trading account.
  • Pay-outs requested on a calendar day will be processed on the same day.
  • Pay-outs will not be processed on Saturdays, Sundays, or holidays.
Margins
Firstock does not engage in client funding. Clients must have a sufficient balance in their accounts to hold or carry forward positions.
Equity & Derivatives
  • NSE/BSE Equity: Firstock allows up to 5x intraday leverage for stocks on which F&O trading is allowed. A 100% margin is required to hold positions.
  • NSE Futures: A 100% total margin (SPAN & Exposure) is required for intraday and carry-forward positions.
Intraday Products Square-off Timings
  • Equity/Cash: 3:25 PM onwards.
  • Equity Derivatives: 3:25 PM onwards.
Note:
  • Intraday square-off timings may change at the discretion of our risk management department.
  • A Call & Trade charge of ₹50 plus 18% GST will apply for all positions squared off by our RMS desk, including auto square-off.
  • If an intraday position or an MIS trade is not squared off on the same day due to a system failure or any risks associated with internet/wireless-based trading, it shall be treated as a Cash and Carry ("CNC") or NRML position and carried forward to the next trading day. In such cases, the onus of squaring off the position is on the client. If sufficient cash is unavailable in the client’s account, our RMS desk may square off the position without requiring a margin call.
  • Option premium received from writing options will not be considered as cash/capital.
  • Positions without sufficient funds can be squared off at any time at the discretion of our RMS desk. No margin calls or intimation will be provided.
Delayed Payment Charges
If a client’s account is in debit balance or lacks sufficient funds to maintain trading positions, an interest of 0.05% per day will be charged as delayed payment charges.
Contract Notes and Margin Statements
Firstock will issue contract notes and margin statements to clients within 24 hours of trade execution. Clients will also receive a daily margin status report, accessible via their back-office personal ledger.
Firstock Charges
  • Equity Delivery Trades: Zero brokerage
  • Intraday Trades: 0.035% or ₹20 per trade (whichever is lower)
  • Equity Futures & Options: ₹20 per trade
For offline clients, charges apply as per the agreed tariff sheet.
Other Charges
  • Annual Maintenance Charges for Demat: ₹300 plus 18% GST
  • DP Charges: ₹8 (Firstock) plus ₹5.5 (CDSL)
  • STT, GST, NSE Turnover and Transaction Charges, SEBI charges: As applicable market-wide
Debit Balance
Clients must make payments before the pay-in time on the settlement day. If payment is delayed beyond the settlement date, a delayed payment charge of 0.05% per day will apply.
Collateral Margins
  • For F&O positions, exchanges mandate that 50% of the margin must be in cash, and the remaining 50% can be collateral.
  • Liquid funds are considered cash equivalents, so the 50% rule does not apply.
Closing of Accounts / Dormant Accounts
  • A client’s account will be closed upon a specific request. The closure will be effective one month after the application/intimation or after account settlement, whichever is later.
  • Dormant accounts will be marked “Inactive” if there is no trade for 12 consecutive calendar months in any segment.
Policy on Unauthenticated News Circulation
  • Firstock does not provide tips or unauthorized news to clients. Employees are prohibited from circulating unauthenticated news or engaging in daily trading activities.
  • Employees are instructed not to provide market forecasts.
Online Surveillance
  • The surveillance team monitors online trades and investigates unusual volume spikes.
  • Large transactions are checked against the client’s declared income (as per KYC records).
Policy on Pre-Funded Instruments and Electronic Fund Transfers
For pre-funded instruments of ₹50,000 or more per client per day, Firstock may only accept them if:
They are accompanied by bank-issued proof verifying the account holder’s name and debited account number.
Refund & Cancellation Policy
  • Fees for account opening (equity and F&O) are non-refundable.
  • If an account is not opened within 10 days after receiving all required documents, a full refund may be requested.
  • In case of duplicate payments, clients can request a refund via email.
Note: Refund processing depends on banks and payment gateways.
AML and CFT Policy
1. Background
SEBI, vide circular dated 18th January 2006, along with all its updates, requires all ‘Market intermediaries’ to lay down a policy framework for anti-money laundering measures to be followed. SEBI has also issued a Master Circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT, last updated on February 3, 2023. Firstock Broking Limited (hereinafter “Firstock”), being a Stock Broker and therefore a market intermediary, is required to adhere to the Master Circular.
2. Objective
The objective of this PMLA policy is to have a system in place for preventing any money laundering financial transactions through Firstock and to identify, monitor, and report any such transactions 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 to as “KYC Standards” and “AML Measures." The objective is to have in place adequate policies, practices, and procedures that promote high ethical and professional standards and prevent Firstock from being used, intentionally or unintentionally, by criminal elements. KYC Standards and AML Measures would enable Firstock 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 Firstock manage its risks prudently.
The management of the company is fully committed to establishing appropriate policies and procedures for ensuring effectiveness and compliance concerning all relevant legal requirements and undertakes to periodically review the policies.
3. Regulatory Requirements
  • Compliance with the provisions of the PMLA and AML guidelines.
  • Acting as a central reference point and playing an active role in identifying & assessing potential suspicious transactions.
  • Ensuring that Firstock discharges its legal obligation to report suspicious transactions to the concerned authorities.
This policy is in relation to customer due diligence, which means:
  • Obtaining sufficient information about the client to identify who is the actual beneficial owner of the securities or on whose behalf the transaction is conducted.
  • Verifying the customer’s identity using reliable, independent source documents, data, or information.
  • Conducting ongoing due diligence and scrutiny of the account/client to ensure that the transactions conducted are consistent with the client’s background/financial status, its activities, and risk profile.
The customer due diligence process includes three specific parameters:
  • Policy for acceptance of clients: Each client should be met in person, or complete KYC must be done online. No account may be opened in a fictitious/benami name or as an anonymous account.
  • Suspicious transaction identification and reporting: Any unusual activity compared to past transactions of a client, sudden activity in dormant accounts, or a sudden increase in the volume or value of transactions is classified as suspicious. These shall be reported to SEBI and any other relevant authority as required by applicable law. account.
  • Aadhaar compliance: Central Depository Securities Limited (CDSL) communique no. CDSL/OPS/DP/POLCY/2017/176 dated April 05, 2017, and CDSL/OPS/DP/POLCY/2017/354 dated July 18, 2017, and all other applicable regulations advise that beneficial owners should submit/update their Aadhaar with their Depository Participant. Please ensure that you update your Aadhaar with Firstock as per these applicable regulations.
4. Client Identification
Before opening any account with us, the following measures shall be taken:
a. In-person or complete online KYC verification of the client.
b. Identify beneficial ownership and control, i.e., determine the persons who beneficially own/control the account.
c. Collect information about the client’s background and occupation and also determine the introducer, if any.
d. Collect and verify all original documents from the client.
e. Collect a certified copy of valid documents showing details of their permanent address, current address, PAN, nature of occupation, financial status, and a recent photograph.
f. For clients trading in the F&O segment, documentary proof of financial details will be collected as determined by policies from time to time.
g. Corporate clients:
  • Collect copies of the certificate of incorporation, the memorandum of association, and other documents required by SEBI.
  • Collect adequate information on the persons authorized to deal on behalf of the company.
5. KYC Updating Process
a. All corporate clients must submit their annual reports to Firstock every year.
b. In the case of individual clients, each client’s master details shall be sent to the client, who will then confirm that the details are updated correctly or shall revise/provide details as required. They shall also specify their present occupation and financial income details per annum in the same declaration.
c. No account shall be opened if the client is unable or refuses to follow the KYC-related requirements.
d. The information shall be adequate to satisfy competent authorities (regulatory/enforcement authorities) in the future that due diligence was observed by Firstock in compliance with the guidelines.
e. Failure by a prospective client to provide satisfactory evidence of identity should be noted and reported to the Principal Officer.
f. Firstock should follow up with clients where inconsistencies in the information provided are found until the client corrects the inconsistencies or provides reasonable proof for the same.
6. Client Categorization
a. Each client will be categorized as High Risk, Medium Risk, or Low Risk from the perspective of anti-money laundering laws. The categorization will be based on the following parameters: nature of business activity, trading turnover per day, manner of making payments on Firstock’s platforms, etc. Firstock shall internally mark the risk category of each client, and high-risk clients will require regular KYC updates as determined by Firstock.
b. Risk profiling may also vary for high-net-worth individuals, trusts, non-profits, charitable organizations, and companies with close family shareholdings.
c. As a general rule, clients who make payments on time and take delivery of shares may be considered low risk.
7. Suspended Persons
SEBI and other authorities suspend or debar persons/entities from participating in the securities market in several instances. Firstock, as a broker, is required to ensure that such persons do not trade through us and shall not be liable for any such blocking or closure of accounts.
8. Role of Compliance Team & Internal Audit
a. The compliance team will play an important role in ensuring compliance with the above policies and procedures. The account opening team will exercise adequate due diligence while onboarding clients. There will be periodic checks by the Principal Officer, and the same report will be properly filed by Firstock.
b. A system of concurrent audits will also ensure compliance with:
  • Due diligence in KYC norms.
  • Generation of exception reports.
  • Trading in dormant client codes.
  • Level of awareness among staff.
9. Risk Management
a. Firstock follows a risk-based approach for mitigating and managing any identified risk. Firstock monitors its policies and may enhance policies if necessary.
b. Client due diligence is undertaken on a risk-sensitive basis.
10. Transaction Monitoring
a. Firstock has undertaken measures to understand the normal and standard activities of each client to detect deviations in transactions and activities.
b. Firstock shall specifically note complex and unusually large transactions/patterns that appear to have no economic purpose.
c. Firstock shall ensure the retention of records as required under the PMLA and all other applicable laws.
11. Illiquid Securities
Exchanges specify a list of illiquid securities wherein higher due diligence is required by brokers. The list is displayed on the Firstock website for clients' information.
12. Employee Training
Firstock has a policy for ongoing employee training to ensure awareness of AML and CFT procedures.
Investor Grievances
The Compliance Officer shall be the designated officer for handling investor grievances and client complaints.
Procedure to file a complaint on SEBI SCORES: Register on the SCORES portal with mandatory details.