Policy on Prevention of Money Laundering (AML / CFT)

Document Control

Document title Policy on Prevention of Money Laundering (AML / CFT)
Entity Choice Equity Broking Private Limited (CEBPL)
Policy owner Compliance Department, CEBPL
Designated Director Mr. Sunil Bagaria (registered with FIU-IND)
Principal Officer Mr. Vijay Kejriwal (registered with FIU-IND)
Version 2.0
Reviewed / approved by Board 22.04.2026 (previous review: 21.04.2025)
Effective date 01.05.2026
Regulatory basis Prevention of Money Laundering Act, 2002 and PML (Maintenance of Records) Rules, 2005 (as amended, including the 2023 Amendment Rules); SEBI Master Circular SEBI/HO/MIRSD/MIRSD-SECFATF/P/CIR/2024/78 dated 06.06.2024 (superseding the 03.02.2023 guidelines); SEBI KYC / UBO circular dated 12.10.2023; UAPA, 1967 (Section 51A) and MHA orders dated 27.08.2009 / 14.03.2019; WMD Act, 2005 (Section 12A) and MoF order dated 30.01.2023; SEBI (Depositories and Participants) Regulations, 2018. Read with the institutional mechanism for fraud / market abuse under the SEBI (Stock Brokers) Regulations, 2026.
Next review due Annually, or earlier upon any SEBI / exchange circular affecting this policy

1. Introduction

This policy is intended for use primarily by Choice Equity Broking Private Limited (“CEBPL”) and its branches and business associates. While a “one-size-fits-all” approach is not appropriate for the securities industry, each branch / business associate shall consider the nature of its business, organisational structure, and the type of clients and transactions when applying the measures in this policy, and shall satisfy itself that the measures taken are adequate, appropriate and consistent with the requirements of the Prevention of Money Laundering Act, 2002 (“PMLA”). This policy reflects the requirements of the PMLA and the PML (Maintenance of Records) Rules, 2005 as applicable to intermediaries registered under Section 12 of the SEBI Act, 1992, as updated by the SEBI Master Circular on AML / CFT obligations of securities market intermediaries dated June 6, 2024 and the amendments to the PML Rules notified in 2023.

2. Background

The PMLA came into effect from July 1, 2005, with rules notified by the Department of Revenue, Ministry of Finance. Under the PMLA and the PML (Maintenance of Records) Rules, 2005, as amended from time to time, every reporting entity — which includes intermediaries registered under Section 12 of the SEBI Act such as a stock-broker, depository participant, research analyst, registrar to an issue, merchant banker, portfolio manager, investment adviser and other securities-market intermediaries — must adhere to client account opening procedures, maintain records, and report transactions as prescribed. For securities-market intermediaries, these obligations are operationalised through the SEBI Master Circular SEBI/HO/MIRSD/MIRSD-SECFATF/P/CIR/2024/78 dated June 6, 2024 (“SEBI AML / CFT Master Circular”), which superseded the earlier guidelines dated February 3, 2023 and consolidates the obligations of intermediaries, including the directions implementing the Weapons of Mass Destruction (WMD) Act, 2005.

Every reporting entity shall maintain a record of all transactions of the nature and value prescribed under the Rules, including:

  • All cash transactions of value more than Rs. 10 lakh or its equivalent in foreign currency;
  • All series of cash transactions integrally connected to each other, individually valued below Rs. 10 lakh, where they take place within a month and the monthly aggregate exceeds Rs. 10 lakh or its equivalent; and
  • All suspicious transactions, whether or not made in cash, including credits or debits into or from any non-monetary account such as a demat or securities account.

For the purpose of suspicious-transaction reporting, apart from “transactions integrally connected,” “transactions remotely connected or related” shall also be considered. The PMLA further provides that violations of the prohibitions on manipulative and deceptive devices, insider trading and substantial acquisition of securities or control under Section 12A read with Section 24 of the SEBI Act are scheduled offences under the PMLA.

3. What is Money Laundering

Money laundering is any act or attempted act to conceal or disguise the identity of illegally obtained proceeds so that they appear to originate from legitimate sources. It typically involves three phases:

  • Placement — the physical movement of currency or funds derived from illegal activity into the financial system or the retail economy;
  • Layering — the separation of proceeds from their illegal source through multiple complex financial transactions to obscure the audit trail; and
  • Integration — the conversion of illegal proceeds into apparently legitimate earnings through normal financial or commercial operations.

Having identified these stages, CEBPL adopts procedures to guard against, and to report, suspicious transactions occurring at any stage.

4. Policies and Procedures to Combat Money Laundering and Terrorist Financing

CEBPL’s framework to combat money laundering (ML) and terrorist financing (TF) includes:

  • Communication of group AML / CFT policies to all management and relevant staff handling account information, securities transactions, money and client records;
  • A client acceptance policy and client due diligence (CDD) measures, including proper identification;
  • Maintenance of records and compliance with statutory and regulatory requirements;
  • Co-operation with law enforcement authorities, including timely disclosure of information; and
  • An internal audit / compliance function — independent and adequately resourced — to test the systems for detecting suspected ML transactions, evaluate exception reports on large or irregular transactions, and assess the quality of suspicious-transaction reporting and staff awareness.

4.1 Group-wide AML / CFT programme

Under the SEBI AML / CFT Master Circular, group-wide AML / CFT programmes apply to a reporting entity that is part of a financial group with branches and majority-owned subsidiaries, including those situated abroad. CEBPL does not have any branch or subsidiary situated abroad; accordingly, the group-wide programme requirements applicable to foreign branches / subsidiaries are not applicable to CEBPL, which implements these AML / CFT measures at the entity level.

5. Written Anti-Money Laundering Procedure

Section 3 of the PMLA defines the offence of money laundering as: whosoever directly or indirectly attempts to indulge, knowingly assists, is a party to, or is actually involved in any process or activity connected with the proceeds of crime — including its concealment, possession, acquisition or use, and projecting or claiming it as untainted property — shall be guilty of the offence of money laundering. CEBPL’s written AML procedure addresses, as part of the overall CDD process: the policy for acceptance of clients; the procedure for identifying clients; risk management; transaction monitoring and Suspicious Transaction Reporting (STR); the type of information to be furnished; the time limits prescribed by FIU-IND; the designated officer for reporting; and employee training.

6. Financial Intelligence Unit – India (FIU-IND)

FIU-IND, established on November 18, 2004, is the central national agency responsible for receiving, processing, analysing and disseminating information relating to suspect financial transactions, and for coordinating national and international efforts against money laundering and related crimes. Reports to FIU-IND are filed electronically through the FINnet / FINgate reporting portal.

7. Implementation of Policy

7.1 Team

A Designated Director and a Principal Officer are appointed to implement this policy. The Principal Officer acts as the central reference point for identifying, assessing and reporting potentially suspicious transactions, and has access to, and is able to report to, senior management and the Board. The Principal Officer analyses the data and, in consultation with the compliance function, decides whether to report a suspicious transaction to FIU-IND.

Designated Director: In terms of Rule 2(ba) of the PML Rules, a “Designated Director” is a person designated by the reporting entity to ensure overall compliance with the obligations under the PMLA and Rules. The Principal Officer shall be an officer at the management level.

The Designated Director for CEBPL is Mr. Sunil Bagaria and the Principal Officer is Mr. Vijay Kejriwal; both are registered with FIU-IND.

7.2 Obligations

Senior management is committed to establishing and maintaining effective AML / CFT policies and procedures. CEBPL shall: issue a statement of policies and procedures reflecting current statutory and regulatory requirements; ensure the content is understood by all staff; regularly review the policies (with the reviewer being different from the person who framed them); adopt risk-sensitive client acceptance policies; undertake CDD measures proportionate to ML / TF risk; and maintain a system for identifying, monitoring and reporting suspected ML / TF transactions.

8. Client Due Diligence (CDD)

CDD means the diligence carried out on a client (as defined under the PMLA) using reliable and independent sources of identification. CEBPL’s CDD measures comprise:

  • Identifying and verifying the client’s identity using reliable, independent source documents, data or information;
  • Identifying the beneficial owner and verifying their identity, and understanding the ownership and control structure of the client;
  • Obtaining information on the purpose and intended nature of the business relationship; and
  • Conducting ongoing due diligence and scrutiny of transactions throughout the relationship to ensure consistency with CEBPL’s knowledge of the client, its business and risk profile, including, where necessary, the client’s source of funds.

8.1 Identification of beneficial ownership

Where the client is a person other than an individual or trust (e.g. a company, partnership or unincorporated association / body of individuals), CEBPL shall identify the beneficial owner(s) — the natural person(s) who, acting alone or together, or through one or more juridical persons, exercise control through ownership or who ultimately hold a controlling ownership interest. Following the revised thresholds under the SEBI AML / CFT Master Circular and the PML Rules, “controlling ownership interest” means ownership of / entitlement to:

  • more than 10% of the shares or capital or profits, where the juridical person is a company (revised from the earlier 25%);
  • more than 10% of the capital or profits, where the juridical person is a partnership firm (revised from the earlier 15%); or
  • more than 15% of the property or capital or profits, where the juridical person is an unincorporated association or body of individuals.

Where no natural person is identified through ownership, the identity of the natural person exercising control through other means (e.g. voting rights, agreement or arrangement) shall be determined; and where no such person is identified, the relevant natural person holding the position of senior managing official shall be identified.

For a trust: CEBPL shall identify the author of the trust, the trustee, the protector, the beneficiaries with 10% or more interest in the trust (revised from the earlier 15%), and any other natural person exercising ultimate effective control over the trust.

Listed companies: where the client, or the owner of the controlling interest, is a company listed on a stock exchange (or a majority-owned subsidiary of such a company), it is not necessary to identify and verify any shareholder or beneficial owner of such company.

Foreign investors: for foreign investors, CEBPL shall be guided by the applicable SEBI master circular on beneficial-ownership identification, as amended.

8.2 Policy for acceptance of clients (new clients)

CEBPL observes the following on client acceptance:

  • In-person verification (in person or through permitted video-based / Aadhaar e-KYC methods) and verification of PAN on the Income-tax portal;
  • Verification of identity, address, income and bank details against original documents, with no account processed on incomplete documentation, and KYC documents properly filled, signed and dated;
  • No accounts opened on a fictitious, benami or anonymous basis, and no account opened where appropriate KYC procedures cannot be applied or where the client does not provide required information;
  • CKYC / KRA registration of the client checked and, where the client is not registered, initiated along with account opening, with KYC data filed electronically with the Central KYC Records Registry (CKYCR);
  • Risk perception of the client defined with regard to the client’s location, nature of business / turnover, and manner of payment; and
  • Updation of Aadhaar / OVD details as required under the PML Rules.

For existing clients, CEBPL keeps the client’s financial status, contact, demat and bank details updated, screens clients against known criminal / debarred / sanctions databases, and reviews the relationship on an ongoing basis.

Screening: clients are screened against the UNSC consolidated sanctions lists, the SEBI debarred / prosecution database, OFAC and other applicable lists. If a client matches a sanctions or debarred list, the account shall not be opened and the matter shall be reported immediately to the Principal Officer / Designated Director for action.

8.3 Non-profit organisations — DARPAN registration (PML Rules, 2023 amendment)

Where a client is a non-profit organisation (as defined under the PML Rules with reference to Section 2(15) of the Income-tax Act, 1961), CEBPL shall register the details of the NPO client on the DARPAN portal of NITI Aayog, and shall maintain such registration records for a period of five years after the business relationship ends or the account is closed, whichever is later.

8.4 Risk-based approach and risk categorisation

CEBPL applies CDD on a risk-sensitive basis, adopting enhanced due diligence for higher-risk clients and simplified due diligence for lower-risk clients. Clients are categorised broadly as follows:

  • High risk: non-resident clients; high-net-worth clients; trusts, charities, NGOs and organisations receiving donations; companies with close family / beneficial-owner shareholding; Politically Exposed Persons (PEPs) and connected persons; companies offering foreign-exchange products; clients in or from high-risk countries; non-face-to-face clients; and clients with a dubious reputation;
  • Medium risk: clients falling within the definition of speculators / day traders and clients trading in the Futures & Options segment; and
  • Low risk: clients not covered in the high or medium categories.

CEBPL carries out and documents a risk assessment to identify, assess and mitigate ML / TF risk having regard to clients, countries / geographies, nature and volume of transactions and payment methods, taking into account country-specific information circulated by the Government / SEBI and the UN sanctions lists. The risk assessment is updated regularly and made available to competent authorities on request.

8.5 Politically Exposed Persons (PEPs)

Following the 2023 amendment to the PML Rules, a PEP is defined as an individual who has been entrusted with prominent public functions by a foreign country, including Heads of State or Government, senior politicians, senior government / judicial / military officers, senior executives of state-owned corporations and important political party officials. CEBPL applies enhanced due diligence to PEPs: senior management approval is obtained before establishing (or continuing) a relationship with a PEP or a client subsequently found to be a PEP, and reasonable measures are taken to establish the source of funds and wealth of PEPs.

8.6 Clients of Special Category (CSC)

CSC clients include non-resident clients; high-net-worth clients; trusts, charities and NGOs; companies with close family shareholding or beneficial ownership; PEPs; companies offering foreign-exchange products; clients in high-risk jurisdictions; non-face-to-face clients; and clients with a dubious reputation. The list is illustrative, and CEBPL exercises independent judgment in classifying clients as CSC. Dealing with clients from high-risk jurisdictions does not preclude legitimate transactions, but such relationships are subject to enhanced scrutiny.

8.7 Client identification procedure (CIP)

CEBPL identifies each client using reliable sources and documents at the establishment of the relationship, while carrying out transactions, and whenever there is doubt about the veracity or adequacy of previously obtained data. Appropriate risk-management systems are in place to determine whether a client or beneficial owner is a PEP. Each original document is seen prior to acceptance of a copy, and any failure to provide satisfactory evidence of identity is reported to higher authority.

8.8 Reliance on third parties for CDD

CEBPL may rely on a regulated, supervised third party for client identification / verification and beneficial-ownership determination, subject to the conditions in Rule 9(2) of the PML Rules: CEBPL immediately obtains the necessary CDD information; satisfies itself that identification data and documentation will be made available from the third party without delay; is satisfied that the third party is regulated and compliant with CDD and record-keeping requirements; and ensures the third party is not based in a high-risk jurisdiction. CEBPL remains ultimately responsible for CDD and enhanced due diligence.

9. Records Keeping

CEBPL maintains records sufficient to permit reconstruction of individual transactions (including amounts and currency types) to provide, if necessary, evidence for prosecution. For the accounts of clients, CEBPL retains the beneficial owner, the volume of funds flowing through the account, and, for selected transactions, the origin and destination of funds, the form in which funds were offered or withdrawn, the identity of the person undertaking the transaction, and the form of instruction and authority. In terms of the PML Rules, CEBPL maintains records of: all cash transactions exceeding Rs. 10 lakh (or equivalent); integrally connected cash transactions individually below that threshold but aggregating above it within a month; cash transactions involving forged or counterfeit currency or forged documents; and all suspicious transactions, whether or not in cash.

10. Information to be Maintained

In respect of transactions referred to in Rule 3 of the PML Rules, CEBPL maintains and preserves: the nature of the transaction; the amount and the currency in which it is denominated; the date on which it was conducted; and the parties to the transaction.

11. Retention of Records

CEBPL ensures all client and transaction records and information are available to competent investigating authorities on a timely basis. The records under Rule 3 of the PML Rules are maintained and preserved for a period of five years from the date of the transaction between the client and CEBPL. Records of documents evidencing the identity of clients and beneficial owners, and account files and business correspondence, are preserved for five years after the business relationship ends or the account is closed, whichever is later. Where records relate to on-going investigations or to transactions that have been the subject of a suspicious-transaction report, they are retained until it is confirmed that the case has been closed. Information reported to FIU-IND under Rules 7 and 8 of the PML Rules is preserved for five years from the date of the transaction.

Depository Participant records: in terms of the SEBI (Depositories and Participants) Regulations, 2018, original records and documents relating to depository operations shall be preserved for a period of eight years; this longer period applies to DP-related documents.

12. Monitoring of Transactions

Regular monitoring of transactions is essential to the effectiveness of CEBPL’s AML procedures. Special attention is given to complex, unusually large transactions or patterns with no apparent economic purpose. Internal threshold limits are specified for each class of client account, and transactions exceeding these limits are examined, with the background, records and findings recorded in writing and made available to auditors, SEBI, exchanges and FIU-IND on request. CDD measures are also applied to existing clients on the basis of materiality and risk, with the extent of monitoring aligned to the client’s risk category. Records are preserved for five years in terms of Section 12 of the PMLA.

12.1 Internal alert generation

The following alerts, among others, are generated as AML measures: client trading pattern; trading in illiquid scrips; concentration in a single scrip; payment track record; client turnover versus exchange turnover; synchronised trading; client purchases relative to income / net worth; groups of clients dealing in common scrips; and off-market transfers from CEBPL’s demat accounts to other demat accounts.

Surveillance tool: CEBPL currently uses the tool “Trackwizz”, provided by TSS Consultancy Pvt. Ltd., to monitor suspicious transactions against the above parameters and to file STRs with FIU-IND. CEBPL is in the process of migrating to “SOS AML” and “AML Sutra”, provided by Secmark Consultancy Ltd.; the tool’s parameters reflect the latest SEBI / FIU-IND red-flag indicators.

13. Suspicious Transaction Monitoring & Reporting

A “suspicious transaction” is a transaction (whether or not in cash) which, to a person acting in good faith, gives rise to a reasonable ground of suspicion that it may involve the proceeds of a scheduled offence (regardless of value); or appears to be made in circumstances of unusual or unjustified complexity; or appears to have no economic rationale or bona fide purpose; or gives rise to a reasonable ground of suspicion that it may involve terrorist financing. For STR purposes, “transactions remotely connected or related” are also considered.

All branches / business associates report suspicious transactions to the Compliance Department immediately on observation; the Compliance Department furnishes the information to the Principal Officer immediately. Circumstances that may indicate a suspicious transaction include, among others:

  • Clients whose identity verification is difficult or who do not co-operate;
  • Sources of funds not clear or not in keeping with the client’s apparent standing / business activity;
  • Substantial, unexplained increases in business volume; unusually large cash deposits; or transfers of investment proceeds to apparently unrelated third parties;
  • Off-market transactions in the client’s DP account; high trading in relatively illiquid scrips or in Z / T-to-T category scrips; and options trades booking unusual profit or loss inconsistent with movements in the underlying; and
  • High exposures relative to the client’s stated income, and unusual transactions by Clients of Special Category.

Suspicion is notified to the Principal Officer in a detailed report referencing the client, transaction and reason for suspicion. Dealings with the client continue as normal until otherwise directed, and the client is not informed of the report or suspicion. Attempted transactions — even if not completed by the client — are reported in STRs, irrespective of amount. An STR is filed wherever there are reasonable grounds to believe that the transaction involves proceeds of crime, irrespective of amount or any threshold for predicate offences in Part B of the Schedule to the PMLA.

14. Reporting Timelines to FIU-IND

Reports are filed electronically with FIU-IND through the FINnet / FINgate portal within the prescribed timelines:

  • Cash Transaction Report (CTR), where applicable, by the 15th of the succeeding month;
  • Suspicious Transaction Report (STR), within 7 working days of arriving at a conclusion that a transaction (or series of integrally connected transactions) is suspicious, with the Principal Officer recording the reasons; and
  • Non-Profit Organisation Transaction Report (NTR), by the 15th of the succeeding month.

The Principal Officer is responsible for timely submission of CTR, STR and NTR. Utmost confidentiality is maintained, and no “nil” reporting is required where there are no reportable transactions.

15. List of Designated Individuals / Entities

CEBPL screens all clients against the updated lists of individuals and entities subject to sanctions measures (such as freezing of assets / accounts and denial of financial services) approved by the UN Security Council Committees. No account is opened in the name of, or linked to, any person or entity on these lists, and all existing accounts are continuously screened. The relevant lists include:

  • The UN Security Council press releases / consolidated sanctions list — https://press.un.org/en/content/press-release;
  • The ISIL (Da’esh) & Al-Qaida Sanctions List — https://www.un.org/securitycouncil/sanctions/1267/press-releases; and
  • The list under UN Security Council Resolution 1718 relating to the Democratic People’s Republic of Korea (DPRK) — https://www.un.org/securitycouncil/sanctions/1718/pressreleases.

Full particulars of any account bearing resemblance to a listed individual / entity shall immediately be intimated to the Central (designated) Nodal Officer for the UAPA — Fax No. 011-23092551, Telephone No. 011-23092548, e-mail jsctcr-mha@gov.in — and shall also be conveyed, without delay, to the UAPA Nodal Officer of the State / UT where the account is held, to SEBI (through post and by e-mail to sebi_uapa@sebi.gov.in) and to FIU-IND.

16. Jurisdictions that Do Not or Insufficiently Apply the FATF Recommendations

CEBPL considers the FATF public statements and the list of jurisdictions under increased monitoring, as circulated by SEBI from time to time and as publicly available, to identify countries that do not or insufficiently apply the FATF Recommendations, and takes into account the risks arising from deficiencies in such jurisdictions’ AML / CFT regimes. This does not preclude legitimate trade and business transactions with such countries.

17. Freezing / Blocking / Restriction of Client Accounts

17.1 UAPA, 1967 — Section 51A

Section 51A of the Unlawful Activities (Prevention) Act, 1967, brought into effect through the UAPA (Amendment) Act, 2008, provides for the freezing of funds, financial assets or economic resources connected with terrorism. The procedure is governed by the Central Government Order dated August 27, 2009, as modified by the Order dated March 14, 2019 (work allocated to the Counter-Terrorism and Counter-Radicalisation Division, MHA), which CEBPL follows.

17.2 WMD Act, 2005 — Section 12A

In line with the SEBI AML / CFT Master Circular, CEBPL complies with the Ministry of Finance Order dated January 30, 2023 implementing Section 12A of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005, under which funds or financial assets connected with the financing of proliferation of weapons of mass destruction may be frozen, seized or attached. CEBPL maintains the “Designated List” and verifies transacting parties against it; on a match, the transaction is not carried out and the particulars are informed to the Director, FIU-IND (dir@fiuindia.gov.in) without delay.

17.3 Other circumstances

CEBPL may also freeze, block or restrict a client’s account on: a suspicious or abnormal trading pattern; suspected criminal activity or legal / statutory action by an appropriate authority; instructions, directions or orders from a regulatory authority (SEBI / RBI / Income-tax / EOW / FIU, etc.); or non-receipt of the client’s self-declaration / documentary evidence required for due diligence.

18. Unfreezing / Unblocking of Client Accounts

On receipt of the client’s explanation and the requisite documents, the matter is analysed and recorded. The account is unblocked only after the satisfaction of the AML team, based on the documents provided and a detailed scrutiny of the client’s trading activity and due diligence, and subject to any applicable regulatory directions (including, where relevant, the UAPA / WMD Act de-listing procedures).

19. Reporting to FIU-IND

The Principal Officer reports information relating to suspicious transactions to the Director, FIU-IND, electronically through the FINnet / FINgate portal (in the formats and through the channels prescribed by FIU-IND from time to time), in accordance with clause 31 of the SEBI Master Circular SEBI/HO/MIRSD/MIRSD-SECFATF/P/CIR/2024/78 dated June 6, 2024. There shall be no restriction on operations in an account merely because an STR has been filed. Directors, officers and employees (permanent and temporary) are prohibited from “tipping off” — disclosing that an STR or related information is being, has been, or will be reported — to the client or any unauthorised person at any stage.

The Principal Officer reports to the Director, FIU-IND at the following address, as may be modified by SEBI / FIU-IND from time to time:

Director, FIU-IND,
Financial Intelligence Unit – India,
6th Floor, Tower-2, Jeevan Bharati Building,
Connaught Place, New Delhi-110001, INDIA.
Telephone: 91-11-23314429, 23314459; 91-11-23319793 (Helpdesk).
Email: helpdesk@fiuindia.gov.in

20. Employee Hiring, Training & Investor Education

Hiring: CEBPL maintains adequate screening procedures to ensure high standards when hiring employees, identifying key positions with regard to ML / TF risk and ensuring that persons in such positions are suitable and competent.

Training: CEBPL maintains an ongoing AML / CFT training programme, with specific focus for frontline, back-office, compliance, risk-management and onboarding staff, so that all concerned understand the rationale, obligations and risks.

Investor education: CEBPL sensitises clients to the AML / CFT basis for the information it must collect (e.g. source of funds, tax / bank records), including through appropriate literature.

21. Review of Policy

This policy is reviewed whenever a statutory authority introduces changes or when otherwise necessary on account of business needs or the Risk Management Policy, and in any case at least annually. The policy is reviewed by the Principal Officer and Compliance Officer, with changes placed before the Board at the first meeting held after such changes, communicated to all departmental heads and associated persons, and made available on CEBPL’s website.

22. Miscellaneous

All employees shall ensure compliance with this policy. It is the duty of every employee / business associate to co-operate with, and provide timely disclosure and information to, any inspecting authority (internal or external), including law-enforcement authorities, in connection with its implementation. In addition to this policy, all directives issued by SEBI, the exchanges, NSDL, CDSL or any other regulatory authority shall be strictly adhered to. This policy also supports CEBPL’s institutional mechanism to prevent, detect and report fraud or market abuse under the SEBI (Stock Brokers) Regulations, 2026.