Samco -Legal Agreement

Welcome to Samco!

This Agreement (the “Terms”) constitute the rules that govern our relationship with you. So please read them carefully. If you do not accept Our Legal Agreement mentioned below, then don’t use the Services. The use of the Services and Platform (as defined hereunder) shall be deemed acceptances of the Terms.

Thanks for using our products and services (“Services”). The Services are provided by Samco, the Giga Trading engine- which is owned and operated by Samco Securities Limited. The terms "we", "us", "our" refers to Samco. Samco is a Stock Broker and a Depository Participant registered with Securities and Exchange Board of India Limited (SEBI) having registration number INZ000002535. For Commodities related services Samco Securities Limited undertakes and executes services.

Our Legal Agreement Covers the Following:

• Terms and Conditions of Use
• Privacy Policy
• Risk Management Policy
• Information/Analyst Disclaimer
• Most Important Terms and Conditions (MITC)
• Good Till Triggered (GTT) Policy
• Policy on facility of voluntary freezing/blocking the online access of the trading account

1. Terms and Conditions of Use

This section contains the Terms of Use of Samco which means Website and/or Mobile Application (on Android and IOS) collectively they are referred to as “Platform” for brevity. By accessing this Platform and any of its pages, you are agreeing to and understand that the information and material contained in this Platform constitutes your consent to the terms and conditions mentioned below. You also agree that Samco can modify or alter the terms and conditions of the use of this service without any liability. By use of the Platform, you agree and acknowledge that you are 18 years and above.

Samco is a Securities (Various Asset Classes) Trading, News aggregation-dissemination and content creation-distribution platform. We Provide Personalised Notes as per user/client’s stock preferences wherein;

Samco on occasion may provide information through our Services by using other Third Party Websites, the links for which may or may not be available. We do not have control on these websites and/or information provided and Samco has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party site. The third party websites are not under our control and we have not reviewed, nor approved them and we are not responsible for the content or omissions of any third party websites or any links contained in a third party website Samco also permits users/experts/third party publishers to upload, share and distribute content created by them. By using our Services, you expressly acknowledge and agree that Samco shall not be responsible for any damages of any kind, claims, or other Liability arising from or related to your use of any third party websites/data/information/opinions. To the extent that the Platform or any links provided therein directs you to a Third Party Website, you agree and acknowledge that Samco is merely acting as an intermediary. Samco also provides certain content which has been created by Samco itself and only to that extent it is not acting in the capacity as an intermediary.

E-mail/SMS/Notification – Messages

Messages/communications sent to and from between Samco and Users/Clients over the Internet cannot be guaranteed to be completely secure. Samco is not responsible in any manner whatsoever for any damages incurred by users/Clients on account of errors/delays/lost data packets/slow data connectivity. Samco is not responsible in any way for direct, indirect, special or consequential damages arising out of the use of this Platform.

As a condition of your use of the Platform, you will not use it for any purpose that is unlawful or prohibited or in violation of the terms and conditions as mentioned here in or prohibited by any domestic laws, statutes, ordinances and regulations. Your use of the Platform is your sole responsibility.

You shall not, display, upload, modify, publish, transmit, update or share any information including any messages/communication on the Platform, that -

• belongs to another person and to which you do not have any right;
• is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, pedophilic, libelous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner;
• involves the transmission of "junk mail," "chain letters," or unsolicited mass mailing or "spamming" or unsolicited commercial advertisement;
• harm minors in any way;
• infringes any patent, trademark, copyright, design or other proprietary rights;
• violates any law for the time being in force;
• deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
• impersonate another person;
• contain software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; and
• threaten the unity, integrity, defense, security or sovereignty of Indi, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation.

Transmission over the internet and Delay in Services:

Due to the nature of the Internet, transactions may be subject to interruption, transmission blackout, delayed transmission and incorrect data transmission. We shall not be liable for any loss or liability resulting, directly or indirectly, from delays, malfunctions or interruptions due to electronic or mechanical equipment failures, telephone interconnect problems, defects, weather, strikes, walkouts, fire, acts of God, riots, armed conflicts, acts of war, or other like causes. We shall have no responsibility to provide you access to the Platform while interruption of the Platform is due to any such cause continues. We are also not liable for delayed trading of Stocks/Commodities not under its control that may affect the accuracy or timeliness of messages and transactions you send and receive.

Downloading of the Platform:

We do not represent or warrant that the Platform will be available and meet your requirements, that access will not be interrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your device. You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. We make no representations or warranties regarding the accuracy, functionality or performance of any third-party software that may be used in connection with the Platform.

Modification

Samco reserves the right to delete, modify, change or discontinue any or all of the information on the Platform without giving notice to any user, individual, group of individuals, institutions and any such governing bodies.

Password Protection and Trading Account:

Samco gives you a unique user name and passwords for Browsing, Trading and Transaction purposes and hence no separate password is required when you place an order. You are free to change the password as and when you want from within the system provided in the Platform. Guest users are also allowed to download and explore the Platform however the access would be limited in such cases as may be decided by the Samco. In order to use full functionality of the Platform the user must register with Samco as a client after completing due registration formalities which are enumerated on the Samco website but which can also be done even through the Platform. Once a trading account is opened after following due procedure, the user/client can operate all the functionality of the Platform.

Internet Scanners and Intrusion Detection System

Samco maintains a database of attack signatures which is continuously updated and against which it will scan all incoming traffic to detect any malicious activity or hacking attempts into the site. In the event of a cyber attack/possibility of attack, it may terminate session/all sessions of the client(s) and log the attack details and take appropriate actions. Such cyber intrusions are external factors beyond the control of Samco and Samco owns no responsibility to users/clients on account of lost access or losses that may arise due to such an eventuality.

About our Services

When a service requires or includes downloadable software/mobile application, this software may update automatically on your device once a new version or feature is available. Some services may let you adjust your automatic update settings. Our Platform may not support all the devices (mobile/laptop/tab/desktop), due to technological factors of the application/operating system/third party softwares or any other factor. Your device may not be supportive or earlier tested with our platform, you should not assume that our platform will work/support your device.

Subject to your compliance with terms and conditions of the agreement, Samco gives you a personal, limited, non-assignable and non-exclusive license to use the Platform. This license is for the sole purpose of enabling you to use and enjoy the benefit of the Platform as provided by Samco, in the manner permitted by these terms. You shall not copy, modify, distribute, sell, or lease any part of our Platform or included software, nor may you reverse engineer or attempt to extract the source code of that Platform, unless laws prohibit those restrictions or you have our written permission.

Account Opening Instruction

By opening account via online EKYC mode. I understand, acknowledge, agree and accept that the account is a normal individual account with single nomination and for joint nomination physical KYC needs to be done.

• All Credit received will be automatically credited in my demat account
• All the pledge instruction will be accepted in my demat account without any further instruction from my end.
• Running A/C authorization consent is provided along with the Online Account Opening option.
• Account statement will be sent to my registered email address on monthly basis.
• Non-PEP Account: I am not linked/exposed to any political party/person.
• Electronic Transaction-cum Holding statement will be sent on my registered email id.
• Registered email id will be shared with RTA for communication and records.
• I have / will read R.D.D & other risk related documents on the Samco / Exchange websites.
• Annual Report will received on mail from RTA
• Interest/Dividend will be transferred directly to client’s registered bank account.
• Demat Instruction Slip will be issued on request made by client.
• BSDA facility will be given on request made by client provided the client is eligible for the same.

If any exception is required to the above conditions, I will open the account via physical mode or submit a modification form.

Referral Update

The referral brokerage sharing has been discontinued as per Exchange’s policy. From Oct 1st, 2024 there will be no brokerage sharing going forward and the final payout will only be effective till Sept 30th, 2024.

Modifying and Terminating our Services

We are constantly changing and improving our Platform. We may add or remove functionalities or features, and we may suspend or stop a Platform altogether.

2. Privacy Policy

Your Content/Information and Privacy:

If you choose to use our Services, then you agree to the collection, storage and use of information in relation to this policy. The information that we collect is used for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy.

Information Collection and Use

For a better experience, while using our Services, we require you to provide us with certain personally identifiable information, including but not limited to username, nickname and passwords. Such information may be in addition to what is prescribed by regulatory authorities for opening and operating accounts in capital markets. The information that we request is will be stored by us and used as described in this policy.

The Platform does use third party services that may collect information used to identify you. We want to inform you that whenever you use our Services, in a case of an error in the Platform we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the Platform when utilizing our Services, the time and date of your use of the Service, and other statistics.

Cookies

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device internal memory.

The Services does not use these “cookies” explicitly. However, the Platform may use third party code and libraries that use “cookies” to collection information and to improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Services.

Service Providers

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Services;
• To provide the Services on our behalf;
• To perform Services-related services; or
• To assist us in analyzing how our Services are used.

We want to inform users of these Services that these third parties may have access to your information including personally identifiable information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Security

We value your trust in providing us your personally identifiable information, thus to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

Data Sharing Policy:

Our automated systems analyze your content/habits/patterns/trading strategies to provide you personally relevant product/service features, such as customized search results, personalised notes, customized advertising etc. This analysis occurs as the content is sent, received, and stored. We may display your Profile name, Profile photo, and actions you take on Samco or on third-party applications connected to our Samco Account, reviews you write and comments you post in our Platform. We will respect the choices you make to limit sharing or visibility settings in your Samco Account. If you submit feedback or suggestions about our Platform/Services, we may use your feedback or suggestions without any obligation to you. Samco may share generalized data of users/clients to any third party for the purposes of display of Advertisements and marketing materials, for which in return, Samco may earn revenues which shall be the sole beneficiaries of such revenues and will not be shared with any users/clients. Personally identifiable information of the users/clients will not be shared otherwise than as required by the Regulatory authorities/Law.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact Manashvi Thakur at compliance@samco.in

3. Risk Management Policy

RISK MANAGEMENT POLICY APPLICABLE TO ALL CLIENTS

OBJECTIVE: In capital market risk management is one of the most important aspects to avoid any future financial crisis; it becomes important to manage risks effectively as it not only affects the organization but it also affects their clients. This can be achieved by placing robust system in place and implementation of the same. Especially in the derivatives market, the amount of margin is small relative to the value of the derivatives contract so the transactions are 'leveraged' or 'geared'. Derivatives trading, which is conducted with a relatively small amount of margin, provides the possibility of great profit or loss in comparison with the margin amount. But transactions in derivatives carry a high degree of risk. You should therefore completely understand the following statements before actually trading in derivatives and also trade with caution while taking into account one's circumstances, financial resources, etc. If the prices move against you, you may lose a part of or whole margin amount in a relatively short period of time. Moreover, the loss may exceed the original margin amount.

You must know and appreciate that trading in Equity shares, derivatives contracts or other instruments traded on the Stock Exchange, which have varying element of risk, is generally not an appropriate avenue for someone of limited resources/limited investment and/or trading experience and low risk tolerance. You should therefore carefully consider whether such trading is suitable for you in the light of your financial condition. You should well verse yourself first about the systems, pay ins & pay outs of funds and securities, order types (intraday, carry forward and delivery trades) and other applicable rules and regulations. You should read RDD which is part of account opening document before beginning to trade or invest. In case you trade on Exchanges and suffer adverse consequences or loss, you shall be solely responsible for the same and Samco/Stock exchanges/its Clearing Corporation and/or SEBI shall not be responsible, in any manner whatsoever, for the same and it will not be open for you to take a plea that no adequate disclosure regarding the risks involved was made or that you were not explained the full risk involved by Samco. The client shall be solely responsible for the consequences and no contract can be rescinded on that account. You must acknowledge and accept that there can be no guarantee of profits or no exception from losses while executing orders for purchase and/or sale of a derivative contract being traded on Stock exchanges.

ROLES & RESPONSIBILITIES: Role of Risk Management Department start from client registration like client categorization, daily limit setting, monitoring of daily transactions, margins etc. checking and monitoring of risk at various level and implementation of Risk Policy.

CLIENT CATAGORIZATION: Classification of both existing and new clients into difference risk categories in back office like Low, Medium, High or CSC depending on the various parameters like client identity, background, financial, transactions pattern etc.

EXPOSURE / LIMIT SETTING: Daily limits will be set and updated in RMS software on the basis of available balance / collateral.

MARGINS: In derivative segment upfront margin will be collected as per Exchange requirements. Futures trading involve daily settlement of all positions. Every day the open positions are marked to market based on the closing level of the index / derivatives contract. If the contract has moved against you, you will be required to deposit the amount of loss (notional) which is generally in the range of average historic volatility. This is also called daily settlement price. This amount will have to be paid latest by the next day morning before the commencement of trading. (For Eg a derivative contract worth Rs 100 requires Rs 20 as margin for carried forward trade. The price fluctuates daily, suppose the price rises to Rs 102 for a short position, then the trader has to deposit Rs 2 as margin money next day before the start of market) If you fail to deposit the additional amount by the deadline or if an outstanding debt occurs in your account, SAMCO may liquidate a part of or the whole position or can sell securities to recover the amount. In this case, you will be liable for any losses incurred due to such close-outs. Samco’s margin calculator available on the website is only indicative and for educational purposes, such calculator is in no way substitute to the actual margins required for initiating a position(s).

QUANTUM OF MARGINS: The client shall pay applicable initial margins, withholding margins, special margins or such other margins as are considered necessary by the stock broker or the Exchange or as may be directed by SEBI from time to time as applicable to the segment(s) in which the client trades. The stock broker is permitted in its sole and absolute discretion to collect additional margins (even though not required by the Exchange, Clearing House/Clearing Corporation or SEBI) and the client shall be obliged to pay such margins immediately failing which the position of the client is liable to be squared off at the sole discretion of Samco.

In case of commodity segment many contracts expiry results into delivery transactions/positions, SAMCO do not allow delivery transactions in commodity segment, therefore in case of tender period which starts before certain day of expiry date, client has to square off or roll over his/her positions prior to beginning of tender period, Samco does not allow to take fresh positions in tender periods of any security. If any trade is executed by client in this period and transaction results into delivery client has to pay required full amount and any loss incurred for whatsoever reason on this account shall be to the client’s account.

RISK AND COLLATERAL MANAGEMENT: Samco has an online real time basis risk monitoring system for each client. If on a real time basis, at any time during the day (including pre opening gaps) the losses(mark to market) exceed more than 80% of the client’s total deposits, SAMCO shall initiate the square off of the position of the client on a real time basis without even informing the client. (Eg. A derivative contract worth Rs 100 requires Rs 20 as margin for carried forward trade or lesser if the trade is for intraday, as the case may be, if at any point of time during the day, price fluctuates more than 16% or more, which means that 80% of the deposit amount is wiped out, (i.e. 20 *80/100= 16) Samco RMS team in such cases will square off the position) Such eventuality may be rare but often happens in financial markets and therefore it is not feasible to inform the client about auto square off being undertaken by SAMCO’s RMS team. Such huge volatility should not be construed as normal volatility and such losses have to be replenished immediately otherwise the position will be squared off subject to 80% condition. Clients should not wait for next day to settle such margin calls on the positions on the pretext that this falls under daily settlement process. There is a difference between daily settlement which is nothing but generally average historic volatility and extraordinary volatility which needs to be replenished immediately, daily settlement price can be paid next day morning but losses beyond average historic volatility or in other words extraordinary large loss has to be replenished on an immediate and real time basis otherwise Samco’s RMS team will square off if losses exceed 80% of the deposits at any given time. Such losses shall be of the client and SAMCO in no way will be held responsible. The client therefore in general is advised to maintain more margins than is required by the Exchanges for his/her safety due to such black swan movement (means massive or abnormal volatility either intraday or due to overnight events) in the prices of the securities. Samco shall endeavor to close out the position once 80% losses of the deposits are triggered but, SAMCO in no way, guarantees that the losses will be squared off at such percentage, in reality, it can be more or less. (Eg. Continuing from the above example if the price of derivative contract moves quickly by 20% without giving an opportunity to Samco’s RMS team to square off at Rs 16 i.e. at 80% but eventually the square off happens at Rs 20, then the client is liable to deposit Rs 4 as the loss amount due to adverse price movements)

TRADING RESTRICTIONS: Restrictions in certain Securities shall be done periodically by RMS Team. SAMCO shall from time to time classify a list of securities which are illiquid as per the list of illiquid securities notified on a periodic basis by the Stock Exchanges concerned and / or based on such internal criteria as SAMCO may deem fit. SAMCO reserves the right to refuse execution of any transaction requests of the Client on such illiquid securities or to reduce the open market interests of the Client in such securities. SAMCO also reserves the right not to allow any trades or transactions in respect of certain securities or segments or orders/requests which may be below / above certain value / quantity as may be decided by SAMCO from time to time. Trading in Illiquid Scrip may be restricted as per management directives. RMS Team will closely monitor such type of transactions. Such list of illiquid stocks is updated on the website. In F&O segment no new position will be permitted in Ban Period securities. Penalties if any due to such transactions if initiated by the client shall be borne by the client solely.

ONLINE PAYMENT: Samco shall give credit to client accounts when it receives the payment advice from IMPS, Payment Gateway, NEFT, RTGS and cheques. Credit limits will be given only on confirmation which generally takes time because Samco has no control over banks or payment gateways. Delays if any in receiving payments by Samco and thereby causing a consequential loss to the client either due to Samco’s RMS auto square off policy or otherwise shall be sole responsibility of the client, Samco in no way shall be held responsible for the delay of any third party payment systems. Samco shall not process payouts on bank holidays although exchanges may remain open for trading. All ledger debits are liable for payment of interests to Samco in addition to any penalties that are levied by the exchanges.

SAMCO's RIGHT TO SQUARE OFF: Without prejudice to SAMCO's other rights (including the right to refer a matter to arbitration), in the event of the Client failing (Samco is not obligated to inform as it operates an online system wherein clients are expected to monitor their positions on a real time basis through Samco’s mobile and desktop trading terminals) to maintain/supply applicable margin money plus mark to market losses on a real time basis required to sustain the outstanding market positions ,SAMCO shall be entitled, at its option and liberty, to liquidate/ close out all outstanding market positions or any part thereof such that the outstanding market positions are either zeroed out or reduced to an extent where available margin covers the market positions remaining after such square off. The Client understands and accepts that authority of SAMCO to square off outstanding market positions of the Client in the event the Client fails to furnish market to market losses/margin money immediately suo motto qua the entire outstanding position and the Client shall not, as a matter of right, be entitled to reduction of the outstanding positions in stages in order that positions to the extent of available margin are retained in the Client's account. SAMCO may also sell off all or any securities of the Client lying with SAMCO as collateral or otherwise, for any amounts due by the Client and adjust the proceeds of such liquidation/close out against the client's liabilities/obligations to SAMCO. Any and all losses and financial charges on account of such liquidation/closing-out shall be charged to and borne by the client. Such liquidation/ close out may be without any prior reference or notice to the client. Client shall keep and hold SAMCO indemnified and harmless from any loss arising out of such closing out/squaring off. Such liquidation or close out of positions shall apply to any segment in which the Client does business with SAMCO. It shall be the duty of the client to be self vigilant and adequately replenish/deposit the margins and mark to market losses on a immediately basis which are calculated on a real time basis by Samco

SYSTEM/NETWORK CONGECTION RISK: Trading on the Exchange is in electronic mode, based on satellite/ leased line communications, combination of technologies and computer systems to place and route orders. Thus, there exists a possibility of communication failure or system problems or slow or delayed response from system or trading halt, or any such other problem/glitch including delayed or missed OTPs whereby not being able to establish access to the trading system/network, which may be beyond the control of and may result in delay in processing or not processing buy or sell orders either in part or in full. You are cautioned to note that although these problems may be temporary in nature, but when you have outstanding open positions or unexecuted orders, these represent a risk because of your obligations to settle all executed transactions. The losses if any arising out of such systems/network risk shall be of the client alone.

The Client shall not have any claim against the Exchange or the Stock broker on account of any suspension, interruption, non- availability or malfunctioning of the Samco trading system or Service or the Exchange's service or systems or non-execution of his orders due to any link/system failure at the Client/Stock brokers/Exchange end for any reason beyond the control of the Samco/Exchanges

Charts are formed using limited tick data (multi cast data) whereas the number of ticks recorded on the exchange are tick by tick (unicast) which are far more higher thus there may arise a perceived difference on the price action observed on the chart and that of actual price action on the exchange. Samco has zero control on such data feeds and is totally dependent on external sources to receive such feeds. Therefore charts may not truly capture all the price actions transpiring on the exchanges.

“The Stock Exchange, Mumbai is not in any manner answerable, responsible or liable to any person or persons for any acts of omission or commission, errors, mistakes and/or violation, actual or perceived, by us or our partners, agents, associates etc., of any of the Rules, Regulations, Bye-laws of the Stock Exchange, Mumbai, SEBI Act or any other laws in force from time to time. The Stock Exchange, Mumbai is not answerable, responsible or liable for any information on this Website or for any services rendered by our employees, our servants, and us. ”

POWER OF ATTORNEY: Clients who have opened their trading accounts online are expected to send the POA in hard copy for demat account within 30 days to Samco’s office otherwise Samco shall at its discretion stop OTP facility for selling the shares on delivery basis and the client in that case will have to then manually (or courier) come to Samco’s office to deposit DIS (delivery instruction slip)

DORMANT CLIENTS RMS: Team will update the dormant client list (inactive from more than 12 months) & restrict their trading rights. Activation of such clients will be done as per Dormant Client policy.

PAY-IN & PAYOUT OF FUNDS & SECURITIES: Third party pay-in of funds & securities will not be accepted. Same way payout of shares and fund will be directly done to client account only. No securities belonging to one client be used/transferred for other client or for Own purpose. Securities sold by client on intraday basis which for whatsoever reasons are not squared off, then such losses, on account of price difference between the selling price and auction purchase price shall be on the account of the client alone and Samco shall not, in any way, be responsible for such losses. Client initiating buy today and sell tomorrow strategy is prone to security shortage risks which eventually, if any, will result into losses on account of difference in auction price and client’s original trade price, the losses arising on such transactions shall be of the client’s account and Samco in no way is responsible for any such losses.

Margin trading Facility(MTF): Margin Trading Funding (MTF) is subject to provisions of SEBI circular CIR/MRD/DP/54/2017 dated June 13,2017 and the terms and conditions mentioned in rights and obligations statement issued by Samco Securities Limited.

4. Information/Analyst Disclaimer

Use of information and materials

Samco makes best endeavour to ensure that it uses current, reliable, comprehensive information and obtain such information from sources which are believed to be reliable. However, such information has not been independently verified by Samco and no representation or warranty, express or implied, is made as to the accuracy or completeness of any information obtained from third parties. The information, opinions, views expressed in the Platform will be those of the independent research analysts as at the date of publishing the reports which are subject to change with passage of time or when new material is available and they do not represent to be an authority on the subject. Samco may or may not subscribe to any and/ or all the views expressed herein.

The information provided by Samco is strictly confidential and is being furnished to you solely for your information. This information should not be reproduced or redistributed or passed on directly or indirectly in any form to any other person or published, copied, in whole or in part, for any purpose. This information is not directed or intended for distribution to, or use by, any person or entity who is a citizen or resident of or located in any locality, state, country or other jurisdiction, where such distribution, publication, availability or use would be contrary to law, regulation or which would subject Samco and associates / group companies to any registration or licensing requirements within such jurisdiction. The distribution of this information in certain jurisdictions may be restricted by law, and persons in whose possession this information comes, should observe, any such restrictions. The information given on this Platform is as of the date of dissemination and there can be no assurance that future results or events will be consistent with this information. This information is subject to change without any prior notice. Samco reserves the right to make modifications and alterations to this statement as may be required from time to time. Samco or any of its associates / group companies shall not be in any way responsible for any loss or damage that may arise to any person from any inadvertent error in the information contained in the Platform. Neither Samco nor any of its associates, group companies, directors, employees, agents or representatives shall be liable for any damages whether direct, indirect, special or consequential including loss of revenue or lost profits that may arise from or in connection with the use of the information provided in the Platform. Samco’s proprietary trading and investment businesses may make investment decisions that are inconsistent with the recommendations expressed in the Platform. Past performance is not necessarily a guide to future performance. The disclosures of interest statements incorporated in the Platform are provided solely to enhance the transparency and should not be treated as endorsement of the views expressed in the Platform. The information provided in the Platform remains, unless otherwise stated, the copyright of Samco. All layout, design, original artwork, concepts and other Intellectual Properties, remains the property and copyright of Samco and may not be used in any form or for any purpose whatsoever by any party without the express written permission of Samco.

Disclaimer for Information and Materials:

Samco and its associates, officer, directors, and employees, research analyst (including relatives) may: (a) from time to time, have long or short positions in, and buy or sell the Securities, mentioned herein or (b) be engaged in any other transaction involving such Securities and earn brokerage or other compensation or act as a market maker in the financial instruments of the subject company/company(ies) discussed herein or act as advisor or lender/borrower to such company(ies) or have other potential/material conflict of interest with respect to any recommendation and related information and opinions at the time of publication of research report or at the time of public appearance. Samco may have proprietary long/short position in the above mentioned securities and therefore should be considered as interested. The views provided herein are general in nature and do not consider risk appetite or investment objective of any particular investor/trader; clients/users are requested to take independent professional advice before investing/trading. This should not be construed as invitation or solicitation to do business with Samco. Samco or its associates may have received compensation from the subject company in the past 12 months. Samco or its associates may have managed or co-managed public offering of securities for the subject company in the past 12 months. Samco or its associates may have received compensation for investment banking or merchant banking or brokerage services from the subject company in the past 12 months. Samco or its associates may have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past 12 months. Research analyst or his/her relative or Samco’s associates may have financial interest in the subject company. Samco and/or its Group Companies, their Directors, affiliates and/or employees may have interests/ positions, financial or otherwise in the Securities/Currencies and other investment products mentioned in the Platform. Samco, its associates, research analyst and his/her relative may have other potential/material conflict of interest with respect to any recommendation and related information and opinions at the time of publication of research report or at the time of public appearance. Samco’s analyst may have served as an officer, director or employee of subject Company. Samco or its Associates may have actual / beneficial ownership of 1% or more securities of the subject company at the end of the month immediately preceding the date of publication of the information on the Platform.

Samco’s analyst or his/her relative may have actual/beneficial ownership of 1% or more securities of the subject company at the end of the month immediately preceding the date of the publication of the information on the Platform. Subject Company may have been client during twelve months preceding the date of publication of the information on the Platform. Samco’s analyst certifies that all of the views expressed on this Platform accurately reflect his or her personal views about the subject company or companies and its or their securities, and no part of his or her compensation was, is or will be, directly or indirectly related to specific recommendations or views expressed herein in the Platform.

Samco disclaims any obligation to update or correct or provide accuracy in information / content contained in any of the sections on the Platform, whether arising as a result of financial, business or any other developments. The information in any or all of the sections of the Platform is updated by Samco on a periodic basis and is uploaded as on a particular date, which may not be the current /latest date. Hence this information may not be an accurate representation of the actual filings, press releases, earnings releases, financials, industry news, stock quotes, etc.

By agreeing the Terms & Conditions, you authorize Samco & its representatives & agents to provide information about various products, offers and services provided by Samco through any mode including telephone calls, SMS, letters, emails etc. you confirm that laws in relation to unsolicited communication referred in “National Do Not Call Registry” as laid down by “Telecom Regulatory Authority of India” will not be applicable for such information/ communication.

Whilst every care has been taken in preparing, aggregating, collating the information / materials contained / published on the Platform, such information/materials are provided "as is" and “as available” basis without any representation and warranty of any kind, either express or implied. In particular, no representation or warranty regarding non-infringement, security, accuracy, fitness for a purpose or freedom from computer/Mobile viruses is given in connection with such information/materials.

Indemnification:

You agree to indemnify, defend and hold Samco including its officers, directors, employees, affiliates or representatives harmless from any claim or action (including legal expenses) arising out your use of the Platform in any manner, your breach of this agreement and violation of any third party’s intellectual property rights.

Application of Contents and their Usage

Apart from the content available on the Third Party websites and the content generated by the Users/Client, the content on the Platform and the interpretation of data are solely the personal views of Samco’s analysts and/or third party expert contributors. We reserve the right to review such content to determine whether it is illegal or violates our policies, and we may remove or refuse to display content that we reasonably believe violates our policies. But that does not necessarily mean that we review content, so please don’t assume that we do.. Users/clients are advised to use the data for the purpose of information only and rely on their own judgement while making investment/trading decisions. The investments/trading ideas discussed or recommended may not be suitable for all investors/traders. Samco does not warrant the timeliness, accuracy or quality of the Platform content.

The content of the Platform cannot be copied, reproduced, republished, uploaded, posted, transmitted or distributed for any non-personal use without obtaining prior permission from Samco. We reserve the right to terminate the accounts of Users/Clients, who violate the proprietary rights, in addition to initiating any necessary legal action.

Samco and its owners/affiliates are not liable for damages caused by any performance, failure of performance, error, omission, interruption, deletion, defect, delay in transmission or operations, computer virus, communications line failure, and unauthorized access to the personal accounts. Samco is not responsible for any technical failure or malfunctioning of the Platform or delays of any kind.

We are also not responsible for non-receipt of registration details or e-mails. Users shall bear all responsibility of keeping the password secure. Samco is not responsible for the loss or misuse of the password.

Our Content

Unless otherwise specified, the content and information contained within our Platform or delivered to you in connection with your use of our Platform is the property of Samco). The trademark, trade names, logos and content(s) (the "Content") that are used and displayed on our Platform include registered and unregistered Content of ours. Nothing on our Platform should be construed as granting any license or right to use any Content displayed on our Platform. We retain all proprietary rights on our Platform. Users are prohibited from using the same without written permission of Samco of such or of such other third parties. The materials on this Platform constitute works in which intellectual property rights (including those in the nature of copyrights) subsist, are protected by intellectual property laws and no part of such materials may be modified, reproduced, stored in a retrieval system, transmitted (in any form or by any means), copied, distributed, used for creating derivative works or used in any other manner for any purposes whatsoever without the prior written consent of Samco.

Third Party Trademark & Copyright

Other brands, trade names, logos or content used on the Platform may be owned and/or proprietary to their respective owners and should be treated as such, We in no way want to infringe or claim or abuse their rights. We have duly acknowledged all the third-party sites/source from where our Platform has accessed information but since it is an automated system driven process it may so happen that the system misses to provide third party links or acknowledge or wrongly acknowledges the content owner. Similarly users of the Platform are permitted to upload, share and distribute content created by them and such content is not necessarily monitored by Samco, though the terms and conditions with regard to what content may be uploaded has been set out herein. Errors, if any, in respect of the aforementioned content should be brought to our attention and we will rectify the error so committed at the earliest possible opportunity.

Using our Services does not give you ownership of any intellectual property rights in our Services or the content you access. You may not use content from our Services unless you obtain permission from its owner or are otherwise permitted by law. These terms do not grant you the right to use any branding or logos or trademarks used in our Services. Don’t remove, obscure, or alter any legal notices displayed in or along with our Services.

Our Services display some content that is not Samco's. This content is the sole responsibility of the entity that makes it available. We may review content to determine whether it is illegal or violates our policies, and we may remove or refuse to display content that we reasonably believe violates our policies or the law. But that does not necessarily mean that we review all content, so please don’t assume that we do.

Samco’s crawlers and automated softwares continuously crawl across the internet to locate and analyze relevant information which is aggregated, collated and indexed for our users on our platform however if anyone does not want us to display their contents/information/data/news they should specifically put instructions in their “meta-tags” within their computer code(HTML) which enables our crawlers and automated softwares to know that such website(s) should not be crawled absent which, such third party websites/data/information/news providers have impliedly consented by their conduct to allow us to crawl aggregate collate and index their data/information/news.

Some of our Services are available on mobile devices. Do not use such Services in a way that distracts you and prevents you from obeying traffic or safety laws.

About the Terms:

Samco may modify these terms or any additional terms that apply to the Platform to, for example, reflect changes to the law or changes to our Platform. You should look at the terms regularly. We’ll post notice of modifications to these terms on this page. We’ll post notice of modified additional terms as applicable in the Platform. Changes will not apply retroactively and will become effective no sooner they are posted. However, changes addressing new functions for a Platform or changes made for legal reasons will be effective immediately. If you do not agree to the modified terms for a use, you should discontinue your use of the Platform. If there is a conflict between these terms and the additional terms, the additional terms will control for that conflict.

These terms control the relationship between Samco and you. They do not create any third party beneficiary rights.

If you do not comply with these terms, and we don’t take action right away, this doesn’t mean that we are giving up any rights that we may have (such as taking action in the future).

Jurisdiction:

The terms of this agreement are exclusively based on and subject to Indian law. You hereby submit to the exclusive jurisdiction and venue of courts in Mumbai, India for any and all disputes arising out of or relating to the use of this Platform. The Platform is for the exclusive purpose of transactions to be carried out within the territorial jurisdiction of India and all such transactions shall be governed by the laws in India. Notice is hereby given that Non Resident Indians (NRI's) and Foreign Nationals accessing the Platform and opting to transact thereon shall do so after due verification at their end of their eligibility to do so. Samco undertakes no responsibility for such pre-eligibility of qualification on part of Non-Resident Indians (NRI's) or Foreign Nationals to transact on this Application.

Conflict Resolution:

Any dispute or difference between the parties arising out of or in connection to this agreement, including but not limited to performance, termination, or breach thereof, that cannot be settled first through mutual negotiation by the parties shall be resolved in accordance with the arbitration procedures stipulated under the Arbitration and Conciliation Act, 1996.

The arbitration proceeding shall be conducted through a sole Arbitrator appointed in accordance with the Arbitration and Conciliation Act, 1996. The proceedings shall be conducted in English language and the seat of arbitration shall be Mumbai, India. Subject to the arbitration clause above, the courts in Mumbai shall have exclusive jurisdiction to try, entertain and dispose of any applications or proceedings which arise out of such aforementioned disputes or differences.

If it turns out that a particular term is not enforceable, this will not affect any other terms.

The users/clients acknowledges that market investment/trading are subject to risk and there can be significant chance of loss in the market environment and also acknowledges and accepts that past performance is not indicative of future returns. Any loss or damage to the users/clients shall not be the responsibility or liability of Samco and that shall solely be the responsibility of the user/client.

5. Most Important Terms and Conditions (MITC)

1. Your trading account has a “Unique Client Code” (UCC), different from your demat account number. Do not allow anyone (including your own stock broker, their representatives and dealers) to trade in your trading account on their own without taking specific instruction from you for your trades. Do not share your internet/ mobile trading login credentials with anyone else.
2. You are required to place collaterals as margins with the stock broker before you trade. The collateral can either be in the form of funds transfer into specified stock broker bank accounts or margin pledge of securities from your demat account. The bank accounts are listed on the stock broker website. Please do not transfer funds into any other account. The stock broker is not permitted to accept any cash from you.
3. The stock broker’s Risk Management Policy provides details about how the trading limits will be given to you, and the tariff sheet provides the charges that the stock broker will levy on you.
4. All securities purchased by you will be transferred to your demat account within one working day of the payout. In case of securities purchased but not fully paid by you, the transfer of the same may be subject to limited period pledge i.e. seven trading days after the pay-out (CUSPA pledge) created in favor of the stock broker. You can view your demat account balances directly at the website of the Depositories after creating a login.
5. The stock broker is obligated to deposit all funds received from you with any of the Clearing Corporations duly allocated in your name. The stock broker is further mandated to return excess funds as per applicable norms to you at the time of quarterly/ monthly settlement. You can view the amounts allocated to you directly at the website of the Clearing Corporation(s).
6. You will get a contract note from the stock broker within 24 hours of the trade.
7. You may give a one-time Demat Debit and Pledge Instruction (DDPI) authority to your stock broker for limited access to your demat account, including transferring securities, which are sold in your account for pay-in.
8. The stock broker is expected to know your financial status and monitor your accounts accordingly. Do share all financial information (e.g. income, networth, etc.) with the stock broker as and when requested for. Kindly also keep your email Id and mobile phone details with the stock broker always updated.
9. In case of disputes with the stock broker, you can raise a grievance on the dedicated investor grievance ID of the stock broker. You can also approach the stock exchanges and/or SEBI directly.
10. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. You will not have any protection/recourse from SEBI/stock exchanges for participation in such schemes.

6. Good Till Triggered (GTT) Policy

1. Purpose

The purpose of this Goods Till Triggered (GTT) Order Policy is to define the procedures and conditions under which GTT orders are placed, managed, and executed. This policy aims to provide clarity on how GTT orders work and ensure that they are handled in a transparent and efficient manner.

2. Definition

A GTT order is a type of conditional order that remains valid until a predefined trigger condition is met. Once the trigger condition is satisfied, the GTT order is activated and executed according to the specified instructions.

3. Scope

This policy applies to all GTT orders placed by clients for the purchase or sale of securities, or other financial instruments through our trading platform.

4. Order Placement

Trigger Condition: The client must specify the conditions under which the GTT order will be activated. This could include price levels, quantity, or other relevant criteria. Further on trigger of price, the GTT order will then be executed with exchange.
Order Details: The client must provide complete details of the GTT order, including the trigger condition, order type (buy/sell), quantity, price, and any additional instructions.

5. Validity

Duration: GTT orders are valid until the trigger condition is met or until the order is canceled by the client. GTT orders do not expire until activated or explicitly canceled. The validity of GTT orders is till 31st Dec 2099, after placing the request if they are not triggered according to the specified conditions.
Trigger Satisfaction: Once the trigger condition is met, the GTT order is activated and treated as a standard order, subject to market conditions and execution practices.

6. Order Execution

Activation: Upon activation, the GTT order will be executed based on the prevailing market conditions and the instructions provided by the client.
Partial Execution: If only part of the order can be filled, the remaining quantity may remain open or be canceled based on client instructions.
Market Conditions: Execution is subject to market liquidity and other factors. The company does not guarantee that the order will be executed at the specified price.

7. Modification and Cancellation

Modification: Clients may modify the trigger condition, order details, or other relevant parameters of a GTT order before it is activated.
Cancellation: Clients can cancel a GTT order at any time before it is triggered. Once activated, the order can only be canceled or modified according to standard order management procedures. In the event of corporate actions, all existing GTT orders are canceled one day before the ex-date of the corporate action and clients will be intimated on the same day.

8. Risk Disclosure

Market Risk: Clients should be aware of market risks, including price volatility and liquidity issues, which may impact the execution of GTT orders.
System Risk: There may be technical issues or system limitations that affect the activation and execution of GTT orders. The company does not guarantee that the order will be triggered and executed during market volatility.

9. Compliance and Reporting

Regulatory Compliance: GTT orders and their execution are subject to relevant regulatory requirements and compliance standards. The GTT orders are subject to certain terms and conditions which are listed on our official website www.samco.in
Reporting: Clients will receive reports and confirmations regarding the status and execution of their GTT orders as per standard practices.

7. Policy on facility of voluntary freezing/blocking the online access of the trading account

1. SCOPE AND APPLICABILITY

Samco Securities Limited, being a Trading Member providing Internet Based Trading/ Mobile Trading/ other online access for trading, is required to make available to the clients at least two modes as prescribed by the exchanges through which the client may request for voluntary freezing/ blocking the online access of trading account if any suspicious activity is observed in the trading account.

2. Mode of receipt of request for freezing/blocking the trading A/c:

Following modes shall be provided by the Company for receipt of request for freezing/blocking the clients trading A/c:
1. Client can raise voluntary freeze request through his own Back-office login under Profile section and complete 2FA authentication.
2. A dedicated land Line No.: 022-69080514 is provided to clients to place request for voluntary freezing/ blocking of the online access of the clients’ trading account.

3. Procedure to be followed on receipt of request for freezing/blocking the trading A/c.:

n receipt of request from clients through any of the prescribed modes of communications; for freezing/blocking of the online access of the trading account from the client:
1. Company shall validate that the request is received from a registered client and issue an acknowledgement for the same.
2. Company shall freeze/block the online access of the client's trading account and simultaneously cancel all the pending orders of the said client.
To validate that the request for freezing/blocking of the online access of the trading account is received from the respective client; company shall verify, whether request is received from the registered e-mail Id / mobile number of the client
3. The timelines for freezing/ blocking of the online access of the clients’ trading account is as under:

Scenario	Timelines for issuing acknowledgement as well as freezing/ blocking of the online access of the trading account
Request received during the trading hours and within 15 minutes before the start of trading	Within 15 Minutes
Request received after the trading hours and 15 minutes before the start of trading	Before the start of next trading session

4. Post freezing/blocking the client’s trading account, company shall send a communication on the registered e-mail ID of the client, stating that the online access to the trading account has been frozen/blocked and all the pending orders in the client’s trading account, if any, have been cancelled along with the process of re-enablement for getting the online access to the trading account.

5. Company shall also communicate / provide the details of open positions of client (if any) along-with contract expiry information within one hour from the freezing/blocking of the trading account.

6. Company shall maintain the appropriate records/logs including, but not limited to, request received to freeze/block the online access of trading account, confirmation given for freezing/blocking of the online access of the trading account and cancellation of pending orders, if any, sent to the clients.

4. Re-enabling the client for online access of the trading account: -

Company shall re-enable the online access of trading account after carrying out necessary due diligence including validating the client request received on support@samco.in and unfreezing / unblocking the online access of the trading account.

5. Clarification

Freezing/blocking is only for the online access to the client’s trading account, and there shall be no restrictions on the Risk Management activities of company.
The request for freezing/ blocking does not constitute request for marking client Unique Client Code (UCC) as inactive in the records of respective Exchanges.

8. PEP declaration

Kindly add a statement in terms and condition after that (point 15) “I hereby confirm that I am not a Politically Exposed Person (PEP). In the event of any change in this status, I acknowledge that it is my responsibility to promptly inform your office, and SAMCO shall bear no responsibility in such cases. Should I become a Politically Exposed Person, I will open a physical trading and demat account accordingly.”

Termination

We reserve the right, at our discretion, to immediately, with or without notice, suspend or terminate your registration on the Platform and/or your access to all or a portion of the Platform and/or remove any registration information or user content from the Platform, for any reason. Upon termination or expiration of this agreement, your obligations and Samco’s rights and disclaimers survive, but your right to use the Platform immediately ceases. Any express waiver or failure to exercise promptly any right under the agreement will not create a continuing waiver or any expectation of non-enforcement.

I agree with the terms and Conditions set out above in total and agree to abide by the same.

This agreement shall come into effect from the date it is accepted electronically by the user/client or upon you using the Platform, whichever is earlier.

Accepted Electronically by Samco and the User/Client.

Place: Mumbai