At SVS Securities Private Limited , we are committed to providing a secure and transparent trading environment for all
our clients. This surveillance policy outlines the measures we implement to monitor and prevent market abuse, ensuring
the integrity and fairness of our trading platform.
- Applicability :-
This policy has been framed under the basis of nse/surv/40148 dated 5th feb 2019, nse/surv/48818 dated 1st july 2021,
nse/surv/62827 dated 8th july 2024 & nse/surv/65921 dated 31st dec 2024 and this policy was updated & approved by the
board on bod meeting held dated 10th march 2025.
Key aspects of a surveillance policy include:-
- Monitoring client behavior:
This involves analyzing trading patterns, identifying unusual activities, and conducting client due diligence.
- Alert generation and disposition:
Stock brokers receive alerts from exchanges based on trading activity and generate their own alerts based on internal
monitoring. These alerts need to be disposed of within a specified timeframe.
- Suspicious activity reporting:
Unusual or abnormal transactions, not in line with the expected trading pattern, need to be reported.
- Internal controls and risk management:
This includes maintaining KYC systems, identifying and reporting suspicious activities,
- Compliance and reporting:
Stock brokers are required to report suspicious activities to relevant authorities, such as stock exchanges or
FIU-India.
- Policy review and updates:
The surveillance policy Is reviewed periodically, at least annually, to ensure it remains effective and in line with
market trends.
Receipt of Alerts From Exchanges :-
| Sr.No. |
Transactional Alerts |
Segment |
| 1 |
Significantly increase in client activity |
Cash |
| 2 |
Sudden trading activity in dormant account |
Cash |
| 3 |
Clients/Group of Client(s), deal in common scrips |
Cash |
| 4 |
Client(s)/Group of Client(s) is concentrated in a few illiquid scrips |
Cash |
| 5 |
Client(s)/Group of Client(s) dealing in scrip in minimum lot size |
Cash |
| 6 |
Client / Group of Client(s) Concentration in a scrip |
Cash |
| 7 |
Circular Trading |
Cash |
| 8 |
Pump and Dump |
Cash |
| 9 |
Wash Sales |
Cash & Derivatives |
| 10 |
Reversal of Trades |
Cash & Derivatives |
| 11 |
Front Running |
Cash |
| 12 |
Concentrated position in the Open Interest / High Turnover concentration |
Derivatives |
| 13 |
Order book spoofing i.e. large orders away from market |
Cash |
In-order to implement the exchange directives, they have provided us alerts which have to be generated by us. In addition
to this we have also have vendor based software for Alert Generation.
Additional alerts generated by our vendor based software at our end
- Clients having significant higher pay-in obligation compared to income declared or net worth uploaded in ucc system of the exchange.
- To check if trading terminals are not misused.
- To check trading concentration in a particular scrip by a client or a group of clients.
- Money in/money out during a period (one month) disproportionate to declared income/net worth.
- Client making net profit/losses over a period which is a significant amount as compared to their income/networth in
cash segment beyond a particular threshold.
- Repeated failure to deliver securities for pay-in obligations leading to auction/close out in illiquid items
(for reasons other than shortage of payout received in previous settlement).
- Circular trading/reversal pattern at same trading member above a threshold over a period of 1 month.
MIS
- A quarterly MIS shall be put up to the Board, on the number of alerts pending at the beginning of the quarter,
generated during the quarter, disposed off during the quarter and pending at the end of the quarter. Reasons for
pendency shall be discussed and appropriate action taken. Also, the Board, shall be apprised of any exception noticed
during the disposition of alerts.
- The surveillance process shall be conducted under overall supervision of its Compliance Officer.
- Designated directors / Compliance Officer would be responsible for all surveillance activities carried out and for the
record maintenance and reporting of such activities.
SVS SECURITIES PVT LTD WHISTLEBLOWER POLICY
At SVS SECURITIES PRIVATE LIMITED, we are committed to maintaining the highest standards of ethical conduct, integrity,
and transparency. This Whistleblower Policy provides a clear procedure for employees, agents, and other stakeholders to
report any concerns or violations related to misconduct, unethical practices, or illegal activities within the firm.
The firm encourages openness and will take appropriate action in response to such reports.
This Policy was Approved by the Board at BOD held on 10th March 2025.
The purpose of this policy is to:
- Safeguard employees and stakeholders from retaliation when reporting misconduct.
- Promote a culture of accountability and transparency.
When making a report, please provide as much detail as possible, including the nature of the concern, the individuals
involved, the date and time of the incident, and any supporting evidence (if applicable).
All reports will be treated with the utmost confidentiality. The identity of the whistleblower will be protected to
the extent possible, and the details of the report will be disclosed only to individuals directly involved in investigating
the matter.
Whistle Blower Committee Members
- Vinayak Lotankar (Redressal head / Compliance Officer)
- Sanjay Shah
- Deepak Trivedi
Kindly report the Wrongdoing at whistleblower@svs.com.
Confidentiality
The Firm will make reasonable efforts to maintain the confidentiality of individuals who report concerns, consistent
with the need to conduct a thorough investigation and comply with applicable laws.
Policy Review
This Policy will be reviewed and updated periodically to ensure its effectiveness and compliance with applicable laws and
regulations.