Proprietary Trading Disclosure

Introduction

Agroy Finance and Investment Limited(“the Member”, “Agroy”) is a SEBI-registered stock broker (SEBI Regn No: INZ000185530) and a Depository Participant with CDSL (DP ID: 12060700). In line with the SEBI requirement for trading members to disclose their proprietary trading activity to clients (per the SEBI Master Circular for Stock Brokers (opens in new tab), consolidated May 2024), this page sets out the relevant disclosure.

Scope of proprietary trading

The Member undertakes proprietary trading on the National Stock Exchange of India Ltd (NSE) and BSE Ltd (BSE) across the cash and equity derivatives (futures & options) segments where authorised by the relevant exchange. The Member does not currently undertake proprietary trading in currency or commodity derivatives; this page will be updated if that position changes.

Segments traded

• NSE Cash Market · Member ID 06919
• NSE Futures & Options · Member ID 06919
• BSE Cash Market · Member ID 3262
• BSE Futures & Options · Member ID 3262

Conflict-of-interest management

The Member has put in place internal controls and policies to ensure that proprietary trading does not adversely affect or conflict with the interests of clients. These controls include but are not limited to:

• Segregation: Proprietary and client positions are held in separate accounts, with separate ledgers and separate fund flows.
• Information barriers: Functional separation between the proprietary trading desk and client-servicing teams (sales, advisory, dealing), supported by access controls on order-management systems.
• Independent compliance oversight by the named Compliance Officer (Ashish Kumar Gupta).
• Pre-trade and post-trade reviews to confirm client orders are not disadvantaged by concurrent proprietary orders in the same security.
• Personal trading restrictionson staff with access to client order flow, per the Member’s internal Code of Conduct.

Client priority

Where the Member receives a client order that can be matched with the Member’s own proprietary order, the client’s order is given priority in execution. The Member also undertakes that proprietary trades will not be placed in a manner that front-runs or otherwise prejudices client orders. Any breach of this commitment is reported to the Compliance Officer for investigation and to the exchange where required.

Material conflict statement

The Member hereby discloses that no material conflict of interest exists between its proprietary trading and client trading activities. The controls described above are reviewed periodically by the Compliance Officer and the Member’s internal audit function. Material changes, including the introduction of new segments or the cessation of proprietary trading in any existing segment, will be communicated through this page and the Agroy Finance and Investment Limited website.

For any clarification regarding this disclosure, please write to compliance@agroy.com.