Policies and Procedures

This document describes the significant policies and procedures of StellarEdge Brokers Private Limited ('StellarEdge') as required under SEBI's uniform documentation framework (SEBI circular CIR/MIRSD/16/2011 and subsequent circulars).

1. Refusal of Orders for Penny Stocks / Illiquid Securities

StellarEdge reserves the right to refuse to execute orders in penny stocks, illiquid securities, or securities placed under enhanced surveillance measures by the Exchange, based on its risk management policy and the Exchange's list of illiquid securities, which is updated periodically by NSE and BSE.

2. Setting Up Client's Exposure Limits

Exposure limits for each client are determined as a multiple of the margin/collateral deposited by the client with StellarEdge, subject at all times to the limits prescribed by the relevant Stock Exchange and SEBI for the segment(s) in which the client trades. The applicable multiple may vary by client risk profile, segment, and prevailing market volatility, and may be revised by StellarEdge at its discretion, with or without prior notice, in line with Exchange-mandated risk management requirements.

3. Applicable Brokerage Rate

Brokerage is charged as follows, in accordance with StellarEdge's published Tariff Sheet:

• Equity Delivery: ₹0 (zero brokerage)
• Equity Intraday: ₹20 per executed order, or 0.03% of trade value, whichever is lower
• Futures (F&O): ₹20 per executed order, or 0.03% of trade value, whichever is lower
• Options (F&O): ₹20 per executed order (flat)

These rates are subject to the maximum permissible limits under the Rules, Regulations and Bye-laws of the relevant Stock Exchanges and SEBI. Any revision to brokerage rates will be reflected in an updated Tariff Sheet, published on StellarEdge's website with appropriate notice to clients.

4. Imposition of Penalty / Delayed Payment Charges

In the event of delayed payment by the client, StellarEdge shall levy delayed payment charges at the rate of 18% per annum (equivalent to 0.05% per day) on the outstanding amount, calculated for the period of delay. Such charges shall not, in any manner, result in a funding arrangement between StellarEdge and the client, in compliance with SEBI norms prohibiting brokers from financing client positions through delayed payment structures.

5. Right to Sell Client's Securities or Close Out Positions

StellarEdge shall have the right to sell client's securities, both collateral and securities bought, or close out client's open positions, without giving prior notice to the client, on account of non-payment of the client's dues. This right is limited to the extent of the settlement/margin obligation outstanding from the client, and shall be exercised in accordance with StellarEdge's risk management policy.

6. Internal Shortage Handling

In the event of an internal shortage of securities (i.e., where StellarEdge's net delivery obligation across clients results in a shortfall not attributable to the Exchange), StellarEdge shall follow the internal auction/close-out mechanism prescribed by SEBI and the relevant Exchange. The shortfall shall be resolved through valuation at the highest price recorded on the Exchange from the date of trading till the date of auction/close-out, or as otherwise prescribed by Exchange guidelines, ensuring that the affected client whose securities were short-delivered is compensated fairly and within the timelines prescribed by the Exchange. A detailed internal auction policy document, consistent with this principle, shall be maintained and made available to clients on request.

7. Conditions for Restricting Further Positions or Closing Existing Positions

StellarEdge may, at its discretion, restrict a client from taking further positions, or may close out existing positions, under circumstances including but not limited to: breach of exposure limits as set out in Section 2; non-payment of margin or dues within stipulated timelines; adverse market volatility affecting the client's outstanding obligations; regulatory directions from SEBI/Exchange; or where StellarEdge has reasonable grounds to believe the client's trading activity poses undue risk to StellarEdge or the market.

8. Temporary Suspension or Closure of Client Accounts

A client may request temporary suspension or closure of their trading account in writing. StellarEdge shall process such requests within a reasonable timeframe, subject to settlement of all outstanding obligations, funds and securities. StellarEdge may also suspend or close an account at its discretion in cases of regulatory non-compliance, prolonged inactivity (see Section 10), or suspected fraudulent activity, with appropriate notice to the client except where immediate action is warranted by regulatory or risk considerations.

9. Deregistering a Client

StellarEdge reserves the right to deregister a client in circumstances including persistent non-compliance with KYC/regulatory requirements, fraudulent activity, repeated default in payment obligations, or at the client's own written request. Deregistration shall be carried out in accordance with SEBI and Exchange guidelines, with all dues settled and client funds/securities returned in accordance with applicable timelines.

10. Inactive Account Policy

An account with no trading activity for a continuous period of 12 (twelve) months shall be classified as inactive. Funds and securities in inactive accounts shall continue to be held in segregated client accounts and handled in accordance with SEBI's settlement norms for inactive/dormant accounts. Reactivation shall require the client to complete any updated KYC or regulatory requirements applicable at the time of reactivation.

11. Treatment of Client Collateral

Client collateral (funds and securities) shall be maintained in segregated accounts distinct from StellarEdge's proprietary accounts, and shall not be used for any purpose other than meeting the respective client's margin requirements and pay-in obligations, in accordance with SEBI's circular on client collateral and subsequent norms on margin pledge in the depository system effective September 1, 2020. StellarEdge shall maintain a complete audit trail of collateral receipt, utilisation, and return.