Risk Disclosure on Derivatives

We will store and process your information on the Sanchit Financial and Management Services Ltd. computers and in any other way. By “your information,” we mean personal and financial information we (a) obtain from you or from third parties (such as joint account holders, credit reference agencies, or other organizations when you apply for an account or any other product or services), or (b) learn from the way you use and manage your account(s), from the transactions you make, and from the payments made to your account(s).

We and other companies in Sanchit Financial and Management Services Ltd. will use your information to manage your account(s), give you statements, and provide our services, for assessment and analysis (including credit and/or behavior scoring, market and product and services—including those of others—which may be of interest to you). Other members of the Group will only send marketing material to you with your consent. If you do not want to receive information about our products and services, please visit or write to your local branch.

The information provided by you will be kept confidential. We will not disclose any such information outside of Sanchit Financial and Management Services Ltd. except:

To credit reference and fraud prevention agencies and other organizations who may record, use, and give out information to other lenders and insurers. The information may be used to make assessments for credit and all types of insurance, for debt tracing, and to prevent fraud and money laundering.

To persons acting as our agents under a strict code of confidentiality.

To anyone to whom we transfer or may transfer our rights and duties under your Customer Agreement.

As required by law or regulation. If we transfer your information to a service provider or agent in another country, we will make sure the service provider or agent agrees to apply the same levels of protection as we are required to apply to information held in India and to use your information only for the purpose of providing the service to you.

Sanchit Financial and Management Services Ltd. wishes to be at the forefront in ensuring compliance with all regulatory requirements and is committed to maintaining and promoting high ethical standards and business practices. As an effort in this direction, we have prepared this Anti-Money Laundering Policy & Procedures (“Policy”) in order to ensure compliance under the Prevention of Money Laundering Act, 2002 and to establish a common vision of our commitment to safeguard India’s values and international peace and security.

Sanchit Financial and Management Services Ltd., as an intermediary under the Prevention of Money Laundering Act, 2002 (PMLA), is required to have a system in place for identifying, monitoring, and reporting suspected money laundering or terrorist financing transactions to law enforcement authorities. The Policy is intended to establish certain guiding principles for all employees and consultants of Sanchit Financial and Management Services Ltd.

All employees subject to the provisions of this Policy must conduct themselves in a manner consistent with the requirements and procedures set forth herein. Adherence to the Policy is a fundamental condition of service with Sanchit Financial and Management Services Ltd., and the provisions of the Policy shall be deemed an intrinsic part of the terms of employment. In the event that any employee experiences any difficulties or doubts regarding the meaning or interpretation of any of the provisions of the Policy or is unsure whether a given action is consistent with the Policy or applicable laws, they should contact the Designated Officer for clarifications.

The Prevention of Money Laundering Act, 2002 (PMLA 2002), forms the core of the legal framework put in place by India to combat money laundering. PMLA 2002 and the Rules notified thereunder came into force with effect from July 1, 2005. Necessary Notifications / Rules under the Act were published in the Gazette of India on July 01, 2005. The PMLA was further amended vide notification dated March 6, 2009, and inter alia provides that violations of prohibitions on manipulative and deceptive devices, insider trading, and substantial acquisition of securities or control, as prescribed in Section 12A read with Section 24 of the SEBI Act, will now be treated as a scheduled offence under Schedule B of the PMLA.

As per the PMLA, every banking company, financial institution (including chit fund companies, co-operative banks, housing finance institutions, and NBFCs), and intermediary (including stock-brokers, sub-brokers, share transfer agents, bankers to an issue, trustees, registrars, merchant bankers, underwriters, portfolio managers, investment advisers, and any other intermediary associated with securities/commodities market and registered under section 12 of the SEBI Act) shall maintain a record of transactions of prescribed nature and value. Such transactions include:

All cash transactions of value more than ₹10 lakhs or its equivalent in foreign currency. All series of cash transactions integrally connected to each other, valued below ₹10 lakhs or its equivalent in foreign currency, taking place within one calendar month. All suspicious transactions whether or not made in cash, including credits or debits into/from any non-monetary accounts such as demat accounts or security accounts maintained by the intermediary.

Ms. Sapna Chauhan of Sanchit Financial and Management Services Ltd. shall serve as the Designated Officer responsible for overseeing the implementation of this Policy and periodically reporting on the issues covered herein to the Partners. Employees shall refer all matters concerning issues covered by this Policy to the Designated Officer and shall act in accordance with her instructions in this regard.

All submissions required to be made by employees in terms of this Policy shall be addressed to the Designated Officer. She shall be responsible for maintaining and updating all records as per this Policy or applicable laws/regulations. In addition, the Designated Officer shall maintain close liaison with enforcement agencies and other institutions involved in the fight against money laundering and the financing of terrorism. In the absence of the Compliance Officer, the Designated Director / Partner will act as the Designated Officer for the purpose of this Policy.

The objective of this policy framework is to:

Create awareness and provide clarity on KYC standards and AML measures.

Establish a proper Customer Due Diligence (CDD) process before client onboarding.

Maintain records of all integrally connected cash transactions within one calendar month.

Discourage and identify money laundering or terrorist financing activities.

Take adequate and appropriate measures to comply with the spirit of the PMLA.