Pawan Parmeshwar Capital Private Limited

Insights

Publications & disclosures

Research notes, market updates and the documents we are required to publish. Every file is a PDF you can download and keep.

All publications

26 documents available.

Order Acceptance Policy (PDF, 504 KB)

This Policy sets out the framework for order acceptance, verification, documentation and audit trail, and operates in conjunction with the Mobile Phone Usage Policy (Version 1.0), the Employee Trading Restriction Policy (Version 2.0) and the Risk Management & Surveillance Policy (Version 2.0).

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Internal Control Policy (PDF, 524 KB)

This Policy reflects the Institutional Mechanism requirement under Chapter IVA (Regulations 18E to 18I) of the SEBI (Stock Brokers) Regulations, 1992 (inserted by Notification SEBI/LAD-NRO/GN/2024/186 dated June 27, 2024 in force June 28, 2024) and the SEBI Master Circular for Stock Brokers SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/90 dated June 17, 2025.

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Investor Charter (PDF, 647 KB)

The Charter is framed in accordance with SEBI Circular SEBI/HO/MIRSD/MIRSD_CRADT/CIR/P/2021/685 dated December 17, 2021 on "Publishing Investor Charter and disclosure of complaints by stock brokers on their websites". It is intended to inform investors of the services provided by the Company, the rights of investors, expected timelines for various activities, the grievance redressal mechanism, and the dos and don'ts for investors transacting in the securities market.

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Settlement Running Account Policy (PDF, 676 KB)

Funds and securities of clients lying with the Company in the ordinary course of business are required to be periodically settled — i.e., returned to the client's registered bank account and demat account — in accordance with the framework prescribed by SEBI. This Settlement of Running Account Policy ("Policy") sets out the procedure that the Company shall follow for settlement, the basis on which settlement amounts are computed, the manner in which the client's election of frequency is taken and operated, and the related communication and recordkeeping framework.

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Code of Conduct Policy (PDF, 679 KB)

As a SEBI-registered intermediary, the Company is required to observe the Code of Conduct set out in Schedule II of the SEBI (Stock Brokers) Regulations, 1992 (the "SBR"), and the broader regulatory framework governing the conduct of stock brokers and their personnel. This Code of Conduct Policy ("Code") consolidates the Company's commitments to ethical conduct, fair dealing, regulatory compliance and the protection of investors and the integrity of the securities markets.

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Business Continuity Plan & Disaster Recovery Framework (PDF, 799 KB)

The Company's ability to execute client orders, settle trades, safeguard client funds and securities, and discharge regulatory reporting obligations is critically dependent on continuous availability of its information systems, premises, connectivity, personnel and Service Providers.

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Mobile Phone Usage Policy (PDF, 600 KB)

The Policy is essential to the Company's compliance with multiple SEBI regulatory requirements concerning: (i) recording of client orders received through telephonic channels; (ii) prevention of circulation of unauthenticated news; (iii) confidentiality of Unpublished Price Sensitive Information (UPSI); (iv) prevention of front-running; (v) cyber security and protection of confidential client data; and (vi) maintenance of an auditable trail of all client communications.

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IT Data Privacy DPDP Policy (PDF, 847 KB)

This Information Technology and Data Privacy (DPDP) Policy ("Policy") sets out the framework within which the Company processes personal data and discharges its obligations as a Data Fiduciary, in compliance with:

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Employee Trading Restriction Policy (PDF, 578 KB)

This Employee Trading Restriction Policy (the "Policy") regulates Personal Account Dealing (PAD) by all Covered Persons to prevent: (a) trading while in possession of UPSI; (b) front-running of client orders; (c) misuse of information learned in the course of employment; and (d) conflicts of interest between the Covered Person and the Company or its clients.

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Unexecuted Orders Policy (PDF, 618 KB)

In the ordinary course of business, certain client orders may not be executed in part or in whole on the date of receipt due to reasons such as the order being a limit order beyond the prevailing market price, partial execution due to liquidity constraints, the order being a stop-loss order that is not triggered, the order being placed after exchange close, system interruptions, or other reasons. This policy lays down the framework for the treatment, communication, cancellation and recordkeeping of such Unexecuted Orders.

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Cyber Security Policy (PDF, 861 KB)

The Policy is framed for compliance with the CSCRF, the SEBI Master Circular for Stock Brokers SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/90 dated June 17, 2025, the Information Technology Act, 2000 and rules thereunder, the CERT-In Directions dated April 28, 2022 (including the 6-hour incident reporting requirement), the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the bye-laws and circulars of the Stock Exchanges and Clearing Corporations, and other applicable Indian law.

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PEP Policy (PDF, 541 KB)

This Policy is a focused, dedicated framework for PEPs and forms part of the Company's AML/PMLA framework. It supplements the AML/PMLA Policy (Version 2.0) without duplicating the broader framework set out therein.

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Insider Trading Policy (PDF, 864 KB)

As a SEBI-registered market intermediary, the Company is required, under Regulation 9(1) read with Schedule C of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (the "PIT Regulations"), to formulate a Code of Conduct to regulate, monitor and report trading by its Designated Persons and their immediate relatives in the securities of listed companies whose Unpublished Price Sensitive Information (UPSI) it handles in the course of its business operations.

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Risk Management Surveillance & Grant of Exposure to Client Policy (PDF, 577 KB)

This Risk Management and Surveillance Policy establishes the Company's framework for the identification, measurement, monitoring, mitigation and reporting of these risks, and incorporates the surveillance obligations of the Company as a market intermediary under SEBI's framework, the SEBI (Stock Brokers) Regulations, 1992, the SEBI Master Circular for Stock Brokers dated June 17, 2025, the SEBI Master Circular on Surveillance dated September 23, 2024, and the regulations and circulars issued by NSE, BSE, NSCCL and ICCL from time to time.

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Inactive Dormant Accounts Policy (PDF, 648 KB)

This policy lays down the framework for the identification, treatment, settlement and reactivation of client accounts that have remained inactive or dormant for a continuous period. The policy is framed for compliance with the SEBI Master Circular for Stock Brokers SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/90 dated June 17, 2025, the SEBI (Stock Brokers) Regulations, 1992 (as amended), and the bye-laws and circulars of NSE and BSE.

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Pre Funded Instrument Policy (PDF, 598 KB)

The acceptance of pre-funded instruments such as demand drafts (DDs), pay orders (POs), banker's cheques and similar instruments from clients in lieu of payments from the client's own bank account is regulated by SEBI to ensure that the trail of funds remains transparent and to prevent the use of stock broking accounts for money laundering.

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Unauthentic News Policy (PDF, 704 KB)

SEBI Circular Cir/ISD/1/2011 dated March 23, 2011 (consolidated in Para 2.3 of the SEBI Master Circular on Surveillance of Securities Market dated September 23, 2024) requires every SEBI-registered market intermediary to adopt and implement an internal code of conduct to prevent the circulation of unauthenticated news. Para 2.3.5 of the said Master Circular makes it clear that both the employee involved in such circulation and the Compliance Officer of the intermediary shall be liable for action where the framework is not implemented in accordance with the said circular.

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AML PMLA Policy (PDF, 542 KB)

This Policy establishes the Company's framework for AML/CFT compliance and is framed in accordance with the Prevention of Money Laundering Act, 2002 ("PMLA") and the rules made thereunder, and the SEBI Master Circular on Guidelines on Anti-Money Laundering Standards and Combating the Financing of Terrorism / Obligations of Securities Market Intermediaries under the PMLA, 2002 SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78 dated June 6, 2024 ("SEBI AML Master Circular") and subsequent SEBI circulars on the subject.

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SORM Policy (PDF, 681 KB)

The Stock Exchanges and SEBI have, from time to time, mandated that Trading Members (referred to as "Members" in this policy) implement an internal surveillance framework to monitor client trading patterns, identify suspicious or unusual activity, and report such activity to the Exchanges where required. The Member's responsibilities in this regard are collectively referred to as "Surveillance Obligations of Members" (SORM).

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Outsourcing Policy (PDF, 796 KB)

This Outsourcing Policy is framed to govern the outsourcing arrangements entered into by the Company in compliance with SEBI Circular CIR/MIRSD/24/2011 dated December 15, 2011 on "Guidelines on Outsourcing of Activities by Intermediaries" (the "Outsourcing Circular"), the SEBI Master Circular for Stock Brokers dated June 17, 2025, the SEBI (Stock Brokers) Regulations, 1992 (as amended), and applicable bye-laws, rules and regulations of the Stock Exchanges and Clearing Corporations.

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Conflicts of Interest Policy (PDF, 703 KB)

As a SEBI-registered intermediary, the Company is bound by the general obligations relating to conflicts of interest applicable to all intermediaries under SEBI Circular CIR/MIRSD/5/2013 dated August 27, 2013, the Code of Conduct prescribed under Schedule II to the SEBI (Stock Brokers) Regulations, 1992, and the Institutional Mechanism for Prevention and Detection of Fraud or Market Abuse introduced by Chapter IVA of the SEBI (Stock Brokers) Regulations, 1992 (vide the SEBI (Stock Brokers) (Amendment) Regulations, 2024).

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KYC Policy (PDF, 725 KB)

This Know Your Client (KYC) Policy lays down the framework within which the Company shall identify, verify, document, periodically review, and maintain KYC records of its clients. It is framed for compliance with the SEBI Master Circular on Know Your Client (KYC) requirements SEBI/HO/MIRSD/SECFATF/P/CIR/2023/0144 dated October 12, 2023, the SEBI Master Circular for Stock Brokers SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/90 dated June 17, 2025, the SEBI AML Master Circular dated June 6, 2024, the Prevention of Money Laundering Act, 2002 and the Prevention of Money-laundering (Maintenance of Records) Rules, 2005 (as amended) ("PML Rules"), the SEBI (KYC (Know Your Client) Registration Agency) Regulations, 2011, and the bye-laws and circulars of NSE and BSE.

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Complaint Redressal Policy (PDF, 551 KB)

As a SEBI-registered intermediary, the Company is required to maintain a robust mechanism for receiving, investigating and resolving client complaints and to provide its clients with the avenues of escalation prescribed by SEBI and the Stock Exchanges.

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Investor advisory: beware of fraudulent groups using our name

Unauthorised WhatsApp and social media groups are being created using the names and logos of SEBI-registered intermediaries, including firms in our line of business.

If you have already made a payment

Contact your bank immediately to attempt to stop or recover the payment, and file a complaint with the police without delay. Further guidance is available at the National Cyber Crime Reporting Portal.

For verified information, use this website and the contact details published on it. Our grievance channel is on the grievance redressal page.