I/we undertake that:

• as per latest audited financial statements our Net Worth is 162 millions.
• Brokerage House has its own website and following information is displayed:
  • Agreement with the Broker;
  • How trading limits are assigned;
  • Steps for Placement and execution of the clients’ order;
  • Mode and timing of reporting of trade confirmation;
  • Margin requirement (Initial, maintenance and other applicable margins) and margin calls.
  • I/We shall disclose to its clients availing IBTS the Service Level Agreements and the infrastructure provided by the third-party vendor, if any.
  • Our Website contains following information in plain English and Urdu Language and in an easily accessible form:
    • A basic explanation of securities trading; including definitions of common terms used on the trading screen;
    • A general statement and information regarding the manner, in which orders are accepted, processed, settled and cleared via the internet;
    • Disclosure of various risks of securities trading, including the risk of systems outages and, failures and any alternative means of placing orders;
    • Procedures to cancel pending orders during a system failure;
    • Rules and regulations affecting inter-alia client broker relationship, arbitration procedures and any other useful information from the perspective of Investor protection;
    • Hyperlink to the websites/page on the websites of the Exchange and the Commission displaying relevant rules, regulations, guidelines of the Exchange and Commission, information regarding the rights and obligations of the Investors and the Broker; Investor’s guidelines issued by the Exchange and the Commission, relevant legal. provisions for Investor protection and the complaint handling and arbitration procedures etc.;
    • Hyperlink to the websites/page on the websites showing information relating to UIS Services of NCCPL and SMS, IVR and Investor Account services of CDC.
    • I/We ensure that the ticker/quote/order book displayed on its website displays the time stamp as well as the source of information against any given information.
• Appropriate human and technological resources are available to facilitate the IBTS operations.
• Internal control and procedures are intact for IBTS operations.
• Completion certificate is attached.
• Agreement with the Client will be executed before offering Internet Trading to him/her.
• I/We shall keep in record for the period of at-least five years all Internet Trading information relating to client orders and communications with the clients along with proper security measures to prevent such as record from any potential misuse.

I/We ensure that:

• Satisfactory arrangements are in place so that it can at all times uniquely identify each and every order during the different stages of processing.
• Orders placed through its systems are fairly allocated in accordance with the rules/regulations/procedures of the Exchange.
• Effective audit trail is maintained to address risks arising from:
  • The opening, modification or closing of a client account;
  • any transaction with significant financial consequences;
  • any authorization granted to a client to exceed a limit;
  • any granting, modification or revocation of systems access rights or privileges.
• Adequate risk management systems are in place for controlling product-wise trading limits and exposure of clients of clients availing Internet Trading. The system is capable of monitoring trading activities of such clients in leverage and derivative products offered through Internet Trading.
• Internet trading system is capable of assessing the risk of the client on real-time basis at order entry level. The client shall be informed of acceptance/rejection of the order instantaneously. In case an order is rejected due to the system based controls because of client having exceeded limits etc., the system may allow a review and release facility for enabling the order to pass through.
• User manual containing complete system and interfaces documentation is available on our website.
• System based reports on margin requirements, payment and delivery obligations etc. are disseminated to the client in a timely manner.
• Any error or omission in the system shall not indemnify us from the responsibility of settling any trade.

I/We further ensure that:

• The internet trading system is in compliance with the information security policy of the Exchange and the service provider/Broker.
• The encryption technology applies for all client orders entered into the system and for all other confidential information the system is capable to uniquely identify each client of the Broker. For this purpose, appropriate technical and administrative controls are also implemented to protect the clients against identify theft and related compromises.
• Firewalls are in place to prevent intrusions by unauthorized persons. The firewall policy is adequately defined, maintained and reviewed periodically.
• The system is configurable to allow auto-logoff in case of inactivity of the trading terminal and/or the trading website.
• Implementation of first and second level passwords and PIN requirement at order placement level are implemented.
• Functionality of automatic expiry of passwords at the end of a reasonable duration and re-initialization of access on entering fresh passwords are implemented.
• All transaction logs with proper audit facilities are maintained in the system.
• Appropriate technical controls are in place against:
  • Presentation of incorrect data, intentionally or malevolently;
  • False presentation or the use of incomplete information for transactions;
  • Manipulation of any data;
  • Viruses/Malware, leading to any loss of data, unauthorized access to data, or threat of unavailability of systems;
  • Cyber extortion (distributed denial of services/distributed agent-based attacks).
• Service is available in the following events:
  • Website is not accessible thereby barring trading, receiving or providing information;
  • Particular section(s) of the website are not accessible due to either denial of service or lack of capacity or inability of the service providers to provide timely access to website;
  • (b) Satisfactory alternative arrangements and contingency plans are in place to make sure that IBTS can continue in the event of a large-scale disruption (Disaster Recovery Planning/Business Continuity Planning).
  • (c) Appropriate arrangements are in place where disruption of service is witnessed on the part of vendor.
  • (d) Information regarding any disruption in the online trading services either on part of the Broker or the third-party vendor, is immediately disclosed on its website and to, its clients.
• I/we ensure that the Internet Trading systems for routing client orders shall not be allowed to cross trade its clients’ orders with each other. All orders must be offered to the market for matching.
• As per PSX Internet based Trading (IBTS) regulations, clause 9.12.1., I/We shall ensure that our IBTS systems, controls and procedures are audited and penetration tested independently, once in every two years, by an audit firm approved by the Exchange.
• I/We also undertake that my/our company has met all the minimum eligibility criteria set forth in PSX Internet Based Trading Regulation for commencement of Internet based trading services in our Company and I/We have read the PSX Internet Based Trading Regulations (Chapter 9 of the PSX Rule Book) and agree to comply with all the clauses/requirements mentioned thereof.