VOLUNTARY FREEZING/BLOCKING
OF THE ONLINE TRADING
      ACCOUNT POLICY
           Version 1.1
Zerodha Broking Limited
           Document Control
           Information:
            Document                                    Classification          Version        Status
            Voluntary Freezing/Blocking Of The          Public                  1.1            Approved
            Online Trading Account Policy
           Version History, Verification and Approval:
             Date                      Version    Description       Owner                    Approved By
                                                  of Change
            August 1, 2022 (Date of 1.0           1st Policy         Shankar Naraya…         Venu Madhav
            preparation)                          prepared
            August 1, 2022             1.0        1st Policy         Shankar Naraya…         Venu Madhav
            (Policy adoption)                     Adopted
            August 1, 2023             1.0         No changes        Shankar Naraya…         Venu Madhav
            (Review)
            June 1, 2024               1.1         Updates           Shankar Naraya…         Venu Madhav
            (Review)
           Distribution List:
                Sl. No.          Departments Involved
                1                Risk Management Team
                2                DP Team
                3                Legal Team
                4                Support Team
                5                Escalation Team
                6                Technology Team
                7                Process Team
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888                 2
Zerodha Broking Limited
           Table of Contents
           Document Control.................................................................................................................. 2
               Information:........................................................................................................................ 2
               Version History, Verification and Approval:.........................................................................2
               Distribution List:..................................................................................................................2
           Table of Contents................................................................................................................... 3
           1. Introduction........................................................................................................................ 4
           2. Purpose............................................................................................................................... 4
           3. Scope and Applicability.....................................................................................................5
           4. Periodic Review..................................................................................................................5
           3. Procedure to Freeze/Block the Online Trading Account................................................ 5
               3.1 Timelines...................................................................................................................... 5
               3.2 Mediums.......................................................................................................................6
               3.3 Verification (Mandatory)............................................................................................... 6
               3.4 Basic Checks & Initial Steps (Mandatory).................................................................... 7
           4. Procedure to Unfreeze/Unblock the Online Trading Account........................................8
           5. Clarifications...................................................................................................................... 8
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888                                                               3
Zerodha Broking Limited
           1. Introduction
           This policy (v 1.1) has been revised as per the SEBI Circular no.
           SEBI/HO/MIRSD/POD-1/P/CIR/2024/4 dated January 12, 2024 and Exchange
           Circular no. NSE/INSP/60277 dated January 16, 2024 on the subject “Ease of
           Doing Investments by Investors - Facility of voluntary freezing/ blocking of
           Trading Accounts by Clients”.
           Accordingly, this document has been derived from the framework presented by
           the exchange in response to the aforementioned circulars, via the Exchange
           Circular no.: NSE/INSP/61529 dated April 08, 2024 on the subject: “Framework
           for Trading Members to provide the facility of voluntary freezing/blocking the
           online access of the trading account to their clients”.
           This document is a handbook for the clientele of Zerodha Broking Limited
           (hereinafter referred to as Zerodha), outlining the process and mode(s) through
           which they can request to freeze / block & unfreeze/unblock their trading
           account. Other details, such as the timelines, clients’ onuses, etc., to facilitate
           the same are also mentioned.
           2. Purpose
           The procedures outlined herein are per regulatory requirements in the
           aforementioned circulars. All clients are requested to note that the forthcoming
           guidelines are issued to facilitate the freezing/blocking of their respective
           online trading accounts upon explicit requests from the client’s end in case they
           notice any suspicious activity on their trading accounts.
           A few instances of suspicious activities would include:
               ● Fresh positions being taken without the client’s knowledge or action.
               ● Holdings being sold without the client’s knowledge or action.
               ● A client is unable to access his/her account.
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888              4
Zerodha Broking Limited
               ● A client notices a change in their linked bank account/ email/ mobile
                   number without them having placed a request.
               ● A share transfer via gift/ easiest is initiated without the client’s
                   knowledge or action.
           3. Scope and Applicability
           The policy statements written in this document apply to all of Zerodha’s
           resources at all levels of sensitivity; including:
               ● All the clients of Zerodha.
               ● All employees who are part of the relevant teams at Zerodha.
           4. Periodic Review
           This document essentially helps curb clients' risk and hence forms an integral part
           of Zerodha’s internal Risk Management Policy. As such, it shall be reviewed every
           year unless an earlier review is necessary to ensure that the policy remains
           updated as per regulatory changes. Changes to this policy shall be exclusively
           performed by the document owner and approved by Management. A change log
           shall be kept current and updated as soon as any change has been made.
           3. Procedure to Freeze/Block the Online Trading Account
           3.1 Timelines
           In line with regulatory requirements, upon the explicit request from a client to
           block the online access to their trading account through any of the modes
           mentioned in the forthcoming sections, all efforts will be taken by Zerodha
           Personnel to fulfill the request as per the below timelines:
               a. For requests received within trading hours, all efforts shall be taken to
                   block the account within 15 min.
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888              5
Zerodha Broking Limited
               b. For requests received after trading hours up until 15 minutes before the
                   market opening time, all efforts will be taken to block the account before
                   the start of the next trading session.
           3.2 Mediums
           Clients can report suspicious activities on their trading account via the
           following mediums:
               a. By mailing on the dedicated email ID: stoptrade@zerodha.com
               b. By raising tickets via Zerodha’s official Support Portal.
               c. By calling the dedicated number: +91-8046801166 (between 8:30 am
                   and 5:00 pm)
           3.3 Verification (Mandatory)
               ● Requests raised on calls
                      ○ Clients should call the dedicated number, +91- 8046801166, from
                          their registered phone numbers (number registered with Zerodha).
                      ○ Please note that stringent identity verification will be conducted
                          before considering any client’s block requests. Hence, all clients
                          are requested to keep all basic Personal Identification Information
                          (PII) handy to facilitate the smooth and fast processing of
                          requests. It is also recommended that clients keep their support
                          code memorized/handy, as this would serve as additional
                          two-factor authentication.
               ● Requests raised via the Support Portal or dedicated Email
                      ○ Clients are recommended to mail from their registered email
                          address (email ID registered with Zerodha).
                      ○ Clients are requested to give relevant and detailed information
                          regarding the suspicious activity they have noticed on their trading
                          accounts.
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888              6
Zerodha Broking Limited
                      ○ Clients who have raised block requests via tickets or by mail shall
                          receive a call back promptly from Zerodha personnel. Hence, they
                          are advised to answer the call without fail.
           3.4 Basic Checks & Initial Steps (Mandatory)
           Zerodha personnel would ask a series of questions (basic checks) to
           understand the gravity of any request received. These queries would relate to
           the existing positions in the client’s account, inadvertent sharing of login
           credentials, OTPs, orders, devices used for trading, etc.
           Clients are requested to kindly cooperate with the Zerodha personnel and
           furnish all the information required, as this is essential for assessing the
           situation of the trading accounts.
           Zerodha's authorized personnel shall communicate to the client the details of
           the client's existing open positions. Subsequently, the personnel will solicit
           input from the client regarding their preferred course of action for these
           positions. Upon the client's directive and subject to successful authentication
           of the client, Zerodha will proceed to close the client's open positions and
           cancel all open orders. In such instances, applicable call and trade charges will
           be imposed.
           Clients are requested to make an informed decision based on these
           suggestions and communicate their decisions clearly and unequivocally so that
           the Zerodha personnel can proceed with the blocking/freezing of their trading
           accounts.
           Following the basic checks, a ticket would be created (if not already raised)
           against the client’s request and all responses would be made note of. Clients
           would receive all further updates on their requests via the ticket thus created.
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888              7
Zerodha Broking Limited
           4. Procedure to Unfreeze/Unblock the Online Trading Account
               ● Clients can unfreeze/unblock their online trading accounts by raising a
                   request via any of the modes prescribed under section 3.2.
               ● Please note that the client must mandatorily complete the Re-KYC
                   procedure successfully to have their trading account
                   unfrozen/unblocked.
               ● Following the successful completion of the Re-KYC procedure and after
                   carrying out any other necessary due diligence, the client shall be
                   intimated via ticket/mail regarding the status of their request.
           5. Clarifications
           It is clarified that:
               a. Freezing/blocking is only for online access to the client’s trading account,
                   and there shall be no restrictions on the Risk Management activities of
                   Zerodha.
               b. The request for freezing/blocking does not constitute a request for
                   marking the client's Unique Client Code (UCC) as inactive in the
                   Exchange records.
                 --------------------------------- End of Document ----------------------------------
                                           CIN: U655929KA2018PLC116815
       Registered Office: 153/154,4 th Cross, Dollars Colony, JP Nagar 4 th Phase, Bangalore - 560078
       Website: zerodha.com     Email id: audit@zerodha.com        Phone no: 080-4718-1888              8