Order in respect of M/s Unique Consulting and Trading Private Limited and its Directors Mr P. Shanmuga Ganesan, Mr. K. Mathan Kumar, Ms U. Indira and Ms. Janet Jenetha

WTM/SR / SEBI/EFD-DRA2/47/08/2017 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA S. RAMAN, WHOLE TIME MEMBER ORDER Under Section 11(1) and 11B of the Securities and Exchange Board of India Act, 1992 in respect of M/s Unique Consulting & Trading Private Limited (PAN: AABCU3526H) (SEBI Registration No. INB0414522138 and INF041452138) and its Directors Mr P. Shanmuga Ganesan (PAN: BDAPS0331N) Mr. K. Mathan Kumar (PAN: AQRPM0642B), Ms U. Indira (PAN: AAUPI9812N) and Ms. Janet Jenetha (PAN: AOVPJ2773C).

1. M/s Unique Consulting & Trading Private Limited (“Unique Consulting”) was registered with Securities and Exchange Board of India as a stock broker having SEBI Registration Nos. INB 041452138 and INF041452138 for Cash and F&O Segments respectively. Unique Consulting was a member of erstwhile Madras Stock Exchange Limited (“MSE”). The Directors of Unique Consulting are Mr P. Shanmuga Ganesan (Promoter/Managing Director) Mr. K. Mathan Kumar (Promoter/Director), Ms U. Indira and Ms. Janet Jenetha.

2. Securities and Exchange Board of India(‘SEBI”) observed the following during an inspection of MSE in the year 2014: i. MSE received several complaints against M/s Unique Consulting and its Managing Director, Mr. P. Shanmuga Ganesan from some of its clients and other general investors alleging, inter alia, collection of deposits from them on the promise of assured returns, non-delivery of securities, non-pay out of funds for the concluded transactions. ii. The complainants also alleged that Mr. P. Shanmuga Ganesan had been absconding. iii. Pursuant to these complaints against Unique Consulting, MSE deactivated the trading terminal of Unique Consulting and blocked the Demat Client Beneficiary account of Unique Consulting maintained with MSE. iv. MSE undertook inquiry into the complaints and also undertook physical verification of the office of Unique Consulting. Pursuant to these, MSE suspended Unique

Consulting from trading, and issued a public notice to this effect to caution the general public not to deal with it.

3. Subsequently, upon preliminary inquiry by SEBI, it was observed that Unique Consulting by misusing the certificate of registration granted as a Stock broker, solicited and collected money from its clients and members of public and also offered portfolio management and advisory services without obtaining the certificate of registration from SEBI. It was also observed that Unique Consulting indulged in fund based activities involving personal financial liability by virtue of collection of money from clients and general public in a fraudulent and deceitful manner by misrepresentation.

4. As the aforesaid activities of Unique Consulting were prima facie in violation of provisions of SEBI Act, 1992 ("SEBI Act"), Securities Contracts (Regulation) Rules, 1957 ("SCRR"), the SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992 ("Brokers Regulations"), the SEBI (Portfolio Managers) Regulations, 1993 (“PMS Regulations”) and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (“PFUTP Regulations”), SEBI passed an ad interim ex-parte order dated April 21, 2014 with the following directions: i. “restrain Unique Consulting (SEBI Stock Broker Registration No. INB041452138, and INF041452138) and its promoters/directors from accessing the securities market and further prohibit them from buying, selling or otherwise dealing in securities, directly or indirectly, or being associated with the securities market in any manner; ii. direct Unique Consulting and its promoters/directors to cease and desist from undertaking the portfolio management activities or any unregistered activity in the securities market, directly or indirectly, in any manner whatsoever; iii. direct Unique Consulting and its promoter/directors to immediately withdraw and remove all advertisements, representations, literatures, brochures, materials, publications, documents, websites, etc. in relation to the portfolio management activities or any unregistered activity in the securities market; iv. prohibit Unique Consulting and its promoters/directors from mobilizing funds from its clients or other general investors or offering any portfolio management activities, in whatever form.”

5. The said ex-parte order cum show cause notice provided that Unique Consulting and its Directors may file their objections, if any, within twenty one (21) days from the date of receipt of the said interim order. The order further provided that they may avail an opportunity of personal hearing before SEBI on a date and time to be fixed on a specific request in writing.

6. Vide separate letters dated April 22, 2014, the ex-parte order cum show cause notice was sent to Unique Consulting and its Directors. The ex-parte order cum show cause notice was served to Unique Consulting and its Directors through MSE. Thereafter, an opportunity of personal hearing before me was granted to Unique Consulting and its Directors on June 15, 2017. The hearing notice in the matter was served through publication in the newspapers viz., ‘The New Indian Express’ (English daily) and ‘Dinakaran’ (Tamil daily) Tirunelveli Edition Tamil Nadu, being the last known address of the entities. Despite the same, neither Unique Consulting/its directors nor its authorized representative attended the personal hearing. The Noticee has also not filed any reply/written submissions till date.

7. Considering that no communication has been received from Unique Consulting and its Directors and also considering the fact that they failed to avail the opportunity of personal hearing, I am of the view that Unique Consulting and its Directors are deliberately avoiding the communication from SEBI. In view of the same, I am constrained to proceed in the matter on the basis of the material available on record.

8. The issues that arise for consideration in the present case is whether Unique Consulting and its Directors violated Section 12(1) of the SEBI Act, read with Regulation 3 of Portfolio Regulations, Rule 8 (3) (f) of the SCRR, Clause (5) of Code of Conduct prescribed for Stock Brokers in Schedule II read with Regulation 9 of the Brokers Regulations read with Section 12 A (a) (b) and (c) of the SEBI Act and Regulation 3 (b), (c) and (d) and Regulation 4 (1) and 4 (2) (k) of the PFUTP Regulations.

9. Before dealing with the charges levelled against Unique Consulting and its Directors, the relevant legal provisions, the contravention of which have been alleged in the instant case are reproduced hereunder:- SCRR "8. The rules relating to admission of members of a stock exchange seeking recognition shall inter alia provide that : (3) No person who is a member at the time of application for recognition or subsequently admitted as a member shall continue as such if ...

(f) he engages either as principal or employee in any business other than that of securities or commodity derivatives except as a broker or agent not involving any personal financial liability, provided that— (i) the governing body may, for reasons, to be recorded in writing, permit a member to engage himself as principal or employee in any such business, if the member in question ceases to carry on business on the stock exchange either as an individual or as a partner in a firm, (ii) in the case of those members who were under the rules in force at the time of such application permitted to engage in any such business and were actually so engaged on the date of such application, a period of three years from the date of the grant of recognition shall be allowed for severing their connection with any such business, (iii) nothing herein shall affect members of a recognised stock exchange which are corporations, bodies corporate, companies or institutions referred to in items (a) to (k) of the proviso to sub-rule (4)." SEBI Act Registration of stock brokers, sub-brokers, share transfer agents, etc. "12.

(1) No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who may be associated with securities market shall buy, sell or deal in securities except under, and in accordance with, the conditions of a certificate of registration obtained from the Board in accordance with the regulations made under this Act: Provided that a person buying or selling securities or otherwise dealing with the securities market as a stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who may be associated with securities market immediately before the establishment of the Board for which no registration certificate was necessary prior to such establishment, may continue to do so for a period of three months from such establishment or, if he has made an application for such registration within the said period of three months, till the disposal of such application: Provided further that any certificate of registration, obtained immediately before the commencement of the Securities Laws (Amendment) Act, 1995, shall be deemed to have been obtained from the Board in accordance with the regulations providing for such registration."

SEBI (Portfolio Managers) Regulations, 1993 REGISTRATION OF PORTFOLIO MANAGERS "3. Registration as portfolio manager. ─ No person shall act as portfolio manager unless he holds a certificate granted by the Board under these regulations: Provided that a merchant banker acting as a portfolio manager immediately before commencement of the Securities and Exchange Board of India (Portfolio Managers) (Second Amendment) Regulations, 2006 may continue to do so for a period of six months from such commencement or, if he has made an application for registration under these regulations within the said period of six months, till the disposal of such application." Broker Regulations “Conditions of registration. 9. Any registration granted by the Board under regulation 6 shall be subject to the following conditions, namely,- (a) .... (b) he shall abide by the rules, regulations and bye-laws of the stock exchange which are applicable to him;

(e) he shall take adequate steps for redressal of grievances, of the investors within one month of the date of receipt of the complaint and inform the Board as and when required by the Board; (f) he shall at all times abide by the Code of Conduct as specified in Schedule II; and ..........................................” SCHEDULE II CODE OF CONDUCT FOR STOCK BROKERS “A General (5) Compliance with Statutory requirements: A Stock broker shall abide by all the provisions of the Act and the rules, regulations issued by the Government, the Board and the Stock Exchanges from time to time as may be applicable to him.” Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. "12 A. No person shall directly or indirectly – (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made there under; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognized stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognized stock exchange, in contravention of the provisions of this Act or the rules or the regulations made there under."

PFUTP Regulations "3. Prohibition of certain dealings in securities No person shall directly or indirectly— (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under." "4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair trade practice in securities.

(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following, namely:— (k) an advertisement that is misleading or that contains information in a distorted manner and which may influence the decision of the investors."

10. I shall now proceed to deal with the charges alleged against Unique Consulting and its Directors. On an examination of the material available on record such as complaints of investors along with documents furnished by them, the Report of MSE, information i. Unique Consulting was incorporated on September 15, 2011 having its registered office at 4/1, First Floor, Raja Rajeshwari Nagar, Tirunelveli, Tamil Nadu- 627 007. During the relevant period Unique Consulting was a SEBI registered Stock Broker and a member of MSE (details are mentioned at paragraph 1 above). SEBI’s inspection of MSE revealed the following: ii. MSE received several complaints against Unique Consulting and its Manging Director Mr. P. Shanmuga Ganesan from its clients and other general investors. The complainants alleged that Unique Consulting and Mr. P. Shanmuga Ganesan collected funds from them and that the office of Unique Consulting was closed and Mr. P. Shanmuga Ganesan had absconded. The details of some of the complaints received as on January 17, 2014 are as under: Client Name Nature of Complaint Claim Sr Amount (Rs.)

1 S. Thangavelu Non-transfer of shares bought 40,700.00 on account of the client 2 K. Thirumalai, Sale of 500 - shares of IOB - 24,000.00 Non-receipt of sale proceeds 3 A. Pagam Piriyal Amount collected from the 1,50,00.00 client assuring periodical returns 4 N. Asha Latha Amount collected from the 50,000.00 client assuring periodical returns 5 N. Asha Latha 100 - shares of Punjab & Sind 7,092.00 Bank of the client, sold without her concurrence 6 C. Prabhakaran Amount collected from the 7,00,000.00 client assuring periodical returns 7 S. Subramanian Shares sold without the 4,80,000.00 concurrence and knowledge of the client - sale proceeds not paid to the client 8 P. Sankara Parvathi Amount paid to Unique Consulting 20,000.00 and not refunded by them 9 S. Dharmaraj Jacob Amount collected from the 7,25,000.00 client assuring periodical returns 10 Ms. D. Dejey Amount collected from the 6,00,000.00 client assuring periodical returns 11 P.S. Krishnan Amount paid to Unique Consulting 10,000.00 and not refunded by them 12 S. Sumathi Non-receipt of amount available to 17,217.49 the credit of the client and non-receipt of 100 shares of West Coast Paper Total Claim 28,24,009.49 iii.

Upon receipt of the complaints, MSE disabled the trading terminal of Unique Consulting on December 20, 2012. MSE also issued Show Cause Notice dated December 20, 2012 to Unique Consulting. On December 21, 2012 MSE also blocked the Demat Client Beneficiary account of Unique Consulting maintained with MSE. However, it is noted that Unique Consulting failed to reply to the said SCN. MSE also conducted a physical verification on December 27, 2012 of the office premises of Unique Consulting and during the visit they could not trace or locate the Directors of Unique Consulting. MSE’s investigations revealed the following: iv. As per the investor complaints received by MSE, the Managing Director, Shri. P. Shanmuga Ganesan raised funds from members of public in cash and through cheques and promised them assured periodic returns on their investments. v. Unique Consulting issued ‘Deposit Certificates’ acknowledging the amount collected from its clients/ investors. The said Deposit Certificates were issued in the name of Unique Consulting and it also displayed SEBI registration number. However, the complainants stated in their complaint that they never received any contract notes nor credited any shares to their demat accounts against the amounts deposited.

vi. From the copies of deposit certificates issued by Unique Consulting, it is noted that funds amounting to Rs.53.25 lacs was collected from 21 entities (clients/general public) under different schemes. The details of the same are as under: Payment Amount Sl. No. Client Code Client Name Plan & term Date (in Rs.) 1 269TVL0137 Carat Prabhakaran Short term (3 Months) 03/10/2012 100000 Short term (3 Months) 04/10/2012 100000 PMS/Monthly 24/09/2012 100000 PMS/Monthly 10/08/2012 100000 Short term (3 Months) 08/06/2012 100000 PMS/Monthly 13/07/2012 100000 Short term (3 Months) 21/05/2012 100000 Short term (3 Months) 10/08/2012 100000 PMS/Monthly 17/09/2012 100000 PMS/Monthly 03/10/2012 100000 269TVL0007 Bala Subramanian Short term (3 Months) 26/05/2012 50000 2 Short term (3 Months) 03/07/2012 100000 269TVL0019 Veera Lakshmi B Short term (3 Months) 27/06/2012 50000 3 Short term (3 Months) 25/06/2012 50000 4 269TVL0096 Augustin PMS/Monthly 05/10/2012 200000 Arputharaj G PMS/Monthly 06/08/2012 200000 5 269TVLO118 Mrudula R S PMS/Monthly 09/06/2012 500000 6 269TVL0043 Lakshmanan K Short term (3 Months) 30/05/2012 50000 7 269TVL0123 Krishnaveni K Short term (3 Months) 16/05/2012 50000 8 269TVL0095 Subramanian S PMS/Monthly 03/10/2012 50000 9 269ADR0006 Pavithra K Short term (3 Months) 21/05/2012 100000 10 269ADR0008 Poothamani R Short term (3 Months) 25/09/2012 100000 11 269ADR0020 Ramasundaram E Short term (3 Months) 05/06/2012 50000 12 269TVL0012 Rama Nathan L Short term (3 Months) 08/09/2012 50000 13 269TVL0046 William Thomas T S PMS/Monthly 18/06/2013 100000 14 269TVL0103 Dharmaraj Jacob S PMS/Monthly 14/08/2012 725000 15 269TVL0032 Vijayalakshmi R Short term (3 Months) 04/05/2012 50000 16 269TVL0091 Uma M PMS/Monthly 08/05/2012 700000 17 269TVL0002 Nataraj S Short term (3 Months) 05/11/2012 50000 18 269TVL0051 Senthil Kumar K PMS/Monthly 21/06/2012 500000 19 269ADR0021 Vijayan K S V Short term (3 Months) 27/07/2012 400000 20 269TVL0025 Esakki A Short term (3 Months) 10/06/2012 50000 21 269TVL0034 Krishnan L Short term (3 Months) 28/05/2012 50000 Short term (3 Months) 26/04/2012 50000 Short term (3 Months) 26/05/2012 50000 Total 5325000 vii.

The funds were not routed through its designated bank accounts for the purposes of trading and settlement, viz., HDFC Bank A/c Nos.06360340000099(Cash Settlement Account) and 06360340000082 (Cash Client Account). viii. Though the office of Unique Consulting was closed and directors were absconding, vide e-mails dated December 26, 2012 and January 02, 2013 from its e-mail i.e., 20unique11@gmail.com, Unique Consulting admitted the allegation of collection of monies from the public. Admittedly, Unique Consulting had extensively solicited deposits in 2012 from investors by misusing its SEBI registration as a member of MSE. ix. Considering the irregularities committed by Unique Consulting such as collection of monies from members of public and closure of the office premises without intimation to the Stock Exchange etc., MSE vide Board Resolution dated December 31, 2012, suspended Unique Consulting from trading and issued a Public Notice to caution the general public. Thereafter, MSE referred the matter for Disciplinary action against Unique Consulting. The Disciplinary Action Committee of MSE vide its Order dated October 08, 2013 expelled Unique Consulting and declared it as a ‘Defaulter’. x. MSE also lodged a complaint with the Superintendent of Police, Economic Offences Wing, (Financial Institutions), Chennai-600040 against Unique Consulting and all its promoters/directors alleging deceit and criminal intent, and for taking appropriate action against them.

Considering the above, I find that Unique Consulting had deceived the public by misusing its status as a SEBI registered intermediary and did not utilize the amount so collected from the clients for the agreed purpose. This is evident from the investor complaints that they neither received any contract notes nor any shares were credited to their demat accounts.

11. In the light of the facts mentioned above and also from the complaints by the clients/investors of Unique Consulting, it is clearly established that Unique Consulting was collecting money from the public by misusing the trade name granted as a Stock Broker. This collection of money gives rise to pecuniary liability to those from whom the money has been collected by Unique Consulting. It is noted that Rule 8 (3) (f) of SCRR clearly prohibits such activities. As per Rule 8 (3) (f) of SCRR, a member of the Stock Exchange is prohibited from engaging in any business other than that of securities or commodity derivatives except as a broker or agent not involving any personal financial liability. In view of the same, I find that as a Stock Broker, Unique Consulting has violated rule 8 (3) (f) of SCRR.

12. It is noted from the abovementioned facts at paragraph 10 above that Unique Consulting had floated various schemes such as short term, PMS/Monthly, PMS/3 months, etc. The use of the terms like “short term”, “PMS/Monthly”, “PMS/3 months”, etc. in the Deposit Certificates issued by Unique Consulting, and the advertisements/pamphlets issued by Unique Consulting offered services including wealth management, as the schemes offered by Unique Consulting are in the nature of portfolio management services. It is noted from the ‘Deposit Certificates’ issued by Unique Consulting to its clients and other general investors that the ‘Deposit Certificates’ bear SEBI registration number granted to it. I note that Unique Consulting misled the investors to believe that it was authorized to do the activities as described above as a portfolio manager by misusing the SEBI registration as a stock broker. Hence, I find that the charges against Unique Consulting that it acted as an unregistered portfolio manager in violation of Section 12(1) of SEBI Act read with Regulations 3 of the PMS Regulations, 1993 stands established.

13. It is noted from the investor complaints and the schemes that Unique Consulting had misused its status as a Stock Broker and solicited and collected funds and deposits from investors through misrepresentation and allurement of periodical returns. In view of the same, I find that Unique Consulting has clearly devised a scheme which is 'fraudulent' as defined in Regulation 2(1)(c) of the PFUTP Regulations. It is therefore clear that Unique Consulting acted in fraudulent and deceitful manner in violation of Section 12A (a) (b) and (c) of the SEBI Act and Regulation 3 (b), (c) and (d) and Regulation 4(1) and 4(2) (k) of the PFUTP Regulations.

14. Unique Consulting as Stock Broker at the relevant time was duty bound to follow the conditions of granting of certificate of registration as a Broker and also to abide by the code of conduct prescribed under the Brokers Regulations. Unique Consulting, by misusing the status as a Stock Broker, solicited and collected money from members of public through various fraudulent schemes as detailed in paragraph 10 above promising them high returns. By doing so, I find that Unique Consulting has violated clause (5) of the Code of Conduct prescribed for Stock Brokers in Schedule II read with regulation 9 of Broker Regulations.

15. Admittedly, Unique Consulting has collected money from its clients and other general investors. It is noted from the material available on record that the Managing Director of Unique Consulting has admitted to MSE about the collection of money from its clients and other general investors. I note that Mr. K. Mathan Kumar and Ms. Janet Jenetha, the directors of Unique Consulting, in their respective depositions before the Disciplinary Committee of MSE, admitted that they were aware of the collection of funds by Unique Consulting. Apparently, some of the Deposit Certificates issued by Unique Consulting to its clients/ other general investors were signed by Ms. U Indira, a director of Unique Consulting. Therefore, I am of the view that Unique Consulting and its Directors are liable for the non-repayment of funds collected under its various schemes from its clients/investors. Furthermore, Unique Consulting and its Directors are liable to refund the money so collected from its clients and other investors along with income, profits or returns promised to them under its various schemes.

16. In this regard, it is also noted that Unique Consulting was a stock broker of erstwhile Madras Stock Exchange. Vide SEBI’s Order dated May 14, 2015, Madras Stock Exchange exited in terms of Clause 8 of SEBI’s Exit Circular, 2012. The following is noted from the Order of Exit for MSE passed by SEBI: ““I note that MSE has transferred all the beneficiary demat accounts to its subsidiary company, MSE Financial Services Ltd. on March 27, 2015. I also note that the demat account of M/s. Unique Consulting & Trading Private Limited, a registered stock broker of MSE, was frozen pursuant to the directions issued by SEBI vide order dated April 21, 2014. In this regard, I note that MSE, vide its aforesaid undertaking dated April 22, 2015, has undertaken to facilitate transfer of the securities to their rightful beneficiary owners, including the admitted claimants, from the "House Demat Account" of the said trading member, as and when suitable direction is given by SEBI in this regard.”

17. Considering the fact that MSE has exited and MSE had already expelled Unique Consulting and declared it as ‘Defaulter’, I am of the considered view that MSE Financial Services Ltd shall take necessary steps “to facilitate transfer of the securities to their rightful beneficiary owners, including the admitted claimants, from the "House Demat Account" of the Unique Consulting”.

18. SEBI has been entrusted with the important mandate of protecting investors and safeguarding the integrity of the securities market. In this regard, necessary powers have been conferred upon it under the securities laws. It is, therefore, necessary that SEBI exercises these powers firmly and effectively to insulate the market and its investors from the fraudulent actions of any of the participants in the securities market, thereby fulfilling its legal mandate. A basic premise that underlines the integrity of securities market is that persons connected with securities market conform to high standards of transparency, good governance and ethical behaviour prescribed in securities laws and do not resort to fraudulent activities. In view of the gravity of the violations perpetrated by Unique Consulting and its Directors viz., Mr P. Shanmuga Ganesan Mr. K. Mathan Kumar, Ms U. Indira and Ms. Janet Jenetha as brought in the foregoing paragraphs I am of the opinion that Unique Consulting and its aforementioned Directors should not be allowed to have access to the securities market in view of the possible danger to the investors at large.

19. In view of the foregoing, I, in exercise of powers conferred upon me by virtue of Section 19 read with Sections 11(1), 11(4), 11B and 11D of the SEBI Act do hereby pass the following directions :

i. M/s Unique Consulting & Trading Private Limited (PAN: AABCU3526H) and it’s Directors viz., Mr P. Shanmuga Ganesan (PAN: BDAPS0331N) Mr. K. Mathan Kumar (PAN: AQRPM0642B), Ms U. Indira (PAN: AAUPI9812N) and Ms. Janet Jenetha (PAN: AOVPJ2773C) are prohibited from mobilizing or pooling any fresh funds from its clients, other general investors or members of public in whatever form; ii. M/s Unique Consulting & Trading Private Limited and it’s aforementioned Directors shall refund the monies so collected from his clients and other investors in the various schemes along with income, profits or returns promised to them under such schemes or interest at the rate of 10% per annum, whichever is higher, from the date of investment till the date of refund, within a period of 90 (Ninety) days from the date of this order and submit a repayment report to SEBI in the following format as certified by two independent Chartered Accountants who are in the panel of any public authority or public institution:

S. Name of PAN of Address of Refund Details No. Client / Client / Client/ From To Amount Investor Investor Investor Cheque No./ Name of Cheque No./ Demand the Bank Demand Draft/ Draft/ NEFT NEFT details details iii. M/s Unique Consulting & Trading Private Limited and its aforementioned Directors shall provide a full inventory of all their assets and properties and details of all his bank accounts, de-mat accounts and holdings of shares/securities, if additionally held in physical form. iv. M/s Unique Consulting & Trading Private Limited (PAN: AABCU3526H) and its Directors viz., Mr P. Shanmuga Ganesan (PAN: BDAPS0331N) Mr. K. Mathan Kumar (PAN: AQRPM0642B), Ms U. Indira (PAN: AAUPI9812N) and Ms. Janet Jenetha (PAN: AOVPJ2773C) are directed not to access the securities market directly or indirectly, and are further restrained and prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner for a period of ten (10) years from the date of this Order. This shall not prohibit M/s Unique Consulting & Trading Private Limited from effecting the repayments to investors.

20. This order shall come into force with immediate effect. The stock exchanges and the depositories are directed to ensure that the above directions are strictly enforced.

Place : Mumbai S. RAMAN Date : August 02, 2017 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA