FAIR PRACTICES CODE

FAIR PRACTICES CODE  

The Company has framed its Fair Practices Code (FPC), which is in tune with the guidelines  issued by the Reserve Bank of India from time to time. The code prescribes fair practice  standards while dealing with the customers and to serve in the best interests of the  Company.  

The Code is applicable to all aspects of operations of the Company. It shall be our policy to  make our services available to all qualified applicants without discrimination of any kind and  to treat our customers fairly. We offer all sorts of assistance and encouragement in a fair,  equitable and consistent manner.  

We are committed to ensure that our charges are properly and timely informed to the  existing and prospective borrowers. Disputes, if any; will be resolved by the Grievance  Redressal Mechanism set up within the Company. We shall ensure employee accountability  at all levels of our operations. The Board and Senior Management will be responsible to  ensure our commitment to fair and reasonable practices as also to ensure high quality  services to our clients.  

We shall ensure the fair practices in all our operations. This will be applicable irrespective of  the fact that the service is provided at our branches or head office or over phone or by  email.  

OBJECTIVES  

The objectives of the FPC are as under.  

1. Adopt the best practices in dealings with customers.  
2. Set challenging benchmarks and strive to achieve high operating standards for  ensuring customer satisfaction.  

iii. Follow transparent, fair, ethical and legally tenable practices while conducting  business.  

1. Provide all necessary information and inputs to customers / prospective customers  and promote a mutually beneficial long term relationship. 
2. Facilitate a continuously growing base of satisfied customers while scrupulously  avoiding acquisition of customers having doubtful credentials or criminal background.  

DECLARATIONS & COMMITMENTS  

1. The Company undertakes to abide by all applicable laws, regulations and guidelines  passed / issued by the Regulators (Reserve Bank of India, SEBI, IRDA etc.) and other  competent authorities such as Government, Local Authority etc.  
2. The Company commits itself to full customer satisfaction through efficient,  professional and courteous services across all its offices.  

iii. The Company shall consistently strive to meet with and improve upon the internally  set benchmarks and practices and be ahead of the standards prevalent in the  industry.  

1. The Company undertakes not discriminate customers on grounds of religion, caste,  gender or language.  
2. The Company will provide clear and full information about its products and services  to its customers / prospective customers and will not resort to any misleading or  potentially misguiding advertisement or publicity.  
3. The Company undertakes to desist from introducing any products / services having  elements of ‘hidden charges’ or lack of transparency.  

vii. The Company will communicate in the local language with the customer and in  English at the request of the customer  

viii. The Company undertakes to take all possible and reasonable measures to secure the  safe custody of the security pledged by the customer and to compensate the  customer for any accidental, inadvertent or fraudulent loss of the security whilst in  the custody of the Company.  

1. The Company undertakes not to take advantage of any unintentional or clerical error  made by the customer while transacting business.  
2. The Company is committed to put in place a system for promptly addressing  complaints and suggestions of the customers supplemented with a structured  Grievance Redressal Mechanism having an escalation matrix.  

The Company shall display the FPC on its website and also make available to the Customer,  on request, a copy of the FPC on demand. 

KEY AREAS  

(A) APPLICATIONS FOR LOANS AND THEIR PROCESSING  

1. All communications to the borrower will be either in English or in Vernacular language.  
2. The application for loan will include matters/information affecting the interests of the  borrower so that a meaningful comparison with the terms and conditions offered by other 

NBFCs can be made and informed decision can be taken by the borrower. The loan  application form will indicate the documents required to be submitted with the application  form.  

iii. The rate of interest and the approach for gradation of risk and rationale for charging  different rate of interest to different categories of borrowers shall be disclosed to the  borrowers in the application form and communicated to them in the sanction letter. Interest  rate shall always be mentioned on an annualized rate basis and shall be charged on a daily  diminishing balance.  

1. Acknowledgement will be issued to all loan applicants and the same will indicate the time  within which the application will be disposed of by the Company.  
2. The application form will clearly state the information to be provided by the customer to  fulfil the KYC norms and to comply with legal and regulatory requirements.  
3. B) GOLD LOAN APPRAISAL AND TERMS/CONDITIONS  
4. Company shall issue a Sanction Letter in Vernacular language as understood to the  borrower showing the amount sanctioned and the terms and conditions applicable including  annualised rate of interest and method of application thereof. The Company shall keep the  acceptance of these terms and conditions by the borrower on its record.  
5. Company shall mention the additional interest charged for late repayment in bold in the  loan agreement.  

iii. A copy of the loan agreement preferably in the vernacular language as understood by the  borrower along with a copy each of all enclosures quoted in the loan agreement shall be  furnished to all the borrowers at the time of sanction / disbursement of loans.  

1. The loan agreement shall also disclose the details regarding auction procedure.  
2. The Company shall at all time keep adequate insurance coverage for the gold ornaments  accepted as security. 

(C)DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND  CONDITIONS  

1. The terms and conditions of the loan shall be accepted by the borrower before  disbursement of the loan amount. Any change in the terms and conditions of the loan,  including disbursement schedule, interest rates, service charges, prepayment charges etc.  will be brought to the notice of the customer by sending notice in vernacular language as  understood by the borrower. Change in interest rates and other charges will be made only  prospectively and not retrospectively. A suitable condition in this regard will be incorporated  in the loan agreement.  
2. Any decision to recall/accelerate payment or performance under the agreement shall be in  consonance with the loan agreement.  

iii. The Company shall release all securities on repayment of all dues or on realisation of the  outstanding amount of loan subject to any legitimate right or lien for any other claim the  company may have against the borrower. If such right to set off is to be exercised, the  borrower shall be given notice about the same with full particulars about the remaining  claims and the conditions under which the Company is entitled to retain the securities till the  relevant claim is settled / paid.  

(D) GENERAL  

1. The Company will not interfere in the affairs of the borrower except for the purposes  provided in the terms and conditions of the loan agreement (unless new information not  earlier disclosed by the borrower has come to the notice of the lender).  
2. In case of receipt of request from the borrower for transfer of borrowal account, the  consent or otherwise of the Company shall be conveyed properly from the date of receipt of  request. Such transfer shall be as per transparent contractual terms in consonance with law.  

iii. In the matter of recovery, the Company will not resort to any type of undue harassment  viz.; persistently bothering the borrowers at odd hours, use of muscular power for recovery  of loans etc. Company shall train all staff to deal with customers in a proper manner. 

1. The Company shall state the repossession clause in the loan agreement with the  borrower, wherever applicable, which shall contain provisions regarding notice period before  taking possession, circumstances under which the notice period can be waived, procedure  for taking possession of the security, provision regarding final chance to be given to the  borrower for repayment of the loan before auction/sale of security, procedure for giving  repossession to the borrower and the procedure for sale/auction of the property. A copy of  such terms and conditions shall be made available to the borrowers.  
2. In the case of gold loan, in case of auction, the Company will give adequate prior notice  before the auction date, which will also be announced to the public by issue of  advertisements in at least two newspapers, one in vernacular language and another in a  national daily newspaper. As a policy the Company itself shall not participate in the auctions  held. The gold pledged will be auctioned only through auctioneers.  
3. All loans are sanctioned at the sole discretion of the Company.  

(E) GRIEVANCE REDRESSAL MECHANISM  

1. The Company has framed a suitable mechanism for redressal of customer grievances/  complaints. The Committee shall review the compliance of the fair practice code and the  functioning of the grievance redressal mechanism at least once in a year.  
2. The Company shall designate a Senior Officer of the Company as Grievance Redressal  Officer for resolving customer complaints. Name, Phone Number and email id of the  Grievance Redressal Officer shall be displayed in all branches.  

iii. The Grievance Redressal Officer shall also act as the Compliance Officer to ensure  compliance of Fair Practice Code.  

INTEGRATED OMBUDSMAN  

In case a customer complaint / dispute is not redressed within a period of one month, that  is, If the Company does not reply within a period of one month after receipt of the  complaint, or rejects the complaint, or if the complainant is not satisfied with the reply  given, the complainant can file the complaint with the integrated Ombudsman under whose 

jurisdiction the company falls (email: crpc@rbi.org.in) or shall be registered on the portal  (https://cms.rbi.org.in).  

CONFIDENTIALITY  

The Company shall treat all personal information of its borrowers as private and confidential  and will not reveal any information to any other entity other than for regulatory/statutory  matters.