Fair Practice Code

All parts of this Code apply to all the products and services, whether they are provided by the Company across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.

Company's key commitments to customers:

• Meeting the commitments and standards in this Code for the products and services being offered, and in the procedures and practices that our staff will follow.
• Making sure that our products and services meet relevant laws and regulations in letter and spirit.
• Resting on ethical principles of integrity and transparency.

2A. The Company shall transparently disclose to the borrower all information about fees/ charges payable fore processing the loan application, the amount of fees refundable if loan amount is not sanctioned/disbursed, pre-payment options and charges, if any, penalty for delayed repayment if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest re-set clause and any other matter which affects the interest of the borrower. In other words, the Company will disclose “all in cost” inclusive of all charges involved in processing / sanction of loan application in a transparent manner. The charges/fees will be non-discriminatory.

• We will ensure that all advertising and promotional material is clear and not misleading.
• We will inform in our advertisement in any media and promotional literature which draws reference to an interest rate on a product or service offered by us, whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request.
• We will provide information on interest rates, common fees and charges through putting up notices in Company’s branches; Through telephone or help-lines; On the company’s website; through designated staff / help desk ;or providing service guide / tariff schedule.
• Third parties working for us will deal with the customer’s personal information with same confidentiality as we do.
• We will inform the customer about other products or promotional offers after receiving their consent to receive such information either by mail or on the website or on customer service number to receive such information.
• We will prescribe code of conduct for the DSA’s and ensure that DSA’s follow the same. We will investigate any act of improper conduct or violation of Company representative/DSA and to handle the violation and make good the loss.
• In the event, if we receive any complaint from the customer that our representative / courier or DSA has engaged in any improper conduct or acted in violation of this Code, we shall initiate appropriate steps to investigate and to handle the complaint and to make good the loss.

4.1(i)Application for loans and their processing:

• We will communicate the interest rate, fees/charges for processing, prepayment option to enable to customer to make a meaningful comparison of the product with products offered by other Companies.
• We will give the customer an acknowledgement and time frame within which loan applications will be processed. The Time frame for disposal of completed loan application shall be indicated in the acknowledgment, which usually will be 4 weeks from the date of receipt of completed loan application.

(ii)Loan appraisal and terms/conditions

• We will collect the information/documents from the customer at the time of application and will contact the customer immediately, if any additional information require on later stage.
• We will convey to the customer the amount sanctioned along with the key features of the product including applicable fees and charges, terms and conditions in the sanction letter.
• We will provide copy of the loan agreement executed by the customer at our cost along with a copy of all enclosures mentioned in the loan document.

(iii) Communication of rejection of Loan Application

• We will communicate in writing the reason for rejection, if the application for loan is rejected.

(iv) Disbursement of loans including changes in terms and conditions

• We will disburse the loan in accordance with the Loan agreement / Sanction letter provided to the customer.
• We will display the change in the terms and conditions at notice board of branches or display the same on our website or inform the change through personal intimation within 30 days of the change and give an option to the customer to close his/her account or switch it without paying any extra cost within 60 days if it is to his disadvantage. We will inform the major changes or lot of minor changes in any year to the customer on request and provide a copy of the new terms and conditions or summary of changes.
• We will give notice to the customer before taking any decision to recall/accelerate the payment or performance under the agreement or seeking additional securities in consonance with the loan agreement.
• We will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim we may have against the customer. Notice to the customer with full particulars about the remaining claims and the conditions under which we are entitled to retain the securities till the relevant claim is settled /paid will be given if such right of set off is to be exercised.

We will inform the person considering being a guarantor to a loan:

• His/Her liability as a guarantor.
• The amount of liability he/she will be committing himself/herself to us.
• Circumstances in which we will call on him/her to pay up his/her liability.
• Whether we have recourse to his/her other monies in the company of he/she fail to pay up as a guarantor.
• Whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited.
• Time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which we will notify him/her about this.
• We will also keep him/her informed of any material adverse changes in the financial position of the borrower to whom he/she stands as a guarantor.
• On request, we will provide the copy of the loan agreement executed to avail the said loan.

5.1 We will treat the personal information of customers as private and confidential even when the customer is no longer a customer. We will not reveal the data or information of customer to anyone including other companies in the group except when:

• Required by law,
• Duty towards public to reveal information,
• Our interest requires giving information,
• With customers permission,
• If we are giving a reference about customer to Companies in the group with the prior written permission of the customer,
• We will inform the customer about his rights/liabilities under the Laws of India for accessing the personal records that we hold about him/her,
• We will not use customer’s personal information for marketing purposes unless the customer specifically authorizes us to do so.

a. We will inform customer on request of the circumstances when we will pass on the account details to credit reference agencies.

b. We may give information to credit reference agencies about the personal debts the customer owes us if:

• The customer has fallen behind his/her payments.
• The amount owed is not in dispute.
• The customer has not made proposal following our formal demand for repayment of dues. We will intimate the customer in writing in such a case.

c. We will give information about the customers account to credit reference agencies if the customer has given his/her permission to do so.

d. We will provide copy of information given to credit reference agencies if demanded by the customer.

6.1 Whenever loans would be given, the customer would be explained of the repayment process by way of the amount, tenure and periodicity of repayment. If the customer fails to adhere to the prescribed repayment schedule, appropriate action for recovery of dues shall be taken under the laws of land and no undue harassment will be resorted to.

6.2 We have framed our collection policy based on courtesy, fair treatment and persuasion. The Company believes in fostering customer confidence and long-term relationship. The staff or any person authorized to represent the Company in collection of dues or / and security repossession shall identify himself / herself and display the authority letter issued by the Company. He/She shall upon request, display his / her identity card issued by the Company or under authority of the company. Company ' shall provide customers with all the information regarding dues and shall endeavor to give sufficient notice for payment of dues.

6.3 All the members of the staff or any person authorized to represent the Company in collection or / and security repossession shall strictly follow the Codes set out below:

• Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation.
• Identity and authority to represent the Company shall be made known to the customer at the first instance.
• Customer's privacy shall be respected.
• Interaction with the customer shall be in a civil manner. Utmost care shall be taken in the use of language while interacting, so that at any point of time the customer should not feel hurt/feel any un-courteous treatment. While interacting with women borrowers, due respect as per Indian culture and tradition shall be maintained.
• Company’s representatives shall contact the customers between 0700 hrs and 1900hrs, unless the special circumstances of the customer's business or occupation require otherwise.
• Customer's request to avoid calls at a particular time or at a particular place shall be honored as far as possible.
• Time and number of calls and contents of conversation would be documented.
• All assistance would be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
• During visits to customer's place for dues collection, decency and decorum shall be maintained.
• Inappropriate occasions such as bereavement in the family or such other calamitous occasions, if comes to the knowledge the Company, shall be avoided for making calls/visits to collect dues unless the same is required for meeting legal compliance.

• The Company will develop a system and a procedure for receiving, registering and disposing of complaints and grievances in each of its offices.
• The Board of Directors of the Company would lay down the appropriate grievance redressal mechanism within the organization to resolve complaints and grievances. Such a mechanism would ensure that all disputes arising out of the decisions of lending institutions' functionaries are heard and disposed of at least at the next higher level.
• Customers would be informed about the procedure for handling complaints fairly and quickly.
• If the customer wants to make a complaint, he/she would be told:
• How to do this
• Where a complaint can be made
• How a complaint should be made
• When to expect a reply
• Whom to approach for redressal
• What to do if the customer is not happy about the outcome.
• The staff of the Company will help the customer with any questions the customer has.
• If a complaint is received in writing from a customer, then the Company will endeavourer to send him/her an acknowledgement / response within a week. The acknowledgement will have the name and designation of the official who will deal with the grievance. If the complaint is relayed over phone at Company’s designated telephone helpdesk or customer service number, the customer shall be provided with a complaint reference number and be kept informed of the progress within a reasonable period of time.
• After examining the matter, the Company shall send the customer its final response or explain why it needs more time to respond and shall endeavourer to do so within six weeks of receipt of a complaint and he/she should be informed how to take his/her complaint further if he/she is still not satisfied.
• The Company shall publicize its grievance redressal procedure and ensure that it is specifically made available on its website.

• If we think necessary, we will verify the details mentioned by the customer in the loan application by contacting the customer at his/her residence and/or business addressees through agencies appointed for the purpose.
• We will inform the customer to cooperate if we need to investigate a transaction on the customer's account and with the police/other investigative agency if we need to involve them.
• We will inform the customer that he will be responsible for all losses if he acts fraudulently or without reasonable care.
• We will inform customer about the products and services in English.
• We will not discriminate the customers on the basis of race, age, caste, gender, marital status, religion or disability.
• We will process request for transfer of borrower account, either from the borrower or from other bank/financial institution in the normal course.
• We will publicize this Code by putting it on our website, providing existing and new customers with a copy of the code to customer on request. We will also ensure that our staff is trained to provide information about the code.
• The Board of Directors of the Company would provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews may be submitted to the Board at regular intervals, as may be prescribed by it.