Fair Practices Code

• All communications with borrowers shall be in a vernacular language or another language understood by the borrower.
• Loan application forms shall contain relevant information regarding the applicable terms and conditions to help borrowers make an informed decision.
• The Company shall provide an acknowledgement upon receipt of a loan application, preferably indicating the expected time frame for processing or disposal.

The Company shall communicate the key loan terms to the borrower in writing and in a language understood by the borrower. The sanction letter or other applicable loan documentation shall include:

• The amount of loan sanctioned
• The annualised rate of interest and the method of application
• Applicable penal charges for delayed repayment, appropriately highlighted

A copy of the Loan Agreement together with applicable enclosures shall be provided to the borrower at the time of sanction or disbursement.

• Borrowers shall be informed of any change in applicable terms, including interest rates, service charges, prepayment charges, or other relevant conditions.
• Changes in interest rates and charges shall be applied prospectively.
• The Company shall release all securities after repayment of all dues, subject to any legitimate right or lien in relation to another valid claim.

• Non-Interference: The Company shall refrain from interfering in the affairs of the borrower except where permitted under the Loan Agreement or applicable law.
• Transfer of Account: Consent or objection to a request for transfer of a borrower’s account shall be communicated within 21 days.
• No Harassment: The Company shall not resort to undue harassment, including persistently contacting borrowers at inappropriate hours or using coercive recovery practices. Staff shall be appropriately trained to deal with customers.
• Foreclosure Charges: No foreclosure charges or prepayment penalties shall be levied on floating-rate term loans sanctioned to individual borrowers where prohibited under applicable RBI requirements.

The Board of Directors shall maintain an appropriate grievance redressal mechanism for resolving customer complaints.

If a complaint is not resolved within one month (30 days), the customer may approach the Reserve Bank of India in accordance with the applicable RBI grievance redressal framework.

The Company shall follow an appropriate interest-rate model taking into account relevant factors such as:

• Cost of funds
• Margin
• Risk premium

The applicable rate of interest and the rationale for charging different rates to different categories of borrowers, where applicable, shall be disclosed in the loan application and sanction documentation.

Interest rates shall be communicated on an annualised basis so that borrowers are aware of the applicable rate.

Where applicable, the Loan Agreement shall contain a legally enforceable repossession clause. To ensure transparency, the agreement shall include provisions relating to:

• Notice period before taking possession
• Circumstances where the notice period may be waived
• Procedure for taking possession of the security
• Final opportunity for repayment before sale or auction
• Procedure for restoring possession to the borrower
• Procedure for sale or auction of the secured asset

Exclusions

• The Company is not engaged in the business of microfinance activities.
• The Company is not engaged in the business of lending against gold as collateral.