Fair Practices Code

INTRODUCTION

Indiumplus Financial Services Pvt Ltd (‘IndiumPlus’ or ‘Company’) is a Non-Banking Finance Company (NBFC) registered with the Reserve Bank of India and is in the business of extending various types of loan products.

The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code (FPC or Code) for NBFCs thereby setting standard for fair business and corporate practices while dealing with their customers vide Master Circular – Fair Practices Code dated July 1, 2015 (DNBR (PD) CC.No. 054/03.10.119/2015-16 dated July 1, 2015 Master Circular – Fair Practices Code read with Chapter VII of Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, dated October 19, 2023 (RBI/DoR/2023-24/106 DoR.FIN.REC.No.45/03.10.119/2023-24) . The Company shall adopt all the best practices prescribed by RBI from time to time and shall make appropriate modifications if any necessary to this Code to conform to the standard so prescribed.

This Code applies to all products and services offered by the Company (currently offered or which may be introduced at a future date). The Code is applicable irrespective of whether the product and service is provided physically, over the phone, on the internet or by any other method whatsoever, existing or futuristic.

The implementation of the Code is the responsibility of the entire organization. and it shall apply across all aspects of its operations including loan origination, application processing, loan servicing and collection activities.

The Company will also communicate the Code to its customers by uploading it on its website.

I. OUR KEY COMMITMENTS

The Company promises to adhere to the following principles :

  1. To act fairly and reasonably in all dealings with its customers by ensuring that:
    1. Its products, services, procedures and practices will meet the commitments and standards in this FPC.
    2. Its products and services will meet relevant laws and regulations as applicable
    3. Its dealings with its customers will rest on ethical principles of honesty, integrity and transparency.
  2. The Company will assist customers in understanding how its financial products and services work by
    1. Providing information about them in simple Hindi and/or English and/or the local language; and
    2. Explaining their financial implications.
  3. The Company will make every attempt to ensure that its customers have a troublefree experience in dealing with it; but in the case of errors or commissions and omissions, the Company will deal with the same quickly and sympathetically
    1. In case a customer is not satisfied with a way complaint is handled, the Company will guide the customer on how to take the complaint forward.
    2. The Company will reverse any charges including interest applied to a customer’s account due to an error or oversight on its part.

II SALES ORIGINATION

  1. Before the customer relationship is established, the Company will:
    1. Give the customer information explaining the key features of the services and products the customer has shown interest in
    2. Give information on products and services which may suit the customer’s needs
    3. Give information about documents that the Company requires from the customer for its products and services.

III. LOANS AND ADVANCES

  1. Before offering any kind of credit facility, the Company will assess the ability of the Customer to repay.
  2. Loan application forms of the Company will include necessary information which are likely to affect the interests of the Customer, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision taken by the Customer.
  3. The loan application form shall indicate the documents required to be submitted for processing of the loan application.
  4. The Company shall have a system to provide an acknowledgement for receipt of all loan applications. An indicative time frame within which loan applications will be disposed of shall be mentioned in such acknowledgement.
  5. The Company shall convey in writing to the prospective borrower the fact of the loan application by means of sanction letter / Key Facts Statement (KFS). In the case of sanction of loan, the sanction letter/KFS shall contain the terms and conditions including loan amount sanctioned, loan tenor, annualized rate of interest, applicable fees and charges and method of application thereof. The acceptance of the terms and conditions communicated by the borrower shall be preserved by the Company in its records. The Company shall comply with KFS requirements for all loans.
  6. The Company shall not charge penal interest for non-compliance of material terms and conditions of the loan agreement by the borrower; and only levy Penal Charges in line with its board approved Penal Charge policy.
  7. The Company shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-borrowers.
  8. The decision of the Company to recall/accelerate payment or performance shall be in consonance with the terms of the loan agreement. The Company shall release all 4 securities upon repayment of all dues or lien for any other claim it may have against borrower. The borrower shall be given due notice with full particulars about the outstanding claims in case such right of set off is to be exercised.
  9. The Company will refrain from interfering in the affairs of the borrower except for the purpose provided in the terms and conditions of the loan agreement, unless new information, not earlier disclosed deliberately or otherwise by the borrower, has come to its notice.
  10. In case of receipt of request from the borrower for transfer of a borrower account to other NBFC, bank or financial institution, the consent or otherwise shall be conveyed within 21 days form the date of receipt of such request. Such transfer shall be in accordance with the contractual terms entered into with the borrower and in consonance with the statutes, rules, regulations and guidelines as may be applicable from time to time.
  11. Recovery of Loans
    1. In the matter of recovery of loans, the Company shall resort only to remedies which are legally and legitimately available to it and will avoid using recovery measure during odd hours of the day.
    2. The Company shall ensure that the staff and agents are adequately trained to deal with the borrowers in an appropriate manner.

IV. LOAN TERMS AND CONDITIONS

  1. All Terms and Conditions will be fair and will set customer’s rights and responsibilities clearly and in plain language. The Company will use legal or technical language only where necessary.
  2. The Company will make available any fees or charges applicable to products and services applicable at the time a customer signs up for the same.
  3. If the Company increases any charges or introduces a new charge, it will notify the same to the customers.
  4. The Company shall give notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, services charges, prepayment charges, loan repayment mechanism etc. The Company shall ensure that changes in interest rates and other charges are affected only prospectively. The loan agreement shall contain a specific clause to this effect.

V. CONFIDENTIALITY

  1. Unless authorized by the customer, the Company will treat all personal information as private and confidential.
  2. The Company will not reveal transaction details to any other entity other than the following exceptional cases
    1. If the Company has to provide the information by statutory or regulatory laws
    2. If there is a duty to the public to reveal this information
    3. If its interest requires it to provide this information (e.g. fraud prevention)
    4. If the Company has taken the customer’s permission to provide such information to its group/associate/partner entities or companies for providing the products or services.

VI. GRIEVANCE REDRESSAL MECHANISM

  1. The Company will guide customer who wishes to lodge a complaint and provide guidance on what to do in case the customer is unhappy with outcome.
  2. After examining the matter, the Company will send a response as soon as possible. The Company will also guide a customer on how to take the complaint further if the customer is not satisfied.
  3. A nodal officer has been appointed for the redressal of grievances of the customers including the borrowers, in connection with any matter pertaining to business practices, lending decisions, credit management and recovery. The name and contact details of the nodal officer shall be displayed on the Company website.
  4. If the complaint / dispute is not redressed within a period of one month, the customer may may reach out to RBI through CMS portal (https://cms.rbi.org.in/).
  5. The Company shall publish its board approved Grievance Redressal Mechanism on the website of the Company.