Direct Selling Agent / Direct Marketing Agent

 1.0 Preamble:

Model Code of Conduct for the Direct Selling Agents/Direct Marketing Agents (DSAs) is a non-statutory code for adoption and implementation by DSAs while operating as Agents of Banks and Financial Institutions. Same has been reviewed in line with RBI Directions dated November 9, 2017 for NBFCs on Managing Risks and Code of Conduct in Outsourcing of Financial Services by NBFCs.

 1.1 Applicability:

The code will apply to all persons involved in marketing and distribution of any loan or other financial product of Navin Bros. Pvt. Ltd. (Navin/Company). The DSAs/DMAs and its employees /telecaller/ representatives must agree to abide by this code prior to undertaking any direct marketing operations on behalf of the Company. Any employees/telecaller /representatives of the DSAs/DMAs found to be violating this code may be blacklisted and such action taken will be reported to the Company from time to time by the DSAs/DMAs.

Navin may consider termination or permanent blacklisting of DSAs/DMAs who fail to comply with this requirement. A declaration to be obtained from employees /representatives by the DSAs/DMAs before assigning them their duties is annexed as Annexure-1 to this Code.

 2.0 Tele-calling a Prospect (a prospective customer):

A prospective customer may be contacted for sourcing a Navin product or Navin-related product only under the following circumstances:

• When a prospective customer desires to acquire a financial product through the Navin’s website/SEO/Social Media/Ad/call center/branch or has been referred by another customer/ prospective customer or through the Relationship Manager of the Company or is an existing customer of the Company who has given consent for accepting calls on other products of the Company.

• When the prospective customer’s name/telephone number / address is available and obtained after taking his /her consent. The employees / representatives of the DSAs/DMAs should not call a person whose name /number is flagged in any “do not call” list made available to him / her.

 3.0 When you may contact a prospect on telephone

Telephonic contact must normally be limited between 09.30 Hrs and 1900 hours. However, it may be ensured that a prospective customer is contacted only when the call is not expected to inconvenience him / her. Calls earlier or later than the prescribed time period may be placed only under the following conditions:

• When the prospective customer has expressly authorized the DSAs/DMAs and its employees / representatives to do so either orally or in writing.

Residence/business/office address visit must normally be limited between 08.00 hours and 20.00 hours. Any deviation should be approved by customer in oral or in writing.

 4.0 RESPECT PROSPECTIVE CUSTOMER’S PRIVACY

DSAs/DMAs or/and its employees will respect the prospective customer’s privacy and his /her interest may normally be discussed only with him /her and with any other individual /family member such as prospect’s accountant /secretary /spouse only when authorised to do so by the prospective customer.

4.1 Leaving messages and contacting persons other than the prospect:

Calls must first be placed to the prospective customer. If the prospective customer is not available, a message may be left for him /her. The aim of the message should be to get the prospective customer to return the call or to check for a convenient time to call again.

Ordinarily, such messages may be restricted to:

“Please leave a message that ******** (name of officer) representing Navin called regarding (Products/Services proposed to be offered) and requested to call back at ********** (phone number)”.

As a general rule, the message must indicate that the purpose of the call is regarding selling or distributing a product of the Company.

5.0 NO MISLEADING STATEMENTS / MISREPRESENTATIONS PERMITTED

DSAs/DMAs and/or its employees / representatives will not:

• mislead the prospective customer on any service / product offered by the Company;

• mislead the prospect about their business or organization’s name, or falsely represent themselves;

• Make any false / unauthorized commitment on behalf of the Company for any facility / loan / service

6.0 Telemarketing Etiquettes

PRE CALL

• No calls prior to 09.30 Hrs or post 1900 Hrs unless specifically requested.

• No serial dialing

• No calling on lists unless list is cleared by the team leader

DURING CALL

• Identify yourself, your company and your principal

• State reason for your call

• If denied interest, politely disconnect.

• Never interrupt or argue

• To the extent possible, talk in the language which is most comfortable to the prospective customer

• Keep the conversation limited to business matters

• Check for understanding of “Most Important Terms and Conditions” by the customer if he plans to buy the product/services.

• Reconfirm next call or next visit details

• Provide your telephone number, your supervisor’s name or the Company’s officer’s contact details if asked for by the customer.

• Thank the customer for his /her time

POST CALL

• Customers who have expressed their lack of interest for the offering should not be called for the next 3 months with the same offer

• Provide feedback to the Company on customers who have expressed their desire to be flagged “Do Not Call”

• Never call or entertain calls from customers regarding products already sold.

• Advise them to contact the Customer Service Staff of the Company.

7.0 Gifts or bribes:

Employees /representatives of Direct Selling Agent (DSA)/DMAs must not accept gifts from prospective customers or bribes of any kind. Any employee/representative of the DSAs/DMAs, who is offered a bribe or payment of any kind by a customer, must report the offer to his /her management.

8.0 PRECAUTIONS TO BE TAKEN ON VISITS / CONTACTS:

Employees/representatives of DSAs/DMAs will:

• respect personal space – maintain adequate distance from the prospective customer;

• ensure that prospect/ customer is not visited within a period of 3 months of expression of lack of interest for the offering by him/ her.

• not enter the prospective customer’s residence /office against his /her wishes;

• not visit in large numbers, i.e. not more than one employee /representative of the DSA and one supervisor, if required;

• respect the prospective customer’s privacy;

• if the prospective customer is not present and only family members /office persons are present at the time of the visit, he /she should end the visit with a request for the prospective customer to call back;

• provide his /her telephone number, name of the supervisor or the concerned officer of the Company and contact details, if asked for by the customer; and.

• Limit discussions with the prospective customer to the business – Maintain a professional distance.

OTHER IMPORTANT ASPECTS – APPEARANCE & DRESS CODE

Employees/representatives of DSAs/DMAs must be appropriately dressed.

A) For men

·         Well ironed trousers

·         Well ironed shirt, shirt sleeves perfectly buttoned down

B) For women

·         Well ironed formal attire (Saree, Suit etc.)

·         Well-groomed appearance

Note- casual wear, open sandals are not considered appropriate

HANDLING OF LETTERS & OTHER COMMUNICATION

Any communication sent to the prospective customer should be only in the mode and format, as approved by the Company.

If at any stage, if a prospect customer is not satisfied with the service given to him/her he/she can contact the NBFC.

The first point of contact for redressal of any compliant will be the Customer Care. Customer can refer to the Grievance Redressal Mechanism being followed by the company.

QUALIFICATION FOR DSAs/DMAs

There is no specific qualification prescribed, however before engaging the DSAs/DMAs the Company shall ensure that Partnership Deed, Memorandum of Association or any other document evidencing the constitution proof the entity shall contain as one of its main objects as soliciting or procuring DSA/DMA business.

EMPANELEMENT OF DSA/DMA

DSA/DMA seeking empanelment/engagement with Company shall submit the application for empanelment in the illustrative format enclosed as Annexure-2.

OUTSOURCING AGREEEMNT

The agreement executed with DSAs/DMAs will be sufficiently flexible to allow the Company to retain appropriate level of control over the outsourcing firm. The agreement shall be in accordance with the Outsourcing Policy of the Company and will contain below key elements:

a. Activities to be performed

b. ability to access all books, records and information relevant to outsourced activity

c. continuous monitoring and assessment

d. Termination clause and minimum period to execute a termination

e. Contingency plan to ensure business continuity

f. Prior approval for appointment of sub-contractors

g. Right to conduct audits/inspection and access to documents by internal and external auditors, RBI or persons authorized by RBI or other regulators.

h. Confidentiality of customer to be maintained

i. Preservation of documents

Maintenance of Database of DSAs / DMAs

The Company shall maintain up-to-date database of DSAs/DMAs engaged / empaneled with them. The Company shall keep the inspection report of the inspection, whenever conducted in terms of the provisions of the agreement entered into with the DSA/DMA, and action taken report (ATR) thereon

GENERAL

1. The Company may, on intervals as decided by its senior management, review the financial and operational condition of the service providers to assess their ability to continue to meet their outsourcing obligations. Such due diligence reviews, which can be based on all available information about the service provider could highlight any deterioration or breach in performance standards, confidentiality and security, and in business continuity preparedness. Management may fix the criteria’s/threshold/ parameters for review and monitoring.

2. The Company has in place a management structure to monitor and control its outsourcing activities. The Company may provide for in the outsourcing agreements with the service providers certain provisions to address monitoring and control of its outsourced activities.

3. Regular audits by either the internal auditors or external auditors of the Company may be carried to assess the adequacy of the risk management practices adopted in overseeing and managing the outsourcing arrangement, the Company’s compliance with its risk management framework and the requirements of this Code.

4. In the event of termination of the agreement for any reason, the Company may publicize it so as to ensure that the customers do not continue to deal with that service provider.

5. Navin constituted a Grievance Redressal Mechanism within the company and give wide publicity about it through electronic and print media. The name and contact number of designated grievance redressal officer of the Company have be made known and widely publicized. The designated officer would ensure that genuine grievances of customers are redressed promptly without involving delay. Company’s Grievance Redressal Mechanism will also deal with the issue relating to services provided by the outsourced agency.

For details pertaining to grievance redressal mechanism, please refer to grievance redressal mechanism published on website of the Company.

6. NO DSA.DMA shall is allowed to do a fresh business on behalf of Company after termination of agreement until it is renewed.

7. No payment/fees/incentive of DSAs/DMAs will be made in cash.

8. The lead shall be shared by the DSAs/DMAs in the illustrative format as prescribed in Annexure-3 as far as possible, this format is non mandatory.

9. By virtue of contract / agreement, the DSA / DMA or/and its employees / representatives may have access to personal and business information of Company and / or Company’s customer. DSA / DMA shall ensure the preservation and protection of the security and confidentiality of the customer information or data which are in the custody or possession.

10. DSA / DMA/Its employees/representatives should acknowledge that he/she/it has read the said Model Code of Conduct and has fully understood all the terms and conditions mentioned there in and declare that the DSA/DMA shall agree to abide by the said code of conduct in letter and spirit.

11. The DSA / DMA shall report the fraud erring employees / representatives periodically to Company. Such employees / representatives shall be barred permanently for doing the business of DSA / DMA in future with the Company.

12. Where DSA / DMA is seeking of engagement / empanelment with the Company, it or/and its Employees / representative will have to go through with training as organized by the Company. Management may decide upon the mode/manner/content of training.

Signature of DSA for accepted of Code of Conduct / Policy

Annexure-1

Declaration-Cum-Undertaking

Declaration–Cum-Undertaking to be obtained by the DSA/DMA from its employees / representatives

(DSA/DMA Name)

(Address)

(Email ID)

Re: Code of Conduct

Dear Sir / Madam,

I am working in your company as a ______________. My job profile, inter-alia, includes offering, explaining, sourcing, and assisting documentation of products and linked services to prospective customers of Navin Bros. Pvt. Ltd.

In the discharge of my duties, I am obligated to follow the Code of Conduct attached to this document.

I confirm that I have read and understood and agree to abide by the Code of Conduct. I further confirm that the trainer mentioned below has explained the contents of the Code of Conduct in full to me.

In case of any violation, non-adherence to the said Code, you shall be entitled to take such action against me as you may deem appropriate.

Signed on this ________________ day of ________________________ 20____

Signature_________________

Name________________

Agency_____________

Place:

Date:

Signature of Trainer                                        Name                                                    Company

Annexure-2

APPLICATION FORM FOR EMPANELMENT OF DSA / DMA

To,

The Manager

Navin Bros. Pvt. Ltd.,

Palace Court, 1st Floor, FL-43 ,

1 Kyd Street , Kolkata 700016

Sir/Madam,

Sub: Application for empanelment as direct selling agent (DSA) / Direct Marketing Agent (DMA) with Navin Bros. Pvt. Ltd.

I/We submit herewith my/our application for the empanelment as Direct Selling Agent (DSA)/ Direct Marketing Agent (DMA) for Navin Bros. Pvt. Ltd.. I/we have read the terms and conditions relating to the service and I/we undertake that those are acceptable to me/us.

I/We declare that the statements in this application and the documents submitted (as per list given below) are true, complete and correct to the best of my knowledge and belief. I/We declare that no criminal proceedings are pending against me/us. I/we further declare that I/we am not related to any existing employee of                           . I/we understand that in the event of any information/document being found untrue / incorrect at any stage, my application is liable to be rejected and if already empaneled, the empanelment is liable to be terminated.

Place:

Signature:

Date:

Name:

Documents to be submitted along with application

1)Copy of PAN card;

2)*Address proof (latest telephone/mobile bill, electricity bill, gas bill, passport or ration card)

3)*Two recent passport size photographs (in addition to one affixed on application form);

4)*Latest IT Return/Form 16

5)Bank statement for last 6 months;

6)Enrolment letter, if enrolled with other Bank/FI for similar services;

7)In case of firm / Company: Registration certificate of firm & Partnership deed/ Articles of Association of the company, incorporation certificate and last Audited balance sheet.

*Applicable only for Individual

Annexure-3

(Name of Loan product)- Customer information

Name of the Applicant/s:

Mobile No.:

Email ID:

Address:

Select which is applicable: Looking for property/Property identified

Details of Property, if identified:

Loan Amount:

Income bracket (P.A.):

(up to 3 lakh)

(Above 3 lakh to 10 lakh)

(Above 10 lakh)

Income based on : Income tax return/other (if other, please, specify)

DSA Code:

Signature of DSA: