Fair Practice Code

BOARD APPROVED FAIR PRACTICE CODE FOLLOWED BY NAVIN BROS. PVT. LTD.

Pursuant to Reserve
Bank of India (RBI)’s direction RBI/DNBR/2016-17/44 Master Direction No.  NBR.PD.007/03.10.119/2016-17 dated 01/09/2016
(as updated from time to time) issued to Non-Banking Financial Companies
(NBFCs), the Board of Directors have adopted the Fair Practices Code vide its
Board Meeting dated 23/09/2022.

The Fair Practices Code, as adopted herein
below by Navin Bros. Pvt. Ltd. (The Company), is in conformity with the Guidelines
on Fair Practices Code for NBFCs as prescribed by the Reserve Bank of India and
as contained in the aforesaid RBI Circular. It provides information to
customers and explains how the Company is expected to deal with them on a day
to day basis.

This policy applies to all customers
including those with any complaints / enquiries as posted on social / any other
media.

OBJECTIVES & APPLICATION

• To promote good & fair practices
  by setting reasonable Standards in dealing with Customers.
• To increase transparency so that the
  Customers can have better understanding of what they
  can reasonably expect of the Services and take informed decisions.
• To encourage market forces, to
  achieve higher Operating standards.
• To promote a fair & cordial
  relationship between Customer & the Company.
• To promote Customer first and provide
  better Customer Satisfaction and Services.
• Building customer confidence in the
  company  

APPLICATION OF THE FPC

The Code applies to
all the Products & Services offered by The Company and all the offices and
all employees of The Company or its associates or agents (as per respective
applicability).

TO ACT FAIRLY AND IN A TRANSPARENT MANNER

• The Company shall act fairly and
  reasonably in all dealings with Customers by ensuring that.
  • The commitments and standards
    prescribed in this Code are met for all Products, Services, Procedures,
    & Practices.
  • Company’s Products & Services
    meet relevant Laws & Regulations in letter & spirit.
  • Company’s dealings with Customers
    rest on the Ethical Principles of Integrity & Transparency
• Company will transparently disclose
  to the applicants/borrower all information including fees / charges
  payable for 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 reset clause and any other matter which affects the
  interest of the borrower. Presently the
  company will not charge any non-refundable loan application fees incase the customer don’t accept the sanction terms offered by the
  company.
• The Company will disclose ‘all in cost’ inclusive of all
  charges involved in processing / sanction of loan application and charges
  applicable thereafter in a transparent manner. The Company ensures that
  such charges/ fees are non-discriminatory.

The company follows
the following procedure in true spirit:

·        
All the communications with
the proposed customer/borrower will be either in English or the vernacular language as understood/preferred/agreed
by the proposed customer /borrower.

I.             Applications for
loans and their processing

a)            The Application Form of the company for products/services offered by
the Company is different depending upon the requirement of each product/services
and will indicate list of information/documents
that is required to be submitted by the Borrower with loan application. Loan
application forms will include necessary information which affects the interest
of the borrower (so that a meaningful comparison with the terms and conditions
offered by other Bank/NBFC/FI’s can be made) and informed decision can be taken
by the borrower.

b)            Acknowledgement
receipt of all loan applications
will be issued with indicative time frame for disposal of
application being received.

II.            Loan appraisal and
terms/conditions

a)                 
The company will convey in
writing to the borrower by means of sanction
letter or otherwise, the amount of loan sanctioned along with terms and
conditions including Annualized rate of interest
(ROI) and method of application of ROI. Also all the fees are mentioned on
Annualised Percentage Rate and the
contingent payments like the Panel
Interest applicable on default
will be mentioned in bold in the
loan agreement.

b)                 
All major fixed fees , Rate of Interest and Contingent event based
fees like delay charges and panel interest will be also mentioned on Annualised Percentage Rate  (wherever possible) in Key Fact Statement and Sanction letter
& also loan agreement.

c)                  
All the Contingent charges
will be calculated on outstanding /
default amount whichever is lower.

d)                 
A copy of the loan agreement
as understood/agreed by the borrower along
with a copy each of enclosures
quoted in the loan agreement will be
furnished to all the
borrowers at the time of disbursement of loans by email/same mode used for
application of loan.

e)                 
The company will send a communication
of rejection of Loan Application to the customer along with the reason(s)
for rejection.

III.           Loan Sanction / Disbursement
and changes in terms and conditions

a)                 
Loan disbursement will be
made in accordance with the disbursement
schedule as per sanction terms and as agreed/accepted by the borrower.

b)                 
Customers would be informed regarding changes to Terms &
Conditions including disbursement schedule, interest rates, service charges,
prepayment charges, other applicable charges etc.

c)                  
Notice to the borrower of any change in the terms and conditions
including disbursement schedule, interest rates, processing charges, prepayment
charges, etc. will be furnished by same mode by which borrower was communicated
Sanction / Disbursement / Loan Agreement.

d)                 
Any changes in interest rates and charges are affected only prospectively giving due notice.  Suitable condition
in this regard will be incorporated
in the loan agreement of customers.
 If such change is to the disadvantage of the Customer, he / she may
within 60 days & without Notice close his / her Account or switch it
without having to pay any extra charges or interest

e)                 
Decision to recall / accelerate
payment or performance under the agreement
will be in consonance with the respective
loan agreement.

f)                  
In cases where company holds Security documents/ Interest, the Company
will release all securities on repayment
of all dues or on realization of the
outstanding amount of the loan subject to any legitimate right or lien for any
other the company claim may have against borrower. If such right of set off is
to be exercised, the borrower will 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/all dues of the
Company is settled/ paid.

g)                 
No objection certificate will be issued to the borrower/customer
on repayment of all dues within 30
workings days of completion of payment including all charges/fees, if
applicable, as per the product type and will be sent to borrower though medium
used for application of loan/email, unless otherwise requested by
borrower/customer.

h)                 
The following Key Fact
Statement will form part of all Loan
Agreement / Credit Agreement and applicable extract of the same shall also
be included in Sanction letter

Key Fact Statement
LOAN
………. (NAME OF THE SPECIFIC LOAN PRODUCT)

Detailed Repayment Scheduled

IV.          General terms and
condition of loan

a)            The Company will refrain from
interference in the business affairs of the borrower except for the purposes
provided in the terms and conditions of the loan agreement. However the company
may enquire/call for information to its satisfaction/ interfere incase new
information, not earlier disclosed by the borrower and has come to the notice
of the Company post sanction / disbursement of loan.

b)            In case of receipt of request from
the borrower for transfer of borrower
account, the consent or otherwise i.e. objection shall be conveyed within 21
days from the date of receipt of request. Such transfer will be as per
transparent contractual terms in consonance with all the applicable laws.

c)            In the matter of recovery of loans,
the Company will not resort to undue
harassment viz. persistently bothering the borrowers at odd hours, use of
muscle
power for recovery of loan, etc. The staffs will be adequately trained to deal
with
the customers in an appropriate manner. Steps will be taken to ensure adherence
to the same and number of complaints received towards harassment or rude behaviour
or similar bad recovery processes will be brought to notice of the senior
management of the company.

d)            The Company will not charge foreclosure / pre-payment penalties on all floating rate loans sanctioned to individual borrowers for purposes other than
business with or without co-obligant(s) and such terms will be clearly be
spelled out in the sanction/disbursement documents. 

V.            Board Approved policy towards Grievance Redressal Mechanism & Grievance
Redressal Officers:

In the present competitive scenario,
excellent customer service is an important tool for sustained business growth.
Customer complaints are part of the business life in any corporate entity.

At the company, customer service and
satisfaction are our prime focus. We believe that providing prompt and
efficient service is essential not only to attract new customers, but also to
retain existing ones. The Company has come up with a lot of initiatives that
are oriented towards providing a better customer experience and an efficient
complaints redressal mechanism with a view to providing enhanced experience to
our customers.

In order to make the companies redressal
mechanism more meaningful and effective, a structured system has been built.
This system would ensure that the redressal sought is just and fair and is
within the given frame-work of rules and regulation.

a)            The Company has laid down the
appropriate grievance redressal mechanism within the organization to resolve
disputes arising out of various lending decisions/customer complaints. Such a
mechanism ensures that all disputes/complaints arising are heard and disposed
of at least at the next higher level.

b)            The Board of Directors will also
periodical review 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 will be submitted to the Board of Directors
at regular intervals, as may be prescribed by it from time to time.

c)            Response to a complaint would be
given within a period of one month from the date of complaint, unless the
nature of complaint requires verification of facts and figures.

d)            The company will ensure that the
following Grievance Redressal Mechanism with Officers details is being
displayed at a prominent location of the company for benefit of the customers
including its website:

Customers are free to bring any
Grievance against the company, its employees or its authorised agents to the
notice of the following officers which will be dealt in best possible manner.

Customers who wish to provide
feedback or send in their complaint may use the following channels:

§ 
Call on 94776 69237

§ 
Email us on cc@ navinbros.in

§ 
Write to us at the below mentioned address

Grievance Redressal Team
Navin Bros. Pvt. Ltd.

Palace court, 1st Fr, FL-43, 1
kyd street, Kolkata 700016

In case the complaint is not
resolved within a period of one month or if he/she is not satisfied with the
solution provided by the Company, the customer can approach the Complaints
Redressal Officer as per followings:

First Level of Grievance
Redressal Officer/ Fintech Grievance Officer:

a) Name of Grievance Redressal
Officer/ Fintech Grievance Officer – Arup

b) Telephone Number –94776 69237

c) Email Id – grievance@ navinbros.in 

In case the complaint is not
resolved within a period of one month or if he/she is not satisfied with the
solution provided, the customer can approach

Second Level Grievance
Redressal Officer:

a) Name of
Grievance Redressal Officer/ Nodal Officer – Shib

b) Telephone Number
–94776 69237

c) Email Id –  shib@navinbros.in

Final Level : Nodal Officer –94776 69237/ nodal@ navinbros.in 

If the complaint/ dispute is
not resolved within 1 month customer may prefer appeal at:

a)     
The Officer In-Charge, Consumer
Education and Protection Cell

Reserve Bank of India 15, Netaji Subhas Road Kolkata-700 001           

The process of the complaints redressal
unit will ensure closure of all complaints to the customers’ satisfaction. They
will ensure that the complaint is escalated to the appropriate levels in case
it is not possible to resolve at his/her level. Whilst the ultimate endeavour
is to ensure we reach a situation where our customers don’t have to complain to
senior management to get an effective redressal, we have put in a robust
mechanism to handle these complaints, review them from a point of view of
understanding reasons for the complaint and for the escalation and working on
prevention of recurrence thereof.

VI.          Regulation of
Interest to be charged from the borrower.

a)            At the time of availing of a loan,
the Company will provide the borrowers
with information on the annualised interest rate payable by
them and adhere to it.

b)            The loan agreement will contain
sufficient information about interest,
charges, approach followed by the company towards grading of risks and
rationale and other important information.

c)            If Company increases any charges or introduces a new charge, shall notify the same to the borrowers and will also be
placed on the website of the company
and it will be applicable prospectively.

d)            The company will not charge excessive interest than allowed by the regulator at any
point of time.

e)            Copy of Board approved policy
document adopting the interest rate
model taking into account the relevant factors such as cost of funds,
margin and risk premium to determine rate of interest to be charged for loans,
Interest rate application as per gradation of risk and rationale for charging
different rate of interest to different
categories of borrowers are mentioned on interest rate model followed the company and is communicated to the borrower along with
Sanction letter and also available on website
of the NBFC.

VII.         Other Terms

a)     
The Company is not yet financing loan again vehicles. Once the company
starts vehicle finance product, it shall immediately update the FPC and include
the terms and condition and procedure for repossession of vehicle against
financed loan.

b)     
The company is not yet lending to individual against gold as security,
once any such                 loan product
is announced by the company, it shall adopt gold lending guideline in the FPC.

VIII.        Customer’s Data Confidentiality

The company might collect data
from customer which it feels are necessary for processing the loan based on
nature of product it offers. The Loan
Application process/ Form will capture
details of all such requirement and copy of such data being taken/captured
with company from customer will be made available as part of loan agreement/ annexure thereon. All
personal information of present and past customers will be treated as private
and confidential. The Company will not reveal information or data relating to
customer accounts, whether provided by the customers or otherwise, to anyone,
other than in the following exceptional cases:

a)     
If the information is to be given by law

b)     
If there is a duty towards the public to reveal the information.

c)      
If Company’s interests require them to give the information to prevent
fraud etc. Customer’s information shall not be given to anyone for marketing
purposes except with his/her permission.

d)     
If the Customer asks Company to reveal the information, or with the
Customer’s permission.

e)     
If Company is asked to give a reference about a Customer, the Company
will obtain his / her written permission before giving it.

f)      
If the Customer account is due / in default than his data will be
shared with respective Collection Agent / Agency/Loan Service Provider hired by
the NBFC on need to know basis. Information of such agent / agencies who are /
will be authorised by the NBFC will be sent to the customer by email/sms/whatsapp/letter
and list of all such agencies will also be made available on the website of the
nbfc i.e. www.navinbros.in

g)     
NBFC will share Customer data and information including Loan, repayment
track and history with Credit Bureaus. Any default / due amount will also be
informed which may impact the credit score / customer’s ability to get credit
from others. Customer can seek information being sent to credit bureau agencies
from NBFC by writing to customer care email id. 

IX.           Collection of Dues

a)     
Whenever loans are given, the Company
will inform to the customer and also include in Sanction letter the repayment process by way of amount, tenure and periodicity of
repayment.

b)     
The Company will also inform to the customer that on non-adherence to repayment schedule,
all the actions in accordance with the laws of the land for recovery of dues
such as reminding the customer by sending him / her notice or by making
personal visits and / or take all legal steps for repossession of security (if
any).

c)      
Company’s Collection Policy is built on courtesy, fair
treatment & persuasion. Company believes in fostering customer confidence
& long-term relationship. Company’s Staff or any person authorized to
represent in collection of dues or / & security repossession shall identify
himself / herself & display the Authority Letter issued by Company &
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 & shall endeavour to give sufficient Notice for
payment of dues.

d)     
The Company will provide customers with all the information regarding
dues and on case to case basis give sufficient notice for payment of dues.

e)     
All the members of the staff or any person authorized to represent the
Company in collection or / and security
repossession should follow the guidelines
set out below:

                    
i.           
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, from reference if customer is not reachable on contact details
available with the Company.

                  
ii.           
Identity and authority to represent the Company would be made known to
the customer at the first instance.

                 
iii.           
Customer’s privacy would be respected.

                
iv.           
Interaction with the customer shall be made in a civil manner

                  
v.           
Company’s representatives shall contact the customers between 08.00 hrs
and 20.00 hrs, unless the special circumstances of the customer’s business or
occupation require otherwise or he has specially requested to connect on other
time.

                
vi.           
Customer’s request to avoid calls at a particular time or at a
particular place shall be honoured as far as possible.

               
vii.           
Time and number of calls and contents of conversation would be
documented.

             
viii.           
All assistance should be given to resolve disputes or differences
regarding dues in a mutually acceptable and in an orderly manner.

                
ix.           
During visits to customer’s place for dues collection, decency and
decorum would be maintained.

                  
x.           
Inappropriate occasions such as bereavement in the family or such
other calamitous occasions would be avoided for making calls/visits to collect
dues.

Further apart from above, our person and
agents abide by the following Do’s and Don’ts to help serve our customers
better

X.            General Terms

a)     
To verify the details mentioned in the Loan Application company may
check about applicant by contacting them at their residence & / or on
business telephone numbers & / or physically visiting their residence &
/ or business addresses through staff or through Agencies appointed for this
purpose, if deemed necessary.

b)     
The customer shall be informed to co-operate if the Company need to
investigate a transaction on the customer’s Account & with the police /
other Investigative Agencies, if Company need to involve them.

c)      
Company shall advise the customer that if the customer acts
fraudulently, he / she will be responsible for all Losses on his / her Account
& that if the customer acts without reasonable care & this causes
losses, the customer may be held responsible for the same.

d)     
Giving Customers information about Products & Services in any of
the following Languages English or the appropriate vernacular Language as
agreed by customer during application.

e)     
Company will not discriminate
on the basis of Age, Race, Caste,
Gender, Marital Status, Religion, or Disability. However, the restrictions on Age/ or any other product
based distinction, if any, will be mentioned
on Loan Products application form
beforehand.

f)      
Each application shall be considered independently on merit, upon
scrutiny of all the information, documents required for verifying identity/
entity and the security to be offered, including guarantees, fetching reports
from Bureau’s, etc.

g)     
Company shall process requests for transfer of a loan account, either
from the borrower or from a bank / financial institution, in the normal course.

FORCE MAJEURE

The Various
commitments outlined and made by the company are applicable under the normal
operating environment. In the event of Force Majeure, the Company will not be
able to fulfil the commitments under the Fair Practice Code to the entire
satisfaction of the customer/s and the public in general.

The Board of
Directors reserves all the right to amend the code from time to time and
updated copy of FPC will always be available on the website of the company.