Fair Practices Code

FAIR PRACTICES CODE AND GUIDELINES
 
Ashish Securities Pvt. Ltd. (“Company”) – Fair Practices Code Policy (“Code”)

This is with reference to the guidelines issued by the Reserve Bank of India on Fair Practice Code for all Non-Banking Financial Companies (NBFCs) vide RBI circular RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 1, 2015.

This Code is aimed to provide to all the stake holders, including but not limited to the Company’s customers, an effective overview of the practices followed, in respect of the services offered by the Company.

The objectives of this Code are:
  • To implement and promote industry standard practices in dealing with customers;
  • To promote a fair relationship between the customer and the Company;
  • To ensure compliance with applicable laws and regulations in matters relating to recovery of loan amount;
  • To create and maintain adequate mechanisms for redressal of customer grievances;
Loan Application
  • The Company shall provide the borrower the information, required in relation to the services, so that the borrower can make a meaningful comparison with the terms and conditions offered by other NBFCs and make an informed decision.
  • The Company shall give an acknowledgement of receipt for all loan applications. The Company shall endeavour to provide the time frame within which loan applications shall be processed.
  • The loan application form shall indicate the documents required to be submitted along with the application form.
  • 4If any additional details/ documents are required, the same shall be reasonably intimated to the borrowers.
Loan Appraisal and Terms & Conditions
  • The Company shall convey in writing to the customer, by means of a sanction letter or any other document, the amount of loan sanctioned along with the terms and conditions including applicable rate of interest and shall maintain, in its record, the acceptance of these terms and conditions by the customer.
  • Company shall mention the charges and penal interest charged for late repayment or prepayment in bold in the loan agreement to be executed between the customer and the Company.
  • Upon the execution of the loan agreement, the Company shall furnish a copy of the loan agreement along with a copy of all annexures attached to the loan agreement, to the customer.
Disbursement of loans including changes in terms and conditions:
  • The Company shall give notice in English, for any change in the terms and conditions – including disbursement schedule, interest rates, service charges, prepayment charges etc. In case the customer has given a declaration in the vernacular language that he/she does not understand English, he/she will be communicated to in the vernacular language.
  • The Company shall, in the loan agreement to be executed between the Company and the customer, ensure that changes in interest rates and charges are effected only prospectively.
  • Any decision to recall/accelerate payment or performance under the loan agreement shall be inconsonance with the respective loan agreement.
  • The Company shall, subject to the respective loan agreement, release all securities pertaining to the loan on receipt of full and final payment of the loan amount, other than any legitimate right or lien, and set-off for any other claim that the Company may have against the customer. If such right of set-off is to be exercised, the borrower shall 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 until the relevant claim is settled / paid.
Interest Charged:
  • The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.
  • The Company would adopt an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, and determine the rate of interest to be charged for loans and advances.
  • The rates of interest and the approach for gradation of risks shall also be made available on the Company’s website. The information published in the website or otherwise published should be updated whenever there is a change in the rates of interest.
  • The rate of interest should be an annualised rate so that the customer is aware of the rates that would be charged to the account.
Grievance Redressal Mechanism:
The company aims to provide the best customer service and is consistently striving to create a robust and efficient customer service platform. If the customers have any issues or wish to register a complaint, they can reach the Company at any of the following coordinates:
  • Step 1 Telephone: The customer can call us and log his/her grievances at +91-8030077553 . Email: Customers can write to us at the given e-mail ID: Care@EarlySalary.com .Alternatively, customers can also write to us at: Ashish Securities Pvt. Ltd., 701, Lunkad Sky Vista, Near Dorabjee’s, Viman Nagar, Pune 411 014
  • Step 2 :If the resolution received does not resolve the customer complaint, he or she can write to our Complaints Management Cell, Attention: Mr. Rajendra Sahu (Manager – Operations) on Complaints@EarlySalary.com * Please quote your Customer ID in your email, which is indicated in the subject line of the resolution in Step 1. Company will endeavour to respond within 7 business days of our receiving the complaint.
  • Step 3 If the customer is still dissatisfied with the resolution received, he or she may write to our Grievance Redressal Officer, Mr. Amit Nosina, on Grievance@EarlySalary.com. * Please quote your Customer ID in your email, which is indicated in the subject line of the resolution in Step 2. Company will endeavour to respond within 7 business days of our receiving the complaint.
  • If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of RBI under whose jurisdiction the Registered Office of the ASPL falls. The details of DNBS is as given below:
    Dy. General Manager, Department of Non-Banking Supervision
    15, Nataji Subhas Road, Kolkata- 700001
    Tel: 033-2230 7850/ 8331 Fax:033 2231 3185
Collection of Dues:
  • a. Whenever we give loans, we will explain to you the repayment schedule, viz. amount, tenure and periodicity of repayment. However, if you do not adhere to repayment schedule, a defined process in accordance with the laws of the land will be followed for recovery of dues.
  • b. We will have a Board approved policy for Collection of Dues as also appointment of Recovery Agents.
  • c. All relevant laws, regulations, guidelines and conditions of approval, licensing or registration will be taken into account when appointing Recovery Agents.
  • d. We will ensure that our Recovery Agents are properly trained to handle their responsibilities with care and sensitivity. We will also ensure that they do not exceed their brief. e. Our collection policy is built on courtesy, fair treatment and persuasion. We believe in fostering customer confidence and long term relationship.
  • f. We will provide you with all the information regarding your dues and will endeavour to give sufficient notice for payment of dues.
  • g. We will have a system of checks before passing on a default case to recovery agencies so that you are not harassed on account of lapses on our part.
  • h. We will write to you when we initiate recovery proceedings against you and will inform you of the name of the recovery agency/ agent, to whom your case has been assigned as also their address and telephone numbers.
  • i. We will provide details of the recovery agency firms / companies engaged by us on our website.
  • j. We will also make available, on request, details of the recovery agency firms/companies relevant to you at our branches.
  • k. Our staff or any person authorized to represent us in collection of dues or/and security repossession will identify himself/herself and produce the authority letter issued by us and upon request show you his/ her identity card issued by the Company or under authority of the Company.
  • l. All the members of our staff or any person authorised to represent us in collection or/and security repossession would follow the guidelines set out below:
    • i. You would be contacted ordinarily at the place of your choice and in the absence of any specified place at the place of your residence and if unavailable at your residence, at the place of business/occupation.
    • ii. Identity and authority to represent would be made known to you.
    • iii. Your privacy would be respected.
    • iv. Interaction with you would be in a civil manner.
    • v. Normally our representatives will contact you between 0700 hrs and 1900 hrs, unless the special circumstances of your business or occupation require otherwise.
    • vi. Your requests to avoid calls at a particular time or at a particular place would be honoured as far as possible.
    • vii. Time and number of calls and contents of conversation would be documented.
    • viii. All assistance would be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
    • ix. During visits to your place for dues collection, decency and decorum would be maintained. Our officials /agents will not resort to intimidation or harassment of any kind, either verbal or physical against any person, including acts intended to humiliate publicly or intrude the privacy of your family members, referees and friends, making threatening and anonymous calls or making false and misleading representations. However, it is your responsibility to keep updating your contact details. In case the Company is unable to contact you on the details provided, the Company will access information available from public/private sources and approach your friends / relatives to trace you.
    • x. Inappropriate occasions such as bereavement in the family or other important family functions like marriages would be avoided for making calls/visits to collect dues.
    • xi. We will investigate any complaint from you about unfair practices of our recovery agents.
General:
  • The Company will refrain from interfering in the affairs of the customer except for the purposes provided in the term and condition of the Loan Agreement unless new information not earlier disclosed by the borrower has come to the notice of the Company.
  • In case of receipt of a request from the borrower for transfer of the borrower account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms in consonance with law.
  • The ‘Vernacular Declaration’ shall be taken from all the customers stating “In case the customers are unable to understand the contents in English Language, we request you to contact us at any of the branches or on the contact details as available on the website; “www.earlysalary.com”.
  • At our branches, we display the name and contact details (Telephone / Mobile nos. / Email Address) of the Grievance Redressal Officer, Regional Office of the RBI and Grievance Redressal Mechanism followed by us.
Review:
The Board of Directors shall conduct a periodical review of the compliance of this Code and the functioning of the Grievances Redressal Mechanism at various levels of management.The Company shall display and maintain this Code on its web site, for the information of/to the various stakeholders. The Company would also review and refine the Code periodically, as required from time to time, based on its own experience and new guidelines, if any, to be issued by the Reserve Bank of India in this regard.