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 +91-90212 77000 . 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
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 the matter of recovery of loan, the Company shall follow the usual measures as per the guidelines and existing provisions and would operate within the legal framework and in compliance with the applicable laws and regulations.
  • The Company will not resort to undue harassment, viz., persistently bothering the customer, at odd hours, use of muscle power for recovery of loans etc. In this regard, Company shall follow an ethical code of conduct for debt collection wherein our staff or any person authorized to represent the Company in collection of dues are extensively trained.
  • Company’s collection policy is built on courtesy, fair treatment and persuasion. We believe in building customer confidence and a long-term relationship with them. Our staff or any person authorized to represent us in collection of dues or/and security repossession will identify himself/herself and interact with our customers in a courteous and polite manner.
  • We will provide our customers with all the information regarding dues and will give sufficient notice for payment of dues. All customers will be contacted ordinarily at the place of their choice, in the absence of a specified place at the residence of the customer and if the customer is unavailable at the residence, at the customer’s place of business/occupation.
  • We will respect privacy of the customer and all our interactions will be in a civil manner. All assistance will be provided to our customers to resolve differences or disputes in a mutually acceptable manner, if any, regarding the dues.
  • 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.