This has reference to RBI Circular No. RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated 01 st July, 2015, wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices Code for NBFCs to implement the same.

This Fair Practices Code (the “Code”) sets out the minimum practices to be followed by Gromor Finance Private Limited (formerly known as Sahayata Savings And Investments Private Limited) (hereinafter referred to as “the Company”) while dealing with customers. This Code is formulated in pursuance of the guidelines issued by the Reserve Bank of India on fair practice code for NBFCs, to ensure better service and provide necessary information to customers to take informed decisions.

OBJECTIVES OF THE CODE:

This Code has been developed:

1. To promote and ensure good and fair practices while dealing with customers.
2. To provide the necessary information to the customers and to increase transparency in order to enable customers to take informed decisions and to appraise them of the services rendered by the Company.
3. To promote a fair and cordial relationship with the customers.

The Company would adhere to the Fair Practices Code mentioned herein below in its functioning as a Non-Banking Finance Company.

APPLICATION FOR LOANS AND THEIR PROCESSING:

1. All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
2. Loan application forms shall include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form shall indicate the documents required to be submitted along with the application form.
3. The Company shall provide acknowledgement for receipt of all loan applications. The acknowledgement includes the time frame within which loan applications will be disposed off.

LOAN APPRAISAL AND TERMS / CONDITIONS:

1. The Company shall convey in writing to the customer/borrower in the vernacular language as understood by the customer/borrower by means of a Sanction Letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof. It would keep the acceptance of these terms and conditions by the customer/borrower on its record.
2. The Company shall mention the penal interest charged for late repayment in bold in the loan agreement.
3. The Company shall furnish a copy of the loan agreement as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS:

1. The Company shall give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc.
2. The Company shall ensure that changes in interest rates and charges are effected only prospectively. The loan agreement shall contain the necessary provisions in this regard.  Decision to recall / accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
3. The Company shall release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company shall have against the borrower. 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 till the relevant claim is settled/paid.

GENERAL PROVISIONS:

1. The Company shall refrain from interference in the affairs of the borrower except for the purposes provided for in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
2. In case of receipt of request from the borrower for transfer of Borrower account, the consent or otherwise i.e., objection of the Company, if any shall be conveyed to the borrower within 21 days from the date of receipt of any such request. Such transfer shall be as per transparent contractual terms in consonance with law.
3. In the matter of recovery of loans, the Company shall not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. Training will be imparted to ensure that staff is adequately trained to deal with customers in an appropriate manner.

RESPONSIBILITY OF BOARD OF DIRECTORS:

1. The Board of Directors of the Company shall lay down the appropriate grievance redressal mechanism within the organization to ensure that all disputes arising out of the decisions of company’s functionaries are heard and disposed of at least at the next higher level of the organization as may be determined by the Board of Directors of the Company.
2. The Board of Directors shall also provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.
3. A consolidated report of such reviews shall also be submitted to the Board at regular intervals.

GRIEVANCE REDRESSAL MECHANISM

The Customers who wish to provide feedback or send in their complaints may use the following channels between 10.00 am to 6:00 pm from Monday to Friday (except on public holidays). The name and contact details of the Grievance Redressal Officers who may be approached for the resolution of complaints against the Company are as under:
Grievance Officer Name: Rashi Kataria
Email address: rashi.kataria@gromor.in
Telephone: 9589078309
The Grievance Officer can be contacted between 10:00 a.m. to 6:00 p.m. from Monday to Friday except on public holidays.

In case complaint / dispute is not redressed within a period of one month or if the borrower /customer is not satisfied with the decision of the Grievance Redressal Officer, the borrower /customer may appeal to the Officer-in-Charge of the Regional Office of DNBS of Reserve Bank of India at the below address:
Officer-in-Charge
Reserve Bank of India
Department of Supervision, 4th Floor, Byculla Office Building, Opp. Mumbai Central Station, Byculla, Mumbai - 400 008
Phone: 022 23028140
Fax No.: 022 23022024
Email ID: nbfcomumbai@rbi.org.in

RATE OF INTEREST:

1. The Company shall frame appropriate internal principles and procedures for determining the rate of interest and processing and other charges, if any, in order to ensure that rate of interest are not excessive and are sustainable and conform to the normal financial practice.
2. The Board of the Company shall 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.
3. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
4. The rate of interest shall be annualized rate so that the borrower is aware of the exact rates that would be charged to the account.

PERIODIC REVIEW

The Company shall abide by this Fair Practice Code following the spirit of the Code and in the manner it may be applicable to its business. The Company would also review and refine the FPC, as may be required periodically – based on its own experience and fresh guidelines, if any, to be issued by the RBI in this regard.