Fair Practice Code – 2022

Version: 1.1

Serial No.	Document Title	Fair Practice Code
1	Version	1.1
2	Date of Preparation	06-10-2022
4	Validity	One year or as and when required whichever is earlier
5	Document Owner	Ashish Kothiyal – Head Compliance

Action	Name & Designation	Date
Approved by	Mohit Chhajer – Director	October 11, 2022
Reviewed by	Ashish Kothiyal – Head Compliance
Prepared by	Gigyasa Agrawal – Company Secretary

Change Log:

Version No.	Date of Change	Change Description
V 1.0		New policy in place
V1.1	11.10.2022	Changes in format and Grievance redressal mechanism

Fair Practices Code

Preamble

Nahar Credits Private Limited (“NCPL”/ “the Company”) endeavors to formulate policy on “Fair Practices Code’ (FPC). The Reserve Bank of India (RBI) has issued directives on Fair Practices Code for Non-Banking Financial Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers vide Circular No. DNBS (PD) CC No.80/03.10.042 /2005-06 of September 28, 2006, RBI/2010-11/25DNBS (PD) CC No.185/03.10.042 /2010-11 dated July 1, 2010, RBI/2011-12/470 dated March 26, 2012, and RBI /2012-13/416 dated February 18, 2013, and Chapter V of the RBI Master Direction DNBR. PD. 008/03.10.119/2016-17 September 01, 2016 (as modified, amended, and updated from time to time, the “FPC”).

It is, and shall be, our policy to make credit products available to all qualified applicants without discrimination based on race, caste, color, religion, sex, marital status, age, or handicap.

Our policy is to treat all the clients consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. We will also communicate our Fair Practices Code to our customers by placing it on the company’s website.

We will ensure that the implementation of the Fair Practices Code is the responsibility of the entire organization. The Company’s Fair lending practices shall apply across all aspects of our operations including marketing, loan origination, processing, servicing, and collection activities. Our commitment to Fair Practice Code would be demonstrated in terms of employee accountability, monitoring and auditing programs, training, and technology.

The Company’s Board of Directors and the senior management team is responsible for establishing practices designed to ensure that our operations reflect our strong commitment to fair lending and that all employees are aware of that commitment.

The Fair Practices Code applies to the following areas:

Applications for loans and their processing
Loan appraisal and terms/conditions
Disbursement of loans including changes in terms and conditions
Advertising and Marketing
General Provisions
Interest Rate Policy
Responsibility of Board of Directors
Grievance Redressal Mechanism

1. Application for Loans and their processing

All communications to the borrower shall be in English or vernacular language or a language as understood by the
Loan application forms of the Company will include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other Non- Banking Financial Companies (NBFCs) can be made and informed decision can be taken by the prospective
The loan application form shall indicate the documents required to be submitted with the application form. Indicative list of KYC documents such as address proof, Identity proof, income proof etc. will be submitted together with the duly completed application
We shall give acknowledgement for receipt of all loan applications. An indicative time frame within which loan applications will be disposed of will be indicated in the
All loans sanctions are subject to completion of credit appraisal and verification procedures. The applications that do not meet the requisite criteria are declined. The loan status whether a sanction or a decline is promptly communicated to the customer in writing or

2. Loan appraisal and terms / conditions

Loan applications are subject to the credit appraisal process followed at NCPL.
At the time of loan sanction, a sanction letter indicating the loan amount sanctioned, method of application of that loan amount, the annualized rate of interest applicable to the borrower, processing fees, loan tenor, Equated Monthly Instalment (EMI) payable, other applicable fees and charges and other details as applicable, shall be conveyed to the loan applicant in writing in the vernacular language as understood by the
NCPL shall mention the penal interest / liquidated damages / additional interest to be charged for default or late payment of dues ‘in bold’ in the loan / facility agreement, besides mentioning prepayment
The loan disbursement process would be initiated on receiving the written acceptance of such terms and conditions as mentioned in loan / facility agreement. This written consent of the applicant shall be retained by NCPL and maintained in its records. A copy of the loan agreement shall be furnished to all borrowers at the time of disbursement of loans or shall be sent along with the welcome

3. Disbursement of loans including changes in terms and conditions

NCPL shall give notice to the borrower in English or vernacular language or language as understood by the borrower through electronic means including but not limited to e-mail, fax or in writing, of any changes to the terms and conditions, including disbursement schedule, interest rates, service charges, prepayment charges
For account specific charges, the changes will be communicated individually to the borrower through electronic means including but not limited to e-mail, fax or in writing. Other charges such as bounce cheque charges, late payment charges, cheque swap charges, statement of account, documentretrieval charges, prepayment charges, re-booking charges, re-pricing charges, cancellation charges, PDC replenishment charges and other incidental charges are applicable depending on the product / scheme opted by the These charges shall be standard across customers irrespective of their credit worthiness and /or credit history.
Changes in the interest rates and charges/ levies will be affected only
The decision of the Company to recall / accelerate payment or performance under the agreement shall be in accordance with the terms and conditions in accordance with the agreement and duly acknowledged by the
All securities pertaining to the loan would be released on receipt of full and final payment of the loans, subject to any legitimate right or lien, and set-off for any other claim that NCPL may have against the borrowers. If such right of set-off is to be exercised, the borrower shall be given prompt notice about the same, with full particulars about the remaining claims and the conditions under which NCPL is entitled to retain the securities until the relevant claim is settled / paid.

4. Advertising and Marketing

We will ensure that all advertising and promotional material is clear, fair reasonable and not misleading.
We will provide the customers with a full range of financial products the customer is eligible for. Some of these products / services will be our own; some others may be the products of the companies with which we have tie-up arrangements. We will inform the customer of these companies with which we have entered a business arrangement and if the customer so desires, we will direct the staff / agents of the company for marketing their products /

5. General Provisions

NCPL shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions for of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of NCPL).
In case of receipt of request from the borrower for transfer of borrowed account, the consent or otherwise i.e. objection of the NCPL, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.
In the matter of recovery of loans, NCPL representatives shall not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. NCPL shall ensure there is no rude behavior from its staff towards customers for which staff will be adequately trained to deal with the customers in an appropriate
There shall be no discrimination in extending products and facilities including loan facilities to the physically/ visually challenged applicants on the grounds of
The clarification issued vide RBI/2019-20/30 DNBR (PD) No.101/03.10.001/2019-20 dated August 02, 2019 on ‘Levy of foreclosure charges/ pre-payment penalty on Floating Rate Term Loans’ state any floating rate term loan lend to individual borrowers for purposes other than business shall not attract foreclosure charges/ pre-payment penalty. The status of co-borrower shall not be relevant for this clause.

6. Interest Rate Policy

The borrower will be communicated the annualized rate percentage in the sanction document while communicating the approval of a
This rate of interest is arrived at through NCPL interest rate model which takes into account relevant factors such as cost of funds, margin and risk
We take a comprehensive approach to the gradation of risk that does not discriminate between classes of borrowers, but rather tailors the interest rate to each
The decision to give a loan and the rate of interest thereon are carefully assessed on a case-by-case basis based on multiple factors which may include the borrower’s cash flows (past, current and projected), borrower’s other financial commitments, the borrower’s credit record, the security for the loan as represented by underlying assets or other financial guarantees
Such information is gathered based on information provided by the borrower, credit reports, market intelligence and information gathered by field inspection of the borrower’s premises.
The approved Interest Rate Policy shall be published on the website of the

7. Responsibility of Board of Directors

NCPL has laid down an appropriate grievance redressal mechanism within the organization. Such a mechanism ensures that all disputes arising out of the decisions of NCPL are heard and disposed of at least at the next higher level. The Board of Directors of NCPL also reviews the compliance of the Fair Practices Code and the functioning of the grievance’s redressal mechanism at various levels of management.

8. Grievance Redressal

NCPL’s policy is to treat and service all the clients consistently and fairly. NCPL has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard. This mechanism shall ensure that all disputes arising in connection with any matter pertaining to business practices, lending decisions, credit management and recovery decisions shall be heard, and the response would be sent for such complaint /

Customer can forward the complaint through any of the below modes of communication namely:

E-mail us at grievance@naharcredits.in
Write to us at:

Nahar Credits Private Limited

Corporate Office-Bangalore: Ground Floor, Indiqube Celestia, No. 19 & 20, Koramangala 1A Block, Bangalore-560034

Visit the nearest Branch of NCPL.

All the customer queries and complaints registered through the above channels shall be reviewed, monitored, and resolved to the satisfaction of the customers. The focus shall be to ensure all grievances are resolved in a timely basis and to the full satisfaction of our customers.

NCPL has appointed a Nodal Officer who can be approached by the public for resolution of complaints against the Company.

Nodal Officer:

Mr. Ashish Kothiyal

Ground Floor, Indiqube Celestia, No. 19 & 20, Koramangala 1A Block, Bangalore-560034

Email ID: nodal.officer@naharcredits.in

All NCPL branches/places where business is transacted a notice board will display the following information prominently, for the benefit of their customers:

Nahar Credits Private Limited

Corporate Office-Bangalore: Ground Floor, Indiqube Celestia, No. 19 & 20, Koramangala 1A Block, Bangalore-560034

Within 30 days of lodging a complaint with us, if you do not get a satisfactory response from us and you wish to pursue other avenues for redressal of grievances, you may approach the CEPC Officer-in-Charge or RBI regional office of the department of Non-Banking supervision of RBI at CRPC@rbi.org.in or sent a in physical mode to the “The Officer In-Charge, Consumer Education and Protection Cell. Reserve Bank of India. Fort Glacis, Rajaji Salai. Chennai-600 001. Telephone: 044-25361910”

Escalation Matrix for Complaints of Customers:

Level 1: Customer Care Team

Complainant can launch a complain to the customer care team at:

E-mail ID: contact@naharcredits.in

The customer shall provide his loan account number to help us understand and address the concerns.

Level 2: Head Customer Service

If there is no satisfactory response received within 7 working days of escalating the complaint to the Customer Care Team, the same can be escalated to the under mentioned:

Email id: grievance@naharcredits.in

Level 3: Grievance Redressal Officer

If the concerns have not been fully addressed within 7 working days. the same can be escalated to the under mentioned:

Email ID: gro@naharcredits.in

Level 4: Nodal Officer

If the concerns have not been fully addressed or if there is no revert from the Grievance Redressal Officer within 7 working days, final level of escalation would be to:

Email ID: nodal.officer@naharcredits.in

Grievance Redressal Contact Number: 7556642791

Contact Time: Monday to Friday between 9.30 AM to 5.30 PM

The top management group, as well as the Board of Directors, must routinely assess whether the NCPL is abiding by the Fair Practices Code described above. They will also make sure that it operates in a way that demonstrates its commitment to provide all stakeholders with a range of financial services, products, and mechanisms for resolving grievances at different levels of management in a fair and equitable manner. In accordance with the rules established by the RBI from time to time, NCPL shall periodically alter, amend, and update the Code.