This Fair Practice Code is adopted by the Company as per Fair Practices Code Guidelines of RBI issued vide their Notification No DNBS.CC.PD.No.320/03.10.01/2012-13 dated 18 February 2013, which sets minimum standard for the Company to follow while dealing with the Customers during the course of our business and as approved by the Board of Directors of the Company vide Resolution 7 of Minutes No BM-01/2016-17 dated 11th April, 2016 and amended vide Resolution ……. of Minutes No. BM-02/2018-2019 dated 29th January, 2019.

1. Applications for Loan
   • The loan applications will be issued on request by the customer. The application will be printed in English/Vernacular Language as understood by the Customer.
   • The application contains the documents required to be submitted and all necessary information which attracts the interest of the customer, so as to enable him to compare the terms and conditions offered by other NBFC.
   • A system to acknowledge the receipt of loan applications has been established. All the loan applications shall be disposed off within 15 days from the date of its receipt.
2. Loan Appraisal and Terms & Conditions
   • Loan application will be appraised properly for its genuineness and identification of the borrower.
   • Sanction letter of loan will be issued in English / Vernacular Language to the Customer which contains the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof etc.
   • The Delay Interest charged for late payment will be printed in the loan agreement/sanction letter in bold letters. A copy of the loan agreement, with all the enclosures will be provided to the borrower.
   • The Company shall continue to have cordial business relation with their Clients securing their privacy, dignity and identity. Further we shall refrain from interference in the affairs of borrower except for purpose provided in terms and conditions of loan agreement.
3. Disbursement of Loans Including Changes in Terms and Conditions
   • The Company shall provide complete and accurate information about the loan products and services to our Customers/borrowers and shall continue to educate them on the same in a manner that is clearly understood by them. We shall ensure that our dealings with our clients are based on ethical principles of integrity and transparency.
   • The Company shall give notice to our Clients in English/vernacular language of any changes in the terms and conditions including disbursement schedule, interest rates, service charges etc. We shall ensure that changes in interest rates and charges are affected prospectively only after informing the clients and as such, suitable conditions being incorporated in the loan document.
   • The decision to recall / accelerate payment of loan shall be in consonance with the loan agreement.
   • There will be no discrimination on caste, creed or sex in sanctioning the loans.
   • The Company shall release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim to the company 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.
4. Fair Recovery Practices
   • The Company shall not resort to undue harassment and unfair practices for recovery. We shall contact our clients only between 9.00 AM and 5.00 PM and avoid inappropriate occasions like bereavement in family, or any other personal calamity.
   • The Company shall make receipt entry in loan passbook for every loan repayment transaction with the Client.
   • The staff are adequately trained to deal with the Customers in an amicable manner. There shall be no complaints from Customers on rude behaviour from the staff of the Company.
   • The Company shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement.
5. Redressal of Grievances
   • The Company has adopted adequate Grievance Redressal Mechanism to cater to the grievances of the Clients, if any..
   • Deputed General Manager / Administrator of the Company acts as Grievance Redressal Officer who can be approached by the public for amicable solutions or for resolving any complaints in this regard. Their contact details such as Telephone/Mobile No. and email address are displayed in all our offices.
   • Periodical review of compliance of Fair Practice Code and the functioning of grievance-redressal mechanism will be carried out by the Board of Directors.
   • If any complaint/dispute is not redressed within a period of one month, the Customer may appeal to the Officer-in-Charge, Reserve Bank of India, DNBS, Fort Glacis, 16 Rajaji Salai, Chennai – 600001, Tele No. 044 – 25399222, 25399283, E mail : dnbschennai@rbi.org.in
   • A complaint/suggestion box will be placed at all offices and complaint/suggestion, if any, will be reviewed by the Managing Director at regular intervals.
6. Fair Pricing of Loan Products
   • Company shall implement appropriate internal principles and procedures in determining interest rates, processing and other charges of all loan products. The Company shall not levy excessive interest.
   • The Company shall disclose the rate of interest and the approach for gradation of risk and criterion for charging different rate of interest to different categories of borrowers and communicate the same to them.
   • The Board of Directors shall adopt an interest rate module, taking into account relevant factors such as cost of funds, margin and risk premium etc and determine the rate of interest to be charged for loans and advances from time to time. The present rate of interest will be:
   • (i) From 22% to 24% on Gold Loan depend up on schemes and rate of advance opted by Customers.
   • (ii) From 12% to 18% flat rate on EMI Loan depend upon the period and schemes opted by the Customers.
7. Privacy of Information
   • The Company shall treat our Client’s personal information and datum as private and confidential, and we shall reveal such information to others only with the consent of our Clients. However, we shall exercise our discretion to furnish the Client’s details to the Statutory Authorities as required under Law notwithstanding the consent of the Clients.
8. Lending Against Collateral of Gold Jewellery

   In addition to the general guidelines, the company shall adopt following guidelines while lending loans against gold jewellery and approved by the Board.

   • Adequate steps to ensure that the KYC guidelines stipulated by RBI are complied with and to ensure that adequate diligence is exercised on the Customer before extending any loan.
   • Proper ascertaining of gold jewellery to be carried out as per the implemented procedure.
   • Ownership of the gold jewellery to be proved and signature of the borrower to be obtained in the Declaration Certificate. – Proper storing system of gold jewellery shall be provided in each branches to ensure its safety. Periodic inspection shall be carried out by internal auditors to ensure that the procedures are strictly adhered to.
   • The Jewellery accepted as collateral security shall be appropriately insured.
   • The Board approved policy is followed with regard to auction of jewellery in case of non-repayment of loan. Minimum two notices shall be issued to the borrower with adequate time frame for re-payment and adequate prior notice to the borrower shall be given before carrying out the auction. The auction procedure shall be given in the loan agreement.
   • The auction shall be announced to the public vide advertisements in two newspapers, one in vernacular language and another in national daily newspaper.
   • The company shall not participate in the auctions. – Gold pledged shall be auctioned only through auctioneers approved by the Board.
   • Systems and Procedures that will be put in place for dealing with fraud including separation of duties of mobilisation, execution & approval.