Fair Practices Code

A. Introduction

This Fair Practices Code of the Company has been framed and put in place on the basis of the revised guidelines issued by the Reserve Bank of India vide Circular No.2012-13/416/DNBS. CC. PD No. 320 /03.10.01/2012-13 dated 18th February, 2013 and also on the basis of various other directions issued from time to time. It sets out the minimum standards of Fair Practice to be followed by the Company when dealing with customers. It provides information to customers and explains as to how the Company is expected to deal with them on a day- to - day basis. This policy applies to all customers with whom the Company has a business relationship.

B. Objective of the Fair Practices Code

This Fair Practices Code has been framed with the objective of:

  1. Ensuring fair practices while dealing with customers
  2. Greater transparency enabling customers in having a better understanding of the product and taking informed decisions
  3. Building customer confidence in the Company

C. Channels of communication

The Borrower shall indicate in the loan application form the language understood by him. If not, the Company will communicate with him in English. The borrower may also furnish his email ID, mobile or landline number implying his consent for resorting to communication with him through these channels also in view of its easiness and fastness. The Company may communicate with the customers through letters in hardcopy and email. The customer may also be contacted through his mobile connection, land line phone connection depending on the urgency of the matter involved. However, the sanction letter and loan agreement will, invariably be given in hardcopy. The letter calling for repayment of the loan/disposal of securities (Final chance letter) will be first sent by email followed by hardcopy since the matter needs immediate attention of the customer. However, it is not necessary and obligatory that the Company should follow both the means, i.e., email and hardcopy in all cases and any of the aforesaid two means would be sufficient to constitute a legal demand/claim.

D. Applications for Loans and their processing

  1. The Company offers various financial products including Loan against securities, Loans against Commodities and Personal Loans among others being developed and promoted from time to time.
  2. The ‘Loan Application Form / appropriate documents’ for each of these loan products offered by the Company is different depending upon the requirement of each product and will include all information/documents that are required to be submitted by the Borrower. Necessary information will be provided by the Company to facilitate the Borrower in making a meaningful comparison with similar terms and conditions offered by other Non Banking Finance Companies (NBFCs) and taking an informed decision.
  3. The ‘Loan Application Form/ appropriate documents’ shall indicate the information/list of documents required to be submitted by the Borrowers along with the Loan Application form.
  4. The Company shall inform the Borrower about its decision within reasonable period of time from the date of receipt of the loan application along with all the required information/documents complete in all respects.

E. Loan appraisal and terms/conditions

The Company shall convey in writing to the Borrower by way of a sanction letter or otherwise, the amount of loan sanctioned along with all the terms and conditions relating to the loan including annualized rate of interest and method of application thereof and keeps the acceptance of these terms and conditions by the borrower on record. Any clause relating to penal interest charged for late repayment will be specified in bold in the Loan Agreement. The Company will furnish a copy of loan agreement to the borrower at the time of completion of all related documentation process.

F. Disbursement of loans including changes in terms and conditions

  1. Through its published website or through email , letters or as appropriate and specific to particular customer, the Company will give Notice to its Borrower(s), of any change in the terms and conditions of the loan sanctioned including disbursement schedules, interest rates, service charges, prepayment charges, etc. The Company will also ensure that changes in interest rates and charges are effected only prospectively.
  2. Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective loan Agreement.
  3. The Company will release all securities of its Borrower only on repayment of all dues by such Borrower, or only on realization of the outstanding amount of the Borrower’s availed limit, subject to any legitimate right or lien for any other claim which the Company may have against its Borrower. If such right of set off is to be exercised, the Borrower will be given notice about the same with full particulars about the remaining claims and conditions under which the Company will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower. Due No-objection certificate will be issued to the customer on fulfilment of said terms within 15 workings days of completion of formalities.

G. Regulation of Excessive Interest

The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges. Accordingly, the Company has adopted an interest rate model taking into account cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances. The rate of interest to be charged depends much upon the gradation of the risk of borrower viz. the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower etc. The rate of interest to be charged on the loan together with the annualised rate of interest thereon will be shown in the Sanction letter and the loan agreement and the same will be communicated to the borrower in writing so that the borrower is aware of the exact rates that would be charged to the loan account.

H. General

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

I. Grievance Redressal Mechanism

In the present competitive scenario, excellent customer service is an important tool for sustained business growth. Customer complaints are part of the business life in any corporate entity. Effective resolution of such complaints is a key differentiator in the competitive business environment. Customer service and satisfaction are of prime focus to the Company. The Company believe that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. With a view to providing enhanced experience to its Customers, the Company has put in place a more meaningful and effective Customers’ Grievances Redressal Authority has been constituted as enumerated below.

J. CUSTOMERS’ GRIEVANCES REDRESSAL AUTHORITY- COGRA

Customers may take up disputes arising out of the lending decisions/ conduct of the Company as follows.

  1. First level

    2. Grievance Redressal Officer and Operations Manager
    Geojit Credits Pvt Ltd
    34/659-P, Civil Line Road, Padivattom, Kochi – 682024
    Email:
    Ph: 0484 2901252

  2. Second Level

    3. In case the grievance persists, the customer may escalate the issue to the Business Head of the Company at the following address

    The Business Head
    Geojit Credits Pvt Ltd
    34/659-P, Civil Line Road, Padivattom, Kochi – 682024
    Email:
    Ph: 0484 2901256

  3. Final Level

    4. In case the grievance persists, the customer may escalate the issue to the Managing Director of the Company at the following address and he shall then examine and resolve the issue.

    The Managing Director,
    Geojit Credits Pvt Ltd
    34/659-P, Civil Line Road, Padivattom, Kochi – 682024
    Email:
    Ph: 0484 2901253

  4. RBI Level

    5. In case the complaint/dispute is not satisfactorily 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 at the following address.

    Officer-in-Charge
    Department of Non Banking Supervsion
    Reserve Bank of India, Bakery Junction,
    P.B No.6507, Thiruvananthapuram-695 033
    Ph: 0471- 2329676/ 2338818

  5. Ombudsman Scheme for NBFCs

    6. RBI has introduced the Ombudsman Scheme for NBFCs with the object of enabling resolution of complaints free of cost, relating to certain aspects of services rendered by certain categories of non-banking financial companies registered with it to facilitate the satisfaction or settlement of such complaints, and matters connected therewith. The Company is coming under the ambit of the aforesaid Scheme, and therefore shall take all necessary steps to comply with the Directions issued by RBI in the matter.

K. Others

  1. Fair practices shall be adopted both in letter and spirit in all lending activities of the Company. The Company shall place the above Fair Practices Code on its website, for the information of various stake holders.
  2. The GCPL Fair Practice Code for Lending is liable for modifications and amendments, subject to directives received from RBI from time to time.
  3. A periodical review of the compliance of the Fair Practices Code and the functioning of the Grievance Redressal Mechanism shall be done on a quarterly basis by the Business Head, half-yearly basis by the Managing Director and yearly basis in the first calendar quarter, every year by the Board.
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