Grievance Redressal Cell

The Reserve Bank of India issued Master Circular - Fair Practices Code for NBFC's with respect Fair Practices code to be followed by defining and setting minimum standards which an NBFC is expected to comply with, while dealing with its existing or prospective customers. Micro Capitals Private Limited ("Micro Capitals") has put in place following best practices and implemented a "Fair Practice Code". The code is applicable on all the services, rendered by the company from all its operating/service locations covering its every single establishment. The officials and authorized signatories of the company are required to meticulously follow the code, irrespective of the place and location as well as the medium through which they render services. We have adopted a revised Fair Practices Code and will implement this Code in our organization which has been duly approved by the Board of Directors of our Company in their meeting held on 9th November, 2014.

1.1 Objectives & Application

It is the sincere endeavor of Micro Capitals to promote its financial services and make it available to all applicants who based on screening process are eligible to avail the same irrespective of caste, colour, creed, religion, sex, marital status, age etc. Our authorized representatives do provide the services in a fair, equitable and consistent manner. The terms and conditions along with the details of charges/fees levied by the company from time to time, affecting the interests of the concerned applicant, are appropriately conveyed to the applicant/borrower. The Company also ensures that disputes arising from the lending decisions are resolved through an appropriate "Grievance Redressal Mechanism".

The primary objectives of the Code are as follows:

• Promoting fair practices by setting minimum standards while dealing with customers.
• Increasing transparency in all the dealings to enable the customers to understand he/she could expect from such services in a language understood by the borrower.
• Encouraging market forces, through competition for better operating standards.
• Promoting cordial relationship between customers and the Company.

1.2 Application of the code

The Company ensures that the responsibility to implement the Code is vested with the entire organization at its all levels. The Company's fair lending practices are applied on all its operations covering the entire activities involved in beginning with a transaction to its end irrespective of services are rendered over the counter, phone, post, or any other medium. The Board of Directors as well as the Management team ensures that our line of activity reflects our strong commitment to fair lending with all our employees.

2. Fairness, Transparency and Disclosures

The Company as well as its employees acts with reasonable fairness and probity while dealing with its customers focusing on the fact that the commitments are fulfilled and the services met with the applicable standards. It is also ensured that the applicable laws are complied with and customers are treated with ethical principles of integrity and transparency. Further, the Company ensures that its staff and authorized representatives are trained and are well equipped to provide relevant information on this code and the same being implemented properly. The company transparently and on non discriminatory basis discloses to its borrower(s) about all the information on fee/charges structure prevailing from time to time. Information on prepayment options with charges involved therein, if any, penalty for delays in repayment or any other matter affecting the interest of the borrower(s). Precisely, the entire cost structure is disclosed under one umbrella.

3 Brand Building and Sales

Since the company always strives to maintain transparency and integrity in all its dealings, it becomes vital for it to observe certain minimum standards while providing its services. These are given below:-

• The advertising material confirms to truthfulness and it is ensured that the same is free from any misleading ambiguity
• Information on interest rates, common fees and charges is made available at branches, telephones or help-lines through designated staff/help desk.
• Whenever any complaint on improper behavior of company's representative or violating the code is received, probe is carried out and accordingly steps are being taken to resolve such complaints.

4 Loans To Customers

4.1 (i) Documentation and Processing:

The Application Form of the Company prescribed for availing loan shall amongst other important parameters covers crucial information's about type of loan, amount of loan etc. Prospective borrower/borrowers are provided complete information about the terms and conditions of the loan to enable them to make a meaningful comparison with the terms provided by other NBFCs and take an informed decision. A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement shall be provided to all the borrowers at the time of sanction / disbursement of loans. The Company has a system of giving acknowledgement for receipt of all loan applications indicating the time frame within which the applications will be disposed of

4.1(ii) Loan appraisal and terms/conditions:

Under normal circumstances the information required for processing the loan application shall be collected by the Company at the time of application. However, if any additional being sought, the same is communicated to the customer promptly. The Company shall convey in writing whether the loan is sanctioned and the amount sanctioned with the terms and conditions on which the same has been sanctioned. The intimation so given will include details on annualized rate of interest, method of application, EMI terms, etc.

4.1(iii) Disbursement of loans including changes in terms and conditions:

The company will make sure that disbursement is made in accordance with the agreed disbursement schedule (original or revised)/sanction letter. Prior to taking a decision to recall/accelerate payment or performance under the agreement or seeking additional securities, the Company will accordingly give notice to its borrowers in accordance with the loan agreement. The company will release all securities on realization of the outstanding amount of loan subject to any legitimate right including guarantees, or lien for any other claim company may have against borrower.

4.2 Guarantors

In case a person desires to provide guarantee for a loan taken by some other person, the company shall keep him informed him/her about the following: Circumstances under which the company will call on him/her to pay up his/her liability & recourse available to the company on his/her failure to act as a guarantor.

4.3 Privacy and Confidentiality

Personal information of customers shall be treated as private and confidential [even when the customers are no longer customers. The Company will not reveal transaction details of the customer's accounts, to a third party except in the following circumstances:-
• If the company has to give the information required under law;
• If there is a duty towards the public to reveal the information;
• If the interests of the company require to give the information; for example, to prevent fraud;
• If the customer expressly gives its consent to reveal the so called information to group/associate/entities or other companies when they have tie-up arrangements for providing other financial service products/other products;
• A copy of the information given to the credit reference agencies shall be provided by the Company to the customer, if so demanded.

4.4 Collection of Dues

4.4.1. The Company shall inform customers about the repayment schedule well in advance. 4.4.2. The Company's collection is based on courtesy, fair treatment and persuasion. The company shall provide all the information to the customers, regarding their outstanding dues and shall also endeavor to give sufficient notice for payment of such dues. 4.4.3. The following guidelines shall be strictly followed by all staff members or authorized persons of the company entrusted with the responsibility of collection and / or security repossession: Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation.
• Customer's privacy shall be respected.
• Interaction with the customer shall be in a civil and courteous manner.
• The Company's representatives shall contact the customers between 7 a.m. and 7 p.m. hrs, unless the special circumstances of the customer's business or occupation require otherwise.
• Customer's request to give telephonic calls at a particular time or place shall be honored as far as possible.
• All assistance should be given to resolve disputes or differences regarding outstanding dues in a mutually acceptable and in an orderly manner.
• During visits to customer's place for collection of dues, decency and decorum shall be maintained.
• The Company has put in place REPO Policy duly approved by Board.
• The company shall not use muscle power to collect outstanding dues.

4.5 Complaints and Grievances

In spite of due care and precautions occasions arises when a beleaguered customer is not satisfied with the service given to him/her. In such cases, he/she can contact the officials of the company. The company commits and assures to provide the best possible recourse to resolve the grievance. Here we have the steps, the customer needs to take for resolving his/her grievances:-
Step 1:
Please visit to the nearest company's Branch and lodge customer complaint/grievance in the "Complaint & Grievance Register" maintained at the branches during working hours, i.e., 10:30 A.M to 6:00 P.M from Monday to Friday and 10.30 am to 1.00 p.m. on Saturdays. The company shall respond to the complaint within 15 working days, from the date of receipt/lodgment of complaint. The company on receipt of the complaint shall examine the same and shall accordingly communicate in writing/email/phone, its response on the same to the customer or else suitable justification shall be provided in case if the resolution of the complaint requires more than the time stipulated above.
Step 2:
If customer is still not satisfied with the resolution customer receive, or customer doesn't receive any response within 15 working days customer can write, mail, fax or call to the Grievance Redressal Officer of the company:-

Ms. Nikita Rattanshi,
G - 002, Morya Landmark - II,
Opp. Infinity Mall,
Andheri West, Mumbai - 400 053.
E-mail Id:grievances@microcaps.co.in
Office: +91-22-4048 2666

After examining the matter, customer grievance/complaint shall be resolved within 15 working days by us. If customer complaint still remains unresolved and is not redressed within a period of one month, customer may approach to the regulatory authority of Non Banking Financial Companies, i.e. Reserve Bank of India for redressal of customer complaints at below address:

The General Manager,
Reserve Bank of India,
Department of Non Banking Supervision,
3rd Floor, Garment House, Worli,
Mumbai - 400 021(Maharashtra)

5. General Covenants

The company shall ensure the following:

• It shall be the duty of the customer to co-operate, if the company needs to investigate a transaction undertaken by the customer with the police/ other investigative agencies, if the situation so demands, subject to the condition that the company shall under normal circumstances maintain confidentiality of such transactions.
• The company shall inform the customer that if he/she acts fraudulently, he/she would be held responsible for all losses arising out of/on account of his/her own account and that if the customer acts without reasonable care and diligence, resulting in losses to the company, the customer solely would be held responsible for the same and shall also be liable for applicable consequences as per law.
• The company shall provide information on its products and services in any one or more of the following languages: Hindi, English or the appropriate local language.

The company with a view to publicize the code shall:

• Make this Code available on request either over the counter or by electronic communication or mail, registered in the records of the company for the purpose.
• Make available this Code at every branch and on its website; and
• Ensure that the employees are trained to provide relevant information about the Code and to put the Code into practice.

6. Pricing Determination Policy/Excessive Interest Rate Policy

Micro Capital Board has adopted an interest rate model/Pricing determination policy taking into account relevant factors such as cost of funds, margin and risk premium, etc and determines the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers is disclosed to the borrower and rate of interest is communicated explicitly in the welcome/sanction letter. Risk gradation is determined on the basis of risk associated with products, type of loans, value of collateral available, tenor, quantum of loan etc. The rate of interest mentioned are annualized rates so that the borrower is aware of the exact rates that would be charged to the account. The same is mentioned on the application form also.