Code Of Conduct

Fair practices has reference to RBI Circular No. RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated 1st July, 2015 tive Code in reference to RBI Circular No. RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated 1st July, 2015

Fair Practice Code

Preamble

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This has reference to RBI Circular No. RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated 1st July, 2015 wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices Code for NBFCs to implement the same. “The Fair Practices Code” is in conformity with these Guidelines and it sets the standard for M/s. Kannattu Fingold Finance Pvt Ltd (Formerly known as M/s. Adyar Anandhaa Finance Private Limited) (“hereinafter called as the Company”) to follow while dealing with borrowers. It provides information to borrowers and explains how the company is expected to deal with them on a day to day basis. This policy will be applicable to all the Offices of the Company including Head Office and the branches located at various places in India. All the Officers and employees of the Company shall also be bound by this policy.

Objective Of The Code

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The code has been developed with an objective of:

Ensuring & Regulating fair practices while dealing with borrowers;
Enabling borrowers in having a better understanding of the product and taking informed decisions;
Building borrowers’ confidence in the company;
Facilitate a continuously growing base of satisfied borrowers while scrupulously avoiding association with borrowers having doubtful credentials or criminal background;
Deal with the Grievances redressal in a quick and efficient manner and to the satisfaction of the borrowers;
Have an Escalation process, in the event of dissatisfaction of the borrowers in handling the complaint(s) raised.

Applicability Of Fair Practice Code

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The Fair Practice Code will be applicable to the following broad areas:

Loan application and processing;
Loan appraisal, sanction, agreement and terms/ conditions;
Loan disbursal;
Recovery and transfer of loan;
Settlement of loan;
General.

i. Loan application and processing

All communications to the borrower shall be either in English or in vernacular language or in a language as understood by the borrower.
Loan application forms issued by the Company shall include necessary information affecting the interests of the borrower, which will enable him to take an informed decision by comparing the terms and conditions with that of other similar NBFCs, and shall also indicate the documents required to be executed/submitted by the borrower.
If any additional documents/information is required from the Customer, the same shall be communicated to the Customer immediately.
In case of all loans, other than gold loans which are sanctioned on the same day of receipt of the application, an acknowledgement will be given to the applicant, also indicating the probable date by which a decision regarding sanction of the loan will be intimated to him. The acknowledgement can also be given in the form of a tear off from the application form or through an SMS message.

ii. Loan appraisal, sanction, agreement and terms/ conditions

The borrower shall be given a loan sanction letter and copy of the loan document together with annexures/enclosures quoted therein in vernacular language or a language as understood by the borrower which shall include the details of the loan such as amount sanctioned, annualized interest rate, method of application thereof and any other terms and conditions.
The penal interest that will be charged for late payment shall be mentioned in bold letters in the sanction letter/loan document.
An acknowledged copy of the sanction letter shall be kept as part of the document.
Subject to receipt of all the requisite information and completion of documentation and creation of charge over the security, loan applications shall be disposed of in the normal course on the same day of receipt of the application form complete in all respects. However, if there is any delay in sanctioning the loan beyond the period of 1 day due to reasons like field verification etc, customer shall be given an acknowledgement for receipt of the application also indicating the time frame within which the loan application will be disposed of. The customer shall be kept informed of the status of his application.
The company will give notice in writing to the borrower upon any change in the terms and conditions with date of such change (prospective date) of the loan sanctioned.

iii. Loan disbursal

The loan shall be disbursed on executing the necessary documents and completion of the formalities regarding creating a charge over the security offered by the borrower. Any change in the terms and conditions including interest rates, service charges, prepayment charges etc. shall be informed to the borrower in vernacular or a language known to the borrower. Any changes in interest rates and charges shall be only prospective. A suitable condition in this regard shall be incorporated in the loan document obtained from the borrower.
Decision to recall/accelerate payment or performance shall be as per the covenants in the loan document.
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 may have against 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.

iv. Recovery and transfer of loan

Decision to recall/accelerate payment or performance under the agreement will be in consonance with the respective loan Agreement.
In the matter of recovery of loans, the company will not resort to any undue harassment to the borrower viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, rude behaviour of staff etc.
In case of receipt of request from the borrower for transfer of loan account, the consent or objection of the company will be conveyed within 21 days from the date of receipt of such request of transfer to both the transferor and transferee in a transparent manner. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.

v. Settlement of loan

The Company will release all securities to the borrower on receipt of repayment of all dues subject to any legitimate right or lien for any other claim the company may have against the borrower. If such right of set off is to be exercised, the borrower will be given notice about the same by the Company with full particulars of the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.
No due/ objection certificate will be issued to the customer on fulfillment of said terms within 15 working days of completion of formalities.

vi. General

SELF 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 SELF).
Training will be imparted to ensure that directors/ staff/ representatives of the company are adequately trained to deal with borrowers in an appropriate manner.
The company shall adopt interest rate by taking into account relevant factors and determine the interest rate to be charged accordingly.

Confidentiality

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Unless authorized by the borrower, the Company will treat all his personal information as private and confidential. The Company may not reveal transaction details of the borrowers to any other persons except under following circumstances:

i. If the Company is required to provide the information to any statutory or regulatory body or bodies;
ii. If arising out of a duty to the public to reveal the information;
iii. If it is in the interest of the borrowers to provide such information (e.g. fraud prevention);
iv. If the borrower has authorized the Company to provide such information to its group / associate / entities or companies or any such person/ entity as specifically agreed upon;

Complaints

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Letter Type	Depletion in Security Value	Spurious/Low Quality: Identified at the branch or before completion of the tenure of the loan	Spurious/Low Quality: Identified at the auction center or after completion of the tenure of the loan
Intimation Letter	A notice in local language should be sent to the borrower within 15 days of identification of loss in the account by registered AD calling upon the borrower to settle the loan within a maximum of 2 weeks from the date of receipt of such notice or replenish the security with additional gold failing which the company may dispose the gold through auction without any further notice.	A notice in local language should be sent to the borrower within 15 days of detection as spurious / low quality by registered AD calling upon the borrower to settle the loan within a maximum of 30 days from the date of such notice. The registered AD notice should refer to the rights conferred on the Company to dispose of the security by virtue of the undertaking of the borrower in the loan application form and clauses in the loan sanction letter (pawn ticket).	A notice in local language should be sent to the borrower within 5 days of detection as spurious/low quality by registered AD. The registered notice should clearly provide reference to the following details, inter alia: Completion of tenure of the loan. That auction notice had already been sent after completion of the tenure of the loan. That the Company had undertaken only a preliminary verification of the gold at the time of disbursing the loan and as per the right conferred on the Company as per the terms and conditions of the loan, to further check the purity/weight of the gold internally or by experts at any time, the purity of the gold was re verified at the auction centre prior to auction and was found to be of inferior quality. That the Company is proceeding with auction as already intimated.
Final Letter	Nil	In the case where the account remains unsettled after the issue of the above notice an auction notice furnishing the date and venue of auction shall be served on the borrower at least 14 days before the proposed date of auction.	Nil

Regulation of excessive interest charged

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The Company has to adopt 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.

Implementation, effect and review

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All necessary steps shall be taken by the Board of Directors to implement this Fair Practice Code at all the offices/ branches/ places where the business of the company is transacted. The Board shall have periodical review of the Fair Practice Code, compliance of Fair Practice Code and the functioning of the Grievance redressal mechanism. For and on behalf of Board of Directors
M/s. Kannattu Fingold Finance Private Limited
Chickoo Mattackal Philip
Managing Director(DIN: 06740057)

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