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Fair Practice Code

Fair Practice Code:

Ichibaan Finance Private Limited business would be conducted in accordance bringing convenience to the lives of the ordinary people of India, to “make life easy” for them. We provide them with “instant” credit at reasonable rates of interest against their used diamond and gold jewellery to enable them to meet their requirements for short term funds.

Core Values:

Customer is all Important: Time is precious and everyone is entitled to courtesy and prompt service with high levels of Transparency.

No compromise on Integrity: We value the contributions of all our stakeholders and we take special pride in recognising those contributions.

Cutting edge technology:

We have standardized our processes to allow us better and more cost effective access to our customers.

Guidelines on Fair Practices Code for NBFCs

(i) Application for loan and processing

 All the borrowers will be fully apprised of the terms and conditions attached to the loan so that she/he will be able to make a comparison of the terms and conditions offered by other NBFC sand take an informed decision. The applicants will be provided with standard loan application forms including the below mentioned information:

 Description of all costs associated with the product(s): price—including the total cost of the loan—the interest rate, and all associated fees.

 All loan terms and conditions, including necessary documentation, eligibility criteria,condition, any compulsory programs (e.g. insurance, savings), the use of client savings in the case of credit default, and how client data is used.

 Receipt of completed application forms will be duly acknowledged.

 The acknowledgement would include the approximate date by which loan applications will be disposed of.

 All loan applications will be disposed of within a period of 15 days from the date of receipt of duly completed loan applications i.e. with all the requisite information/papers.

 In case of rejection of loan application, irrespective of category of loans or threshold limits, the same would be conveyed in writing along with the main reason(s), which led to rejection of the loan application.

(ii) Loan appraisal and terms/conditions

 In accordance with the Ichibaan Finance Private Limited prescribed assessment procedures, each loan application will be assessed and suitable margin/securities will be stipulated based on such assessment and Company’s existing guidelines, however without compromising on due-diligence.

 The sanction of loans along with the terms and conditions thereof is conveyed to the borrower in writing by means of a sanction letter and borrower’s acceptance of such terms and conditions will be obtained in writing on the copy of the sanction letters and kept on record

 The copy of the loan agreements along with a copy of each of the enclosures quoted in the loan agreements will be made available to the borrowers at the time of sanction of loans.

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

 Ichibaan Finance Private Limited shall under no legal obligation to consider increase /additional limits /facilities without proper review /assessment.

 Any change in the terms and conditions, including disbursement schedule, interest rate and other charges / levies will be informed to the borrowers.

 The changes in interest rates and charges shall be effected only prospectively. A suitable condition in this regard has been incorporated in the loan agreement.

 Before taking a decision to recall/accelerate payment or performance under the agreement or seeking additional securities, IDF FSPL would give reasonable notice to the borrower.

 All securities pertaining to the loan would be released on receipt of full and final payment of the loans subject to borrower satisfying any legitimate right/any other claim that Ichibaan Finance Private Limited may have against the borrowers.

 If such right is to be exercised, borrowers would be given due and proper notice along with full particulars about the remaining claims and the conditions under which the company would be entitled to retain the securities till the relevant claim is settled/ paid.

(iv) General

 The Company shall treat customer information as private and confidential and shall be guided by following principles and policies: The information shall be parted by the Company only in the following circumstances:

i) Information required to be given under law or as demanded or required by statutory authorities.

ii) Information is given with customer’s specific written permission.

 In case of receipt of request for transfer of borrowable account, either from the borrower or from a lender which proposes to takes over the account, the consent or otherwise would be conveyed within 21 days from the date of receipt of request. Such transfer would be as per transparent contractual terms in consonance with law.

 The company will not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. in the matter of recovery of loans.

(v) Collection of Dues:

 Company’s collection policy shall be built on courtesy, fair treatment and persuasion. Efforts will be made in building customer confidence and long term relationship.

 The staff deputed to make recovery calls will be adequately trained to deal with customer and shall identify themselves and shall provide details with regard to outstanding claims to the customer.

 Under no circumstances, Company shall resort to any illegal means for recovery of the dues from the customer. Further the Company will not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans etc.

(vi) Complaints, Grievances and Feedback

 If complaint is received in writing or over phone, customer’s grievances will be recorded by the Company.

 The Company shall ensure that the staffs are adequately trained to deal with the customers in an appropriate manner.

 Company will endeavour to sort out the matter within fifteen days of receipt of a complaint.

 In case the complaint requires more time, then the same would be informed to the customer. Customer would be updated at regular intervals regarding the status of the same.

 The grievance redressal mechanism within the organisation will be explained to the customer to resolve any dispute, such a mechanism would ensure that all disputes arising out of decisions of our functionaries are heard and disposed of at least at the next higher level.

 A complaint of misconduct against an official of the Company shall be redressed by next level of authority.

(vii) Internal Principle and Procedure

 Boards of NBFCs are; therefore, lay out appropriate internal principles and procedures in determining interest rates and processing and other charges.

 Guidelines indicated in the Fair Practices Code about transparency in respect of terms and conditions of the loans are to be kept in view.

(viii) Regulation of excessive interest charged by NBFCs

 The Board of each NBFC adopt an interest rate model 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. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.

 The rates of interest and the approach for gradation of risks made available on the web-site of the companies or published in the relevant newspapers. The information published in the website or otherwise published will be updated whenever there is a change in the rates of interest.

 The rate of interest should be annualised rates so that the borrower is aware of the exact rates that would be charged to the account.

(ix) Lending against collateral of Gold Jewellery:

The Board has approved policy for lending against gold that should inter alia, cover the following:

 Adequate steps to ensure that the KYC guidelines stipulated by RBI are complied with and adequate due diligence is carried out on the customer before extending any loan,

 Proper assaying procedure for the jewellery is followed.

 Internal systems to satisfy ownership of the gold jewellery.

 The policy shall also cover putting in place adequate systems for storing the jewellery in safe custody, reviewing the systems on an on-going basis, training the concerned staff and periodic inspection by internal auditors to ensure that the procedures are strictly adhered to.

 As a policy, loans against the collateral of gold should not be extended by branches that do not have appropriate facility for storage of the jewellery.

 The jewellery accepted as collateral should be appropriately insured.

Non- Repayment – Auction

 The Board approved policy with regard to auction of jewellery in case of non-repayment shall be transparent and adequate prior notice to the borrower should be given before the auction date.

 It should also lay down the auction procedure that would be followed. There should be no conflict of interest and the auction process must ensure that there is arm’s length relationship in all transactions during the auction including with group companies and related entities.

 The auction should be announced to the public by issue of advertisements in at least 2 newspapers, one in vernacular language and another in national daily newspaper.

 As a policy the NBFCs themselves cannot participate in the auctions held

 Gold pledged will be auctioned only through auctioneers approved by the Board.

 The policy shall also cover systems and procedures to be put in place for dealing with fraud including separation of duties of mobilization, execution and approval.

 The loan agreement shall also disclose details regarding auction procedure.

The Board of Directors of the Company shall every half yearly i.e. at the end of the month of September and March; review the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews may be submitted to the Board every half yearly for their perusal and comments, if any.

The Company shall modify, amend and update the above Code from time to time, in accordance with the guidelines prescribed by the RBI.

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