Fair Practices Code

• Preamble:
  The Reserve Bank of India (RBI) vide its Master directions dated September 01, 2016 and as amended from time to time, issued guidelines on Fair Practices Code (FPC) for all NBFCs to be adopted by them while doing lending business.
• Introduction
  The Domain name flexiloans.com (“website”) is owned by Epimoney Private Limited,
  (“the Company”). The Company is a Non-Banking Finance Company registered with Reserve Bank of India (“RBI”) having its registered office at No. 249 A, Ambujammal Street, Off TTK Road, Alwarpet, Chennai-600018 and its corporate address at Quest Coworks, Technopolis Knowledge Park, 5th floor, Hanuman Nagar, Opp Holy Family High School, and Junior College. Andheri East, Mumbai – 400093 is in the business of providing different types of collateral free loans for business which includes Working Capital Loan, Invoice Financing etc., to its various customers. Such credit facilities are extended to different types of customers, which include Individuals, Partnership Firms, Companies and other Legal entities.

The Company has framed and adopted a voluntary code, which sets out the principles for fair practice standards when dealing with customers. As per the RBI directives, we have adopted and will implement this Code in our organization which has been duly approved by Board of Directors of the Company. This Fair Practices Code applies to the all categories of products and services offered by the Company (currently offered or which may be introduced at a future date).

It is, and shall be, our policy to make credit products available to all qualified applicants without discrimination on the basis of race, caste, color, religion, sex, marital status, age (over that of majority), or handicap and the Company will provide appropriate clarification to the customers, if there is any sort of discrimination in the product offered, interest charged and grievance sought by the customer.

Our policy is to treat all the clients consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner.
We will also communicate this Fair Practice Code (“Code”) to our customers by placing it on the Company’s website.

We shall ensure that charges/fees which affect the interest of the prospective borrowers are appropriately informed to the borrower. Terms and conditions pertaining to the facility will be conveyed to prospective borrowers. We commit that disputes arising out of the lending decisions will be appropriately resolved by a grievance redressal mechanism set up by us.

This Fair Practice Code is applicable to all facilities and services provided by the Company whether the same is provided over the phone, by post, through interactive electronic devices, on the internet or by any other method we maybe currently using or may introduce at a future date.

• Key Commitments
  The Company’s key commitments to customers:
• Act fairly and reasonably in all their dealings with customers by:
  • Meeting the commitments and standards in this Code, for the products and services the Company offers and, in the procedures and practices its staff follows.
  • Making sure that Company’s products and services meet relevant laws and regulations. Company’s dealings with customers will rest on ethical principles of integrity and transparency.
•  Help customers understand how Company’s products work by:
  • Explaining their financial implications.
  • Providing information about them in simple Hindi and/ or English and/or the local language.
  • Help the customer choose the one that meets his/her needs the best.
• Deal quickly and sympathetically with things that go wrong by:
  • Correcting mistakes quickly by acting in a timely manner and handling the customer’s complaints effectively in a time bound manner
  • Telling customers’ how to take their complaint forward if they are still not satisfied.
• Publicize this Code, put it on Company’s website and have copies available for customer on request.
• Information
  • Helping customer choose products and services, which meet their needs and give them clear information explaining the key features of the services and products they are interested in.
    • Inform customers about the documentary information the Company needs from them to establish customer’s true identity and address and, other documents to comply with legal and regulatory requirements.
• Applications for loans and their processing
• All communications to the borrower shall be in the vernacular language/ Hindi/ English or a language as understood by the borrower.
  • The Loan application forms of the Company will include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form will indicate the documents required to be submitted with the application form.
  • The Company will have a system of giving acknowledgement for receipt of all loan applications. The time frame /within which loan applications will be disposed of will be indicated in the acknowledgement.
• Loan appraisal and terms/conditions
  The Company will convey in writing to the borrower in the vernacular language/ Hindi/ English or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. The Company will mention the penal interest charged for late repayment in bold in the loan agreement.

The Company will furnish a copy of the loan agreement preferably in the language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans based on declaration obtained from the customer on his/her preferred language of communication

• Disbursement of loans including changes in terms and conditions
  • The Company will give notice to the borrower in the vernacular language/ Hindi/ English or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company should also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard should be incorporated in the loan agreement.
  • Decision to recall / accelerate payment or performance under the agreement will be in consonance with the loan agreement.
  • The Company will 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 will 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.
• Confidentiality
  1. The Company shall treat all information of the borrower as private and confidential, this shall even apply after the repayment of all money due to us from the borrower.
  2. The Company shall not reveal transaction details to any other person other than the following exceptional cases:
• If required to provide the information relating to a borrower by law or under an order of government, statutory, regulatory authority.
• Associate/entities or companies for providing other services or products
• General
  • The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
    • In the matter of recovery of loans, 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. To avoid rude behavior from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
    • In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise – i.e., objection of the Company, if any – shall be conveyed to the borrower within 21 days from the date of receipt of any request. Such transfer shall be as per transparent contractual terms in consonance with law.
• Further Assistance
  • A grievance redressal mechanism within the organization comprising Business Heads, Grievance Redressal Officer and Customer Service has been set up to resolve disputes arising in this regard. This Forum will ensure that all the disputes arising out of the decisions the Company’s functionaries are heard and disposed of at least at the next higher level.
    • There will be a periodical review of the compliance of the Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals.
    • The following information shall be displayed prominently, for the benefit of the customers, at all branches / places of the Company where business is transacted:
    • the contact details of the Grievance Redressal Officer who can be approached for resolution of complaints and for grievances in relation to Cyber Security/Cyber threats incidents faced by the customers against the Company is as set out below:

Name: Mr. Manish Lunia

Address: Quest Coworks, Technopolis Knowledge Park, 5th floor, Hanuman Nagar, Opp Holy Family High School, and Junior College. Andheri East, Mumbai – 400093

Phone: 022-68219546

E-mail: nodal.grievance@epimoney.com

• • If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in Charge of the Regional Office of DNBS of RBI (complete contact details are set out below), under whose jurisdiction the registered office of the Company falls as displayed at all the operating offices of the company.
    [The public notice should serve the purpose of highlighting to the customers, the grievance redressal mechanism followed by the Company, together with details of the Grievance Redressal Officer.]
• Posting on Website
  Fair Practices Code, preferably in the vernacular language or a language as understood by the borrower should be put up on the web-site of the Company for the information of various stakeholders.
• Regulation of rate of interest
  • The Company has laid down appropriate internal principles and procedure in determining interest rates, processing fees and other charges. The Company has adopted 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 customers shall be communicated explicitly in the sanction letter. The rates of interest and the approach for gradation of risks shall also be made available on the web -site of the Company. The information published on the website or otherwise published should 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 him.
    • The Company shall not charge foreclosure charges/ pre-payment penalties on floating rate term loans sanctioned, if any, to individual borrowers.
• Review of the Policy
  There will be an Annual review of 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 will be submitted to the Board at regular intervals.