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Policy 2

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Fair Practice Code

1. Introduction

The Reserve Bank vide its circular dated September 28, 2006, issued guidelines on Fair
Practices Code (FPC) for all NBFCs to be adopted by them while doing lending business.
The guidelines inter alia, covered general principles on adequate disclosures on the
terms and conditions of a loan and also adopting a non-coercive recovery method. The
same was revised in view of the recent developments with sector including creation of
New Category of NBFCs viz; NBFC-MFI and also the rapid growth in NBFCs lending against
gold jewellery. Revised circular was issued on March 26, 2012.

2. Guidelines on Fair Practices Code for NBFCs

(i) Applications for loans and their processing

(a) All communications to the borrower shall be in the vernacular language or a language as
understood by the borrower.

(b) Loan application forms should 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
may indicate the documents required to be submitted with the application form.

(c) The Company shall provide acknowledgement for receipt of all loan applications. The
Acknowledgement includes the time frame within which loan applications will be disposed off.

(ii) Loan appraisal and terms/conditions

The Company shall convey in writing to the borrower in the vernacular language or in 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 loan agreement shall contain the Penal
interest charged for late repayment.

The Company shall furnish a copy of the loan agreement 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.

Corporate Office: Urban Vault 1515, 2nd Floor, 19th main, Vanganahalli, Sector 1, HSR Layout, Bengaluru, Karnataka 560102.
Registered Office Address: SY NO. 7P & 93P, Electronic City West, Industrial Area, Begur Hobli, Bengaluru 560100 T: 81978 61629
Email: info@davintafinserv.com www.davintafinserv.com (CIN) U67200KA2018PTC111905
(iii) Disbursement of loans including changes in terms and conditions

(a) The Company shall give notice to the borrower in vernacular language 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.

Any Changes in interest rates and charges shall be effected only prospectively and the
loan agreement shall contain the necessary provisions in this regard.

(b) Decision to recall / accelerate payment or performance under the agreement shall be in
consonance with the terms of the loan agreement.

(c) The Company shall release all securities on repayment of all dues or on realisation of the
outstanding amount of loan subject to any legitimate right or lien for any other claim the company
shall have against the 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) General

(a) The Company shall refrain from interference in the affairs of the borrower except for the
purposes provided in the terms and conditions of the loan agreement (unless information, not
earlier disclosed by the borrower, has come to the notice of the lender).

(b) In case of receipt of request from the borrower for transfer of borrower account, the
consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from
the date of receipt of request. Such transfer shall be as per transparent contractual terms in
consonance with law.

(c) In the matter of recovery of loans, the company shall not resort to undue harassment viz;
persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc.
The Company shall ensure that the staff are adequately trained to deal with the
customers in an appropriate manner.

(d) As a measure of customer protection and also in order to bring in uniformity with regard
to prepayment of various loans by borrowers of banks and The Company the company shall not
charge foreclosure charges/ pre-payment penalties on all floating rate term loans sanctioned to
individual borrowers, with immediate effect.

(v) Responsibility of Board of Directors

I. The Board of Directors of the company shall also lay down the appropriate grievance redressal
mechanism within the organization. Such a mechanism should ensure that all disputes arising

Corporate Office: Urban Vault 1515, 2nd Floor, 19th main, Vanganahalli, Sector 1, HSR Layout, Bengaluru, Karnataka 560102.
Registered Office Address: SY NO. 7P & 93P, Electronic City West, Industrial Area, Begur Hobli, Bengaluru 560100 T: 81978 61629
Email: info@davintafinserv.com www.davintafinserv.com (CIN) U67200KA2018PTC111905
out of the decisions of lending institutions' functionaries are heard and disposed of at least at
the next higher level. The Board of Directors shall also
provide for periodical review of the compliance of the Fair Practices Code and the
functioning of the grievances redressal mechanism at various levels of management. II. A
consolidated report of such reviews may be asked by the Board at regular intervals.

(vi) Grievance Redressal Officer

At the operational level, The Company has displayed the following information
prominently, for the benefit of their customers, at their website / branches / places
where business is transacted:

• the name and contact details (Telephone / Mobile No's as also Email address) of the
Grievance redressal officer who can be approached by the customers for resolving the
complaints against the company.

• 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), under whose jurisdiction the registered office of the Company (NBFC) falls. The
complete contact details of the of the said Officer-in-Charge will be available at the branch
premises.

(a) Mr. Cariappa Kunjira Madappa of the Company is the Grievance Redressal Officer
under the Fair Practices Code who can be approached by the public for resolution of
complaints against the Company on the below mentioned address (a) Grievance Redressal
Officer

DAVINTA FINANCIAL SERVICES PRIVATE LIMITED Registered


Office:
SY NO. 7P & 93P, ELECTRONIC CITY WEST, INDUSTRIAL AREA, BEGUR HOBLI, BANGALORE
Bangalore KA 560100 IN
Email ID: gro@davintafinserv.com
Ph. 080-4718-5381

(vii) Language and mode of communicating Fair Practice Code

Fair Practices Code (which should preferably be in the vernacular language or in a


language as understood by the borrower) based on the guidelines outlined hereinabove
shall be put in place by the Company with the approval of the Board. The Company shall
have the freedom of drafting the Fair Practices Code, enhancing the scope of the
guidelines but in no way sacrificing the spirit underlying the above guidelines. The same

Corporate Office: Urban Vault 1515, 2nd Floor, 19th main, Vanganahalli, Sector 1, HSR Layout, Bengaluru, Karnataka 560102.
Registered Office Address: SY NO. 7P & 93P, Electronic City West, Industrial Area, Begur Hobli, Bengaluru 560100 T: 81978 61629
Email: info@davintafinserv.com www.davintafinserv.com (CIN) U67200KA2018PTC111905
shall be put up on the web-site of the company for the information of various
stakeholders.

(viii) Interest rates charged by NBFC

(a) The Board of directors of the company has adopted an interest rate model taking into account
relevant factors such as cost of funds, margin and risk premium and determine the rate of
interest to be charged for loans and advances. Based on internal risk gradation , derived rate
of interest should be communicated to the borrower.

(b) The rate of interest shall be annualised rate so that the borrower is aware of the exact rates
that would be charged to the account.

(c) Company will adhere to all Digital Lending Guidelines issued by RBI from time to time related
to fairness and transparency with respect to interest rates charged.

Corporate Office: Urban Vault 1515, 2nd Floor, 19th main, Vanganahalli, Sector 1, HSR Layout, Bengaluru, Karnataka 560102.
Registered Office Address: SY NO. 7P & 93P, Electronic City West, Industrial Area, Begur Hobli, Bengaluru 560100 T: 81978 61629
Email: info@davintafinserv.com www.davintafinserv.com (CIN) U67200KA2018PTC111905

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