1.1. Introduction

• This Fair Practices Code has been prepared taking in to account and in accordance with the “Guidelines on Fair Practices Code for NBFCs” issued by the Reserve Bank of India updated from time to time.
• This Fair Practice Code (‘the Oleevia Fair Practice Code’) is adopted and approved by Board of Directors of Oleevia Grameen Credits Private Limited (‘the Company’).
• This Fair Practices Code has been framed with a view to providing to all its stake holders, especially customers (whether Direct Products or Third Party Products, whether Asset or Liability Products) an effective overview of the practices followed by the Company while offering its products and services.
• The Fair Practice Code aims to enable all stakeholders including customers to take informed decisions and provide a grievance redressal mechanism in respect of the facilities and services offered by the Company.

 1.2. Scope of the Code

      The Fair Practices Code adopted by the Company covers the following areas.

• Applications for loans by Customers and their processing by the Company.
• Loan appraisal and terms/conditions.
• Disbursement of loans, including changes in terms and conditions.
• Disclosures about interest rates and approach for gradation of risk.
• Policy on KYC, Appraisal, insurance, storage of securities, Auction etc.
• Confidentiality
• Grievance Redressal Mechanism.
• General Provisions and Other Matters.

1.3.  Objective of the Code

      This Oleevia Fair Practice Code has been drawn up to:

• Adopt the best practices followed by entities in the financial and similar service sector while dealing with customers.
• Communicate the Practices of the Company to stakeholders including in English and their Regional Language.
• Provide to the customers effective overview of practices followed by the Company in respect of financial facilities and services (including Direct and Third party Products) offered by the Company to its Customers.
• Promote good, fair, transparent and legally tenable practices by setting minimum standards in dealings with customers.
• Enable customers to have better understanding of what they can reasonably expect of the services offered by the Company.
• Reckon with market forces, through competition and strive to achieve higher operating standards.
• Foster fair and cordial relationship between the customers and the Company.

• All communications to the Customers including borrower shall be either in English or in a vernacular language of the place where the loan is taken or in a language as understood by the borrower to the extent possible.
• Loan application forms and Other 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’s are required from the Stakeholders including the Customer, the same shall be communicated to the Customer immediately.
• In the case of all other loans other than 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 or other computer printed acknowledgement.

• A Loan Application format shall be provided to the customer in English or in a vernacular language of the place where the loan is taken or in a language as understood by the borrower to the extent possible.
• The borrower shall be given a loan sanction letter and a copy of the loan document together with annexures/enclosures quoted therein in a vernacular language of the place where the loan is taken or in a language as understood by the borrower to the extent possible which shall include the details of the loan such as amount sanctioned, annualized interest rate, method of application thereof and all other terms and conditions as may be applicable.
• The penal interest that will be charged for late payment or failure to settle on the scheduled maturity 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 documentation pertaining to the relevant loan.
• Subject to the 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 in accordance with the turnaround time specified in the relevant loan scheme documentation and as communicated to the customer.
• If there is any delay in sanctioning the loan beyond one day from receipt of application due to reasons like field verification, credit appraisals, exception approvals or the like, the customer shall be given an acknowledgement for receipt of the application also indicating the time frame within which the loan application will be disposed off.
• The customer shall be kept informed of the status of his application at periodic intervals or on his request till final disbursement or the rejection of his application.

• The loan shall be disbursed on executing the necessary documents and completion of the formalities including creating a charge over the security offered by the borrower if applicable.
• Any change in the terms and conditions including interest rates, service charges, prepayment charges etc. shall be informed to the borrower in English or in a vernacular language of the place where the loan is taken or in a language as understood by the borrower to the extent possible.
• Any changes in interest rates and charges shall be only prospective. A suitable condition in this regard, if applicable, 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. This will be as per Call or Demand Policy of the Company as updated from time to time (for e.g., a margin call made on reduction in the value or purity of gold in the case of a gold loan).
• 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.
• Disclosures about interest rates and approach towards gradation of risks.

The Company shall put in place Policies and Procedures duly approved by the Board covering the following aspects:

• Adequate steps to ensure that the KYC guidelines stipulated by RBI are complied with and to ensure that adequate due diligence is carried out on the customer before extending any loan.
• Proper Rrsk, safety and fraud detection training will be provided to the staff of the Company.
• Proper appraisal procedure for assessing the value and purity of the jewellery accepted as collateral security in the case of a gold loan.
• Declaration shall be obtained from the borrower confirming ownership of gold jewelry.
• All branches shall have proper storage facility of either Strong Rooms or Safes conforming to BIS Standards of reputed make to store the jewelry in safe custody.
• The sets of keys to the strong room/safe shall be held separately by two officials and the operations thereof shall be done jointly.
• The staff shall be imparted training on a continuous basis to ensure that the guidelines covering security issues are strictly adhered to. The gold items shall be periodically inspected by the internal auditors or gold inspectors to ensure quality, quantity and proper storage.
• The jewelry accepted as collateral security shall be adequately and appropriately insured. The auction procedure in case of non-repayment shall be transparent. Prior notice to the borrower shall be given before the auction and the Company shall consistently avoid any conflict of interest in the auction process. The auction process shall ensure that an arm’s length relationship in all transactions during the auction is maintained including with group companies and/or related entities. The details regarding procedure for auction shall be disclosed in the loan document for availing the loan.
• The auction will be only through auctioneers approved by the Board and the Company shall not participate in the auction. The auction shall be announced to the public by issuing advertisements in at least two newspapers, one in a vernacular language of the place where the gold loan was taken and the other in a national daily newspaper.
• Any fraud in the functioning of the Company shall be enquired into by the appropriate authority and suitable punitive measure shall be taken by the appropriate disciplinary authority. Any review of the decision of the disciplinary authority shall be carried out by the Board of Directors or Committee authorised by the Board of Directors of the Company.
• Vigil Mechanism and Whistle Blower Policy of the Company will be made easily available to Stakeholders including staff of the Company.

Interest is calculated at simple interest based on the product method, i.e. the product of the principal outstanding and the time or number of days for which the principal was outstanding.

However, where a minimum number of days is specified for the loan in the loan agreement, if the borrower closes the loan within such minimum days from the date of disbursement, then a minimum interest for such specified number of days shall be payable for all loans. In such cases, the borrower will be charged the basic interest rate specified for the loan less any applicable rebates in accordance with the loan agreement.

For loans not settled on the maturity, the Company may charge a penal interest on simple or compounding basis as has been outlined in the relevant loan agreement.

The Company may, at its discretion allow grace period from the due dates as decided from time to time if the date for payment of interest falls due on a Holiday/Sunday.

For the purpose of calculation of interest, a year will be reckoned as 365 days. Leap years shall be also calculated as 365 days basis.

• The Company shall frame appropriate internal policies and procedures for determining the interest rates and processing and other charges, if any, and also ensure that they are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and other charges, if any, on loan and advances are in strict adherence to above referred internal policies and procedures.
• The rate of interest will be annualized rates so that the borrower is aware of the exact rates that would be charged on the loan.
• Interest will be charged on the daily balance outstanding at monthly rest on the basis of the actual number of days from the date of availing the loan to the date of closure of the loan.
• The information published in the website shall be updated whenever there is change in the rates.
• The rate of interest and the approach for gradation of risk and rationale for charging different rates of interest to different schemes shall be disclosed in the application form and also communicated explicitly in the sanction letter issued to the borrower.
• Rebate on interest rates meant to encourage timely periodical payment of interest under each scheme, levying of additional interest for discouraging loans from crossing the sanctioned period etc., shall be mentioned clearly in the loan agreement.
• No pre-payment penalties/foreclosure charges will be levied on loans in the normal course. In case such charges or minimum days of interest is applicable for any scheme, it will be disclosed in the sanction letter.
• Changes in Rate of Interest shall be made only prospectively and as disclosed in the loan agreement.

• Unless authorized by the customers, the Company will treat all personal information as private and confidential.
• Privacy Policy of the Company will strictly followed by the Company.
• The Company may not reveal transaction details of the borrowers to any other persons except under following circumstances.
• If the Company is required to provide the information as per regulatory directives to any statutory or regulatory body or bodies.
• If arising out of a duty to the public to reveal the information.
• If it is in the interest of the customers and Company to provide such information (eg. Fraud prevention)
• If the customer has authorized the Company to provide such information to its group/associate/entities or Companies or any such person/entity as specifically agreed upon.

Towards ensuring redressal of disputes arising out of decisions of the functionaries of the Company, the following mechanism is put in place:

1.1. Primary Grievance Redressal Mechanism

First Line of The Grievance Redressal Mechanism:

A Branch will be the first line of the Grievance Redressal in the Company. Any decisions of an official below the designation of Branch Manager shall be heard and disposed of by the Branch Manager.

Second Line of The Grievance Redressal Mechanism

The Regional Office or the Cluster Manager of the Company under which Concerned Branch Office is located or such official as may be designated shall be the Second Line of the Grievance Redressal Mechanism. Decisions of Branch Managers shall be heard and disposed of by the Regional Manager or Cluster Manager or such designated official by whatever designation called.

Third Line of The Grievance Redressal Mechanism

If not satisfied with the decision of the Regional Manager, the customer has the option to escalate the matter to Grievances Redressal Cell at the Company’s Head Office at 1st floor, Majestic Square, Paravataani, Thrissur, Kerala- 680655.

Grievances against any of outsourced agencies engaged by the Company for various activities like sourcing of applications/collections etc. will also come under the purview of the Grievance Redressal Mechanism as above. In case the complaint is not disposed of to his satisfaction, the customer can exercise the option to escalate the matter to a higher authority in the Company as per the matrix given above.

Customer Grievances Redressal Cell at the Company’s Head Office at 1st floor, Majestic Square, Paravataani, Thrissur, Kerala- 680655 will be headed by an official not below the grade of Asst. or Deputy General Manager who will be designated as the Grievance Redressal Officer by a Management Committee consisting of the Heads of Operations and Credit.

Complaints received directly and appeals against the decisions of Regional Managers on complaints handled by him shall be heard and disposed of by the Grievances Redressal Officer at Head Office. The official shall also be designated as the Nodal Officer for the RBI Ombudsman and dispose of complaints received through him.

If the complaint/dispute is not redressed within a period of one month, the customer may appeal to the NBFC Ombudsman of RBI as per the contact details displayed in the branch.

The contact details of the Grievance Redressal Officer and also that of the RBI Ombudsman/Regional Office of the Reserve Bank of India shall be displayed in all the Branches for the benefit of customers.

Proper training shall be imparted to staff on an ongoing basis with a view to improving staff behaviour and customer service.

The compliance with the Oleevia Fair Practices Code as well as the functioning of the Customer Grievances Redressal Cell shall be reviewed by the Executive Director and Managing Director on a Quarterly basis.

A consolidated report of Management reviews shall be placed before the Board of Directors.

• The Company shall display the normal business hours at the respective Branches, the list of holidays and notify the changes, if any, by way of a notice displayed in the premises of the branch or through web notification.
• The Company shall refrain from interfering in the affairs of the borrower except for the purposes provided in the terms and conditions of the letter of undertaking (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
• Personal information of the customer will not be shared with unauthorized persons or agencies or third parties by the Company. However, the Company will be bound to honour and comply with legal or regulatory requirements, if any, in this matter obligating it to part with such information even without notice to the customer.
• In the matter of recovery of loans, the Company shall not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans etc.
• The staff of the Company shall be adequately trained to deal with the customers in an appropriate manner so as to ensure proper behaviour.
• The Company will call delinquent customers between 0900 hrs to 1730 hrs unless special circumstances of the borrower’s business require to call them or meet them otherwise outside the hours mentioned.

• The Company undertakes to abide by all applicable laws, regulations and guidelines passed/issued by the Sectoral Regulators (for e.g., Reserve Bank of India, IRDA etc) and other competent authorities such as Government or Local Authorities.
• The Company commits itself to full customer satisfaction through efficient, professional and courteous services across all its branches and offices.
• The Company shall consistently strive to meet with and improve upon the internally set benchmarks and practices and be ahead of the standards prevalent in the industry.
• The Company undertakes not discriminate customers on grounds of religion, caste, gender or language.
• The Company will provide clear and full information about its products and services to its customers/prospective customers and will not resort to any misleading or potentially misguiding advertisement or publicity.
• The Company undertakes to desist from introducing any products/services having elements of hidden charges or lack of transparency.
• The Company undertakes not to take advantage of any unintentional or clerical error made by the customer while transacting business.
• The Company shall display the Oleevia Fair Practices Code on its website and also make available to the Customer on request, a copy of the Oleevia Fair Practices Code .

A periodical review (not including quarterly review of grievances redressal) of the Fair Practices Code and functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by the Company at least on yearly basis and a consolidated report of such reviews shall be submitted to the Board of Directors.