CORPORATE GOVERNANCE POLICY

FAIR PRACTICE CODE (FPC)

Harshreejee Finance & Leasing Company Private Limited (HSFLCL)
Date of Board Approval: _______
Website: https://www.hsflcl.com
Approved by: Board of Directors

1. PREAMBLE

In line with Chapter VII of the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 and other applicable RBI guidelines (as amended from time to time), Harshreejee Finance & Leasing Company Private Limited (“HSFLCL” or “the Company”) has formulated this Fair Practice Code (“FPC”).

The Code establishes the minimum standards for fair, transparent, and responsible lending practices to be followed by HSFLCL across all its business operations, including digital lending activities, and is intended to promote ethical behaviour, customer confidence, and financial inclusion consistent with the objectives of the Company’s microfinance operations.

2. PURPOSE AND APPLICABILITY

The objectives of this Code are:

  • To promote fair, honest, and transparent dealings between the Company and its customers.
  • To ensure clarity and fairness in all loan terms, conditions, and pricing.
  • To prevent any form of coercive recovery or unethical business conduct.
  • To ensure compliance with all regulatory directions, circulars, and fair practice standards prescribed by the RBI.
  • To provide a robust and accessible mechanism for grievance redressal.

This Code shall apply to all lending and associated services provided by HSFLCL, whether sourced directly through its website, by digital means, or otherwise.

3. DEFINITIONS

  • “Board” means the Board of Directors of HSFLCL.
  • “Customer” or “Borrower” means any individual or entity that has applied for, or availed, a loan from HSFLCL.
  • “FPC” refers to this Fair Practice Code.
  • “Internal Ombudsman” means the independent authority to be appointed by the Company in due course in compliance with the RBI (Internal Ombudsman for Regulated Entities) Directions, 2023.
  • “Principal Nodal Officer (PNO)” means the designated senior officer appointed for grievance redressal under the RBI’s Integrated Ombudsman Scheme, 2021.
  • “Annual Percentage Rate (APR)” means the annual cost of credit to the borrower, including interest and all other charges.

4. GENERAL PRINCIPLES OF FAIR LENDING

  • Conduct lending operations in a transparent, non-discriminatory, and professional manner.
  • Provide clear and comprehensive information to customers before, during, and after the loan process.
  • Ensure all communications are made in English, Hindi, or the vernacular language understood by the borrower.
  • Treat all customers with dignity and courtesy, ensuring privacy and confidentiality.
  • Avoid any unfair or deceptive acts or practices in advertising, marketing, or recovery.

5. LOAN APPLICATION AND PROCESSING

  • All loan applications shall contain essential information about applicable charges, processing fees, penal charges, prepayment options, and required documentation.
  • Borrowers shall be informed of the approximate time frame within which loan applications will be processed.
  • The Company shall acknowledge receipt of all loan applications.
  • In case of rejection of any application, the applicant shall be informed promptly, with reasons, in writing or by email.

6. LOAN APPRAISAL AND SANCTION

  • The Company shall undertake credit assessment in accordance with internal credit and risk policies.
  • Upon approval, the borrower shall be issued a Sanction Letter containing:
    • Loan amount sanctioned and tenure
    • Annualized rate of interest and method of calculation
    • Penal charges, if any
    • All applicable fees or charges
  • The borrower’s acceptance of terms shall be obtained before disbursement, and copies of executed agreements shall be shared.

7. LOAN DISBURSEMENT AND CHANGES IN TERMS

  • Loans shall be disbursed in accordance with the sanction terms.
  • Any change in interest rates, charges, or repayment terms shall be communicated in advance.
  • Notice shall be issued before recalling or accelerating repayment obligations.
  • Upon full repayment, all securities or documents shall be returned to the borrower promptly.

8. RESPONSIBLE LENDING AND CUSTOMER PROTECTION

  • No coercive or abusive recovery practices shall be employed.
  • Recovery agents shall be trained and maintain courteous, lawful behaviour.
  • No discrimination shall be made based on gender, caste, religion, or disability.
  • Borrowers shall be informed about the implications of late payments and their rights.

9. INTEREST RATE POLICY

  • Interest rates shall align with the Board-approved Interest Rate Policy, considering cost of funds, risk, and market conditions.
  • Annualized rates and all charges shall be clearly disclosed in the KFS, sanction letter, and loan agreement.
  • Rates shall be displayed on the Company’s website and updated periodically.
  • No hidden or retrospective charges shall be levied.

10. PENAL AND PREPAYMENT CHARGES

  • Penal charges shall not be capitalized as penal interest.
  • Charges must be reasonable, non-discriminatory, and disclosed upfront.
  • No prepayment or foreclosure penalties shall be charged on personal loans in line with RBI norms.

11. DIGITAL LENDING FRAMEWORK

  • HSFLCL shall comply with RBI (Digital Lending) Directions, 2025 and related circulars.
  • All digital lending via www.hsflcl.com shall be transparent and secure.
  • Borrower data shall be stored and processed securely with confidentiality.

12. RECOVERY OF LOANS

  • Recovery shall be fair, lawful, and non-aggressive.
  • Borrowers shall not be harassed through repeated or untimely communications.
  • Recovery staff shall display identification and maintain professionalism.

13. GRIEVANCE REDRESSAL MECHANISM

The Company has a Board-approved Grievance Redressal Mechanism to ensure prompt and fair resolution of complaints.

Principal Nodal Officer (PNO):
Mr. Tanmay Gupta
Director & Principal Nodal Officer
Email: [Insert official grievance email ID]
Contact: [Insert phone number]

If unresolved within 30 days, the borrower may escalate to the RBI Ombudsman via https://cms.rbi.org.in.

14. OMBUDSMAN AND INTERNAL OMBUDSMAN

  • Compliance with the Reserve Bank – Integrated Ombudsman Scheme, 2021 shall be ensured.
  • An Internal Ombudsman shall be appointed as per RBI (Internal Ombudsman for Regulated Entities) Directions, 2023.

15. DISPLAY AND COMMUNICATION OF FPC

  • The FPC shall be available in English and vernacular languages understood by borrowers.
  • It shall be displayed on the Company’s website and shared at all customer touchpoints.
  • Employees shall receive regular training to ensure compliance.

16. BOARD OVERSIGHT AND REVIEW

  • The Board shall review the implementation of this Code annually.
  • Effectiveness of grievance redressal shall be reviewed quarterly by senior management and reported to the Board.

17. REGULATORY COMPLIANCE AND AMENDMENTS

This Code shall be reviewed and amended periodically in line with RBI guidelines or operational changes. In case of conflict, the regulatory provisions shall prevail.

Approved by:
Board of Directors
Harshreejee Finance & Leasing Company Private Limited
Date: _________