Avanti Finance Customer Service Policy

1.Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) has framed the Customer Service Policy (hereafter referred to as “Customer Service Policy” or “the Policy”) in accordance with the regulatory requirements specified by the Reserve Bank of India (RBI).

2.Objectives of the Policy

The objective of the Customer Service Policy is to ensure all customers are treated fairly and without bias; issues raised by customers are attended and dealt with utmost care and resolved within a reasonable time; customers are made aware of their rights and alternative remedies if they are not satisfied with the response or resolution to their complaint.

3.Categories of Customer’s Communications

1. Query - General inquiries, primarily relating to loans, interest rates, repayment terms, eligibility norms, categories of loans, eligibility criteria, terms of financing / refinancing etc.
2. Request – Requests for obtaining any valid services including financing or refinancing support by the customers directly.
3. Grievance – A communication by prospective / existing customers that expresses dissatisfaction because of lack of action, inadequate quality of services.
4. Complaint – Related to staff misbehaviour, cheating / fraud, false commitments, mis-conduct with the customers.
5. Suggestion / Feedback – suggestions / feedback with respect to its operations, policies or practices.

4.Mechanism for complaints

Customer can lodge his / her grievance through any of the following channels:

1. Complaint in Person: A customer can lodge a complaint in person during working hours at any of the branches with the designated officer.
2. Complaints through post / mail / email/box: Customers can also submit their grievances by post at the following address or through email at customerservice@avantifinance.in by giving full disclosures and details of the complainant and giving specific instances of the cause of complaint.

Addressed to: Head Operations, 3rd Floor Elphinstone Building, Veer Nariman Road, Horniman Circle, Fort, Mumbai 400001. Telephone - 022 62352121

5.Recording and tracking of Complaints

All the complaints received is recorded and tracked for end-to-end resolution in a spreadsheet format. Complaint MIS is published and shared to the management on quarterly basis for quality control.

6.Resolution of Complaints

1. Any complaint through e-mail / letters / person shall be acknowledged promptly after receipt, at the corporate office or Regional / Branch Offices as and when set up.
2. The Complaints should be registered in the Customer Grievance Register (CGR) maintained electronically and / or physically, and shall include full details of the complainant (name, address and contact details), date of receipt, fact of the complaint, category of complaint etc.
3. The company has appointed Mr. Sunil Kumar Tadepalli (sunil.kumar.t@avantifinance.in) authorised official of the company as its Grievance Redressal Officer (‘GRO’). The GRO will take steps to redress the grievances with care and diligence, normally within the period of 21 working days from the date of receipt of the complaints.
4. If the complainant is not satisfied with the reply / action / resolution given by Grievance Redressal Officer (GRO) (or equivalent), he / she may directly approach the Chief Executive Officer (CEO), for further action on the same.
5. Anonymous complaints will not be entertained.

6.1 Recovery Process

The staff  shall be trained in proper etiquette for recovery process as elaborated in the Fair Practice Code adopted by the company.

6.2 Internal Machineries to handle Customer complaints / grievance

1.  Customer Service contact (CSC): The Customer Service contact (CSC) will be the first point of contact for the customers in most of the cases. CSC will be responsible to receive the complaint of customers by whatever means, i.e. in person, post, mail etc. If the complaints received by Nodal officers it will be forwarded to CSC with related documents / enclosures (if any) for early resolution on the next working day of receipt of the complaint.

CSC will provide an acknowledgment for the complaint received from the customer within 5 working days of the receipt, and also make necessary entries in the Customer Grievance Register (CGR) which shall include but without limitation to, full details of the complainant (name, address, and contact details), date of receipt, fact of the complaint, category of complaint etc.

1.  The Company will designate a GRO (or equivalent) at its corporate office. GRO (or equivalent)will have the responsibilities of ensuring early resolution of complaints.

GRO will first examine the nature of the Complaint and initiate necessary action to address the complaint to the satisfaction of the complainant.  He / She will also ensure to record the action initiated or taken in the CGR along with the status of the complaint- resolved / unresolved or escalated to next level, as the case may be.  GRO will circulate the monthly Action Taken Report on all the complaints received, within 7 working days of the next month to the Chief Grievance Redressal Officer (or equivalent) for information / guidance. (Not regulatory , but a good practice).

6.3 Time Frame

1.  The Complaints received will be analysed from all possible angles. All efforts will be made to resolve each complaint received generally within the stipulated time as per the following escalation matrix:

Within 10 working days

-Customer Service contact (CSC) or Partner engagement manager (or equivalent)

Within 20 working days

-Grievance Redressal Officer (GRO) or Head- Partnerships & Alliances (or equivalent)

Within 30 working days

-Chief Executive Officer / Board of directors

1.  There may be some complaints which require deeper analysis from all possible angles which may cause delayed resolution of the complaint. In such cases, the company will try to resolve the grievances at the earliest depending on the nature of the case. Such delay in addressing the complaint beyond the prescribed time limit shall be conveyed to the complainant along with reasons for the same.

If the resolution of the complaint is delayed beyond 30 days of receipt, or the complainant is not satisfied with the reasons of delay conveyed to him / her, he / she may appeal to the Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision (DNBS) of RBI, Mumbai within whose jurisdiction the registered office of the Company is situated and the following message shall be displayed at the branch and on the website of the Company: “If your complaint/dispute is not redressed within a period of 30 days, you may appeal to the officer-in-charge of the Regional Office of DNBS at RBI, at the following address: Officer-in-charge, Reserve Bank of India, Regional Office, DNBS, fourth floor, opp. Mumbai Central Station, Byculla, Mumbai – 400 008”

6.4 Reporting to Board of Directors

Summary of the customer grievance reports along with actions initiated would be reported to the Board at least once in a year. The report shall contain information like, the total no. of complaints received, disposed of and pending, with reasons thereof, which will be placed before the Board for information / guidance.

7.Regulatory References

This policy is framed as per the following regulatory references and in accordance with leading industry practice: RBI circular on Master Direction - Non-Banking Financial Company –Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016.

Interest Rate Policy

1. Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) has framed the Interest Rate Policy (hereafter referred to as “Interest Rate Policy” or “the Policy”) in accordance with the regulatory requirements specified by the Reserve Bank of India (RBI).

2. Objectives of the Policy

This document aims to establish a framework for determining interest rates, processing charges and other charges. (All charges and rates mentioned herein are exclusive of Goods and Service Tax (GST) or any other applicable tax and the company shall charge and collect such taxes wherever applicable over and above mentioned charges and rates).

3. Methodology for determining an Interest Rate

The guiding principles for determining interest rate are as follows:

1. The Board of the company shall adopt 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. 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 electronic application form and communicated explicitly through electronic means.
2. The rate of interest to be charged for loans and advances will be in the range of 12% to 29% p.a.
3. The rate of interest shall be arrived at after taking into account relevant factors, such as cost of funds, margin and risk premium, including the following.

(a)  Tenor of the Loan – The rate of interest charged will depend on the term of the loan;

(b) Internal and External Costs of Funds – The rate of interest charged will also be determined depending on the rate at which funds necessary to provide loan facilities to customers are sourced by the Company, normally referred to as internal cost of funds. From an external cost of funds perspective, the benchmark interest rate that may be used by the Company could be the 10 year Government of India bond rate or any other generally acceptable benchmark rate as adjusted for the rating spreads available in the markets.

(c)  Internal Cost Loading – The interest rate charged will also take into account costs of doing business. Factors such as the complexity of the transaction, the size of the transaction and other factors that affect the costs associated with a particular transaction will also be taken into account before arriving at the final rate of interest quoted to a customer.

(d)  Credit Risk – As a matter of prudence, bad debt provision cost should also be factored into all transactions. This cost is then reflected in the final rate of interest quoted to a customer. The amount of bad debt provision applicable to a particular transaction will depend on the credit strength of the customer.

(e)  Fixed rate versus Floating rate – The applicable rate of interest shall also be commensurate from the perspective of the fixed versus floating interest rate requirements of the customers.

(f)  Periodicity of Interest – Interest will be charged for the period as stipulated in the loan agreement, subject to any modifications thereto as may be agreed by and between the Company and the customer electronically.

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

Table below illustrates the ranges of the various components that drive the interest rate charged to the customer

4. General Provisions

1. Changes in Terms – The Company shall give electronic notice to the borrower in English language with an option to choose a vernacular language as understood by the borrower of any change in the terms and conditions of the loan, including disbursement schedule, interest rates, service charges, prepayment charges etc. Further, any changes in the rate of interest shall be effected only prospectively and the electronic loan agreement shall contain the necessary provisions in this regard.
2. Grace Period - Interest will be payable by the customer / borrower on or before the due date stipulated therefor in the loan agreement entered into by the customer / borrower with the Company. However, the Credit Committee of Executives shall have discretionary power to grant a considered grace period to any customer / borrower.
3. Moratorium - The Company may consider necessary moratorium for payment of interest and repayment of principal amount with proper built in pricing, on a case to case basis.
4. Additional Interest and other Charges - Besides the normal interest, the Company levies additional interest for delays in payment of dues by the customer / borrower or additional interest on other facilities etc (annualised interest on the outstanding balance). The Company may charge other financial charges including processing fees, cheque bouncing charges, pre-payment / foreclosure charges, RTGS or such other remittance charges, commitment fees, charges for services like issuance of “no due certificate”, security swap charges etc along with relevant taxes.
   

The Company shall not charge foreclosure charges / pre-payment penalties on all floating rate term loans sanctioned to individual borrowers.

1. Communication of Interest Rate to the Customer – The Company shall convey electronically to the borrower in English language with an option to choose a vernacular language as understood by the borrower, by digital means, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof and shall keep an electronic record of the acceptance of these terms and conditions by the borrower. The loan agreement shall expressly stipulate the penal interest chargeable for late payment / repayment of dues by the borrower, in bold. The apportionment of the equated monthly instalments (“EMI”) amount towards the principal and interest will also be communicated by the Company to the customer / borrower by way of the repayment schedule.
2. Waiver of Additional Interest / Financial Charges – Requests by the customer for waiver of additional interest / financial charges would normally not be entertained by the Company and such waiver will be at sole and absolute discretion of the Credit Head or a person of equivalent position, exercised on a case to case basis or any other person that the Board deems fit.
3. Annualised Rates - The rate of interest shall be annualised rates so that the borrower is aware of the exact rates that would be charged to the account.
4. Pre-Payment - Pre-payment options available to the customer and the penalty / charges payable for exercise of such option shall be mutually agreed to on a case-to-case basis and communicated to the customer. There will be no pre-payment penalty / charges on Microfinance Loans.
5. Company Website: The rates of interest and the approach for gradation of risks shall be made available on the web-site of the company and literature issued by it. The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.
6. Though the primary mode of all operations, processes or procedures set in this Policy are electronic or digital in nature the company may at its discretion decide to use physical/written means for all or any points covered in this Policy.

5. Regulatory Reference

This policy is framed as per the following regulatory references and in accordance with leading industry practice:

1. Master Direction - Non-Banking Financial Company –Non-Systemically Important Non- Deposit taking Company (Reserve Bank) Directions, 2016
2. Master Direction – Reserve Bank of India (Regulatory Framework for Microfinance Loans) Directions, 2022

6. Policy Review and Updates

The implementation of this policy shall be monitored and reviewed periodically by the Board of the Company.

This Policy was:

(i)  drafted on behalf of the Company by: Mr. Nagaraj Subrahmanya, CRO

(ii)  internally reviewed by: Mr. Rahul Gupta, CEO

(iii)  approved by the Board of the Company on: September 12, 2018, Revision 1 on: March 31, 2022, Revision 2 on September 30, 2022

This Policy comes into effect from date of Board Approval

Annexure – I

Interest rate and other charges framework:

Whistle blower policy

1. Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) strongly believes in conducting all affairs of its constituents in a fair and transparent manner by adopting the highest standards of honesty, inclusiveness, professionalism, integrity and ethical behaviour. 

The whistle blower policy has been formulated as part of corporate governance norms and transparency where the employees, customers or stakeholders are encouraged to refer any complaints which have not been resolved or satisfactorily resolved within the usual applicable protocols. The employees may refer any complaints covering areas such as corruption, misuse of office, criminal offences, suspected / actual fraud, failure to comply with existing rules and regulations, conflicts of interest, related party transactions and acts resulting in financial loss/ operational risk, loss of reputation, etc.

This policy shall provide a channel to the employees (including directors) and other stakeholders to report to the management or the board about unethical behaviour, actual or suspected fraud or violation of the Code of Business ethics or legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports and such other matters.

2. Objectives of the Policy

The key objectives of the policy are as under:

1.  Promote a culture of speaking up/ raising red flags on matters relating to breaches/ violations of the Company’s Code of Business ethics or fraudulent transactions.

2.  Provide a platform and mechanism for the employees and relevant stakeholders to voice genuine concerns of grievances about unprofessional conduct without the fear of reprisal to the employee raising the concern.

3.  Provide a non-threatening environment to employees to discuss matters relating to the Code of Business ethics.

4.  Adhere to the highest standards of ethical, moral and legal conduct of business operations.

5.  Promote clean business transactions, professionalism, productivity, promptness and transparent practices and ensures putting in place systems and procedures to curb opportunities for corruption.

6.  Sustain, strengthen and encourage a culture of integrity & compliance

7.  Institutionalize a mechanism for protection of employees from reprisals or victimization, for whistle blowing in good faith as the Company strictly follows No Retaliation Policy.

8.  Provide an assurance to external stakeholders that there is internal cordiality and transparency.

9.  Treat the violations/ breaches/ non-compliance at various levels of the Company with vigour and due care and accordingly realign processes and take corrective actions as part of its corporate governance.

The Policy shall help the Company to create an environment where employees and relevant stakeholders feel free and secure to raise the alarm where they see a problem. It shall also ensure that whistleblowers are protected from retribution, whether within or outside the Company.

3. Applicability of the Policy

The Policy applies to all the Company’s employees. The policy shall also apply to any complaints made by other stakeholders of the Company such as outsourced agents, customers and members of public.

4. Governance Structure

Avanti Finance Private Limited has devised an effective whistle blower mechanism enabling stakeholders, including individual employees to freely communicate their concerns about illegal or unethical practices.

4.1 Nominated Director

A Director nominated by the Company’s Board of Directors (or the audit committee when legally required to be setup) will review the effectiveness of the vigil mechanism and implementation of the Whistle Blower Policy to provide adequate safeguards against victimization of employees and relevant stakeholders. The details of establishment of Vigil mechanism shall be disclosed by the Company on the website, if any, and in the Board’s Report to the stakeholders.

In case of repeated frivolous complaints being filed by a director or an employee, the Audit committee (when it is formed) or a director to be nominated by the Board  {(As required under Section 177 of the Companies Act, 2013 read along with Rule 7 of The Companies (Meetings of Board and its Powers) Rules, 2014} shall take suitable action against the concerned director or employee.

4.2 Whistle blowers Committee

The Whistle-blower committee shall comprise Mr. Rahul Gupta, Mr. Manish Thakkar and Mr. Sunil Kumar Tadepalli. The Committee shall look into the complaints report prepared by the nominated officer Mr. Saikrishnan Srinivasan and can suo moto institute further investigation / call for additional documentary evidence before submitting its findings on the matter. 

The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup)

5. Scope

This Policy intends to cover serious complaints that could have grave impact on the operations and performance of the business of the Company. Receipt of information about corruption, malpractice or misconduct on the part of employees, from whatever source, would be termed as a complaint. Complaints may be received from any of the following sources:

1. Complaints received from employees of the organisation or from the public
2. Departmental inspection reports
3. Scrutiny of transactions reported under the Code of Business ethics
4. Reports of irregularities in accounts detected in the routine audit of accounts, e.g. tampering with records, over-payments, misappropriation of money or materials, etc.
5. Audit reports of the accounts of the Company
6. Complaints and allegations appearing in the press, etc.
7. Source information, if received verbally from an identifiable source, to be reduced in writing.
8. Intelligence gathered by agencies like CBI, local bodies etc.

Under the Policy, employees and relevant stakeholders of the Company having sufficient grounds for a concern can lodge complaints. 

The Policy intends to cover the following types of complaints:

1. Fraudulent activities or activities in which there is suspected fraud
2. Intentional or deliberate non-compliance with laws, regulations and policies
3. Questionable accounting practices including misappropriation of monies
4. Illegal activities
5. Corruption and deception
6. Misuse/ Abuse of authority
7. Violation of the Company’s rules, manipulations and negligence
8. Breach of contract
9. Pilferation of confidential/proprietary information
10. Deliberate violation of law/regulation
11. Wastage/misappropriation of Company’s funds/assets
12. Malpractices/ events) causing danger to public health and safety.

The following nature of complaints shall not be covered in the policy:

1. Complaints those are frivolous in nature.
2. Issues relating to personal grievance (increment, promotion, etc.)

6. Guiding Principles

To ensure that this Policy is adhered to, and to assure that the concerns raised under this Policy will be acted upon seriously, the Company will:

1. Ensure that the Whistle Blower and/or the person processing the Protected Disclosure is not victimized
2. Ensure complete confidentiality of the identity of the WhistleBlower
3. Not attempt to conceal evidence of the Protected Disclosure
4. Take disciplinary action, if any one destroys or conceals evidence of the Protected Disclosure made/to be made
5. Provide an opportunity of being heard to the persons involved, especially to the subject
6. Provide protection to Whistle Blower under this Policy provided that Protected Disclosure is made in good faith, the WhistleBlower has reasonable information or documents in support thereof and not for personal gain or animosity against the subject
7. Ensure that the Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious be liable to Disciplinary Action.
8. Take Disciplinary Action for event covered under this Policy or upon victimizing Whistle Blower or any person processing the Protected Disclosure or if any one destroys or conceals evidence of the Protected Disclosure made/to be made.
9. Ensure that any other Director/ Employee or other stakeholders assisting in the said investigation or furnishing evidence, is protected to the same extent as the Whistleblower. 

7. Procedure 

7.1 Lodging of Complaints

The Protected Disclosure shall be submitted in a closed and secured envelope and shall be super scribed as “Protected disclosure under the Whistle Blower policy”. Alternatively, the same can also be sent through email or any other acceptable mode of communication with the subject “Protected disclosure under the Whistle Blower policy” to a functional email id of the company who’s access is only with the whistle-blower committee. If the complaint is not super scribed and closed as mentioned above, it will not be possible for the Board to protect the complainant and the protected disclosure will be dealt with as if a normal disclosure. 

In order to protect identity of the complainant, the nominated officer (or designated equivalent officer) will not issue any acknowledgement to the complainants and they are advised neither to write their name/address on the envelope nor enter into any further correspondence with the nominated officer. The nominated officer shall assure that in case any further clarification is required he will get in touch with the complainant.

The Company shall not entertain anonymous / pseudonymous disclosures except of such disclosures have merit shall be entertained.

The Protected Disclosure shall be forwarded under a covering letter signed by the complainant. The nominated officer shall detach the covering letter bearing the identity of the WhistleBlower and process only the Protected Disclosure.  

All Protected Disclosures shall be addressed to the nominated officer or Director of the Company or to the audit committee (when the committee is required to be legally setup).

The Protected Disclosures shall be addressed to the following address:

The Nominated officer OR the nominated Director 

‍Avanti Finance Private Limited,

Floor-3rd, 10, Elphinstone Building, 

Veer Nariman Road, Horniman Circle, Fort, Mumbai

Maharashtra 400001

E-mail: whistleblower@avantifinance.in

7.2 Receipt of Complaint

On receipt of the protected disclosure the nominated officer shall maintain and preserve records of the Protected Disclosure and also ascertain from the complainant whether he / she was the person who made the protected disclosure or not. The record will include:

1. Brief facts
2. whether the same Protected Disclosure was raised previously on the same subject and if so, the outcome thereof
3. Details of actions taken by the nominated officer (or equivalent department) or CEO for processing the complaint
4. Findings of the Audit Committee (or the whistle-blower committee duly approved by the board), the recommendations of the Committee/ other action(s).

An exclusive e-mail ID under the control of the whistle-blower committee has been set up to which any Wrongful Conduct can be reported by any WhistleBlower. The said email id is: - whistleblower@avantifinance.in

The nominated officer will carry out a preliminary analysis as to whether the complaint pertains to Wrongful Conduct or not or there is a prima-facie case and shall then refer the matter to the Whistleblower committee. 

The Whistleblower Committee, if deems fit, may call for further information or particulars from the complainant. 

7.3 Investigation Report

All Protected Disclosures reported under this Policy will be thoroughly investigated by the nominated officer of the Company who will investigate / oversee the investigations under the authorization of the Audit Committee. The nominated officer may at its discretion consider involving any investigators for the purpose of investigation.

The decision to conduct an investigation taken into a Protected Disclosure by itself is not an acceptance of the accusation by the Authority. It is to be treated as a neutral fact-finding process because the outcome of the investigation may or may not support accusation; unless there are compelling reasons not to do so, subjects will be given reasonable opportunity for hearing their side during the investigation. No allegation of wrongdoing against a subject shall be considered as maintainable unless there is good evidence in support of the allegation.

The subject shall have right to access any document/ information for their legitimate need to clarify/ defend themselves in the investigation proceedings.

The nominated officer shall normally complete the investigation within 45 days of the receipt of protected disclosure.

Based on a thorough examination of the findings, the nominated officer shall submit a report to the Whistleblower Committee on a regular basis about all Protected Disclosures referred to him/her since the last report together with the results of investigations, if any.

The Committee shall look into the complaints report prepared by the nominated officer and can suo moto institute further investigation / call for additional documentary evidence before submitting its findings on the matter. The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup). The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup).

7.4 Appeal and Decision

If an investigation leads the nominated officer to conclude that an improper or unethical act has been committed which would result in suggested disciplinary action, including dismissal, if applicable; the nominated officer shall recommend to the WhistleBlower Committee of the Company to take such disciplinary or corrective action as he may deem fit. All discussions would be documented and the final report will be recommended by the whistleblower committee and duly approved by the Nominated Director.  

If the report of investigation is not to the satisfaction of the complainant, the complainant has the right to report the event to the appropriate legal or investigating agency. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

7.5 Confidentiality

Every effort will be made to protect the identity of the complainant, subject to legal constraints except in cases where the complainant turns out to be vexatious or frivolous and action has to be initiated against the complainant. In the event of the identity of the complainant being disclosed, the nominated officer  can initiate appropriate action against the person making such disclosure.

7.6 Protection 

The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against WhistleBlowers. Complete protection will therefore be given to WhistleBlowers against any unfair practice like retaliation, threat or intimidation of termination / suspension of service, disciplinary action, transfer, demotion, refusal of promotion or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties / functions including making further Protected Disclosure.

A WhistleBlower may report any violation of the above clause to the Chairman of the Audit Committee, who shall investigate into the same and recommend suitable action to the Internal Complaint Committee. 

8. Record Keeping

All documentation pertaining to the complaint including the investigation report, corrective action taken and evidence will be maintained for a period of 8 years or such other period as specified by any other law in force, whichever is more.

9. Reporting Requirements

The following are the reporting requirements -

1. The details of establishment of Vigil mechanism shall be disclosed by the Company on the website, if any, and in the Board’s Report.
2. Whistle blower policy, and affirmation that no personnel has been denied access to the Board for reporting actions under the whistle blower policy.

10. Policy Review and Updates

The Board approved policy shall be reviewed as and when required for incorporating regulatory updates and changes, if any. 

11. Definitions

1. Audit Committee: A Committee constituted by the Board of Directors of the Company in accordance with Companies Act, 2013.

2. Protected Disclosure: a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity. Protected Disclosures should be factual and not speculative in nature

3. Subject: a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation

4. Whistle Blower/Complainant: an Employee making a Protected Disclosure under this Policy. An employee making a disclosure under this process is commonly referred to as a complainant. The complainant is not expected to prove the truth of an allegation, the complainant needs to demonstrate that there are sufficient grounds for concern and expected to provide the complete details/evidences in his possession.

CODE OF CONDUCT

1   SCOPE AND PURPOSE OF THIS CODE

• 1.1   In this Code of Conduct Policy (“Code”), “we” or “us” or “our” means Avanti Finance Private Limited (“Company”), and includes our executive directors, officers, employees and those who work with us, as the context may require.
• 1.2   This Code sets out how we behave with:
• (i)   our employees, or those who work with us;
• (ii)  our customers;
• (iii) the communities and the environment in which we operate;
• (iv) our value-chain partners, including suppliers and service providers, distributors, sales representatives, contractors, channel partners, consultants, intermediaries and agents;
• (v)  our joint-venture partners or other business associates;
• (vi) our financial stakeholders; and
• (vii) the governments of the regions where we operate.
• 1.3  This Code sets out our expectations of all those who work with us. We also expect those who deal with us to be aware that this Code underpins everything we do, and in order to work with us they need to act in a manner consistent with this Code.
• 1.4  This Code applies to following activities undertaken by us:
• (i) providing credit services to clients individually or in groups;
• (ii) recovery of credit provided to clients;
• (iii) collection of thrift from clients, where ever applicable;
• (iv) providing insurance and pension services, remittance services or any other products and services permitted under applicable law, that will reduce vulnerability of our clients;
• (v) formation of any type of community collectives including self-help groups, joint liability groups and their federations; and
• (vi) business development services including marketing of products or services made or extended by the eligible clients or for any other purpose for the welfare and benefit of clients.

2.  OUR CORE VALUES

2.1  The core values that underpin the way we conduct our business activities are:

2.1.1  INTEGRITY: We are fair, honest, transparent and ethical in our conduct; everything we do must stand the test of public scrutiny. Our primary mission is to service financially excluded individuals and families by providing them access to financial services, which are client focused, designed to enhance their well-being, and delivered in an ethical, dignified, transparent, equitable and cost-effective manner.

2.1.2  QUALITY OF SERVICE: We are committed to ensure quality services to our clients, appropriate to their needs and delivered efficiently in a convenient and timely manner. While doing so, we agree to maintain high standards of professionalism based on honesty, equality and dedication to serve the poor.

2.1.3  TRANSPARENCY: We shall provide our clients complete and accurate information and educate them about the terms of financial services offered by us such as interest rates and all other charges as well as our policies and procedures in a manner that is understandable by them.

2.1.4  PIONEERING: We will be bold and agile, courageously taking on challenges, using deep customer insight to develop innovative solutions.

2.1.5  PRIVACY OF CLIENT INFORMATION: We will safeguard personal information of clients, only allowing disclosures and exchange of such information to others who are authorised to see it, with the knowledge and consent of clients.

2.1.6  RESPONSIBILITY: We will integrate environmental and social principles in our businesses, ensuring that what comes from the people goes back to the people many times over.

3. OUR CORE PRINCIPLES

3.1  We are committed to operating our businesses by conforming to the highest moral and ethical standards. We do not tolerate bribery or corruption in any form. This commitment underpins everything that we do.

3.2  We are committed to good corporate citizenship. We treat social development activities, which benefit the communities we operate in as an integral part of our business plan.

3.3  We seek to contribute to the economic development of the communities in regions we operate, with due respect to their culture, norms and heritage. We seek to avoid any project or activity that is detrimental to the wider interests of the communities in which we operate.

3.4  We shall not compromise safety in the pursuit of commercial advantage. We shall strive to provide a safe, healthy and clean working environment for our employees and all those who work with us.

3.5  When representing the Company, we shall act with professionalism, honesty and integrity, and conform to the highest moral and ethical standards. Our conduct shall be fair and transparent and be perceived as fair and transparent by third parties.

3.6  We shall respect the human rights and dignity of all our stakeholders.

3.7  We shall strive to balance the interests of our stakeholders, treating each of them fairly and avoiding unfair discrimination of any kind.

3.8  The statements that we make to our stakeholders shall be truthful and made in good faith.

3.9  We shall not engage in any restrictive or unfair trade practices.

3.10  We shall provide avenues for our stakeholders to raise concerns or queries in good faith, or report instances of actual or perceived violations of our Code.

3.11  We shall strive to create an environment free from fear of retribution to deal with concerns that are raised, or cases reported in good faith. No one shall be punished or made to suffer for raising concerns or making disclosures in good faith or in the public interest.

3.12  We expect the leaders of our businesses to demonstrate their commitment to the ethical standards set out in this Code through their own behavior and by establishing appropriate processes.

3.13  We shall comply with the laws of the countries in which we operate and any other laws which apply to us. With regard to those provisions of the Code that are explicitly dealt with under an applicable law or employment terms, the law and those terms shall take precedence. In the event that the standards prescribed under any applicable law are lower than that of the Code, we shall conduct ourselves as per the provisions of the Code.

4. OUR EMPLOYEES

4.1  Equal opportunity employer

4.1.1  We provide equal opportunities to all our employees and to all eligible applicants for employment in our Company. We do not unfairly discriminate on any ground, including race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, disability or any other category protected by applicable law.

4.1.2  When recruiting, developing and promoting our employees, our decisions will be based solely on performance, merit, competence and potential.

4.1.3  We shall have fair, transparent and clear employee policies which promote diversity and equality, in accordance with applicable law and other provisions of this Code. These policies shall provide for clear terms of employment, training, development and performance management.

4.2  Dignity and respect

4.2.1  Our leaders shall be responsible for creating a conducive work environment built on tolerance, understanding, mutual cooperation and respect for individual privacy.

4.2.2  Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whether sexual, physical, verbal or psychological.

4.2.3  We have clear and fair disciplinary procedures, which necessarily include an employee’s right to be heard.

4.2.4  We respect our employees’ right to privacy. We have no concern with their conduct outside our work environment, unless such conduct impairs their work performance, creates conflicts of interest or adversely affects our reputation or business interests.

4.3  Collection, Use and Disclosure of personal information of Employees

4.3.1  Purpose of collection: In the course of conducting our business and complying with various applicable law relating to employment, tax, insurance, etc., we collect certain personal information from our Employees (“Employee Personal Information”). The nature of the Employee Personal Information collected varies for each employee and depends upon employee’s responsibilities, citizenship, work location, and other factors. The purpose of collecting and using Employee Personal Information is limited to the business purposes, including those related directly to employee’s employment with the Company, and any other such requirement as per applicable law.

4.3.2  Types of information collected: Employee Personal Information includes, without limitation, the following:

1. Name
2. Phone numbers
3. Email address
4. Mailing addresses
5. Banking and other financial data
6. Date of birth
7. Gender, race, and ethnicity
8. Health and disability data

4.3.3  Usage: The primary purposes for collection, storage and/or use of your Personal Information include, but are not limited to:

1. Human Resources Management. We collect, store, analyze, and may share (internally) Employee Personal Information in order to attract, retain and motivate a highly qualified workforce. This includes recruiting, compensation planning, succession planning, reorganization needs, performance assessment, training, employee benefit administration, compliance with applicable legal requirements, and communication with employees and/or their representatives. 
2. Business Processes and Management. Employee Personal Information is used to run our business operations including, for example, scheduling work assignments, managing company assets, reporting and/releasing public data (e.g., Annual Reports, etc.); and populating employee directories.
3. Safety and Security Management. We use such Employee Personal Information as appropriate to ensure the safety and protection of employees, assets, resources, and communities. 
4. Communication and Identification. We use Employee Personal Information to identify you and to communicate with the employees.

4.3.4  Disclosure: We stive to protect Employee Personal Information and ensure that unauthorized individuals do not have access to such information by using adequate security measures. We will not knowingly disclose, sell or otherwise distribute Employee Personal Information to any third party without the relevant employee’s knowledge and, where appropriate, your express written permission, except under the following circumstances:

1. Legal requests and investigations. We may disclose Employee Personal Information when such disclosure is reasonably necessary (i) to prevent fraud; (ii) to comply with any applicable law; or (iii) to comply with an order by a competent court.
2. Third-party vendors and service providers. We may, from time to time, outsource services, functions, or operations of our business to third-party service providers. When engaging in such outsourcing, it may be necessary for us to disclose Employee Personal Information to those service providers (for example, payroll service providers). In some cases, the service providers may collect Employee Personal Information directly from the employee on our behalf. Our relationship with such service providers will be governed by such commercial, operational and other terms as negotiated under valid contract.
3. Business Transfers: During the term of employment, we may buy other companies, create new subsidiaries or business units or sell part or all of our assets. It is likely that, as part of such process, some or all of Employee Personal Information will be transferred to another company as part of any such the transaction. 
4. Reserved Matters. We may release Employee Personal Information when we believe release is necessary to comply with the law; enforce or apply our policies and other agreements; or protect the rights, property, or safety of Company, our employees, or others. This disclosure will never, however, include selling, renting, sharing or otherwise disclosing Employee Personal Information for commercial purposes in violation of the commitments set forth in this Code.

4.3.5  Security Practices

1. We employ commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Employee Personal Information. These include internal reviews of our collection, storage and processing practices and security measures, such as appropriate encryption and physical security measures to guard against unauthorized access to systems where we store such information.
2. Only authorized employees have access to Employee Personal Information. 
3. Paper and other hard copy containing Employee Personal Information (or any other confidential information) is secured in a locked location when not in use. 
4. Computers and other access points should be secured when not in use by logging out or locking. Passwords should be guarded and not shared. 
5. Electronic files containing Employee Personal Information should only be stored on secure computers and not copied or otherwise shared with unauthorized individuals within or outside of Company.
6. All Employee Personal Information shall be maintained by Company for such time period as may be required as per applicable law. 

4.3.6  The Employees, as and when requested by them, may review the information provided and ensure that the Employee Personal Information found to be inaccurate or deficient is correct or amended as feasible.

4.4  Human rights

4.4.1  We do not employ children at our workplaces.

4.4.2  We do not use forced labour in any form. We do not confiscate personal documents of our employees or force them to make any payment to us or to anyone else in order to secure employment with us, or to work with us.

4.5  Bribery and corruption

4.5.1  Our employees and those representing us including agents and intermediaries shall not, directly or indirectly, offer or receive any illegal or improper payments or comparable benefits that are intended or perceived to obtain undue favours for the conduct of our business.

4.6  Gifts and hospitality

4.6.1  Business gifts and hospitality are sometimes used in the normal course of business activity. However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit payment’. Therefore, gifts and hospitality given or received should be modest in value and appropriate, and in compliance with our Company’s gifts and hospitality policy.

4.6.2  As a general rule, we can accept gifts or hospitality from a business associate, only if such a gift:

(a)  has modest value and does not create a perception (or an implied obligation) that the giver is entitled to preferential treatment of any kind;

(b)  would not influence, or appear to influence, our ability to act in the best interest of our Company; and/ or

(c)  would not embarrass our Company or the giver if disclosed publicly.

4.6.3  The following gifts are never appropriate and should never be given or accepted:

(d)  gifts of cash or gold or other precious metals, gems or stones;

(e)  gifts that are prohibited under applicable law;

(f)  gifts in the nature of a bribe, payoff, kickback or facilitation payment*;

(g)  gifts that are prohibited by the gift giver’s or recipient’s organization; and

(h)  gifts in the form of services or other non-cash benefits (e.g. a promise of employment).

(*‘Facilitation payment is a payment made to secure or speed up routine legal government actions, such as issuing permits or releasing goods held in customs.)

4.7  Freedom of association

4.7.1  We recognise that employees may be interested in joining associations or involving themselves in civic or public affairs in their personal capacities, provided such activities do not create an actual or potential conflict with the interests of our Company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable Company policies and law.

4.8  Working outside employment with us

4.8.1  Taking employment, accepting a position of responsibility or running a business outside employment with our Company, in your own time, with or without remuneration, could interfere with your ability to work effectively at our Company or create conflicts of interest. Any such activity must not be with any customer, supplier, distributor or competitor of our Company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable Company policies and law.

4.9  Integrity of information and assets

4.9.1  Our employees shall not make any willful omissions or material misrepresentation that would compromise the integrity of our records, internal or external communications and reports, including the financial statements.

4.9.2  Our employees and directors shall seek proper authorization prior to disclosing Company or business-related information, and such disclosures shall be made in accordance with our Company’s media and communication policy. This includes disclosures through any forum or media, including through social media.

4.9.3  Our employees shall ensure the integrity of personal data or information provided by them to our Company. We shall safeguard the privacy of all such data or information given to us in accordance with applicable Company policies or law.

4.9.4  Our employees shall respect and protect all confidential information and intellectual property of our Company.

4.9.5  Our employees shall safeguard the confidentiality of all third party intellectual property and data. Our employees shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable Company policies or law.

4.9.6  Our employees shall promptly report the loss, theft or destruction of any confidential information or intellectual property and data of our Company or that of any third party.

4.9.7  Our employees shall use all Company assets, tangible and intangible, including computer and communication equipment for the purpose for which they are provided and in order to conduct our business. Such assets shall not be misused. We shall establish processes to minimize the risk of fraud, and misappropriation or misuse of our assets.

4.9.8  We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws.

4.10  Insider Trading

4.10.1  Our employees must not indulge in any form of insider trading nor assist others, including immediate family, friends or business associates, to derive any benefit from access to and possession of price sensitive information that is not in the public domain. Such information would include information about our Company, our clients and our suppliers.

4.11  Prohibited drugs and substances

4.11.1  Use of prohibited drugs and substances creates genuine safety and other risks at our workplaces. We do not tolerate prohibited drugs and substances from being possessed, consumed or distributed at our workplaces, or in the course of Company duties.

4.12  Conflict of interest

4.12.1  Our employees and executive directors shall always act in the interest of our Company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our Company or the operations of our Company. Further, our employees and executive directors shall not engage in any business, relationship or activity, which might conflict with the interest of our Company.

4.12.2  Should any actual or potential conflict of interest arise, the concerned person must immediately report such conflicts and seek approvals as required by applicable law and Company policy. The competent authority shall revert to the employee within a reasonable time as defined in our Company’s policy, so as to enable the concerned employee to take necessary action as advised to resolve or avoid the conflict in an expeditious manner.

4.12.3  In the case of all employees other than executive directors, the Chief Executive Officer / Managing Director shall be the competent authority, who in turn shall report such cases to the Board of Directors on a quarterly basis. In case of the Chief Executive Officer / Managing Director and executive directors, the Board of Directors of our Company shall be the competent authority.

4.12.4  Notwithstanding such or any other instance of conflict of interest that exists due to historical reasons, adequate and full disclosure by interested employees shall be made to our Company’s management. At the time of appointment in our Company, our employees and executive directors shall make full disclosure to the competent authority, of any interest leading to an actual or potential conflict that such persons or their immediate family (including parents, siblings, spouse, partner, children) or persons with whom they enjoy close personal relationships, may have in a family business or a company or firm that is a competitor, supplier, customer or distributor of, or has other business dealings with, our Company.

4.13  Examples of Potential Conflict of Interest

4.13.1  A conflict of interest, actual or potential, arises where, directly or indirectly, an employee or executive director:

1. engages in a business, activity or relationship with anyone who is party to a transaction with our Company;
2. is in a position to derive an improper benefit, personally or for any family member or for any person in a close personal relationship, by making or influencing decisions relating to any transaction;
3. conducts business on behalf of our Company or is in a position to influence a decision with regard to our Company’s business with a supplier or customer where a relative of, or a person in close personal relationship with, an employee or executive director is a principal officer or representative, resulting in a personal benefit or a benefit to the relative;
4. is in a position to influence decisions with regard to award of benefits such as increase in salary or other remuneration, posting, promotion or recruitment of a relative or a person in close personal relationship employed in our Company;
5. undertakes an activity by which the interest of our Company can be compromised or defeated; or
6. does anything by which an independent judgement of our Company’s best interest cannot be exercised.

3.12.2  A conflict of interest could be any known activity, transaction, relationship or service engaged in by an employee, his/her immediate family (including parents, siblings, spouse, partner, and children), relatives or a close personal relationship, which may cause concern (based upon an objective determination) that the employee could not or might not be able to fairly perform his/her duties to our Company.

3.12.3  If there is a failure to make the required disclosure and our management becomes aware of an instance of conflict of interest that ought to have been disclosed by an employee or executive director, our management shall take a serious view of the matter and consider suitable disciplinary action as per the terms of employment. In all such matters, we shall follow clear and fair disciplinary procedures, respecting the employee’s right to be heard.

3.12.4  Acceptance of a position of responsibility (whether for remuneration or otherwise) in the following cases would typically be permitted, provided the time commitments these demand do not disturb or distract from the employee’s primary duties and responsibilities in our Company, and are promptly disclosed to the relevant competent authority

1. directorships on the Boards of any of our joint ventures or associate companies;
2. memberships/positions of responsibility in educational/professional bodies, where such association will promote the interests of our Company; or
3. memberships or participation in government committees/bodies or organizations.

5. OUR CLIENTS AND CUSTOMERS

5.1  Transparency: To ensure that the Company maintains transparency in its operations and communications vis-à-vis its clients, Company will adhere to the following:

1. disclose to clients all the terms and conditions (including changes if any) of our financial services offered in the language understood by the client;
   
2. provide loan sanction letter or any other document clearly indicating the rate of interest, mode of charging interest, levy of any other charges, terms of repayment to the client against his/her acknowledgement;
3. provide information to clients on the rate of interest offered on the thrift services, wherever applicable;
4. provide information to clients related to the premium and other fees being charged on insurance services;
5. provide a valid receipt for every payment received from the borrower;
6. provide periodical statements of their accounts by means of a passbook or any other mechanism to the clients; and
7. all the above disclosures to the client may be made digitally.

5.2  Client Protection: In protecting the interest of the clients/borrowers, the Company is committed to following fair practices built on dignity, respect, fair treatment, persuasion and courtesy to clients.

5.3  Avoiding over-indebtedness: Company will take reasonable steps to ensure that credit services are based on the need and repayment capacity of the client and that this service will not put the client / borrowers at significant risk of over-indebtedness. Accordingly, the Company will:

1. undertake appropriate interaction and collection practices;
2. interact with the clients in an acceptable language and dignified manner and spare no efforts in fostering clients’ confidence and long-term relationship;
3. have a clearly defined and phased procedure in case of client default;
4. maintain decency and decorum during the visit to the clients’ place for collection of dues;
5. avoid inappropriate occasions such as bereavement in the family or such other calamitous occasions for making calls/visits to collect dues; and
6. avoid any demeanor that would suggest any kind of threat or violence.

5.4  Privacy of client information: Company is committed to keep personal client information strictly confidential except in the following circumstances:

1. client has been informed about such disclosure and permission has been obtained;
2. it is legally required to do so;
3. the party in question has been authorized by the client; or
4. this practice is customary amongst financial institutions and available for a close group on reciprocal basis (such as a credit bureau).

6. OUR COMMUNITIES AND THE ENVIRONMENT

6.1  Communities: We are committed to good corporate citizenship and shall actively assist in the improvement of the quality of life of the people in the communities in which we operate.

6.1.1  We engage with the community and other stakeholders to minimize any adverse impact that our business operations may have on the local community and the environment.

6.1.2  We encourage our workforce to volunteer on projects that benefit the communities in which we operate, provided the principles of this Code, where applicable, and in particular the ‘Conflicts of Interest’ clause is followed.

6.2  The environment: In the production and sale of our products and services, we strive for environmental sustainability and comply with all applicable laws and regulations.

6.2.1  We seek to prevent the wasteful use of natural resources and are committed to improving the environment, particularly with regard to the emission of greenhouse gases, consumption of water and energy, and the management of waste and hazardous materials. We shall endeavor to offset the effect of climate change in our activities.

7. OUR VALUE-CHAIN PARTNERS

7.1  We shall select our suppliers and service providers fairly and transparently.

7.2  We seek to work with suppliers and service providers who can demonstrate that they share similar values. We expect them to adopt ethical standards comparable to our own.

7.3  Our suppliers and service providers shall represent our Company only with duly authorized written permission from our Company. They are expected to abide by the Code in their interactions with, and on behalf of us, including respecting the confidentiality of information shared with them.

7.4  We shall ensure that any gifts or hospitality received from, or given to, our suppliers or service providers comply with our Company’s gifts and hospitality policy.

7.5  We respect our obligations on the use of third-party intellectual property and data.

8. OUR FINANCIAL STAKEHOLDERS

8.1  We are committed to enhancing shareholder value and complying with laws and regulations that govern shareholder rights.

8.2  We shall inform our financial stakeholders about relevant aspects of our business in a fair, accurate and timely manner and shall disclose such information in accordance with applicable law and agreements.

8.3  We shall keep accurate records of our activities and shall adhere to disclosure standards in accordance with applicable law and industry standards.

9. GOVERNMENTS

9.1  Political non-alignment: We shall act in accordance with the constitution and governance systems of the regions/countries where we operate. We do not seek to influence the outcome of public elections, nor to undermine or alter any system of government. We do not support any specific political party or candidate for political office. Towards this end:

9.1.1  Our conduct must preclude any activity that could be interpreted as mutual dependence/favour with any political body or person, and we do not offer or give any Company funds or property or other resources as donations to any specific political party, candidate or campaign.

9.1.2  Any financial contributions considered by our Board of Directors in order to strengthen democratic forces through a clean electoral process shall be extended only through the Progressive Electoral Trust in India, or by a similar transparent, duly-authorized, nondiscriminatory and non-discretionary vehicle outside India.

9.2  Government engagement: We conduct our interactions with them in a manner consistent with our Code.

9.2.1  We engage with the government and regulators in a constructive manner in order to promote good governance.

9.2.2  We do not impede, obstruct or improperly influence the conclusions of, or affect the integrity or availability of data or documents for any government review or investigation.

10. RAISING CONCERNS

10.1  We encourage our employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of our Code, policies or law. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles.

10.2  Avenues available for raising concerns or queries or reporting cases could include:

(i)  immediate line manager or the Human Resources department of our Company;

(ii)  designated ethics officials of our Company;

(iii)  the ‘confidential reporting’ third party ethics helpline (if available); or

(iv)  any other reporting channel set out in our Company’s ‘Whistleblower’ policy.

10.3  We do not tolerate any form of retaliation against anyone reporting legitimate concerns. Anyone involved in targeting such a person will be subject to disciplinary action.

10.4  If you suspect that you or someone you know has been subjected to retaliation for raising a concern or for reporting a case, we encourage you to promptly contact your line manager, the Company’s Ethics Counsellor, the Human Resources department or the MD/CEO.

11. ACCOUNTABILITY

11.1  This Code is more than a set of prescriptive guidelines issued solely for the purpose of formal compliance. It represents our collective commitment to our value system and to our core principles.

11.2  Every person employed by us, directly or indirectly, should expect to be held accountable for his/her behavior. Should such behavior violate this Code, they may be subject to action according to their employment terms and relevant Company policies.

11.3  When followed in letter and in spirit, this Code is ‘lived’ by our employees as well as those who work with us. It represents our shared responsibility to all our stakeholders, and our mutual commitment to each other.

12. NOTE

12.1  The Code does not provide a comprehensive and complete explanation of all expectations from a Company standpoint or obligations from a stakeholder standpoint.

12.2  Our employees have a continuing obligation to familiarise themselves with all applicable law, Company-level policies, procedures and work rules as relevant. For any guidance on interpretation of the Code, we may seek support from our Company’s Ethics Counsellor.

12.3  For any query or clarification on the Code, please contact the office of the Company’s Chief Ethics Officer via email at:

Sunil.kumar.t@avantifinance.in

12.4  For further information on the Code please

contact: The Ethics Office,

Email: Sunil.kumar.t@avantifinance.in

Co-lending Policy

1. Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) has drafted the Co-lending Policy (hereafter referred to as “Co-Lending Policy” or “the Policy”) in accordance with the Reserve Bank of India (“RBI”) notification for the Co-Lending model - RBI/2020-21/63, FIDD.CO.Plan.BC.No.8/04. 09.01 /2020- 21 dated November 05, 2020 (“CLM”).

2. Objectives of the Policy

This document covers the general principles and practices to be followed by the Company when entering into co-lending arrangements with partner institutions. The Policy will be applicable to all the categories of products and services offered by the Company under the co-lending model and apply to related operations such as customer sourcing, loan processing, loan servicing and collection activities.

3. Co-Lending Arrangement Modes

The Master Agreement entered into with partner institutions (Banks/NBFCs) for implementing the co-lending model could be one of 2 (two) options:

(i)  Where the Company and the partner Bank/NBFC jointly originate the loan and take it on their respective books basis a pre-determined share (“Co-Origination”); or

(ii)  Where the Company originates the loan and subsequently transfers it to the partner Bank/NBFC (“Originate and Transfer”) with the partner institution retaining the right to reject certain loans subject to its due diligence.

If the co-lending model chosen is Option (ii) above, this arrangement will be akin to a direct assignment transaction. Accordingly, the taking over Bank/NBFC shall ensure compliance with all the requirements in terms of Guidelines on Transactions Involving Transfer of Assets through Direct Assignment of Cash Flows and the Underlying Securities issued vide RBI/2011-12/540 DBOD.No.BP.BC-103/21.04.177/2011-12 dated May 07, 2012 and RBI//2012- 13/170  DNBS.  PD.  No.  301/3.10.01  /2012-13  dated  August  21,  2012

respectively, as updated from time to time, with the exception of Minimum Holding Period (MHP) which shall not be applicable in such transactions undertaken in terms of the co-lending arrangement. The MHP exemption shall be available only in cases where the prior Master Agreement between the Company (on the one hand) and Banks / NBFCs (on the other hand) contains a back-to-back basis clause and complies with all other conditions stipulated in the guidelines for direct assignment.‍

4. Roles & Responsibilities

(i)  Origination / Loan Sanction:

The Company will source leads of applicants who meet the eligibility criteria as per the credit policy agreed in terms of each co-lending arrangement.

In the case of a “Co-Origination” arrangement, a joint loan agreement will be executed with the borrower wherein both the Company and the partner Bank /NBFC will be parties as lenders in the agreement.

In the case of a “Originate & Transfer” arrangement, the Company will enter into the agreement with the borrower and the partner Bank/NBFC shall then choose to take over its share on back-to-back basis.

(ii)  Interest Rate:

The Company and the co-lending partner would have the flexibility to price their part of the exposure in a manner found fit as per their respective risk appetite/ assessment of the borrower and the RBI regulations issued from time to time.

Based on the respective interest rates and proportion of risk sharing, a single blended interest rate will be offered to the ultimate borrower in case of fixed rate loans. In the scenario of floating interest rates, a weighted average of the benchmark interest rates in proportion to the respective loan contribution, will be offered.

Company shall provide all information such as loan details including interest rate and other charges, details of risk sharing arrangement, etc., as and when called for by the RBI.

(iii)  Know Your Customer (KYC):

The Company and the co-lending partner shall adhere to all applicable KYC/ AML guidelines, as prescribed in the Master Directions - Know Your Customer (KYC) Direction, 2016, issued vide RBI/DBR/2015-16/18 Master Direction DBR.AML.BC.No.81/14.01.001/2015-16 dated February 25, 2016 and updated from time to time.

(iv)  Borrower Agreement

The borrower loan agreement shall clearly contain the features of the arrangement and the roles and responsibilities of Company and the partner Bank/NBFC. All the details of the arrangement shall be disclosed to the customers upfront and their explicit consent shall be taken.

(v)  Common Account

 The Company and its partner Bank/NBFC shall open an escrow type common account for pooling respective loan contributions for disbursal as well as to appropriate loan repayments from borrowers, without holding the funds for usage of float. All transactions between the co-lending partners relating to the co-lending shall be routed through this escrow account.

The Company and partner Bank/NBFC shall maintain their share of the individual borrower’s accounts but should also be able to generate and share a single unified statement to the customer, through appropriate sharing of required information between the two entities.

(vi)  Customer Communication & Grievance Redressal

 The Company will be the single point of interface with the borrower for the purpose of the loan provided and will be responsible for providing a detailed explanation to the borrower regarding the co-lending arrangement and the roles and responsibilities of the co-lending entities. The Company will also be primarily responsible for providing the required customer service and grievance redressal to the borrower that will be in line with the customer grievance redressal policy approved by the Board of the Company.

However, any complaint registered by a borrower with the Company and/or partner Bank / NBFC, shall also be shared with the Bank/ NBFC / Company and in case, the complaint is not resolved within 30 days, the borrower would have the option to escalate the same with concerned Banking Ombudsman/ Ombudsman for the Company or the Customer Education and Protection Cell (CEPC) in RBI as laid out in the Fair Practices Code adopted by the Company.

(vii)  Reporting / Provisioning

Each of the Company and partner Bank/NBFC shall follow its respective and independent provisioning requirements including declaration of account as NPA, as per the regulatory guidelines respectively applicable to each of them. Each of the two entities shall carry out their respective reporting requirements including reporting to Credit Information Companies, under respectively applicable law and regulations.

(viii)  Outsourcing of services

The Company will adhere to extant guidelines on outsourcing of financial services and the Outsourcing Policy approved by the Board. The outsourcing policy may be accessed at: [Outsourcing Policy].

(ix)  Other policies & guidelines

Company will ensure that it adheres to the regulations prescribed by the RBI/any other relevant regulatory body. Subject to the relevant Master Agreement, Company’s policies shall continue to apply on loans disbursed under the co-lending arrangement.

(viii)  Other Operational Aspects

 (a)  The co-lenders shall establish a framework for monitoring and recovery of the loan, as  mutually agreed upon.

(b)  The co-lenders shall arrange for creation of security and charge as per mutually agreeable terms.

(c)  The loans under the CLM shall be included in the scope of internal/statutory audit the banks and NBFCs to ensure adherence to their respective internal guidelines, of the agreement and extant regulatory requirement

(d)  Any assignment of a loan by a co-lender to a third party can be done only with the consent of the other lender

5. Policy Review and Updates

The implementation of this policy shall be monitored and reviewed periodically by the Board of the Company.

Frequently Asked Questions on Moratorium during of Covid -19

Based on the recommendation from RBI to grant Moratorium on the subject of Covid -19 Regulatory package (Circular dated RBI/2019-20/186 DOR.No.BP.BC.47/21.04.048/2019-20), Avanti has decided to grant all borrowers a moratorium for EMI deferment falling due between the period March 01, 2020 to May 31, 2020(upto 92 days).    Frequently Asked Questions  

1.  What is Avanti’s response to the RBI announcement of EMI deferment?

Res) In line with the RBI’s suggestion, Avanti has decided to grant moratorium for 3 months starting 1st March 2020.  Accordingly -

1. Loan tenure of all active loans will increase by 3 months (at least).
2. Borrowers have the option of making repayment during this 3 month period and accordingly their interest will be calculated. (Some borrowers have already paid their March EMI).
3. Non-payment of EMI in these 3 months will not affect the DPD and hence will not be reported as delay/default to credit bureaus.
4. Interest will continue to accrue on the outstanding portion of the loans during the moratorium period

2.  What does granting moratorium for EMI deferment mean?

Res) Moratorium for EMI deferment means -  A2.1 - Borrowers whose EMI was due in March 2020 will be due now in June 2020, A2.2 - Borrowers whose EMI was due in April 2020 will be due now in July 2020  A2.3 - Borrowers whose EMI was due in May 2020 will be due now in August 2020.  The original schedule of these borrowers will be accordingly adjusted. Any borrowers who are not able to pay as per their original schedule i.e., in March, April and May 2020 will not be reported as “default” to the credit bureaus.  

3.  Will the borrowers pay interest for this period of March 2020 to May 2020?

Res) Interest will continue to accrue (accumulate in simple terms) based on the outstanding balance on a daily basis for these loans. This additional interest will be paid along with the last instalment.  

4.  Can borrowers make repayments during this period till May 2020?

Res) Yes. Borrowers can continue making repayments during this moratorium period. Avanti encourages all borrowers whose income is less affected to continue making the repayment during this period.  This will help borrowers avoid paying additional interest at the end of the loan period.  

5.  What are the avenues for repayment available for the borrowers during the coming 2 months?

Res) Borrowers can make payment through digital modes like UPI, NEFT, IMPS, Banking correspondents to their Loan numbers (e-collect numbers).  

6.  Should the partner and agents continue collection on the field?

 Res) Considering the lockdown imposed by the Central government, Avanti strongly recommends all partners and agents not to go out for collections. However, you can reach out to the borrowers through tele-calling to educate them on the advantages of repayments, modes of digital payment, moratorium granted by Avanti etc. Continuous contact with borrowers will be crucial for you to ensure the collections effort is minimal from June 2020.  

7.  Should the borrowers/Partners inform Avanti through any official mode to avail this moratorium benefit?

 Res) Avanti, in consultation with its partners, has granted the moratorium to all loans due to the impact of COVID-19 on various livelihoods.  However, the borrowers can continue to make repayments to  their respective e-collect numbers, if they want to.  

8.  What about the overdue amount from previous months (Before March 2020)?

Res) The overdue amount will need to be paid by the borrower and there is no relief. Borrowers are strongly advised to use the digital modes of repayment to pay the overdue amount and thereby not accrue additional interest on them.  

9.  What if the borrowers have already paid their March 2020 due? Will this be refunded?

Res) Considering that the borrower has made their March 2020 due, it will be considered that they have made their June 2020 due amount (prepayment of due and hence lesser interest). However, Avanti strongly recommends the borrowers to continue making payments in June 2020 also. Thereby, they can pre-close the loan in a shorter period and pay lesser interest.

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Data Privacy and Security Policy

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable. This electronic record is generated by a computer/electronic system and does not require any physical or digital signatures.

1. Introduction

1. Avanti Finance Private Limited (“Company” / “Us” / “We” / “Our”) has entered into business relationships with various partners (“Partners”) under the respective partner engagement agreement or master services agreement (each of which is referred as “Agreement”) whereby We appoint respective Persons (as defined below) as Partners (terms of the relevant Agreement) and engage them for the provision of certain services more particularly described in the Schedule of Services of the respective Agreement. In order to increase the efficiency of provision of services, the Partner may be provided access and usage to Our Website (as defined below) on the terms as given under the respective Agreement.
2. Moreover, access to Our Website is provided to any other Person who is not appointed as a Partner as mentioned in the paragraph above. Both classes of Persons (appointed Partners and other Persons) may have access and usage to Our Website and are recognized as Users in the manner as defined below.
3. We consider User relationship and data security to be an important component of Our service offerings through Our Website. We are committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) of Our Users. We are proud of Our privacy practices and the strength of Our Website security and want the User (as defined below) to know how We protect information of User and use it to provide Our products and services to User. 
4. This Data Privacy and Security Policy (“Policy”) gives a broad outline as to how We protect information provided by Users during the course of access and usage of Website. We constantly re-evaluate this Policy and adapt it to meet data security standards and to deal with new challenges.
5. Where applicable, this Policy shall be read in conjunction with the respective Agreement for the respective User under which such User may have been given access to Our Website (including the App).

2. Definitions

In this Policy: (i) capitalized terms defined by inclusion in quotations and / or parenthesis have the meanings so ascribed; and (ii) the following terms shall have the following meanings assigned to them herein below:

“Applicable Law” includes all applicable Indian statutes, enactments, acts of the state legislature or parliament, laws, ordinances, rules, bye-laws, regulations, notifications, guidelines, directions, directives and orders of any governmental authority, statutory authority, board,  as may be applicable including but not limited to Reserve Bank of India and in each case, any implementing regulation or interpretation issued thereunder including any successor Applicable Law;

“Non-Personal Information” shall have the meaning as provided under Paragraph 3(e) of this Policy;

“Person” shall mean any individual (including personal representatives, executors or heirs of a deceased individual) or legal entity, including but not limited to, any partnership, joint venture, corporation, trust, unincorporated organisation, limited liability company, limited liability partnership or governmental authority;

“Personal Information” shall mean certain personally identifiable information of the User as specified under Paragraph 3(a) of this Policy;

“User” / “You” / “Your” shall mean any natural or legal person who has access to and is using Website;

“User Information” shall have the meaning as provided under Paragraph 3(h) of this Policy; and

“Website” shall mean and include https://avantifinance.in, mobile application of Company including with the name Avanti Early Access (“App”), any successor website/ applications, any website of related entity or any other channel facilitated and permitted by Company including but not limited to App, any other digital medium including phone, displays, emails, social media interfaces, messaging interfaces, wallet, payment intermediaries using Company’s interface.

3. Collection, Storage and Use of Information

Personal Information:

a. We may collect Your Personal Information when You voluntarily and successfully submit information against relevant fields on Our Website. Personal Information is the data that, alone or in combination with other information, can be used to uniquely identify You (“Personal Information”). Personal Information may include, without limitation, the following:

(i)  Name

(ii)  User ID(s)

(iii)  Phone numbers

(iv)  Email address (es)

(v)  Mailing addresses

(vi)  Banking and other financial data

(vii)  Government identification numbers, eg., driver’s license number

(viii)  Date of birth

(ix)  Gender

(x)  Health and disability data

(xi)  Family information

(xii)  Financial and asset information

b. In particular, if You register/log in to Our Website through any social media platform (for example, Google), then We may collect the following information:

(i)  The email/phone number used on the social media platform to register/ log in;

(ii)  The display name connected to the relevant social media account used; and

(iii)  The profile image (if any) connected to the relevant social media account used.

c. Please note that the information We obtain from such social media accounts also depends on the privacy policies of the social media platforms and Your respective settings therein. Please check the respective policies to understand the privacy practices of those social media platforms.

d. In case of Partners, We may request such additional Personal Information as may be specified in or as part of the respective Agreement.

e. Purpose of Collection of Personal Information: Your Personal Information is collected when You voluntarily submit such information. It is used, handled and stored by Us for the purposes of Your identification/ verification and/or creation of Your account on Our Website. Accordingly, such information shall be retained by Us till the time You have access and use of Our Website or You communicate to Us Your decision to withdraw Your permission to store and retain such information. 

Non-Personal Information: 

f. When You visit the Website, We may collect certain non-personal information for the purpose of enhancing Your use of the Website (“Non-Personal Information”). This Non-Personal Information is in the nature of technical and navigational information generated each time You visit the Website, which are saved in Our server logs. The Non-Personal Information may include, without limitation, the following details in respect of:

(i)  the server (Internet Protocol) from where the Website is being accessed;

(ii)  the browser and operating system used to browse the Website; 

(iii)  links clicked, scrolled and pages visited;

(iv)  details of Your last visit to the Website, including time, date and the duration of Your session on the Website, etc.; and/or

(v)  cookies as per Paragraph 4 of this Policy. 

g. Purpose of Collection of Non-Personal Information: Non-Personal Information is in the form of encrypted statistics, which helps Us in improving the efficiency of the Website by giving Us information relating to Your use of the Website.

h. Personal Information and Non-Personal Information are together referred to as “User Information” in this Policy.

i. By using Website, You authorize Us to collect, store, process, handle and use such User Information, in accordance with this Policy and any other terms and conditions of use of Website (as amended from time to time).

j. We reserve the right to retain such User Information that forms part of anonymized and aggregated data derived from User Information which may be used for improvement of Our Website, to produce analytical reports, marketing, advertising or such other activities as We may deem fit.

4. Cookies

1. Like most other sites, We use data collection devices known as “cookies” to collect and store information of Users visiting the Website. A cookie is an alpha-numeric identifier, which is small amount of data that is sent to a User’s browser from a web server and is eventually stored on a User’s computer hard drive. Cookies are a reliable mechanism to remember the activities of the User on the Website and help in improving Your experience on the Website. 
2. We may set and access cookies on Your computer to track and store preferential information about You. We may gather information about You through cookie technology. This anonymous information is maintained distinctly and is not linked to the Personal Information You submit to Us. The option of accepting cookies is up to You, however certain features of the Website including Content and the forms may not be accessible without accepting cookies. If You choose to eliminate cookies, the full functionality of the Website may be impaired for You.
3. Most cookies are session cookies that are automatically deleted from Your device’s hard drive when You close the browser/App. Additionally, You may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third-party cookies. 
4. We may use third party service providers to help Us analyse certain online activities. For example, these service providers may help us measure the performance of Our online campaigns or analyse visitor activity on the Website. We may permit these service providers to use cookies and other technologies to perform these services for Company. We do not share any Personal Information with these third party service providers, and these service providers do not collect such information on Our behalf. 

5. User Rights

a.  Review:

To ensure the accuracy and adequacy of the Personal Information provided by You, You shall at all times have the option of reviewing the same by requesting Us in the manner as provided under Paragraph 10 of this Policy.

b.  Withdrawal of Consent:

You shall at all times have the option of withdrawing Your consent for the collection, storage and retention of Your Personal Information. In case of Partners, their right to withdraw consent shall also be subject to the respective Agreement. 

c.  Please note that Your withdrawal of consent may result in restriction/revocation of access and/or usage of Our Website. Please further refer to Paragraph 10 of this Policy for the manner of communication with Us.

d.  Account Deletion:

You may choose to delete Your account at any time You like by requesting Us in the manner as provided under Paragraph 10. Please note that it may take up to 30 days to delete all of Your information, like the data stored in our backup systems. However, We may also preserve such information/data as required for legal reasons or to prevent harm.

6. Disclosure of User Information

a.  We do not share Your User Information with any third parties for commercial use or revenue generation. However, We may share User Information with third party service appointed by Us who may be located in India or outside India:

(i)  for sending SMS/ Email communications to You in relation to Website and Our products and services; and 

(ii)  to improve and personalize Our products and services. This may involve, for example, activities such as troubleshooting and protection against errors; data analysis and testing; and developing new features. 

b.  We ensure that such third-party service providers maintain strict confidentiality (ensuring the same level of confidentiality as maintained by Us) in respect of User Information. Our third party service providers are required to comply fully with this Policy.

c. Further, We reserve the right to utilize, share and/or disclose User Information if:

(i)  required to do so to comply with orders of governmental authorities that have jurisdiction over it or as otherwise required by Applicable Law after providing You a written intimation prior to such disclosure; and/or

(ii)  We determine, in Our sole discretion that disclosure of User Information is necessary to identify, contact, or bring legal action against You.

7. Indemnification

You agree to indemnify, defend and hold harmless Us and Our parent, subsidiaries, affiliates, partners, officers, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third-party due to or arising out of Your breach of this Policy or the documents they incorporate by reference (including the respective Agreement, where applicable for use of Website), or Your violation of any law or the rights of a third party.

8. Security Precautions

To prevent any form of unlawful interception or misuse of User Information, We use reasonable physical, electronic and managerial procedures to safeguard and secure User Information collected. We use reasonable secure and technologically appropriate measures, in compliance with the Information Technology Act, 2000 and the rules related thereto to protect You against loss or misuse of Your User Information including internal reviews of data collection, storage and processing practices and other reasonable security measures which are equivalent to security measures that We use to protect Our own confidential information. However, as You are aware, no internet website or online platform is completely free of security risks and We do not make any representation in respect of the same.

9. Change in Privacy Policy

We reserve the right to update, modify and amend any of the terms of this Policy, at any time without prior intimation to You. These changes will become effective immediately on posting. We shall not be liable for any failure or negligence on Your part to review the updated Policy before accessing Website. Your continued access to Website, following changes to this Policy, will constitute Your acceptance of those changes.

10. Contacting Us

If You have any queries regarding: (i) this Policy; (ii) information and/or services available on Website, or (iii) Your dealings with Us or believe that We have not adhered to it, You may contact Us at Urvashi Bahirsheth, Company Secretary at urvashi@avantifinance.in.

11. Email Opt-Out

You can opt out of receiving Our marketing and update emails. To stop receiving Our promotional emails, please email at info@avantifinance.in. It may take about ten days to process Your request. Please note that Your opting out of getting marketing messages would still enable You to receive transactional messages through email and SMS in relation to Your usage/access of Website.

Repayment Moratorium Policy of Avanti Finance Private Limited

Reserve Bank of India (RBI) has released the Statement of Developmental and Regulatory Policies on March 27, 2020 that directly addresses the stress in financial conditions caused by COVID-19. One of the policies relates to easing financial stress caused by COVID-19 disruptions by relaxing repayment pressures and improving access to working capital. In this area, RBI has permitted all lending institutions including NBFCs to grant a moratorium of three months on payment of all instalments falling due between March 1, 2020 and May 31, 2020. RBI has permitted to shift the repayment schedules and all subsequent due dates, as also the tenor for such loans across the board by three months. RBI has also asked all the lending institutions to put in place a Board approved policy in this regard. Our company being a Non-Banking Finance Company registered with RBI has framed the following policy after considering the policy guidelines issued by RBI vide circular no. RBI/2019-20/186 DOR. No. BP. BC. 47 / 21.04.048 /2019-20 dated March 27, 2020: Approved by the Board of Directors of Avanti Finance Private Limited on April 03, 2020 Relief measures approved by the Board for the retail loans outstanding as on March 31, 2020

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1. All borrowers will be given the option of a moratorium for EMI falling due between the period March 01, 2020 to May 31, 2020 (upto 92 days) without a change in the EMI amount.

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1. All borrowers will be given an option to continue making repayments falling due between the moratorium period in case their cash flows permit & they are not in favour of extending their loan tenure & paying additional accrued interest for the moratorium period.
2. Interest will continue to accrue on the outstanding portion of the term loans during the moratorium periodand will be collected along with the last EMI or additional installment.

1. The revised asset classification of the loans will be on the basis of revised due dates and the revised repayment schedule. The same will be shared with the Credit Information Companies (Regulatory requirement).

Relief measures approved by the Board for the institutional loans outstanding as on March 31, 2020 All institutional borrowers will be provided an option to opt for moratorium. However, decision pertaining to grant of moratorium will be solely made by Avanti, on a case to case basis. For further details, you may click here for FAQs related to moratorium under Covid-19. In case you seek any clarification, you may write to us at info@avantifinance.in.