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

1.1 In thisCode of Conduct Policy (“Code”), “we” or “us” or “our” means Avanti Finance PrivateLimited (“Company”), and includesour executive directors, officers, employees and those who work with us, as thecontext may require.

  1.2      This Code sets out howwe behave with:

(i)     our employees, or those whowork with us;

(ii)    our customers;

(iii)   the communities and theenvironment 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 orother business associates;

(vi)  our financial stakeholders; and

(vii)  the governments of the regions where we operate.

1.3          This Code sets out our expectationsof all those who work with us. We also expect those who deal with us to beaware that this Code underpins everything we do, and in order to work with usthey need to act in a manner consistent with this Code.

1.4          This Code applies to followingactivities undertaken by us:

(i)     providing credit services toclients individually or in groups;

(ii)    recovery of credit provided toclients;

(iii)   collection of thrift fromclients, where ever applicable;

(iv)  providing insurance and pensionservices, remittance services or any other products and services permittedunder applicable law, that will reduce vulnerability of our clients;

(v)    formation of any type ofcommunity collectives including self-help groups, joint liability groups andtheir federations; and

(vi)  business development servicesincluding marketing of products or services made or extended by the eligibleclients 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 weconduct 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 ofpublic scrutiny. Our primary mission is to service financially excludedindividuals and families by providing them access to financial services, whichare client focused, designed to enhance their well-being, and delivered in anethical, dignified, transparent, equitable and cost-effective manner.

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

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

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

2.1.5 PRIVACY OF CLIENT INFORMATION: We willsafeguard personal information of clients, only allowing disclosures andexchange of such information to others who are authorised to see it, with theknowledge and consent of clients.

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

  3       OUR CORE PRINCIPLES

3.1 We arecommitted to operating our businesses by conforming to the highest moral andethical standards. We do not tolerate bribery or corruption in any form. Thiscommitment underpins everything that we do.

3.2 We arecommitted to good corporate citizenship. We treat social developmentactivities, which benefit the communities we operate in as an integral part ofour business plan.

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

3.4 We shallnot compromise safety in the pursuit of commercial advantage. We shall striveto provide a safe, healthy and clean working environment for our employees andall those who work with us.

3.5 Whenrepresenting the Company, we shall act with professionalism, honesty andintegrity, and conform to the highest moral and ethical standards. Our conductshall be fair and transparent and be perceived as fair and transparent by thirdparties.

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

3.7 We shallstrive to balance the interests of our stakeholders, treating each of themfairly and avoiding unfair discrimination of any kind.

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

  3.9     We shall not engage in any restrictive orunfair trade practices.

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

3.11 We shallstrive to create an environment free from fear of retribution to deal withconcerns that are raised, or cases reported in good faith. No one shall bepunished or made to suffer fo raising concerns or making disclosures in goodfaith or in the public interest.

3.12 We expectthe leaders of our businesses to demonstrate their commitment to the ethicalstandards set out in this Code through their own behavior and by establishingappropriate processes.

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

  4        OUR EMPLOYEES

  4.1       Equal opportunity employer

4.1.1 We provideequal opportunities to all our employees and to all eligible applicants foremployment 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 othercategory protected by applicable law.

4.1.2 Whenrecruiting, developing and promoting our employees, our decisions will be basedsolely on performance, merit, competence and potential.

4.1.3 We shallhave fair, transparent and clear employee policies which promote diversity andequality, 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 leadersshall be responsible for creating a conducive work environment built ontolerance, understanding, mutual cooperation and respect for individualprivacy.

4.2.2 Everyone inour work environment must be treated with dignity and respect. We do nottolerate any form of harassment, whether sexual, physical, verbal orpsychological.

4.2.3 We haveclear and fair disciplinary procedures, which necessarily include an employee’sright to beheard.

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

  4.3       Collection, Use and Disclosure of personalinformation of Employees

4.3.1 Purpose of collection: In the course ofconducting our business and complying with various applicable law relating toemployment, tax, insurance, etc., we collect

certain personal information fromour Employees (“Employee PersonalInformation”). The nature of the Employee Personal Information collectedvaries for each employee and depends upon employee’s responsibilities,citizenship, work location, and other factors. The purpose of collecting andusing Employee Personal Information is limited to the business purposes,including those related directly to employee’s employment with the Company, andany other such requirement as per applicable law. We will not retain EmployeePersonal Information for longer than is required for the purpose herein.

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

•        Name

•        Phone numbers

•        Email address

•        Mailing addresses

•        Banking and other financialdata

•        Date of birth

•        Gender, race, and ethnicity

•        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 limitedto:

•        Human Resources Management. Wecollect, store, analyze, and may share (internally) Employee PersonalInformation in order to attract, retain and motivate a highly qualifiedworkforce. This includes recruiting, compensation planning, successionplanning, reorganization needs, performance assessment, training, employeebenefit administration, compliance with applicable legal requirements, andcommunication with employees and/or their representatives.

•        Business Processes andManagement. Employee Personal Information is used to run our businessoperations including, for example, scheduling work assignments, managingcompany assets, reporting and/releasing public data (e.g., Annual Reports,etc.); and populating employee directories.

•        Safety and Security Management.We use such Employee Personal Information as appropriate to ensure the safetyand protection of employees, assets, resources, and communities.

•        Communication andIdentification. We use Employee Personal Information to identify you and tocommunicate with the employees.

4.3.4 Disclosure: We stive to protect EmployeePersonal Information and ensure that unauthorized individuals do not haveaccess to such information by using adequate security measures. We will notknowingly disclose, sell or otherwise distribute Employee Personal Informationto any third party without the relevant employee’s knowledge and, whereappropriate, your express written permission, except under the followingcircumstances:

•        Legal requests and investigations. Wemay disclose Employee Personal

Information when such disclosure is reasonably necessary(i) to prevent fraud;

(ii) to comply with any applicablelaw; or (iii) to comply with an order by a competent court.

•        Third-party vendors and service providers. We may, from time to time, outsource services, functions, oroperations of our business to third-party service providers. When engaging insuch outsourcing, it may be necessary for us to disclose Employee PersonalInformation to those service providers (for example, payroll serviceproviders). In some cases, the service providers may collect Employee PersonalInformation directly from the employee on our behalf. Our relationship withsuch service providers will be governed by such commercial, operational andother terms as negotiated under valid contract.

•        Business Transfers: During the term ofemployment, we may buy other companies, create new subsidiaries or businessunits or sell part or all of our assets. It is likely that, as part of suchprocess, some or all of Employee Personal Information will be transferred toanother company as part of any such the transaction.

•        Reserved Matters. We may releaseEmployee Personal Information when we believe release is necessary to complywith the law; enforce or apply our policies and other agreements; or protectthe rights, property, or safety of Company, our employees, or others. Thisdisclosure will never, however, include selling, renting, sharing or otherwisedisclosing Employee Personal Information for commercial purposes in violationof the commitments set forth in this Code.

              4.3.5    Security Practices

•        We employ commerciallyreasonable physical, managerial, and technical safeguards to preserve theintegrity and security of Employee Personal Information. These include internalreviews of our collection, storage and processing practices and securitymeasures, such as appropriate encryption and physical security measures toguard against unauthorized access to systems where we store such information.

•        Only authorized employees haveaccess to Employee Personal Information.

•        Paper and other hard copycontaining Employee Personal Information (or any other confidentialinformation) is secured in a locked location when not in use.

•        Computers and other accesspoints should be secured when not in use by logging out or locking. Passwordsshould be guarded and not shared.

•        Electronic files containingEmployee Personal Information should only be stored on secure computers and notcopied or otherwise shared with unauthorized individuals within or outside ofCompany.

•        All Employee PersonalInformation shall be maintained by Company for such time period as may berequired as per applicable law.

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

  4.4       Human rights

4.4.1     We do not employ children atour workplaces.

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

  4.5       Bribery and corruption

4.5.1    Ouremployees and those representing us including agents and intermediaries shallnot, directly or indirectly, offer or receive any illegal or improper paymentsor comparable benefits that are intended or perceived to obtain undue favoursfor the conduct of our business.

  4.6       Gifts and hospitality

4.6.1     Business gifts and hospitalityare sometimes used in the normal course of business activity. However, ifoffers of gifts or hospitality (including entertainment or travel) are frequentor of substantial value, they may create the perception of, or an actualconflict of interest or an ‘illicit payment’. Therefore, gifts and hospitalitygiven or received should be modest in value and appropriate, and in compliancewith our Company’s gifts and hospitality policy.

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

(a)           has modest value and does notcreate a perception (or an implied obligation) that the giver is entitled topreferential treatment of any kind;

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

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

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

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

(e)           gifts that are prohibited underapplicable law;

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

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

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

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

  4.7       Freedom of association

4.7.1 We recognisethat employees may be interested in joining associations or involvingthemselves in civic or public affairs in their personal capacities, providedsuch activities do not create an actual or potential conflict with theinterests of our Company. Our employees must notify and seek prior approval forany such activity as per the ‘Conflicts of Interest’ clause of this Code and inaccordance with applicable Company policies and law.

  4.8      Working outside employment with us

4.8.1 Takingemployment, accepting a position of responsibility or running a businessoutside employment with our Company, in your own time, with or withoutremuneration, could interfere with your ability to work effectively at ourCompany or create conflicts of interest. Any such activity must not be with anycustomer, supplier, distributor or competitor of our Company. Our employeesmust notify and seek prior approval for any such activity as per the ‘Conflictsof Interest’ clause of this Code and in accordance with applicable Companypolicies and law.

  4.9      Integrity of information and assets

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

4.9.2     Our employees and directorsshall seek proper authorization prior to disclosing Company or business-relatedinformation, and such disclosures shall be made in accordance with ourCompany’s media and communication policy. This includes disclosures through anyforum or media, including through social media.

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

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

4.9.5     Our employees shall safeguardthe confidentiality of all third party intellectual property and data. Ouremployees shall not misuse such intellectual property and data that comes intotheir possession and shall not share it with anyone, except in accordance withapplicable Company policies or law.

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

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

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

  4.10     Insider Trading

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

  4.11     Prohibited drugs and substances

4.11.1 Use ofprohibited drugs and substances creates genuine safety and other risks at ourworkplaces. 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 executivedirectors shall always act in the interest of our Company and ensure that anybusiness or personal association including close personal relationships whichthey may have, does not create a conflict of interest with their roles andduties in our Company or the operations of our Company. Further, our employeesand executive directors shall not engage in any business, relationship oractivity, which might conflict with the interest of our Company.

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

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

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

  4.13    Examples of Potential Conflict of Interest

4.13.1 A conflict ofinterest, actual or potential, arises where, directly or indirectly, anemployee or executive director:

(i)            engages in a business, activityor relationship with anyone who is party to a transaction with our Company;

(ii)  is in a position to derive animproper benefit, personally or for any family member or for any person in aclose personal relationship, by making or influencing decisions relating to anytransaction;

(iii)  conducts business on behalf of our Company or is in a position toinfluence a decision with regard to our Company’s business with a supplier orcustomer 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;

(iv)  is in a position to influence decisions with regard to award ofbenefits such as increase in salary or other remuneration, posting, promotionor recruitment of a relative or a person in close personal relationshipemployed in our Company;

(v)  undertakes an activity by whichthe interest of our Company can be compromised or defeated; or

(vi)  does anything by which an independent judgement of our Company’sbest interest cannot be exercised.

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

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

4.13.4Acceptance of a position of responsibility (whether for remuneration orotherwise) in the following cases would typically be permitted, provided thetime commitments these demand do not disturb or distract from the employee’sprimary duties and responsibilities in our Company, and are promptly disclosedto the relevant competent authority:

(i)   directorships on the Boards ofany of our joint ventures or associate companies;

(ii)  memberships/positions ofresponsibility in educational/professional bodies, where such association willpromote the interests of our Company; or

(iii)  memberships or participation in government committees/bodies ororganizations.

  5       OURCLIENTS AND CUSTOMERS

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

(i)     disclose to clients all theterms and conditions (including changes if any) of our financial servicesoffered in the language understood by the client;

(ii)    provide loan sanction letter orany other document clearly indicating the rate of interest, mode of charginginterest, levy of any other charges, terms of repayment to the client againsthis/her acknowledgement;

(iii)   provide information to clientson the rate of interest offered on the thrift services, wherever applicable;

(iv)  provide information to clientsrelated to the premium and other fees being charged on insurance services;

(v)    provide a valid receipt forevery payment received from the borrower;

(vi)  provide periodical statementsof their accounts by means of a passbook or any other mechanism to the clients;and

(vii)  all the above disclosures to the client may be made digitally.

5.2          Client Protection: In protectingthe interest of the clients/borrowers, the Company is committed to followingfair practices built on dignity, respect, fair treatment, persuasion andcourtesy to clients.

5.3          Avoiding over-indebtedness:Company will take reasonable steps to ensure that credit services are based onthe need and repayment capacity of the client and that this service will notput the client / borrowers at significant risk of over-indebtedness.Accordingly, the Company will:

(i)     undertake appropriate interactionand collection practices;

(ii)    interact with the clients in anacceptable language and dignified manner and spare no efforts in fosteringclients’ confidence and long-term relationship;

(iii)   have a clearly defined andphased procedure in case of client default;

(iv)  maintain decency and decorumduring the visit to the clients’ place for collection of dues;

(v)    avoid inappropriate occasionssuch as bereavement in the family or such other calamitous occasions for makingcalls/visits to collect dues; and

(vi)  avoid any demeanor that wouldsuggest any kind of threat or violence.

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

(i) client has been informed aboutsuch disclosure and permission has been obtained; (ii) it is legally requiredto do so;

(iii)   the party in question has beenauthorized by the client; or

(iv)  this practice is customaryamongst financial institutions and available for a close group on reciprocalbasis (such as a credit bureau).

  6      OURCOMMUNITIES AND THE ENVIRONMENT

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

6.1.1 We engagewith the community and other stakeholders to minimize any adverse impact thatour business operations may have on the local community and the environment.

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

6.2 Theenvironment: In the production and sale of our products and services, we strivefor environmental sustainability and comply with all applicable laws andregulations.

6.2.1 We seek toprevent the wasteful use of natural resources and are committed to improvingthe environment, particularly with regard to the emission of greenhouse gases,consumption of water and energy, and the management of waste and hazardousmaterials. We shall endeavor to offset the effect of climate change in ouractivities.

  7        OURVALUE-CHAIN PARTNERS

  7.1     We shall select our suppliers and service providersfairly and transparently.

7.2 We seek towork with suppliers and service providers who can demonstrate that they sharesimilar values. We expect them to adopt ethical standards comparable to ourown.

7.3 Oursuppliers and service providers shall represent our Company only with dulyauthorized written permission from our Company. They are expected to abide bythe Code in their interactions with, and on behalf of us, including respectingthe confidentiality of information shared with them.

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

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

  8      OURFINANCIAL STAKEHOLDERS

8.1 We arecommitted to enhancing shareholder value and complying with laws andregulations that govern shareholder rights.

8.2 We shallinform our financial stakeholders about relevant aspects of our business in afair, accurate and timely manner and shall disclose such information inaccordance with applicable law and agreements.

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

  9          GOVERNMENTS

9.1 Politicalnon-alignment: We shall act in accordance with the constitution and governancesystems of the regions/countries where we operate. We do not seek to influencethe outcome of public elections, nor to undermine or alter any system ofgovernment. We do not support any specific political party or candidate forpolitical office. Towards this end:

9.1.1 Our conductmust preclude any activity that could be interpreted as mutual dependence/favourwith any political body or person, and we do not offer or give any Companyfunds or property or other resources as donations to any specific politicalparty, candidate or campaign.

9.1.2 Anyfinancial contributions considered by our Board of Directors in order tostrengthen democratic forces through a clean electoral process shall beextended only through the Progressive Electoral Trust in India, or by a similartransparent, duly-authorized, nondiscriminatory and non-discretionary vehicle outsideIndia.

9.2 Governmentengagement: We conduct our interactions with them in a manner consistent withour Code.

9.2.1 We engagewith the government and regulators in a constructive manner in order to promotegood governance.

9.2.2 We do notimpede, obstruct or improperly influence the conclusions of, or affect theintegrity or availability of data or documents for any government review orinvestigation.

  10       RAISINGCONCERNS

10.1 Weencourage our employees, customers, suppliers and other stakeholders to raiseconcerns or make disclosures when they become aware of any actual or potentialviolation of our Code, policies or law. We also encourage reporting of anyevent (actual or potential) of misconduct that is not reflective of our valuesand principles.

  10.2  Avenues available forraising concerns or queries or reporting cases could include:

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

(ii)           designated ethics officials ofour Company;

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

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

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

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

  11        ACCOUNTABILITY

11.1 This Codeis more than a set of prescriptive guidelines issued solely for the purpose offormal compliance. It represents our collective commitment to our value systemand to our core principles.

11.2 Everyperson employed by us, directly or indirectly, should expect to be heldaccountable for his/her behavior. Should such behavior violate this Code, theymay be subject to action according to their employment terms and relevantCompany policies.

11.3 Whenfollowed in letter and in spirit, this Code is ‘lived’ by our employees as well as those who work with us. Itrepresents our shared responsibility to all our stakeholders, and our mutualcommitment to each other.

  12        NOTE

12.1 The Codedoes not provide a comprehensive and complete explanation of all expectationsfrom a Company standpoint or obligations from a stakeholder standpoint.

12.2 Ouremployees have a continuing obligation to familiarize themselves with allapplicable law, Company-level policies, procedures and work rules as relevant.For any guidance on interpretation of the Code, we may seek support from ourCompany’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 pleasecontact:

The Ethics Office,

Email: Sunil.kumar.t@avantifinance.in

13. Policy Review updated

This documentshall be reviewed by the COO, and shall be reviewed at least once a year.Reviews shall also account for any significant business changes and/or anyregulatory requirements.

This Policy was:

I.          Drafted on behalf of theCompany by: Mr Nagaraj Subrahmanya, CRO

II.        Internally reviewed by: MrManish Thakkar, COO

III.       Approved by the Board of theCompany on: June 25, 2019, Revision 1 on : March 22, 2021 and Revision 2 on :March 13, 2023

‍

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.

‍

‍

Data Privacy and Security Policy

This document is an electronic record interms of Information Technology Act, 2000 and rules there under as applicable.This electronic record is generated by a computer/electronic system and doesnot require any physical or digital signatures.

1.        Introduction

a)         Avanti Finance Private Limited(“Company” / “Us” / “We” / “Our”) has entered into business relationships withvarious partners (“Partners”) under the respective partner engagement agreementor master services agreement (each of which is referred as “Agreement”) wherebyWe appoint respective Persons (as defined below) as Partners (terms of therelevant Agreement) and engage them for the provision of certain services moreparticularly described in the Schedule of Services of the respective Agreement.In order to increase the efficiency of provision of services, the Partner maybe provided access and usage to Our Website (as defined below) on the terms asgiven under the respective Agreement.

b)         Moreover, access to Our Websiteis provided to any other Person who is not appointed as a Partner as mentionedin the paragraph above. Both classes of Persons (appointed Partners and otherPersons) may have access and usage to Our Website and are recognized as Usersin the manner as defined below.

c)         We consider User relationshipand data security to be an important component of Our service offerings throughOur Website. We are committed to maintaining the confidentiality, integrity andsecurity of any Personal Information (as defined below) of Our Users. We areproud of Our privacy practices and the strength of Our Website security andwant the User (as defined below) to know how We protect information of User anduse it to provide Our products and services to User.

d)         This Data Privacy and SecurityPolicy (“Policy”) gives a broad outline as to how We protect informationprovided by Users during the course of access and usage of Website. Weconstantly re-evaluate this Policy and adapt it to meet data security standardsand to deal with new challenges.

e)         Where applicable, this Policyshall be read in conjunction with the respective Agreement for the respectiveUser under which such User may have been given access to Our Website (includingthe App).

f)          By accessing or using OurWebsite, User consents and authorizes Us to collect, store, process, handle anduse User Information (as defined below), in accordance with this Policy and anyother terms and conditions of use of Website (as amended from time to time).

2.        Definitions

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

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

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

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

“PersonalInformation” shall mean certain personally identifiable information of theUser as specified under Paragraph 3(a) ofthis Policy;

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

“UserInformation” shall have the meaning as provided under Paragraph 3(h) of this Policy; and “Website” shall mean and include https://avantifinance.in, mobileapplication of

Company including with the name AvantiEarly Access (“App”), any successorwebsite/ applications, any website of related entity or any other channelfacilitated and permitted by Company including but not limited to App, any otherdigital medium including phone, displays, emails, social media interfaces,messaging interfaces, wallet, payment intermediaries using Company’s interface.

3. Collection,Storage and Use of Information PersonalInformation:

a)         We may collect Your PersonalInformation when You voluntarily and successfully submit information againstrelevant fields on Our Website. Personal Information is the data that, alone orin combination with other information, can be used to uniquely identify You (“Personal Information”). PersonalInformation 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 financialdata

(vii)     Government identificationnumbers, 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 Youregister/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 onthe social media platform to register/ log in;

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

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

c)         Please note that theinformation We obtain from such social media accounts also depends on theprivacy policies of the social media platforms and Your respective settingstherein. Please check the respective policies to understand the privacypractices of those social media platforms.

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

e)         Purpose of Collection of Personal Information: Your Personal Information is collected when You voluntarily submitsuch information. It is used, handled and stored by Us for the purposes of Youridentification/ verification and/or creation of Your account on Our Website.Accordingly, such information shall be retained by Us till the time You have accessand use of Our Website or You communicate to Us Your decision to withdraw Yourpermission to store and retain such information. We will not retain YourPersonal Information for longer than is required for the purpose herein. Non-Personal Information:

f)          When You visit the Website, Wemay collect certain non-personal information for the purpose of enhancing Youruse of the Website (“Non-PersonalInformation”). This Non-Personal Information is in the nature of technicaland navigational information generated each time You visit the Website, whichare saved in Our server logs. The Non-Personal Information may include, withoutlimitation, the following details in respect of:

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

(ii)        the browser and operatingsystem used to browse the Website;

(iii)      links clicked, scrolled andpages visited;

(iv)      details of Your last visit tothe Website, including time, date and the duration of Your session on theWebsite, etc.; and/or (v) cookies as per Paragraph4 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 Usinformation relating to Your use of the Website.

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

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

j)          We reserve the right to retainsuch User Information that forms part of anonymized and aggregated data derivedfrom User Information which may be used for improvement of Our Website, toproduce analytical reports, marketing, advertising or such other activities asWe may deem fit.

4.        Cookies

a)         Like most other sites, We usedata collection devices known as “cookies” to collect and store information ofUsers visiting the Website. A cookie is an alpha-numeric identifier, which issmall amount of data that is sent to a User’s browser from a web server and iseventually

stored on a User’s computer hard drive.Cookies are a reliable mechanism to remember the activities of the User on theWebsite and help in improving Your experience on the Website.

b)         We may set and access cookieson Your computer to track and store preferential information about You. We maygather information about You through cookie technology. This anonymousinformation is maintained distinctly and is not linked to the PersonalInformation 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 notbe accessible without accepting cookies. If You choose to eliminate cookies,the full functionality of the Website may be impaired for You.

c)         Most cookies are sessioncookies that are automatically deleted from Your device’s hard drive when Youclose the browser/App. Additionally, You may encounter cookies or other similardevices on certain pages of the Website that are placed by third parties. We donot control the use of cookies by third parties and shall not be liable for anyreason whatsoever for these third- party cookies.

d)         We may use third party serviceproviders to help Us analyse certain online activities. For example, theseservice providers may help us measure the performance of Our online campaignsor analyse visitor activity on the Website. We may permit these serviceproviders to use cookies and other technologies to perform these services forCompany. We do not share any Personal Information with these third partyservice providers, and these service providers do not collect such informationon Our behalf.

5.       UserRights

a)        Review:

To ensure the accuracy and adequacy ofthe Personal Information provided by You, You shall at all times have theoption 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 ofrefusing / withdrawing Your consent for the collection, storage and retentionof Your Personal Information. In case of Partners, their right to refuse /withdraw consent shall also be subject to the respective Agreement.

c)         Please note that Your refusal /withdrawal of consent may result in restriction/revocation of access and/orusage of Our Website. Please further refer to Paragraph10 of this Policy for the manner of communication with Us.

d)        Account Deletion:

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

6.    Disclosureof User Information

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

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

(ii)        to improve and personalize Ourproducts and services. This may involve, for example, activities such astroubleshooting and protection against errors; data analysis and testing; anddeveloping new features.

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

c)         Further, We reserve the rightto utilize, share and/or disclose User Information if:

(i)         required to do so to complywith orders of governmental authorities that have jurisdiction over it or asotherwise required by Applicable Law after providing You a written intimationprior to such disclosure; and/or

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

7.         Indemnification

You agree to indemnify, defend and holdharmless 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, includingreasonable attorneys’ fees, made by any third-party due to or arising out ofYour breach of this Policy or the documents they incorporate by reference(including the respective Agreement, where applicable for use of Website), orYour violation of any law or the rights of a third party.

8.         Security Precautions

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

9.         Change in Privacy Policy

We reserve the right to update, modifyand amend any of the terms of this Policy, at any time without prior intimationto You. These changes will become effective immediately on posting. We shallnot be liable for any failure or negligence on Your part to review the updatedPolicy before accessing Website. Your continued access to Website, followingchanges 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 maycontact Us at Urvashi Bahirsheth, Company Secretary at urvashi@avantifinance.in.

11.      Email Opt-Out

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

12.      Policy Review and Updates

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

This Policy was:

(i)             Drafted on behalf of theCompany by: Mrs. Urvashi Bahirsheth, Company Secretary

(ii)            Internally reviewed by: Mr.Manish Thakkar, COO

(iii)          Approved by the Board of theCompany on: June 04, 2021, Revision 1 on : March 13, 2023

Thisrevised Policy comes into effect from date of approval of the Board.

Client Privacy Policy

This document is an electronic record in terms ofInformation 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   SCOPE AND PURPOSE OF THIS POLICY}

A.           In this Client PrivacyPolicy (“Policy”), “we” or “us” or “our” means Avanti Finance Private Limited (“Company”),and includes its executive directors, officers, employees , as the context may require.

B.           The scope of this Policy is to ensure the protection of interests of Clients (as defined below) of Company in respect of personal information shared by Clients with Company and provide abroad-level mechanism to regulate the use of such information by the Company.

C.           This Policy has been framed and adopted by us in line with our commitments under the Information TechnologyAct, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and other applicable laws of India.

D.           This Policy applies to all persons (natural or juristic) who seek to or have availed loan from Company or from any other financial institution wherein Company acts in the capacity of business correspondent or any other similar capacity (“Clients”), and have, in the process, shared their personal information with Company (“ClientInformation”).

E.            This Policy delineates various measures that we shall endeavour to take in operationalising our commitment.

F.            By agreeing to avail the services offered by Company, Client agrees to the collection and use of ClientInformation by Company.

_{2  TYPES OF CLIENT INFORMATION COLLECTED}

A.        Company may, for the purpose of providing services to Clients, collect the following types of Client Information:  

(a)           Personal Information: Includes any information collected from the Client that is about his/her family, health, consumption behaviour, personal preferences, attitudes, beliefs or living conditions. It may include the following:  

(i)            Name, gender, residential /correspondence address, telephone number, date of birth, marital status, sizeof family, details of family members, email address or other contact information; and/or

(ii)           PAN, KYC Status, signature and/or photograph.

(b)           Financial Information: Includes any information collected from the Client regarding his/her businesses, income, expenses, immoveable assets, moveable assets, loans outstanding, repayment history, guarantors, or collateral Bank account or other payment instrument details; or any other detail which may be required by us for providing services.

B.           Client Information is collected from Client on a voluntary basis and is necessary in order for theClient to avail services from Company. Client is not required to provide theClient Information that the Company requests, and, if Client chooses not to do so, Company may not be able to provide Client with services or respond to any queries Client may have. Company

and its affiliates may share this Client Information with each other and use it consistent with thisPolicy. They may also combine it with other information to provide and improveCompany products, services, content, and advertising.

C.           To ensure the accuracy and adequacy of the Client Information, Client shall at all times have the option of reviewing the same by requesting Us in the manner as provided under paragraph 7(B) of this Policy.

_{3              PURPOSE OF COLLECTION}

A. Company collects, retains, and usesClient Information in order to provide financial and other services to Clients.Accordingly, such information is collected for specified business purposes,such as:

(a)           to process financial and non-financial transaction request;

(b)           to undertake research and analytics for offering or improving Company services;

(c)           to check and process Client’s applications which may be submitted for availing any financial services;

(d)           to share any updates/changes to the services and their terms and conditions with Client;

(e)           to take up and investigate any complaints/claims/disputes;

(f)            to respond to Client’s queries and feedback submitted by Client;

(g)           for verification of Client’s identity and other parameters; and

(h)           to fulfil the requirements of applicable laws / regulations and / or court orders / regulatory directives.

_{4              DISCLOSURE OF CLIENT INFORMATION}

A.    Company may disclose Client Information only under the following circumstances:

(a)           RBI/SEBI/ NSE/ BSE/ MCX /AssetManagement Companies of Mutual Funds / Registrar and transfer Agents /Collecting Banks / KYC Registration Agencies and other such agencies, solely for the purpose of processing your transaction requests for serving you better;

(b)           To process loans with any other bank/non-banking financial company/other financial institution where Company is acting as agent/banking correspondent or in any similar capacity under a valid contract;

(c)           As part of valid contracts with service providers/research agencies/external consultants etc.; or

(d)           Where Client has permittedCompany to share it with a third party located in India or outside India. In such case, Company shall ensure that there is written permission from the Client authorising the disclosure.

_{5  RETENTION OF CLIENT INFORMATION}

A.           Company shall not retain or store Client Information for periods longer than is required for the purposes except when such information may lawfully be used or is otherwise required under any other law for the time being in force.

B.           By agreeing to avail the services offered by Company, Client has agreed to the collection and use ofClient Information by Company. Client has the right to refuse or withdraw his/her consent to share/disseminate Client Information by contacting the ChiefOperating Officer of the Company. However, in the event of your refusal or withdrawal of consent, Client shall not be able to avail any services ofCompany to the fullest extent.

_{6              SECURITY PRACTICES AND CONTROL MECHANISM}

A.           Company uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Client Information. These include internal reviews of our data 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 personal data.

B.           Company maintains physical and electronic safeguards to protect Client’s personal and financial information. Company has placed the mechanisms outlined below to ensure information – both physical and electronic data storage, access, retrieval, sharing of data.

_{Information Management and Data Security}

C.           Records may be transferred from and between offices of Company/ third party service providers for record keeping purposes. We ensure that such third-party service providers maintain strict confidentiality (ensuring the same level of confidentiality as maintained by Us) in respect of Client Information.

D.           The database of currentClients and those Clients who do not have any current loan outstanding withCompany are properly archived and kept and stored in the same manner as we store data/ documents of our Clients.

E.            All Client data/ records/documents/ information shall be maintained by Company for such time period as may be required as per applicable laws.

_{Specific Authorization}

F.            Authorized personnel may see data from all the branches, but rights to edit or modify the data is given to select personnel with specific login access. ‍

G.           Client database changes require the Chief Risk Officer, Chief Operating Officer and Chief ofPartnerships to authorise/ approve the changes.

H.           Each personnel who accesses the database uses an individual username and password.

I.              Whenever an employee logs into the database, their name, the information they query, and the time when the request is made, are all recorded in a query log.

J.            Company has a strong back-up system in which it uses a combination of hardcopy and digital backups of Client Information. Company’s system backs-up all information on our cloud servers periodically.

_{7              COMPLAINT REDRESSAL MECHANISM}

A.           It is the Company’s constant endeavour to put the interest of its Clients first and to provide with financial solutions that are right for them. In keeping with its promise, theCompany looks forward to receiving both positive and negative feedback from theClients on its products and services.

B.           Any discrepancies and grievances related to the processing and use of Client Information can be raised to the grievance officer appointed by Company as below:

Mr.Sunil Kumar Tadepalli Chief       of         Partnerships

sunil.kumar.t@avantifinance.in

C.           The grievances of theClients will be redressed in the manner provided below:

(i)            Clients can register grievances through email id and toll-free number provided at the Company’s branches / HeadOffice / website and at any other place where the business of the Company is transacted.

(ii)           After examining the matter, theCompany will endeavour to send the Client its response expeditiously and intimate the stakeholder how to escalate the complaint to higher level, if they are not satisfied with the response.

(iii)          Clients have to confirm whether the grievance has been resolved to their satisfaction or not. The grievance will be deemed to be closed, if Client does not respond via toll free number or mail.

(iv)          The Company shall also request the Client to provide feedback on the services rendered. This can be done through direct contact by staff or through specific stakeholder satisfaction surveys that may be conducted from time to time.

(v)           A periodical review of the above mechanism at various levels of management would be undertaken by theCompany.

_{8.    Policy Review updated}

This document shall be reviewed by the CRO, and shall be reviewed atleast once a year. Reviews shall also account for any significant business changes and/or any regulatory requirements.

This Policy was:

I.             Drafted on behalf of theCompany by: Mr Nagaraj Subrahmanya, CRO

II.            Internally reviewed by: Mr Manish Thakkar, COO

Approved by the Board of the Company on: June 04, 2021, Revision 1 on : March 13, 2023

Introduction

This Fair Practices Code (this “Code”) is aimed to provide to the customers effective overview of practices, which will be followed by the Avanti Microfinance Private Limited (the “Company”) in respect of the financial facilities and services offered by the Company to its customers. The Code will facilitate the customers to take informed decisions in respect of the financial facilities and services to be availed by them and will apply to any loan that the Company may sanction and disburse.

1.  Objective of the Code

This Code has been developed to:

(a)  Promote good, fair and trustworthy practices by setting minimum standards in dealing with the customers.

(b)  Increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services.

(c)  Encourage market forces, through competition, to achieve higher operating standards; and

(d)  Promote a fair and cordial relationship between the customers and the Company.

2.  Our Key Commitments and Declarations

We shall act efficiently, fairly and diligently in our dealings with all our customers by:

1. Meeting the commitments and standards in this Code for the financial products and services we offer, and the procedures and practices our staff follow.
2. Ensuring that all the financial services meet relevant laws and regulations.
3. Providing professional, courteous and speedy services; and
4. Providing accurate and timely disclosure of terms and conditions, costs, rights and liabilities as regards financial transactions.
5. We shall help the customer understand how our financial products and services work by:
6. Giving verbal information about the financial schemes in Hindi and / or English and / or local vernacular language as understood by the borrower.
7. Ensuring that our advertising & promotional literature is clear and is not misleading.
8. Explaining financial implications of the transactions.
9. Helping the customer to choose the financial scheme.

We shall deal quickly and proactively with things that go wrong by:

(a)  Correcting mistakes quickly.

(b)  Attending customer complaints quickly.

(c)  Telling our customers how to take their complaint forward if the customers are still not satisfied with our assistance; and

(d)  Reversing any charges that we apply due to our mistake.

3.  Non-Discrimination Policy

We will not discriminate between our customers on the basis of gender, race or religion.

4.  Applications for loans and their processing

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

(b)  Loan application forms issued by the Company shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other non-banking financial companies (“NBFCs”) can be made and an informed decision can be taken by the borrower. The loan application form shall indicate the documents required to be submitted along with the application form.

(c)  The Company shall collect all necessary information from the customer only with prior customer consent and the borrower shall be provided with an option to provide or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent.

(d)  The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 days, from the date of receipt of the application form complete in all respects. The Company will endeavour to keep the customer / applicant informed with regard to the status of his application from time to time. The customer may also contact the Company’s customer service team at the prescribed toll-free number or email id to obtain an update on the status of application.

(e)  If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.

5.  Loan appraisal and terms / conditions

(a)  The Company shall conduct a due diligence on the credit worthiness of the borrower, which will be an important parameter for taking a decision on the application. The assessment would be in line with the Company’s credit policies, norms and procedures in respect thereof.

(b)  The Company shall appraise through its partner to under the customer’s business, household income, current indebtedness and assess the customer’s loan requirement and repayment capacity.

(c)  The borrower would be informed by means of SMS sent to the phone number of the borrower as provided by him/her in the Loan Application in vernacular language or a language as understood by the borrower, of the amount of loan sanctioned or otherwise. The said communication shall contain the terms and conditions including the annualized rate of interest and the method of application thereof.

(d)  The Company provides borrower with the flexibility to accept or reject the loan

(e)  The Company shall ensure that digitally signed document ,Key Fact Sheet, summary of loan product, sanction letter, terms and conditions, account statements, privacy policies of the partner with respect to borrowers data, etc. shall automatically flow to the borrowers on their registered and verified email/ SMS upon execution of the loan contract/ transactions.

(f)  The Company shall, wherever applicable, have a built-in repossession clause in the contract / loan agreement so as to have legal enforceability.

(g)  The Company shall clearly communicate to the borrower that the borrower can not be member of more than one SHG/JLG.

(h)  The moratorium period between the grant of the loan and the due date of the repayment of the first instalment shall be in line with the regulatory guidelines.

(i)  The privacy of borrower data will be always respected.

(j)  The Company does not have any lock in period for loan closure, customers can close their loan at their discretion.

6.  Disbursement of loans including changes in terms and conditions

The Company shall frame appropriate internal principles and procedures for determining and ensuring that the interest rates and processing and other charges are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and processing and other charges on loan are in strict adherence to above referred internal principles and procedures.

The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower.

The Company shall give a notice to the borrower in the vernacular language, or a language as understood by the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition to this effect shall be incorporated in the loan agreement.

The Company shall provide a Key Fact Statement (KFS) to the borrower in vernacular language or language understood by the borrower before the execution of the contract in a standardized format for all lending products incorporating information like

1. Basic customer details.
2. Terms and conditions.
3. Details of the grievance redressal system, including the name and contact number of the nodal officer of the Company.

The Company shall disburse all loan proceeds into the bank account of the borrower except for disbursals covered exclusively under statutory or regulatory mandate (of RBI or of any other regulator), flow of money between the Company and the partner for co-lending transactions and disbursals for specific end use, provided the loan is disbursed directly into the bank account of the end-beneficiary.

Any decision to recall / accelerate payment or performance under the loan agreement shall be in consonance with the loan agreement.

The Company shall release all securities offered by the borrower on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against the borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled / paid.

7.  Guidelines related to recovery of Loans

a. In the matter of recovery of loans, the Company shall not resort to undue harassment like bothering the borrowers at odd hours, use of muscle power for recovery of loans etc. The Company shall ensure that its staff is adequately trained to deal with the customers in an appropriate manner so as to not to behave rudely with customers.

b. The Company or its Partner shall not engage in any harsh methods towards recovery, without limiting the general application of the foregoing, following practices shall be deemed as harsh:

i.  Use of threatening or abusive language .

ii.  Harassing relatives, friends, or co-workers of the borrower

iii.  Publishing the name of borrowers

iv.  Use or threat of use of violence or other similar means to harm the borrower or borrower’s   family/ assets/ reputation

Misleading the borrower about the extent of the debt or the consequences of nonrepayment .

c. The Company will call delinquent customers between 09 00 hours to 1800 hours unless special circumstances of the borrower’s business require to call them otherwise outside the hours mentioned.

d. The Company may arrange for enforcing security charged to it of the delinquent borrower, if required, with an aim only to recover dues and will not be aimed at whimsical deprivation of the property.

e. The Company shall ensure that the entire process of enforcing its security, valuation and realization thereof be fair and transparent.

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

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

8.  Engagement of Recovery Agent

1. Recovery agents shall mean agencies engaged by the Company for recovery of dues from its borrowers and the employees of these agencies.
2. The Company shall have a due diligence process in place for engagement of recovery agents, which shall, inter alia, cover individuals involved in the recovery process.
3. The Company shall ensure that the partner engaged by them for recovery carry out verification of the antecedents of their employees, which shall include police verification and their periodicity.
4. The Company shall provide the details of recovery agents to the borrower while initiating the process of recovery like name, contact number of the agent and the partner’s name.

9.  Training of Staffs

1. The Company shall have a board approved policy regarding the conduct of employees and system for their recruitment, training and monitoring. The Company will ensure the partner employees dealing with borrowers will be adequately trained
2. Field staff shall be trained to make necessary enquiries regarding the income and existing debt of the household.

10.  Complaint Redressal Mechanism

It is the Company’s constant endeavour to put customers interest first and to provide with financial solutions that are right for the customers. In keeping with its promise, the Company looks forward to receiving both positive and negative feedback from the customers on its products and services. The grievances of the customers will be redressed in the following manner.

i.  The customer can register grievances through email id and tollfree number provided at the Partner branches / Head Office / website and at any other place where the business of the Company is transacted.

ii.  After examining the matter, the Company will endeavour to send the customer its response expeditiously and intimate the customer how to escalate the complaint to higher level, if he/she is not satisfied with the response.

iii.  The customer has to confirm whether the grievance has been resolved to his / her satisfaction or not. The grievance will be deemed to be closed, if the customer does not respond via toll free number or email.

iv.  At all Partner branches / Head Office / any other place where the business of the Company is transacted, notice will be put up informing the customers about the Customer Care Executives, Escalation Mechanism and the Grievance Redressal Officer (including the name and contact details responsible for logging and resolving the grievances) who can be approached by the Customer for resolution of complaints against the Company.

v.  Email id: helpdnbs@rbi.org.in. The complete contact details of such Officer of the Reserve Bank of India shall be provided at all Partner branches / Head Office / Website or any other place where the business of the Company is transacted.

vi.  The Company shall also request the customer to provide feedback on the services rendered. This can be done through direct contact by staff or through specific customer satisfaction surveys that may be conducted from time to time.

vii.  A periodical review of the Fair Practices Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by the Company and a consolidated report of such reviews shall be submitted to the Board of Directors of the Company, at regular intervals in a manner as prescribed by the Board from time to time.

11.  Language and mode of communicating this Code

a.  The Company shall endeavour to have this Code translated into any vernacular language or other language as understood by the borrowers.

b.  The Company shall ensure that this Code is published on its website so that the information contained in this Code is accessible to all stakeholders.

12.  Policy for determining Interest Rates, Processing and Other Charges

a.  To ensure that the customers are not charged excessive interest rate and charges on loans by the Company, the Board of Directors of the Company shall adopt a Interest rate model taking into account relevant factors such as cost of funds, margin, risk premium, for determining interest rates, processing and other charges (“Interest Rate Policy”).

13.  General

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

b.  The Company shall display the necessary details of their partner is being displayed in the Company website.

c.  The Company shall ensure that the partner engaged by them do not store personal information of borrowers except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out their operations.

d.  The Company shall ensure any lending done by the Company directly or through its partner shall be reported to the Credit Information Committee irrespective of tenure and nature.

The Company shall abide by this Code following the spirit of this Code and in the manner, it may be applicable to its business.

The policy is subject to subject to revision as and when applicable.

14.  Policy Review and Updates

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