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I. Preamble
It is, and shall be, the policy of International Financial Services Ltd. (IFSL)
to make available to all eligible qualified applicants, without discrimination
on the basis of race, caste, colour, religion, sex, marital status, age or
handicap all financial products, either directly or through subsidiaries and /
or associates
IFSL’s policy is to treat all the clients consistently and fairly. The
employees of IFSL will offer assistance, encouragement and service in a fair,
equitable and consistent manner. IFSL will also communicate its Fair Practices
Code (FPC) to its customers by uploading the FPC it on its website
IFSL will ensure that the implementation of the FPC is the responsibility of
the entire organisation. IFSL’s fair lending practices shall apply across all
aspects of its operations including marketing, loan origination, processing,
servicing and collection activities. Its commitment to FPC will be demonstrated
in terms of employee accountability, training, counselling, and monitoring,
auditing programs and internal controls, and optimal use of technology
IFSL’s Board of Directors and the management team are responsible for
implementing the fair practices hereinafter detailed, and also to ensure that
its operations reflect its strong commitment to all the stakeholders for
offering in a fair and equitable manner, the various financial services and
products including lending and that all employees are aware of this
commitment...
The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code
for Non Banking Finance Companies (NBFCs) thereby setting standards for fair
business and corporate practices while dealing with their customers. The
Company shall adopt all the best practices prescribed by RBI from time to time
and shall make appropriate modifications if any necessary to this Code to
conform to the standards so prescribed.
This Fair Practices Code applies to the following categories of products and
services offered by us (currently offered or which may be introduced at a
future date)
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1. Loans, guarantees and other products in the nature of financial assets.
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2. Wealth management products offered by IFSL.
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3. Third party products offered through a network consisting of the branches of
IFSL, its subsidiaries and associates
The FPC is applicable to the above irrespective of whether the same is provided
physically, over the phone, on the internet or by any other method whatsoever,
existing or futuristic.
Key Commitments
The key commitments which IFSL promises to follow in its dealings with its
customers are
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a. To act fairly and reasonably in all dealings with its customers by ensuring
that
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Its products, services, procedures and practices will meet the commitments and
standards in this FPC.
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Its products and services will meet relevant laws and regulations as applicable
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Its dealings with its customers will rest on ethical principles of honesty,
integrity and transparency
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b. IFSL will assist customers in understanding how its financial products and
services work by
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Providing information about them in simple Hindi and/or English and/or the
local language
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Explaining their financial implications and
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Helping the customer choose the one that meets his / her needs
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c. IFSL will make every attempt to ensure that its customers have a
trouble-free experience in dealing with it; but in the case of errors or
commissions and omissions, IFSL will deal with the same quickly and
sympathetically
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Mistakes will be corrected quickly
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Complaints will be handled quickly
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In case a customer is not satisfied with the way a complaint is handled, IFSL
will guide the customer on how to take the complaint forward
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IFSL will reverse any charges including interest applied to a customer’s
account due to an error or oversight on its part
II. Sales Origination
IFSL will guide its customers in choosing products and services which meets his
/ her requirements.
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a. To act fairly and reasonably in all dealings with its customers by ensuring
that
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Give the customer information explaining the key features of the services and
products the customer has shown interest in
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Give information on accounts, products and services which may suit the
customer’s needs
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Clearly state the information that IFSL require to collect from the customer to
fulfil its ‘Know Your Customer’ norms and to comply with legal and regulatory
requirements in force from time to time.
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Request for additional information about the customer and his / her family to
build a database; but this information may be furnished by the customer only if
she / he wishes to do so
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b. IFSL will provide information on the various channels that can be used to
access its products and services. The customer will also be informed on where
further information on this is available.
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c. Once a customer has chosen a product, IFSL will tell the customer how it
works
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d. IFSL will guide its customer on rights and responsibilities specific to the
mode of operation under which the product is taken
III. Loans And Advances
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a. Before offering any kind of fund based or non fund based non-banking
facility IFSL will assess the ability of the customer (prospective borrower) to
repay.
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b. Loan application forms of IFSL will include necessary information which are
likely to affect the interests of the prospective borrower, so that a
meaningful comparison with the terms and conditions offered by other Non
Banking Finance Companies can be made and an informed decision taken by the
prospective borrower.
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c. The loan application form shall indicate the documents required to be
submitted along with the application form.
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d. IFSL shall provide to the prospective borrower an acknowledgement for
receipt of all loan applications. An indicative time frame within which loan
applications will be disposed of will be mentioned in such acknowledgement.
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e. IFSL shall convey in writing to the prospective borrower the fate of the
loan application by means of sanction letter or otherwise. In the case of
sanction of loan, the sanction letter shall contain the terms and conditions
including annualised rate of interest and method of application thereof. The
acceptance of the terms and conditions communicated by the borrower shall be
preserved by IFSL in its records.
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f. IFSL shall give notice to the borrower of any change in the terms and
conditions including disbursement schedule, interest rates, service charges,
prepayment charges etc. IFSL shall ensure that changes in interest rates and
other charges are effected only prospectively. The loan agreement shall contain
a specific clause to this effect.
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g. The decision of IFSL to recall / accelerate payment or performance shall be
in consonance with the terms of the loan agreement. IFSL shall release all
securities upon repayment of all dues or on realisation of the outstanding
amount of loan subject to any legitimate right or lien for any other claim it
may have against borrower. The borrower shall be given due notice with full
particulars about the outstanding claims in case such right of set off is to be
exercised.
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h. IFSL will refrain from interfering in the affairs of the borrower except for
the purposes provided in the terms and conditions of the loan agreement, unless
new information, not earlier disclosed deliberately or otherwise by the
borrower, has come to its notice..
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i. In case of receipt of request from the borrower for transfer of a borrower
account to other NBFC, bank of financial institution, the consent or otherwise
shall be con eyed within 21 days from the date of receipt of such request. Such
transfer shall be in accordance with the contractual terms entered into with
the borrower and in consonance with the statutes, rules, regulations and
guidelines as may be applicable from time to time.
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j. In the matter of recovery of loans, IFSL shall resort only to remedies which
are legally and legitimately available to it and will avoid using recovery
measures during odd hours of the day
IV. Terms And Conditions
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a. When a customer accepts a product or service for the first time, IFSL will
provide the customer with the Rules and Regulations that are relevant to the
product / service.
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b. All Terms and Conditions will be fair and will set the customer’s rights and
responsibilities clearly and in plain language. IFSL will use legal or
technical language only where necessary.
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c. IFSL will make available any charges applicable to products and services
applicable at the time a customer signs up for the same.
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d. If IFSL increases any charges or introduces a new charge, IFSL will notify
the same to the customers.
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e. IFSL will provide the terms and conditions in respect of any product or
service whenever a customer requests for the same.
V. Marketing And Product Synergy.
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a. IFSL will ensure that all advertising and promotional material is clear,
fair reasonable and not misleading.
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b. IFSL will provide the customers with a full range of financial products the
customer is eligible for. Some of these products / services will be its own;
some others may be the products of the group or associate companies and also
companies with which IFSL may have arrangements with.
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c. It will be the endeavour of IFSL to bring synergy between the various
financial services, financial products, by cross selling these products to its
clientele.
VI. Confindentiality
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a. Unless authorized by the customer IFSL will treat all personal information
as private and confidential.
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b. IFSL will not reveal transaction details to any other entity including
within the group other than the following exceptional cases
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If IFSL have to provide the information by statutory or regulatory laws
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If there is a duty to the public to reveal this information
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If its interest requires us to provide this information (e.g. fraud
prevention). IFSL will not use this reason for giving information about
customers to anyone else (including group companies) for marketing purposes
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If IFSL have taken the customers permission (for instance at the time of loan
sanctioning) to provide such information to its group / associate / entities or
companies for providing other products or services
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Where the customer asks us to reveal such information to its group / associate
/ entities or companies for providing other services or products
VII. Grievance Redressal Mechanism
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a. IFSL will guide customers who wish to lodge a complaint and also provide
guidance on what to do in case the customer is unhappy with the outcome.
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b. After examining the matter, IFSL will send a response as soon as possible;
IFSL will also guide a customer on how to take the complaint further if the
customer is not satisfied.
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c. A nodal officer has been appointed for the redressal of grievances of the
customers including the borrowers, in connection with any matter pertaining to
business practices, lending decisions, credit management and recovery. The name
and contact details of the nodal officer shall be displayed in the website of
IFSL
VIII. Force Majeure
The various commitments outlined and made by IFSL are applicable under the
normal operating environment. In the event of Force Majeure, IFSL will not be
able to fulfil the commitments under the FPC to the entire satisfaction of the
customer/s, the other stake holders. And the public in general
IX. Effective Date
This FPC shall come into effect from October 26, 2006
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