Corporate governance

FAIR PRACTICES CODE

INTEREST RATE POLICY

VIGIL MECHANISM

KYC AND AML Policy

NOMINATION & REMUNERATION POLICY

POLICY AGAINST SEXUAL HARASSMENT

POLICY ON RELATED PARTY TRANSACTIONS

CSR POLICY

INTERNAL GUIDELINES ON CORPORATE GOVERNANCE

COOKIES POLICY

PRINCIPLES GUIDING INTEREST RATE DETERMINATION

Interest rate being charged is based on various factors like cost of funds, margin, risk premium, un-allocable expenses among other things. As far as risk premium is concerned, it will be based on variables like Profile, underlying security, tenure, other terms and conditions etc.

Asset Liability Committee (ALCO) has been authorised by Board for the purpose of laying out appropriate internal principles and procedures in determining interest rates and other charges. ALCO comprises of Head of the organization along with relevant head of the departments. ALCO has product pricing as one of the responsibilities among other things authorised by Board.

The Board of Directors of the Company or a Committee drawing power from the Board, while fixing interest rates shall be guided by this document on Interest Rate Determination. In addition to basic cost elements, the Board or the Committee shall be guided by the market conditions and various rules and regulations, if any, prescribed by the Reserve Bank of India or such other competent authority from time to time.

Interest charged for various products / Schemes shall have the following components:

1. Base Rate
2. Approach for Gradation of Risk/Risk Premium
3. Penalty Charges

1 Base Rate

3. Penalty Charges

• Base Rate represents the rate chargeable under every product / Scheme irrespective of the risk weight attached to the product / schemes or the type of scheme. Basic Interest shall be arrived at after considering the following aspects:

  1 Cost of Funds

  2 Overhead Cost

  3 Return on Capital Employed

  • This component represents the interest and other incidental charges payable by the Company for servicing the borrowed funds deployed by the Company. Major contributing factor to this component includes Interest on Bank Borrowings, interest on other financial instruments and other incidental charges thereto.
  • This represents the Employee cost to the Company and other operating & miscellaneous overheads.
  • After considering the above cost factors, the Board / committee shall take into consideration a fair return on capital employed which is to be generated by the management for servicing the owners' capital employed in the business.
  • Thus the basic interest rate for the gold loan schemes shall be determined by considering the cost of funds, overhead cost and fair return on capital employed.
• 2. Approach for Gradation of Risk/Risk Premium
• Risk Premium shall be determined by taking into account the degree of risk involved in loans under each product / scheme. While the rate shall be lower for the schemes where advance amount vis-Ã -vis security available is the lowest, it shall be increased for schemes offering higher advance amount for the same security. Further, irrespective of the product /scheme, the risk interest shall also be determined after taking into account the period of the loan as the incidence of risk goes up with the passage of time. Profile of the borrower will also affect premium being charged based on either his repayment capacity or his track record on previous loans with the company, other financial commitments, geography (location) of the borrower, end use of the loan as represented by the underlying asset etc. Such information is collated based on discussions with the borrower, reports from credit bureau wherever necessary etc. and field inspection by the Company officials.
• Loans outstanding for more than due date shall be charged penal interest in order to compensate for the opportunity cost of cash flows and also to discourage liability getting exceeded the realizable value of security.

Interest Rate Policy

GRIEVANCE REDRESSAL MECHANISM

A. INTRODUCTION:

Customers are the life blood of business. There is growing relevance of excellence in customer service to propel growth considering intense competition in the Market to acquire and grow the business. This would include existence of a proper and effective redressal mechanism for customers. The broad principles to be kept in view in forming a customer complaint resolution mechanism are as under.

1. Customers must be served with courtesy, respect and understanding at all times.

2. Customers must be treated with fairness - both actual and perceived.

3. There is a structured and well publicized mechanism for customers to ventilate grievances.

4. Complaints are addressed within a reasonable time frame and to the satisfaction of the customers.

5. Strategies are in place to improve customer service on a continuous basis to minimize the scope for grievances.

6. Employees are sensitized to the importance of customer acquisition and retention.

B. CUSTOMER TOUCH-POINTS:

All customers are treated fairly at all times. All customer escalations and grievances are dealt with courtesy and resolved on time.

As a customer service strategy, the company shall provide multiple channels through which the customer could raise his concerns and seek a redressal. On-line customer complaints tracking is being introduced internally so that requests / complaints can be addressed within defined turn-around-time.

Following are the touch-points for customer service / grievance redressal:

a. Branch Outlet

Customer can reach any of our branches with regard to his request / complaint. Customer Complaint Register is being maintained in every branch at prominent location through which customer can register his complaint. After registration of complaint, acknowledgement is issued to the customer for tracking purpose.

b. Customer care Telephone Number

Dedicated telephone number of customer service desk has been incorporated in the 'Guidelines for the customers' which has been displayed in English as well as Regional language in all the branches. Customer may register his request / complaint with customer service desk by calling at that number in case request / complaint is not resolved at branch level. Contact details of persons at Corporate Office (CO) are made available by way of display in the branches.

c. Customer Care Email ID

Customer can also send an email to customer care desk. Email ID has been published on the website of the company. The customer care email ID is also made available by way of display in the branches.

d. Nodal Officer

As per grievance redressal mechanism, in case the issue still remains unresolved up to the customer's satisfaction, he could have his grievance details intimated to the Operations-In charge, Fedbank Financial Services Limited, Kanakia Wall Street, A-Wing, 5th Floor, Unit No.501/502/511/512, Andheri – Kurla Road, Chakala, Andheri East, Mumbai, Maharashtra – 400093. Email ID: Sougata.roy@fedfina.com & Telephone Number: 022-68520837.

C. SALIENT POINTS

• Following are the salient points of customer grievance redressal mechanism
• Online Tracking of Customer Requests / grievances supported by dedicated customer care executive
• Time Limits for Acknowledgement and resolution
• Language of Communication
• When should a Grievance be treated as resolved
• Treatment of Anonymous, Pseudonymous, and Fictitious Grievances
• Training of Employees & Disciplinary Action
• Periodic review of Customer Complaints and Maintenance of Records / Registers

1 Online Tracking of Customer Requests / grievances supported by dedicated customer care executive (CCE)

• Whenever a customer registers a service request / complaint, it will be responsibility of the branch staff / CCE to log the same in the IT Service Portal under "Customer Request" category on the same day.
•  For each logged complaint, system will generate unique request number. Moment a complaint is registered and entered into the system (irrespective of source), the ID should be generated for future correspondence and tracking - customer to be educated for the same. Also, the subsequent tracking of the complaint must happen through a System FCRM with an in built escalation matrix. Off line tracking is prone to manipulation and error.
•  Logged complaint will automatically be assigned to Customer Care Executive for further course of action.
•  Acknowledgment of Customer Complaint Register must carry a provision to capture the unique request number. This will ensure that the details are entered in the system and number generated.
•  Compliance to the above needs to be checked during Operation Manager Visits and Accounts Audit.
•  Customer Care Executive to understand the nature of complaint & forward that complaint to the concerned official for its immediate resolution.
•  Customer Care Executive has to monitor these complaints closely and follow up with concerned authorities for immediately action.
•  Prompt disposal of grievances needs proper monitoring by Customer Care Executive (CCE) in the organization keeping in view the seriousness of the complaint and value of customer relationship.

• The under mentioned matrix should be observed:

  Complaint received by	Immediate action to be taken
  Branch Staff via Customer Complaint Register	Recipient should record the nature and gravity of the complaint in the IT Service Portal under 'Customer Request' menu. Logged complaint will automatically be assigned to Customer Care Executive who in-turn will forward that request to concerned official for resolution. Concerned Staff should take an appropriate action to resolve the grievance. CCE will track resolution of the grievance and follow up with concerned staff.
  Customer Care Executive at Head office via a email or call from the complainant litigate	CCE should log the complaint immediately in system and inform nature of complaint to the concerned official / head of the department in Head office basis gravity of the complaint. CCE will simultaneously take follow-up / action with concerned staff to resolve the grievance and track resolution of grievance If required, CCE to escalate the issues to higher authorities.

• 2. Time Limits for Acknowledgement and resolution:

  1. Grievances need to be addressed within a reasonable time otherwise not only will the purpose be lost but the delay itself could become another cause for 'grievance' for the customer.

  2. Prompt acknowledgement is the first step towards resolution and likely to have an immediate soothing effect on the complainant. Such acknowledgement must preferably state as far as possible within what period the grievance will be resolved. Of course, this would depend on the nature of the complaint including availability of adequate details.

  3. Once Receipts of grievance is acknowledged, all efforts should be made to have the grievance resolved at the earliest to the full satisfaction of the customer. Accordingly, time norms as under shall be complied with.

  Nature of response	Mode of Communication	Period within which to be sent	Remarks
  Acknowledgement of complaint	The same mode through which received. E.g. if complaint is received by email acknowledgement should be sent by email Well drafted & pre-approved format for acknowledgement must be used. - This should be automated reply	Acknowledgment should be provided Immediately/td>	If full details to facilitate resolution of complaint is not provided by the complainant the acknowledgement / subsequent mail/ communication must clearly request him/her to provide the required details. If the complaint does not contain the address / telephone number of the complainant, reasonable efforts should be made to ascertain the same based on the information available. If despite efforts, the details cannot be ascertained. The complaint may be shown as pending with specific remarks on non-availability of required information to address the complaint and closed after a period of 1 month from receipt of the grievance if there is no further communication.
  Resolution of Complaint	The same mode through which received. The communication regarding final resolution should be sent by the concerned official handling the complaint. However, draft of response letter to be vetted by legal in case of any legal issue.	At the earliest depending on the nature of the complaint and details available but not later than 14 days from the date of receipts of complaint. When the complaint cannot be resolved within the time frame of 14 days due to factor beyond the company's control, the complainant should be promptly advised.	The time line to be observed would apply from the date of receipt of complete details which are required for resolving the complaint.

• Mentioned below is the Escalation Matrix for the unresolved grievances.
  ESCALATION MATRIX FOR UNRESOLVED GRIEVANCES FOR GOLD LOAN VERTICAL

  Complaint received / Pending with	TAT	Escalation to & by after the time period mentioned
  Branch Staff	Day 0 to Day 3	Area Operations Manager by CCE
  Area Operations Manager	Day 4 to Day 6	Regional Operations Manager by CCE
  Regional Operations Manager	Day 7 to Day 10	Head - Operations by CCE
  Head - Operations	Day 11 to Day 12	Head - Finance by Head-Operations
  Head - Finance	Day 13 to Day 14	President by Head - Finance

  The Overall responsibility for the timely escalation shall be with the CCE who must track each complaint individually and take up the issue with concerned officials / Department Head in Corporate office.

  All Unresolved complaints beyond 14 working days from date of receipt of the complaint from the customer shall be escalated by CCE through Head - Finance to President for immediate intervention.

  If the complaint / dispute is not redressed within a period of one month the customer may appeal to The Deputy General Manager, Reserve Bank of India, Department of Non-Banking Supervision, Bakery Junction, PB No. 6507, Thiruvananthapuram - 695033, Kerala. Tel - 0471-2338818/ dnbsthiro@rbi.org.in

• ESCALATION MATRIX FOR UNRESOLVED GRIEVANCES FOR DISTRIBUTION VERTICAL

  Complaint received / Pending withng>	TAT	Escalation to & by after the time period mentioned
  Location Head	Day 0 to Day 4	Head - Sales / Head - Credit & Risk / Head - Finance by CCE
  Head - Sales / Head - Credit & Risk / Head - Finance	Day 5 to Day 6	President by Head - Sales / Head - Credit & Risk / Head - Finance

  The Overall responsibility for the timely escalation shall be with the CCE who must track each complaint individually and take up the issue with concerned officials / Department Head in Corporate office.

  All Unresolved complaints beyond 6 working days from date of receipt of the complaint from the customer shall be escalated by CCE through Head - Sales / Head - Credit & Risk / Head - Finance to President for immediate intervention.

  If the complaint / dispute is not redressed within a period of one month the customer may appeal to The Deputy General Manager, Reserve Bank of India, Department of Non-Banking Supervision, Bakery Junction, PB No. 6507, Thiruvananthapuram - 695033, Kerala. Tel - 0471-2338818/ dnbsthiro@rbi.org.in

• Language of Communication:

  The responses to grievances shall be in the same language as that used by the complainant in case resolution is provided by Front End Team. In case response is going from CO then it should be in English.

  Extreme care should be taken to ensure the correct choice of word / clauses in communications with complainant.

  Draft will be prepared by CCE after taking inputs from respective persons and response will be vetted by legal team wherever applicable.

7. Periodic review of Customer Complaints and Maintenance of Records / Registers:

• 4 When should a grievance be treated as resolved?

  A grievance can be considered as finally resolved normally only after customer gives a communication to that effect either in writing or over the telephone which will be recorded in the system by the CCE while closing the complaint. A letter from the customer must not be insisted upon as it can cause irritation.

  In order to take issues to a conclusion, we will need to treat the same as resolved when appropriate revert is provided by the company to customer complaints and there is no subsequent communication from the custome

  5. Treatment of Anonymous, Pseudonymous and Fictitious Grievances:

  After preliminary enquiry by the CCE if the complaint is found to be Anonymous, Pseudonymous or Fictitious, the complaint may be treated as dealt with and closed after a proper study

  6. Training of Employees and Disciplinary Action:

•  Senior officials like AOMs/ROMs visiting the branches must emphasise the importance of Good Customer Service.
•  Employees treating customers in rude and inappropriate manner should be penalized swiftly and appropriately.
•  Data on grievances must be appropriately classified (e.g. Staff behaviours , Misrepresentation, interest / Charges rates, Delivery of damaged ornaments, Poor amenities etc.) period wise, area-region wise, pendency wise, severity wise etc.
• Such analysis must be reviewed continuously by Operations staff and once a month, at Corporate Office with President.
•  Necessary measures should be taken to address repetitive issue or chronic grievances to minimize complaints of such nature.
•  Efficiency of resolution of complaints should be measured periodically through MIS.
•  The CCE shall be responsible to ensure proper maintenance of records and register relating to the functioning of the redressal mechanism.
• Head - Operations shall arrange to verify the compliance of the Grievance Redressal Mechanism on weekly basis.

TERMS AND CONDITIONS OF APPOINTMENT OF AN INDEPENDENT DIRECTOR

• The tenure of appointment shall be subject to the provisions of the Companies Act 2013 and the applicable RBI guidelines.
• The appointment is also subject to the formal election at the next Annual General Meeting (AGM) as well as the Memorandum and Articles of Association (The “Memorandum” & “Articles”) of the Company, as amended from time to time.

2. Role, Duties, Responsibilities and Expectations

• The primary role of the members of the Board is to provide guidance and to act in what they believe to be the best interests of the Company and its shareholders. The role, duties and responsibilities shall be in line with the applicable provisions and Schedule IV of the Companies Act, 2013 read with its Rules, Articles of Association, Listing Agreement and corporate code of conduct.

3. Time Commitment:

• The Independent Director needs to confirm that, he/she is able to allocate sufficient time to the Company to discharge the required duties and responsibilities.

4. Remuneration:

• The Independent Director will be paid sitting fees as approved by the Board in line with the provisions of the Companies Act, 2013 for every Board or Committee meetings attended; subject to appropriate deduction of applicable taxes. The Company will also reimburse the Independent Director for travel, hotel and all reasonable and properly documented expenses that are incurred.

5. Disclosure of Interest:

• It is accepted and acknowledged that the Independent Director may have business or professional interests other than those of the Company and has declared all and any conflicts of interests that are apparent or that the Independent Director is aware of.
• If, in future, any potential conflicts of interests arise, these should be disclosed to the Company as soon as possible.
• Based on the information provided to the Company, the Company can come to the determination that the Independent Director is an independent Board member and will remain so, unless otherwise determined at a later date.

6. Confidentiality:

• All information acquired during the Independent Director’s appointment is confidential to the Company and should not be disclosed to third parties or used for any reason other than in the interest of the Company, either during the NEID’s appointment or later, without prior clearance from the Company.
• Attention is also drawn to the legal and regulatory requirements as they apply to the Company and to its Board members with regard to the disclosure of ‘insider’ information. Consequently, any public or press statements should be avoided, if that will risk a breach of these requirements or does not have prior clearances from the Board of the Company.
• Nothing in this clause shall prevent the Independent Director from disclosing information which he/she is required to disclose by law, provided that the disclosure is made in accordance with the provisions of the relevant law.

7. Governing Law

• The Contract of Appointment is governed by and will be interpreted in accordance with Indian law and Independent Director’s engagement shall be subject to the jurisdiction of the Indian courts.

Fedbank Financial Services Limited-Ombudsman details

Ombudsman_Scheme_for_NBFCs-_2018

RBI-Ombudsman-Scheme-Form

Salient Features NBFC Ombudsman Scheme - English

Salient Features NBFC Ombudsman Scheme - Gujarati

Salient Features NBFC Ombudsman Scheme - Hindi

Salient Features NBFC Ombudsman Scheme - Kannad

Salient Features NBFC Ombudsman Scheme - Malayalam

Salient Features NBFC Ombudsman Scheme - Marathi

Salient Features NBFC Ombudsman Scheme - Tamil

Salient Features NBFC Ombudsman Scheme - Telugu

Mr. Sumit Kakkar, Nominee Director, resigned from the Board of Directors of the Company w.e.f. 13th March, 2020

Mr. Dilip Sadarangani, Independent Director, retired from the Board of Directors of the company w.e.f 8th September 2019

Mr. Ganesh Sankaran, Nominee Director, resigned from the Board of Directors of the company w.e.f 15th February 2019

Mr. Rajagopalan Santhanam, Nominee Director, resigned from the Board of Directors of the company w.e.f 20th December 2018

Mr. Suresh Kumar, Independent Director, resigned from the Board of Directors of the company w.e.f 19th June 2017.

Mr. Ujwal Thakar, Independent Director, resigned from the Board of Directors of the company w.e.f 5th August 2016.

Q3 FY 20

June 2020

September 2020

December 2020

Mr. Anil Kothuri-MD & CEO

Mr. Sudeep Agrawal- Chief Financial Officer

Mr. S. Rajaraman- Company Secretary & Compliance officer

Company has 4 Selling and Servicing Agents, which are as follows:

1. New Opportunity Consultancy Private Limited (NOCPL)

2. Svasti Microfinance Private Limited

3. Si Creva Capital Services Private Limited (Kissht)

4. Loantap Credit Products (P) Ltd.