Introduction The National Housing Bank (NHB) has framed the guidelines on Fair Practices Code for Housing Finance Companies (HFCs) which sets the fair practices standards when dealing with individual customers and to serve as a part of best corporate practice. In accordance with these guidelines, Sahara Housingfina Corporation Ltd (SHCL) has formulated the policy on Fair Practices Code which is designed to assist both the company and the consumer and will be applicable to all the products and services offered by the Branches across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method. Objectives It is, and shall be, our policy to make our Home Loan Products available to all eligible and qualified applicants without discrimination on the basis of face, caste, colour, religion, sex, martial status, age or handicap. Our Policy is to treat all the clients consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. The Company will also communicate our Fair Practices Code to our Customers by placing it on the Company’s website. The Company shall ensure that charges/fees which effect the interest of the prospective borrowers are appropriately informed to the borrower. Terms and conditions pertaining to the facility will be conveyed to the prospective borrowers. The Company commit that disputes arising out of the lending decisions will be resolved by an appropriate grievance redressal mechanism. The main objective shall be : Promote good and fair practices by setting minimum standards in dealing with customers; Increase transparency so that the customer can have a better understanding of what he/she can reasonably expect of the services; Encourage market forces, through competition, to achieve higher operating standards; Promote a fair and cordial relationship between customer and the Company; and Foster confidence in the housing finance system. Application of the Code The Company will ensure that the implementation of the Fair Practices Code is the responsibility of the entire organization. The Company’s Fair lending practices shall apply across all aspects of operations including marketing, loan origination processing, and servicing and collection activities. Our commitment to Fair Practice Code would be demonstrated in terms of employee accountability, monitoring and auditing programs, training and technology. The Company’s Board of Director and the Management Team is responsible for establishing practices designed to ensure that our operation reflect our strong commitment to fair lending and that all employees are aware of the commitment. Commitment to Customers The Company shall ensure that the products and services are met with relevant laws and regulations in letter and spirit. All the dealings with customers rest on ethical principles of integrity and transparency. The key commitments which the Company promise to follow in our dealing with our customers : Act fairly and reasonably in all our dealing with our customers by ensuring: Our products, services, procedures and practices will meet the commitments and standards in this Code Our products and services will meet relevant laws and regulations Our dealings with customers will rest on ethical principles of integrity and transparency. The Company will ensure that the staff is trained to provide relevant information about the Code and to put the Code into practice The Company will assist customers in understanding how our financial products and services work by: Providing information about them in simple Hindi and/or English and/or the local language Explaining their financial implication Helping the customer choose the one that meet his/her needs The Company will help customers to use the products and service by Providing the customer with information on regular, appropriate updates. Keeping them informed about the changes in the interest rates, changes or terms and conditions. To Deal quickly and sympathetically The Company will make every attempt to ensure that the customers have a trouble free experience in dealing with us, but if something does go wrong, the Company will deal with the same quickly and sympathetically Mistakes will be corrected quickly Complaints will be handled quickly In case a customer is not satisfied with the way a complaint is handled, the Company will guide the customer on how to take the complaint forward The Company will reverse any charges applied to a customer’s account due to an error on our part. Confidentiality Unless authorized by the customer the Company will treat all personal information as private and confidential save and except as may be required by the Regulators, Credit Agencies or under the order of any Court Publicise this Code, put it on Company’s sour website and have copies available on request. Disclosure and Transparency The Company will guide our customers in choosing products and services which meet his / her / their requirements. The Company shall take maximum steps to ensure disclosure and transparency in the products offered by it as regards to the interest rates, common fees and charges and the terms and conditions. The customers can find out about our interest rates by: Looking at the notices in our branches Phoning our branches or help-lines Looking on our website, or Enquiring with our designated staff. In case of prospective customers, the Company shall : Before the customer relation is established, the Company will: Provide clear information explaining the key features of our services and products that customers are interested in; Provide information on any type of product and service offered, that may suit the customer's needs; Provide the customers about the various means through which products and services are offered [for example, on the Internet, over the phone, in branches and so on] and explain them how to find out more about them; Tell the customer what information is needed from him / her /their to prove his / her identity and address, for complying with legal, regulatory and internal policy requirements In case of customers of the Company, the company shall : give the customer more information on the key features of the products, including applicable interest rates / fees and charges; Provide extra information on his / her / their rights and responsibilities especially regarding availing of nomination facility offered on all deposit accounts; Automatically register the customer's name under a 'Do Not Call ' Service. The Company will not inform / extend through telephone calls / SMSs / emails any new product / service unless and until the customer inform the Company in writing his / her consent to avail of this information / service. Interest Rates : At the time of availing of a loan the Company shall disclose the following information to the customers regarding the interest rates: the interest rates which apply to his/her/their accounts, both deposit and loan. when interest is paid on his/her/their deposits, or charged on his / her loan accounts. how interest is applied to his / her/their account and method of calculation of interest. The loan agreement shall contain sufficient information about interest, charges, etc. Changes in the Interest Rates When the Company change the interest rates on its products, it will update the information on its telephone help-line and its website. Fees and Charges The Company will make available any changes applicable to products and services applicable at the time a customers sign up for the same. The customers can also find out about charges by : Asking staff at the branch where they have their account. Phoning help-line or Looking on Company’s website. The Company will inform its customer the charge for any other service or products before it provide the service or product, and at any time they ask. The Company will inform the customers about the penalties liable to be levied in case of non-observance/violation of any of the terms and conditions governing the products/services chosen by them. Changes in fees and charges : If the Company increases any of these charges or introduce a new charge, it will be notified in advance, before the revised charges are levied / become due. Terms and Conditions When a customer accepts a product or service for the first time, the Company will provide the customer with the Rules and Regulations that are relevant to the product/service. All Terms and conditions will be fair and set the customer’s rights and responsibility clerkly and in plain languages. The Company will use legal or technical language only where necessary. Changes to Terms and Conditions At the time of availing of a loan, the Company will inform/notify the customer about the changes to terms and conditions, if any. Normally, changes (other than interest rates) will be made with prospective effect giving notice of at least one month. If the changes are to the disadvantage of the customers, he/she/their may close the account at any time within two months from the date of the notice without having to pay any extra charges or interest for doing this and setting the entire dues payable simultaneously. Advertising , Marketing and Sales The Company shall ensures that : All advertising and marketing done by the Company will be truthful and no tolerance can be provided for misleading information or poor descriptions of the services. The Company shall take maximum steps to ensure that all advertising and promotional material is clear, and not misleading. In any advertising or in any media and promotional literature that draws attention to a service or product and includes a reference to an interest rate, the Company shall also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request. The Company shall from time to time, communicate to its customers various features of their products availed by them. Information about their other products or promotional offers in respect of products / services, may be conveyed to customers only if he/ she / they has given his / her / their consent to receive such information / service either by mail or by registering for the same on the website or on customer service number. The Company shall prescribe a code of conduct for their Direct Selling Agencies (DSAs), if nay, whose services are availed to market products / services which amongst other matters require them to identify themselves when they approach the customer for selling products personally or through phone. In the event of receipt of any complaint from the customer that Company representative / courier or DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint. Privacy and Confidentiality All personal information of customers shall be treated as private and confidential [even when the customers are no longer customers]. The Company will not reveal transaction details of the customers’ accounts, to a third party, including entities in the group, other than in the following exceptional cases when the Company are allowed to do: If the Company have to give the information by law If there is a duty towards the public to reveal the information. If the Company’s interests require to give the information [for example, to prevent fraud) but the Company will not use this as a reason for giving information about its customer or its customers accounts [including name and address] to anyone else, including other companies in the group, for marketing purposes. If the company customer ask it to reveal the information, or if company has the customers’ permission to provide such information to group/ associate /entities or other companies when they have tie-up arrangements for providing other financial service products Credit Reference Agencies When a customer opens an account, the Company shall inform him / her/ when the Company may pass his / her their account details to credit reference agencies and the checks the Company may make with them. The company may give information to credit reference agencies about the debts the customer owes them if: The customer has fallen behind with his / her payments; The amount owed is not in dispute; and The customer has not made proposals that the Company is are satisfied with, for repaying his / her debt, following Company's formal demand In these cases, the Company shall intimate the customer in writing that the Company plan to give information about the debts the customer owes them to credit reference agencies. At the same time, the Company shall explain to the customer the role of credit reference agencies and the effect the information they provide can have on customer's ability to get credit. the Company may give credit reference agencies other information about the customer's account if the customer has given them his / her permission to do so. A copy of the information given to the credit reference agencies shall be provided by the Company to a customer, if so demanded. Collection of Dues The Company shall inform customers about the repayment schedule well in advance. However, if the customer does not adhere to repayment schedule, the Company must inform the customers by sending notice or by making personal visits and / or repossession of security if any. The Company’s collection policy should be built on courtesy, fair treatment and persuasion. The staff appointed for the collection of the dues must follow the guidelines given below: DThe collection staff must identify himself / herself and display the authority letter issued by the Company and upon request, display his / her identity card Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation. Customer’s privacy should be respected. Interaction with the customer shall be in a civil manner The Company’s representatives shall contact the customers between 0700 hrs and 1900 hrs, unless the special circumstances of the customer's business or occupation require otherwise. Customer’s request to avoid calls at a particular time or at a particular place shall be honored as far as possible. Time and number of calls and contents of conversation would be documented. All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner. During visits to customer's place for dues collection, decency and decorum should be maintained. Inappropriate occasions such as bereavement in the family or such other calamitous occasions should be avoided for making calls/visits to collect dues. Complaints and Grievances Internal Procedures If at any stage, if a customer is not satisfied with the service given to him/her, he/she can to contact the Company. The customers’ first point of contact for redressal of any complaint will be our Branch Heads who are fully capable of redressing customer grievances satisfactorily. If he/she does not receive a reply within 7 working days from the Branch Head, or if he/she is not satisfied with the reply received him/her, the customer can write to our Corporate Office, to the COO & Company Secretary at Sahara Housingfina Corporation Limited, Sahara India Sadan, 2A Shakespeare Sarani, Kolkata – 700 071. Web-site:www.saharahousingfina.com. If the customer does not hear from the Company within next 10 working days, or if he/she is satisfied with the response, customer may write to the by the National Housing Bank to look into the provision of satisfactory service, if so desired by them. Know your Customer (KYC) Guidelines Before the customer relation is established , the company will Ask the customer to submit or provide necessary documents or proofs to do so; Obtain only such information to meet with HFC's KYC, Anti Money Laundering policy or any other statutory requirements. In case any additional information is asked for, it will be sought separately and the Company will specify the objective of obtaining such additional information. Providing such information will be voluntary; Provide the account opening forms and other material to the customer. The same shall contain details of essential information required to be furnished and documents to be produced for verification and/or for record for meeting the KYC requirements; Explain the procedural formalities and provide necessary clarifications sought by the customer while opening a deposit account Deposit Accounts The Company is barred for accepting Public Deposits Loans to Customers The Company must assess whether the customer will be able to repay it before the Company gives loan to the customers. The Company may pass his / her account details to credit reference agencies after informing the customers about the same. The Company may give information to credit reference agencies about the personal debts the customer owes them if: The customer has fallen behind with his / her payments; The amount owed is not in dispute; and In these cases, the Company shall intimate the customer in writing that they plan to give information about the debts the customer owes them to credit reference agencies. At the same time, the Company shall explain to the customer the role of credit reference agencies and the effect the information they provide can have on customer's ability to get credit. The Company may give credit reference agencies other information about the customer's account if the customer has given them his / her permission to do so. A copy of the information given to the credit reference agencies shall be provided by the Company to a customer, if so demanded. the Company cannot provide the loan to the customer, it shall communicate in writing the reason(s) for rejection. If the customer wants the Company to accept a guarantee or other security from someone for his liabilities, the Company may ask the customer for his permission to give confidential information about his finances to the person giving the guarantee or other security, or to their legal adviser. The Company may encourage the customers to take independent legal advice to make sure that they understand their commitment and the possible consequences of their decision The Company must also tell the customers that by giving the guarantee or other security they may become liable instead of, or as well as, him; and tell them what their liability would be. Processing of Loans At the time of sourcing a loan product, the Company shall provide information about the, interest rates applicable, as also the fees/charges, if any, payable for processing, pre-payment options and charges if any and any other matter which affects the interest of the borrower, so that a meaningful comparison with those of other companies can be made and informed decision can be taken by you. The Company should devise a system of giving acknowledgement for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of should also be indicated in the acknowledgement. Normally all particulars required for processing the loan application shall be collected by the Company at the time of application. In case it needs any additional information, the customer should be told that he would be contacted immediately again. The Company shall convey to the customer the loan sanction along with the terms and conditions thereof. Company shall supply authenticated copies of all the loan documents executed by the customer at our Company' cost along with a copy each of all enclosures quoted in the loan document on request if so demanded. Company shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course. Before taking a decision to recall / accelerate payment or performance under the agreement or seeking additional securities, the Company should give notice to borrowers in consonance with the loan agreement. The Company should release all securities immediately on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim Company may have against 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 Company are entitled to retain the securities till the relevant claim is settled /paid Guarantors The Company must inform the following information to the person considering to be a guarantor to a loan, • his/her liability as guarantor; the amount of liability he/she will be committing him/herself to the company; circumstances in which the Company will call on him/her to pay up his/her liability; whether the Company has recourse to his/her other monies in the company if he/she fail to pay up as a guarantor; whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which the Company will notify him/her about this The Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor. General The Company reserves to itself the right to alter/delete/add to these codes at any time without prior individual notice and such alterations /deletion/addition shall be binding on the customers Customers are requested to enquire with the branch/Corporate Office for the latest interest rates or any other changes to these codes.