FAIR BUSINESS PRACTICE CODE

Introduction

D.S. Integrated Finsec Private Limited (hereinafter referred to as “the Company” or “DSIFPL”) is a Non‑Banking Financial Company (NBFC) holding a valid Certificate of Registration (CoR) with Reserve Bank of India (RBI) vide registration no. B.01.00327 dated 26 June 2000 under RBI classification as NBFC – Base Layer with more than 20 years of experience in finance business.

The Company has put in place this Fair Practices Code (“FPC” or “Code”) in conformity with the Guidelines on Fair Practices Code for NBFCs as contained in Chapter VI of Master Direction – Non‑Banking Financial Company – Non‑Systemically Important Non‑Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016, duly approved by the Board of Directors. The FPC sets out the principles for fair practices, transparency and adequate disclosures while dealing with customers.

This FPC sets minimum fair practice standards for the Company to follow when dealing with customers. It explains how the Company is expected to deal with customers on a day‑to‑day basis. This policy applies to all customers and to all categories of products and services offered by the Company.

A. Applications for Loan & their Processing

• The Company offers various financial product categories like Micro Business Loan and Gold Loan through DSA mode or physical office meet via a web‑based platform.
• The Company shall convey all communications to the borrower in the vernacular language or a language as understood by the borrower.
• Loan application forms will include necessary information which affects the interest of the borrower and will indicate the documents required to be submitted with the application.
• The Company shall provide or send to the prospective borrower an acknowledgement of receipt of a loan application after receipt of complete information as per the standard application format in the mobile application itself. An indicative time frame for disposal of applications shall be mentioned in such acknowledgement.
• Applications complete in all respects shall be processed within a reasonable time frame. In case a proposal is not approved by the Company, the borrower will be intimated accordingly.

B. Loan Appraisal and Terms / Conditions

• The Company will ensure proper assessment of loan applications in line with the Company’s credit policies and procedures.
• The Company shall convey in writing to the borrower, in the vernacular language or a language understood by the borrower, by means of a sanction letter and/or email or via the online platform, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and the method of application thereof, and shall keep the borrower’s acceptance on record.
• The Company shall mention the penal interest charged for late repayment in bold in any of the documents namely loan agreement / transaction documents / sanction letter and/or email communication / mobile application / charges section on the Company & product websites. Information related to interest rates and other charges (late payment or otherwise) will also be available on the website.
• The Company’s digital platform and risk assessment model requires digital acceptance of all terms and conditions of the loan, including digital signing, Aadhaar‑based OTP authentication (if applicable), or clickwrap / clickthrough acceptance on the loan agreement and/or terms and conditions.
• The terms and conditions of the respective financial products of the Company shall be applicable for all borrowers without discrimination.

C. Disbursement of Loans including Changes in Terms and Conditions

• The Company will give notice to the borrower, in the vernacular language or a language understood by the borrower, of any change in terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, etc. Changes in interest rates and charges are effected only prospectively. A suitable condition to this effect is incorporated in the loan agreement.
• Decision to recall / accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
• The borrower shall enter into an agreement with the Company by providing consent via Aadhaar OTP / digital signature / electronic signature, agreeing to all standard and specific terms and conditions before disbursement.
• For Micro Business Loan and Suchit Property Loan, the Company will verify business proof and residence. A Company executive will visit and capture photographs of the residence and business place, followed by tele‑verification of the borrower.
• Subject to the above, the Company may disburse the loan amount to the borrower as deemed fit.

D. General

• The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement or as consented by the customer during onboarding and disbursement on the mobile application / web process (unless new information, not earlier disclosed by the borrower, has come to the Company’s notice).
• In case of a request from the borrower for transfer of the borrowal account, the Company’s consent or objection, if any, will be conveyed within 21 days from receipt of the request. Such transfer shall be as per transparent contractual terms in consonance with law.
• In recovery of loans, the Company will not resort to undue harassment, such as persistently bothering borrowers at odd hours or use of muscle power. To avoid rude behaviour from staff, the Company will ensure trainings are provided on the code of conduct to deal with customers appropriately.
• The Company shall not charge foreclosure charges / pre‑payment penalties on floating‑rate term loans sanctioned to individual borrowers.
• Interest, processing fees and other charges will be levied strictly in accordance with the Company’s loan policy.
• No discrimination in extending loans and other financial products to physically / visually challenged applicants on grounds of disability, subject to eligibility criteria as per the Company’s credit policy.

E. Grievance Redressal Mechanism

• The Company shall lay down an appropriate Grievance Redressal Mechanism within the organization to ensure that disputes arising out of decisions of Company functionaries are heard and disposed of at least at the next higher level.
• The Board of Directors will provide for periodical review of compliance with this Code and the functioning of the Grievance Redressal Mechanism at various levels of management. A consolidated report of such reviews may be submitted to the Board at regular intervals, as prescribed.
• The Company shall guide customers wishing to lodge a complaint and provide information on steps to take if dissatisfied with the outcome.

F. Interest Rate Model and Other Charges

• The Company will 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, the approach for gradation of risk and the rationale for differential rates will be disclosed to the borrower in the application form and communicated explicitly in the sanction letter.
• The rates of interest and the approach for gradation of risks will also be made available on the Company website and updated whenever there is a change.
• Information related to interest rates and other charges (including late payment or otherwise) and the approach to risk will also be available on the website.
• The rate of interest shall be annualised so as to make the borrower aware of the exact rates that would be charged to the account.

G. Review

The Board of Directors reserves the right to review the Fair Practices Code from time to time and carry out necessary changes as and when required.

Regulatory Conformance

The Company will abide by all guidelines, directives, instructions and advices of the Reserve Bank of India as in force from time to time. The content in this document shall be read in conjunction with these guidelines, directives, instructions and advices. The Company will apply better practices so long as such practices do not conflict with or violate RBI regulations.