Harshreejee Finance & Leasing Company Private Limited (HSFLCL)

Date of Board Approval: _______

Website: https://www.hsflcl.com

Approved by: Board of Directors

1. PREAMBLE

In line with Chapter VII of the Master Direction – RBI (NBFC – SBR) Directions, 2023 and other RBI guidelines, HSFLCL has formulated this Fair Practice Code (FPC) to ensure minimum standards for fair, transparent, and responsible lending practices across all business operations, including digital lending.

2. PURPOSE AND APPLICABILITY

• Promote fair, honest, and transparent dealings between Company and customers.
• Ensure clarity and fairness in all loan terms, conditions, and pricing.
• Prevent any form of coercive recovery or unethical conduct.
• Ensure compliance with RBI regulatory directions.
• Provide robust and accessible grievance redressal mechanism.

3. DEFINITIONS

• Board: Board of Directors of HSFLCL.
• Customer/Borrower: Any individual/entity that has applied for or availed a loan from HSFLCL.
• FPC: This Fair Practice Code.
• Internal Ombudsman: Independent authority appointed as per RBI directions.
• Principal Nodal Officer (PNO): Senior officer for grievance redressal under RBI’s Integrated Ombudsman Scheme, 2021.
• APR: Annual Percentage Rate including interest and all other charges.

4. GENERAL PRINCIPLES OF FAIR LENDING

• Conduct lending operations transparently, non-discriminatorily, professionally.
• Provide clear and comprehensive information to customers before, during, and after loan process.
• Communications in English, Hindi, or vernacular understood by borrower.
• Treat customers with dignity, privacy, and confidentiality.
• Avoid unfair or deceptive practices in advertising, marketing, or recovery.

5. LOAN APPLICATION AND PROCESSING

All loan applications shall contain essential info about charges, processing fees, penal charges, prepayment options, and required documentation. Borrowers shall be informed of processing time frames, and rejected applications shall be communicated promptly with reasons.

6. LOAN APPRAISAL AND SANCTION

Credit assessment will follow internal credit & risk policies. Upon approval, borrower receives Sanction Letter containing loan amount, tenure, interest, penal charges, and fees. Acceptance required before disbursement.

7. LOAN DISBURSEMENT AND CHANGES IN TERMS

Loans disbursed as per sanction terms. Changes in interest, charges, or repayment communicated in advance. Full repayment returns all securities/documents promptly.

8. RESPONSIBLE LENDING AND CUSTOMER PROTECTION

• No coercive or abusive recovery practices.
• Recovery agents trained, maintain courteous and lawful behaviour.
• No discrimination based on gender, caste, religion, or disability.
• Borrowers informed about late payment implications and rights.

9. INTEREST RATE POLICY

Interest rates follow Board-approved Interest Rate Policy. Annualized rates and charges disclosed in KFS, sanction letter, loan agreement, and website. No hidden or retrospective charges.

10. PENAL AND PREPAYMENT CHARGES

Penal charges not capitalized as penal interest. Charges reasonable, non-discriminatory, disclosed upfront. No prepayment penalties on personal loans per RBI norms.

11. DIGITAL LENDING FRAMEWORK

Compliance with RBI (Digital Lending) Directions, 2025. Digital lending via website is transparent, secure, and borrower data confidential.

12. RECOVERY OF LOANS

Recovery conducted fairly, lawfully, and non-aggressively. Borrowers not harassed; recovery staff professional and display identification.

13. GRIEVANCE REDRESSAL MECHANISM

Principal Nodal Officer (PNO):
Mr. Tanmay Gupta
Director & Principal Nodal Officer
Email: [Insert official grievance email ID]
Contact: [Insert phone number]
Unresolved complaints may escalate to RBI Ombudsman: https://cms.rbi.org.in

14. OMBUDSMAN AND INTERNAL OMBUDSMAN

Compliance with RBI Integrated Ombudsman Scheme, 2021. Internal Ombudsman appointed as per RBI directions.

15. DISPLAY AND COMMUNICATION OF FPC

FPC available in English & vernacular languages. Displayed on website and shared at all customer touchpoints. Employees trained regularly.

16. BOARD OVERSIGHT AND REVIEW

Board reviews implementation annually. Grievance redressal effectiveness reviewed quarterly by senior management and reported to Board.

17. REGULATORY COMPLIANCE AND AMENDMENTS

Reviewed and amended periodically in line with RBI guidelines or operational changes. Regulatory provisions prevail in case of conflict.

Approved by: Board of Directors, Harshreejee Finance & Leasing Company Private Limited

Date: _________