Fair Practice Code
This has reference to RBI Circular No. 2012-13/416/DNBS. CC. PD No. 320 /03.10.01/2012-13 dated 18th
February, 2013, wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices
Code for NBFCs to implement the same.
Objectives
- Greater transparency
enabling customers to understand the products and for taking informed decisions.
- Building customer
confidence in the company.
- Ensuring fair practices
while dealing with customers.
Applications for loans and their processing.
- All communications to the
borrower shall be in the vernacular language or a language as understood by the borrower.
- The Loan application
forms shall include necessary information which affects the interest of the borrower, so that a
meaningful comparison with the terms and conditions offered by other NBFCs can be made and
informed decision can be taken by the borrower. The loan application form shall indicate the
documents required to be submitted along with the application form.
- The rate of interest and the approach for gradation of risk and rationale for charging different
rate of interest to different categories of borrowers shall be disclosed to the borrowers in the
application form and communicated to him in the sanction letter.
- The Company shall devise a system of giving acknowledgement for receipt of all loan applications
indicating the time frame within which loan applications will be disposed off.
- The application form will clearly state the information to be provided by the customer to
fulfill the KYC norms and to comply with legal and regulatory requirements.
Loan appraisal and terms / conditions.
- The Company shall convey
in writing to the borrower by means of sanction letter or otherwise, the amount of loan
sanctioned along with the terms and conditions including annualised rate of interest and method
of application thereof and keeps the acceptance of these terms and conditions by the borrower on
its records.
- Company shall mention the
penal interest charged for late repayment in bold in the loan agreement.
- A copy of the loan
agreement preferably in the vernacular language as understood by the borrower along with a copy
each of all enclosures quoted in the loan agreement shall be furnished to all the borrowers at
the time of sanction/ disbursement of loans.
Disbursement of loans including changes in terms and conditions.
- The terms and conditions
of the loan shall be accepted by the borrower before disbursement of the loan amount. The
Company shall give notice to the borrower of any change in the terms and conditions including
disbursement schedule, interest rates, service charges, prepayment charges etc. The Company
shall also ensure that changes in interest rates and charges are effected only prospectively. A
suitable condition in this regard shall be incorporated in the loan agreement.
- Decision to recall/
accelerate payment or performance under the agreement shall be in consonance with the loan
agreement
- The Company shall release
all securities 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 the Company may have against the
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 the
Company is entitled to retain the securities till the relevant claim is settled or paid.
General
- The Company shall refrain
from interference 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 by the
borrower, has come to the notice of the lender).
- In case of receipt of
request from the borrower for transfer of borrower account, the consent or otherwise i.e.
objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of
request. Such transfer shall be as per transparent contractual terms in consonance with law.
- In the case of a recovery
of loan, the Company shall not resort to undue harassment viz. persistently bothering the
borrowers at odd hours, use of muscle power for recovery of loans, etc.
- The company shall state
the repossession clause in the loan agreement with the borrower which shall contain provisions
regarding notice period before taking possession, circumstances under which the notice period
can be waived, procedure for taking possession of the security, provision regarding final
chance to be given to the borrower for repayment of the loan before auction/sale of security,
procedure for giving repossession to the borrower and the procedure for sale/auction of the
property. A copy of such terms and conditions shall be made available to the borrowers.
- All loans are sanctioned
at the sole discretion of the company.
- As complaints from
customers also include rude behavior from the staff of the companies, we ensure that the staff
are adequately trained to deal with the customers in an appropriate manner.
Responsibility of Board of Directors
- The Board has laid down an
appropriate grievance redressal mechanism which ensures that all disputes are heard and
disposed of atleast at the next higher level.
- The Board reviews periodically
the compliance of the Fair Practices Code and the functioning of the grievances redressal
mechanism at various levels of management.
- A consolidated report of such
reviews is submitted to the Board at regular intervals.
Grievance Redressal Policy
Preface
- The Reserve Bank of India has
mandated NBFCs for the constitution of an effective grievance redressal mechanism within
the organization. Such a mechanism shall ensure that all disputes arising out of the
decisions of the lending institutions are heard and disposed of atleast at
the next higher level.
Objective of the Policy
- The Grievance Redressal Policy
was formed with an aim to ensure customer satisfaction and speedy disposal of customer
grievances effectively and efficiently. The reason for the shortfall in service will be
scrutinized and activities will be engineered to ensure high quality of service in the
future.
Principles of the Policy
- We have drafted the Grievance
Redressal policy keeping our customer's needs in mind. The prescribed document is available
at all branches. The policy is laid down based on the following principles:
a. Fair treatment
to the customers at all times.
b. Customer complaints to be dealt with complete courteousy
and priority.
c. complete information provided to the customers to escalate their complaints,
to a higher hierarchal authority.
d. Company will treat all complaints efficiently and fairly.
e.
Employees work in good faith and in the interest of the customers
Handling Customer Complaints
- At GEO VPL Finance Private Limited,
we have a customer service committee that is headed by the company's general manager and
other senior functional heads. This ensures that every complaint is given due importance and
solved at the earliest. The functions of the committee are as follows:
a. To screen each
feedback and complaint received from various quarters and ensure quick redressal and
implementation of the valuable comments.
b.To ensure that the regulatory instructions
regarding customer service are followed consistently and constantly with the involvement of
the cluster heads, the branch heads and the functional heads.
c. To offer advice and aid for
complaints referred by the heads.
Grievances Resolution Mechanism in Geo VPL Finance
- The Branch Managers appointed
are responsible for the any resolution of complaint/ grievances received by the branch. There is
a standard 7 days resolution policy for such customer complaints. However, in extreme
cases, the managers report a complaint to the nodal officer. Once escalated, the nodal
officer will examine the same and offer a solution at the earliest. The time frame for the
entire process will not exceed 21 days.
- Step 1: Please visit the
nearest Branch of the company and submit your complaint/ grievance and get your complaint
logged in the "Complaint & Grievance Register", maintained at the branches (during the
working hours from 9:30 a.m to 5:30 p.m) or in the drop box placed at the branches.
- Step 2: If you are still not
satisfied with the resolution you receive, or you don't receive any response within 7
working days you can write, mail, or call to the Grievance Redressal Officer of the
company:
Mr. George Shan,
General Manager Geo VPL Finance Private Limited
Opposite St. Sebastian Church
Thoppumpady,
Cochin-682005
E-mail Id:gmadmin@geovpl.com
Mob: +918589988502
Nodal officer
- Name and contact details of the
nodal officer of the company as per Ombudsman Scheme for Non- Banking Financial Companies,
2018:
Name: Mr. George Shan
Designation: General Manager Admin
Telephone: 0484-4210424
Mobile: 8589988502
Email: gmadmin@geovpl.com
Regulation of excessive interest charged by applicable NBFC
- The board adopted an interest
rate model after taking into account relevant factors such as cost of funds, margin and risk
premium and thus determine the rate of interest to be charged for loans and advances. The rate of
interest, the approach for gradations of risk and rationale for charging different rate of
interest to different categories of customers shall be disclosed to the customer
in the application form and communicated explicitly in the sanction letter. The rates of
interest and the approach for gradation of risks shall also be made available on the
website of the company. The information published in the website or otherwise published
shall be updated whenever there is a change in the rate of interest. The rate of interest
must be annualized rate so that the customer is aware of the exact rates that would be
charged to the account.
Complaints about excessive interest charged by applicable NBFCs
- The Board has laid out
appropriate internal principles and procedures in determining interest rates, processing and
other charges.
Repossession of vehicles financed by applicable NBFCs
- The company has a built in
re-possession clause in the loan agreement with the borrower which must be legally
enforceable. In order to ensure transparency, the terms and conditions of the loan agreement
contains provisions regarding notice period before taking possession, circumstances under
which the notice period can be waived, the procedure for taking possession of the security,
a provision regarding final chance to be given to the borrower for repayment of loan before
the sale/ auction of the property, the procedure for giving repossession to the borrower
and the procedure for sale/ auction of the property. A copy of such terms and conditions
shall be made available to the borrower. The Company shall furnish a copy of the loan
agreement along with all enclosures to all the borrowers at the time of sanction/
disbursement of loans.
Lending against collateral of gold jewellery
While lending to individuals
against collateral of gold jewellery, the company can adopt the following in addition to the
general guidelines as above:
-
Board approved policy for lending against gold.
-
Loan agreement shall also disclose details regarding auction procedure.
-
Obtaining PAN card from the borrower for transactions above 2 lakhs.
-
Not issuing misleading advertisements.
Vigil Mechanism / Whistle Blower Policy
Preface:
- Section 177 of the Companies Act,
2013 and Rule 7 of the Companies (Meetings of Board and its Powers) Rules, 2014 requires every
listed company/ companies which accept deposits from the public and companies which have
borrowed money from banks and public financial institutions in excess of 50 crore rupees to
establish a vigil mechanism for the directors and employees to report genuine concerns or
grievances about unethical behavior, actual or suspected fraud or violation of the Company's
Code of Conduct or Ethics Policy.
SCOPE OF THE POLICY
- In compliance of the above
requirements, GEO VPL FINANCE PRIVATE LIMITED, has established a Vigil (Whistle Blower)
Mechanism and formulated a policy in order to provide a framework for responsible and secure
whistle blowing/ vigil mechanism involving misuse or abuse of authority, breach of company’s code
of conduct, breach of terms and conditions of employment and rules thereof, gross or willful
negligence causing substantial and specific danger to health, safety and environment,
manipulation of company data/ records, intentional financial irregularities, including fraud, or
suspected fraud, pilfering of confidential/ propriety information, deliberate violation of
law/ regulation, gross wastage/ misappropriation of company funds/ assets, deliberate violation of
law/ regulation, wastage/ misappropriation of company funds/ assets, breach of employee code of
conduct or rules.
POLICY OBJECTIVES
The mechanism provides for adequate safeguards against victimization of employees and Directors to avail
of the mechanism and also provide for direct access to the Chairman of the Audit Committee.
This neither releases employees from their duty of confidentiality in the course of their work nor can
it be used as a route for raising malicious or unfounded allegations about a personal situation.
- It covers malpractices and events
which have taken place/ suspected to have taken place, misuse or abuse of authority, fraud or
suspected fraud, violation of Company rules, manipulations, negligence causing danger to public
health and safety, misappropriation of monies, and other matters or activity on account of which
the interest of the Company is affected and formally reported by whistle blowers concerning its
employees.
- The Company is committed to
developing a culture where it is safe for all employees to raise concerns
about any poor or unacceptable practice and any event of misconduct.
- The Company is committed to adhere
to the highest standards of ethical, moral and legal conduct of
business operations.
- To maintain these standards, the
Company encourages its employees who have concerns about suspected
misconduct to come forward and express these concerns without fear of punishment or unfair
treatment.
- A Vigil (Whistle Blower) mechanism
provides a channel to the employees and Directors to report to the
management concerns about unethical behavior, actual or suspected fraud or violation of the
Codes of
conduct or policy.
- The mechanism provides for adequate
safeguards against victimization of employees and Directors to avail of the mechanism and also
provide for direct access to the Chairman of the Audit Committee.
- This neither releases employees from
their duty of confidentiality in the course of their work nor can it be used as a route for
raising malicious or unfounded allegations about a personal situation.
DEFINITIONS
- “Protected Disclosure” means a
written communication of a concern made in good faith, which discloses or demonstrates
information that may evidence an unethical or improper activity under the title “SCOPE OF THE
POLICY” with respect to the Company. It should be factual and not speculative and should contain
as much specific information as possible to allow for proper assessment of the nature and extent
of the concern.
- “Subject” means a person or group of
persons against or in relation to whom a Protected Disclosure is made or evidence gathered
during the course of an investigation.
- “Vigilance Officer” is the Chairman
of the Audit Committee nominated/ appointed to receive Protected Disclosures from whistle
blowers, maintaining records thereof, placing the same before the Audit Committee for its
disposal and informing the whistle blower the result thereof.
- “Whistle Blower” is a Director or an
employee who makes a Protected Disclosure under this Policy and also referred in this policy as
complainant.
Î
ELIGIBILITY
- All Directors and Employees of the
Company are eligible to make Protected Disclosures under the Policy in relation to matters
concerning the Company.
PROCEDURE
- All Protected Disclosures should be
reported in writing by the complainant as soon as possible, not later than 30 days after the
Whistle Blower becomes aware of the same and should either be typed or written in a legible
handwriting in English/Vernacular language.
- The Protected Disclosure should be
submitted under a covering letter signed by the complainant in a closed and secured envelope and
should be superscribed as “Protected Disclosure under the Whistle Blower policy” or sent through
email with the subject “Protected Disclosure under the Whistle Blower policy”. If the complaint
is not superscribed and closed as mentioned above, the Protected Disclosure will be dealt with
as if a normal disclosure. All Protected Disclosures should be addressed to the Chairman of the
Audit Committee.
- The contact detail of the Chairman
of audit committee is as under:-
Pradeesh Lawrence
Geo Farm House
Binny Company Road
Palluruthy
Ernakulam - 682006
Email id: pradeeshlawrence@geovpl.com
Ph: 0484 4210400
- All Protected Disclosures under this
policy will be recorded and thoroughly investigated. The Chairman of the Audit Committee will
carry out an investigation either himself or by involving any other officer of the Company/
Committee constituted for the same/ an outside agency.
- The investigation by itself would
not tantamount to an accusation and is to be treated as a neutral fact finding process. The
investigation shall be completed normally within 90 days of the receipt of the protected
disclosure and is extendable if deemed necessary.
DECISION AND REPORTING
- If an investigation leads to a
conclusion that an improper or unethical act has been committed, the Chairman of the Audit
Committee shall recommend to the Board of Directors of the Company to take such disciplinary or
corrective action as it may deem fit.
- Any disciplinary or corrective
action initiated against the subject as a result of the findings of an investigation pursuant to
this policy shall adhere to the applicable personnel or staff conduct and disciplinary
procedures.
- A quarterly report with number of
complaints received under the policy and their outcome shall be placed before the Audit
Committee and the Board. A complainant who makes false allegations of unethical & improper
practices or about alleged wrongful conduct of the subject shall be subject to appropriate
disciplinary action in accordance with the rules, procedures and policies of the Company.
CONFIDENTIALITY
- The Complainant, Chairman of the
Audit Committee , Members of Audit Committee, the subject and everybody involved in the process
shall, maintain confidentiality of all matters under this policy, discuss only to the extent or
with those persons as required under this policy for completing the process of investigations
and keep the papers in safe custody.
PROTECTION
- No unfair treatment will be meted
out to a Whistle Blower by virtue of his/ her having reported a Protected Disclosure under this
policy. Adequate safeguards against victimisation of complainants shall be provided. The Company
will take steps to minimize difficulties, which the Whistle Blower may experience as a result of
making the Protected Disclosure. The identity of the Whistle Blower shall be kept confidential
to the extent possible and permitted under law. Any other employee assisting in the said
investigation shall also be protected to the same extent as the Whistle Blower.
DISQUALIFICATIONS
- While it will be ensured that
genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as
herein set out, any abuse of this protection will warrant disciplinary action. Protection under
this Policy would not mean protection from disciplinary action arising out of false or bogus
allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide
intention. Whistle Blowers, who make any Protected Disclosures, which have been subsequently
found to be mala fide, frivolous or malicious, shall be liable to be prosecuted.
COMMUNICATION
- Directors and Employees shall be
informed of the Policy by publishing it on the website of the Company.
RETENTION OF DOCUMENTS
- All Protected Disclosures in writing
or documented along with the results of Investigation relating thereto, shall be retained by the
Company for a period of 5 years or such other period as specified by any other law in
force, whichever is more.
AMENDMENT
- The Company reserves its right to
amend or modify the policy in whole or in part, at any time without assigning any reason
whatsoever.
Fair Practice Code- Microfinance
Fair practices code adopted for Micro Finance division of Geo VPL Finance Private Limited as per
CircularNo. DNBS. CC. PD. No. 320/03.10.01/2012-13 dated February 18, 2013 approved by the board of
directors of the company in its meeting held on 29.03.2019.
Geo VPL Finance Private Limited (“Company”) is registered as Non-deposit taking, Non Systemically
Important NBFC with RBI and commits itself for implementing and adopting fair practices in all its
activities and transactions with the stakeholders. The Company has adopted a code of conduct to promote
good and fair practices by setting minimum standards in dealing with the clients and increasing
transparency so that the clients have a better understanding of the services provided. The Company
commits itself for implementing and adopting these fair practices in all its activities and transactions
with its members while functioning as an NBFC.
Methodology of extending Microfinance loans:
- The methodology of loan delivery is
initiated by an orientation meeting organized in the villages where women are briefed on the
loan disbursements and procedures. Women are then asked to form into groups of five members of
their choice. The Company does not influence the selection of group members, the decision
regarding the income generation activity and the loan amount they intend to take. After
formation of the Group, the concerned Field Executive collects the ID proof and address proof
for processing of client details to the Credit Bureau enquiry. After getting the Credit Bureau
results, training is conducted on procedures, methodology, calculation of interest rates etc.
Once the initial group training is complete and enrolled into a group through a Group
Recognition test conducted by the Credit Officer, the groups meet weekly/monthly in their
villages at a place and time convenient to them. The members undertake the responsibility of
approving, disbursing and repaying the loans.. The field executive of the Company facilitates
the loan utilisation, repayments and credit discipline of the groups.
1. General