Fair Practices Code

1.0 Introduction
1.1 RBI has issued guidelines on Fair Practices Code (“FP Code”)applicable to Non-Banking Finance Companies which sets the fair practices standards when dealing with individual customers and to serve as a part of best corporate practice.

1.2 In line with the RBI’s guidelines, our company has proposed to amend the existing FP Code.

2.0 PURPOSE AND OBJECTIVE OF THE POLICY
2.1 It is, and shall be, our Company’s policy to make loan products available to all eligible applicants without discrimination. Our Company’s policy is to treat all the customers consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. We will also communicate our FP Code to our customers by placing it on the company’s website, www.sakthifinance.com.

2.2 The Company shall ensure that charges / fees are appropriately informed to the borrower. Terms and conditions pertaining to the facility will be conveyed to the prospective borrowers. We commit that disputes arising out of lending decisions will be appropriately resolved by a grievance redressal mechanism set up by the Company.

2.3 The Company’s Fair lending practices shall apply across all aspects of our operations including marketing, loan origination, processing, servicing and collection activities.

2.4 The Company’s Board of Directors and the Senior Management Team will be responsible for establishing practices designed to ensure that our Company’s operations reflect its commitment to fair lending.

2.5 The FP Code applies to allthe products and services offered by us(currently offered or which may be introduced at a future date).

3.0 APPLICATIONS FOR LOANS AND THEIR PROCESSING
3.1 Loan applicationformswill include necessary information which affects the interestof the borrower, so that a meaningful comparison with the terms and conditionsoffered by other NBFCs can be made and informed decision can be taken by theborrower. The loan application form will indicate the documents required to besubmitted along with the application form. The loan application form and the sanction letterissued to the customers shall disclose the approach for gradation of risks and rationalefor charging different rates of interest to different categories of borrowers and it shall also be made available on the website of the company. The information shall be updated whenever there is a change.

3.2 The company will devise a system of giving acknowledgement for receipt of all loanapplications. Preferably, the time frame within which loan applications will bedisposed of will also be indicated in the acknowledgement.

3.3 Loan Applicationform willclearly state the information that the company requires tocollect from the customer to fulfill the KYC norms and to comply with legal andregulatory requirements. The Company may request for additional information about thecustomer and his / her family to build a database; but this information is furnished bythe customer only if he / she wishes to do so.

4.0 LOAN APPRAISAL AND SANCTION
4.1 The company will convey in writing to the borrower by means of a sanction letter orotherwise, the amount of loan sanctioned along with the terms and conditions, annualized rate of interest,penal interest, method of application of interest, disbursement schedule, service charges, prepayment charges, rationale for charging different rates of interest, notice period and procedure for repossession and sale or auction of security etc.The Company will obtain acceptance ofthe borrower to the sanction letter and keep it on its record.

4.2 The loan sanction letter and all communications relating to sanction of HP finance facility to the borrower shall be in vernacularlanguage or a language understood by the borrower in addition to its version in English.However, if any question or disputearise with respect to interpretation, then the English version of the relevant document / communication shall prevail. The Company shall furnish a copy of the loan agreement along with a copy each of all enclosures quoted as enclosures to the loan agreement to all the borrowers.

5.0 DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS
5.1 After loan agreements are successfully executed along with the submission of KYC documents by the borrower, the loan shall be disbursed by the Company to the borrower.

5.2 The penal interest to be charged by the company for late repayment of loan shallbe mentioned in bold letters in the loan agreement.

5.3 The company will give notice to the borrower of any change in the terms andconditions including disbursement schedule, interest rates, service charges,prepayment charges etc. The Company will also ensure that change in interest rates andcharges are effected only prospectively. A suitable condition to this effect will beincorporated in the loan agreement.

5.4 Decision to recall / accelerate payment or performance under the agreement willbe in conformity with the loan agreement.

6.0 RECOVERY AND TRANSFER OF LOAN
6.1 In the matter of recovery of loans, the company will not resort to any undueharassment to the borrower.

6.2 In case of receipt of request from the borrower for transfer of borrower’s account,the consent or objection of the company, if any, will be conveyedwithin 21 days from the date of receipt of request for transfer to both transferor and transferee. Such transfer shall be as pertransparent contractual terms in consonance with law.

7.0 REPOSSESSION OF VEHICLES
7.1 The Company will have a re-possession clause in the contract / loan agreement with the borrower which can be legally enforceable. The terms and conditions of the contract / loan agreement shall also contain provisions for the following:

7.1.1 notice period before taking repossession;
7.1.2 circumstances under which the notice period can bewaived;
7.1.3 the procedure for taking possession of the security;
7.1.4 a provision regarding final chance to be given to the borrower for repayment of loan before the sale / auction of the property;
7.1.5 the procedure for giving possession back to the borrower; and
7.1.6 the procedure for sale/auction of the property

7.2 A copy of above terms and conditions shall also be made available to the borrower.

7.3 Incase the Asset is possessed under Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest (“SARFAESI”) Act2002, the company shall display the information on their website in respect of the borrowers whose secured assets have been taken into possession under the Act in the format given below.

Sl No	Branch Name	State	Borrower Name	Guarantor Name (wherever Applicable)	Registered address of the Borrower	Registered address of the Guarantor (wherever applicable)	Outstanding amount (in `)	Asset Classifi- cation	Date of Asset Classifi- cation	Details of Security possessed	Name of the Title holder of security possessed

7.4 The above list shall be updated on a monthly basis.

8.0 SETTLEMENT OF LOAN
8.1 The company will release all securities on receipt of repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for anyother claimcompany may have against borrower. If such right of set off is to beexercised, the borrower will be given notice about itwithin a period of 30 days with full particularsabout the remaining claims and the conditions under which the company is entitled toretain the securities till the relevant claim is settled/paid.The Company shall release all the original movable/immovable property documents, if any, within a period of 30 days after full repayment / settlement of loan account.

8.2 The Company will ensure that “No Objection Certificate” (NOC for cancellation of endorsement) is issued to the Customers, within a period of 30 daysfrom the date of full settlement(Including settlement of all lien in respect of that loan).

9.0 GENERAL
9.1 The company will refrain from interference in the affairs of the borrower exceptfor the purposes provided in the terms and conditions of the loan agreement(unless new information, not earlier disclosed by the borrower, has come to thenotice of the Company).

9.2 The company will train its employees to deal with the customers in an appropriate manner.

10.0 COMPLAINTS, FEEDBACK AND SUGGESTION
10.1 The borrower may report his/her complaint/ grievance in writing to the branch concerned from where he / she availed the loan or applied for the loan. On receipt of such compliant /grievance, the head of the Branch of the Company shall immediately take up the matter for redressal.

10.2 The Customers are requestedto give their feedback, suggestion on the services of the Company to the Nodal Officer.

11.0 GRIEVANCES REDRESSAL MECHANISM
11.1 All disputes arising out of the decisions of branches in relation to the products and services shall be heard and disposed of within 30days from the date of receipt of the complete details in respect of the grievance.

The following ‘Grievances Redressal Mechanism’ has been put in place.

11.2 In case of grievances,the borrower may contact the Grievance RedressalOfficer, as detailed below:

Name of Grievance Redressal Officer:
Dr K Natesan
President

The borrower can also send a written communication to the Company at the following address:

Grievance Redressal Officer (Nodal Officer)
Sakthi Finance Limited
62, DrNanjappa Road
Coimbatore – 641 018
Tamil Nadu, India
Tel: 91 (0422) 2231471-74, 4236200
Email: nodalofficer@sakthifinance.com

11.3 In case the borrower is not satisfied with the decision of the Grievance Redressal Officer of theCompany, he may approach the Officer in Charge of the Regional Office of Department of Non-Banking Supervision of RBI at the address given below:

General Manager
Department of Non-Banking Supervision
Chennai Regional Office
Fort Glacis, RajajiSalai
Chennai – 600 001, India
Tel: +91 (44) 25361490
E-mail: dnbschennai@rbi.org.in

11.4 A consolidated report of periodical review of compliance of fair practices code and functioning of the grievances redressal mechanism at various levels of management may be submitted to the Board by Grievance Redressal Officer at regular intervals or as may be prescribed by the Board.

12.0 COMPLAINTS ABOUT EXCESSIVE INTEREST CHARGED BY NBFCS
12.1 The Company charges interest only as per the terms of the contract. The terms of the contract are clearly mentioned in the sanction letter as well as in the loan agreement and any delay in payment of instalments as per the repayment schedule will attract penal charges as may be specified and agreed between the parties. The penal charges are fixed to act as a deterrent to the borrower against delaying the payment of instalment. The interest and charges are also displayed on the website of the Company.

13.0 CONFIDENTIALITY
13.1 Unless authorized by the customer,the Company will treat all personal information asprivate and confidential.

13.2 Unless authorized by the customer, the Company will not reveal transaction details to anyother entity except in the following exceptional cases:
* If the Companyhas to provide the information by statutory or regulatory laws
* If there is a duty to the public to reveal this information
* If the Company’s interest requires it to provide this information (e.g. fraud prevention) toBanks / Financial Institutions
* The Company will not use this reason for giving information about customers to anyone else for marketing purposes.

14.0 IMPLEMENTATION, EFFECT AND REVIEW
14.1 All steps shall be taken by the Nodal Officer to implement this FPCode at all the offices of the Company. This amendedFPCode shall come into effect from the date of approval of this FP Code by the Board of Directors.

14.2 The Board shall review of the FPCode, compliance of FPCode and the functioning of the Grievance redressal mechanism as and when found necessary.

14.3 The FPCode and the Interest Rate Model will be displayed on the website of the Company,www.sakthifinance.com.

14.4 The FPCodewith a statement about commitment to transparency and fair lending practices shall be displayed in vernacular language or in a language as understood by the borrowersat the offices and branches of the Company.

Date: 27thMarch 2024
Place: Coimbatore