Grievance Redressal Policy

Serving customer needs satisfactorily remains the top corporate priority for Finagle Financial Services Private Limited (henceforth referred to as “Company” or “FINAGLE”). Customer service is of extreme importance for the sustained business growth and we are committed to ensure that our customers receive exemplary service across different touch points.

An important component of this priority is designing an efficient mechanism to address customer queries and issues.

This policy on Grievance Redressal of Finagle Financial Services Private Limited is set out as a structured grievance redressal framework to enable the customers of the company to file their complaints or grievances or give their feedback and suggestions in relation to their dealings with the Company and to address the same promptly, by following the provisions as laid down herein.

This Grievance Redressal Policy describes the various channels available to the Company's customers for lodging their complaints, obtaining the right redressal solutions from the concerned department and the Company's mechanism for responding to customers within the stipulated time period.

The company has laid down this Grievance Redressal Policy (the “Policy”) on the basis of guidelines on Fair Practice Code and master direction of Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 dated September 1, 2016 issued by Reserve Bank of India (RBI) and Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023. Since RBI would issue circulars and instructions on an ongoing basis, any subsequent amendment to the above circular would update in the Policy accordingly.

The company believes in providing prompt and efficient services to its customers irrespective of the fact whether the customer is new or existing one. With this objective of serving its customers in a time-bound and efficient manner, the Company has drafted this Grievance Redressal Mechanism. The Company's policy on grievance redressal has been formulated taking into account the following objectives:

To treat each customer fairly and equally at all times.

To deal with any complaints raised by customers with courtesy and without undue delay.

To handle the grievances of pensioners, physically challenged and senior citizens on priority basis.

To inform all customers about the various avenues/channels to escalate their complaints/grievances within the organization and their rights to alternative remedy, if they are not fully satisfied with the response of the company to their complaints.

To deal with all the complaints efficiently and fairly to protect the reputation and business.

To ensure that the Company's employees work in good faith and without prejudice in the best interest of the customers.

In order to make the Company's redressal mechanism more meaningful and effective, a proper structure shall be implemented to ensure that the redressal sought is fair and within the given framework of rules and regulations of the Company.

The customer shall have the right to register his/her complaint if he/she is not satisfied with the services provided by the company or any other agencies associated with the company.

Our constant efforts to ensure utmost client satisfaction will ensure that the redressal sought is just and fair and is within the given framework of rules and regulations.

The grievance redressal processes contained in this Policy are applicable to all employees (permanent as well as contractual) and offices of the Company and to all activities where there is an interaction with prospective or existing customers.

A “Customer” is a person or entity that has availed a loan facility from the Company.

A “Complaint” is an expression of dissatisfaction or resentment either in the form of a representation or an allegation made in writing or through an approved electronic channel containing a grievance alleging deficiency in the following areas:

Services, products, policies, and procedures of the Company;

Employee behavior towards the customers of the Company; and

Confidentiality and protection of the personal (including sensitive personal information) and financial information of the Company's customers.

The Company is committed to its objective of ensuring the highest levels of customer satisfaction and has, therefore, set out the following guidelines to be followed for redressal of each complaint by its customers.

To act fairly and reasonably in all dealings with its customers by ensuring that:

All products and services meet relevant laws and regulations, as applicable from time to time;

Customer dealings are honest and transparent; and

The process and procedures of the Company are in the best interest of its customers.

To assist customers in selecting financial products and services by:

Providing relevant information in English and/or a local language of choice;

Explaining the financial implications of any product and service; and

Allowing the customer to choose the one that meets his/her needs.

To make every attempt to ensure that the customers have a trouble-free experience while dealing with the Company and its employees.

In case of errors of commissions and/or omissions, the Company will deal with the same on priority by:

Correcting mistakes;

Addressing customer complaints;

Guiding the customer on the escalation process in case of any dissatisfaction; and

Consider reversing any charges including interest applied to a customer's account due to an error or oversight by the Company.

Customer can file/register complaint(s) on the following grounds mentioned under clause 8 of Ombudsman Scheme for NBFCs, 2018, in writing containing the nature of grievance/deficiency, inter alia, with regard to:

Failure to convey in writing, the amount of loan sanctioned along with terms and conditions including annualised rate of interest and method of application thereof;

Failure or refusal to provide sanction letter/ terms and conditions of sanction in vernacular language or a language as understood by the borrower;

Failure or refusal to provide adequate notice on proposed changes being made in sanctioned terms and conditions in vernacular language as understood by the borrower;

Failure or inordinate delay in releasing the securities documents to the borrower on repayment of all dues; levying of charges without adequate prior notice to the borrower/ customer; failure to provide legally enforceable built-in repossession clause in the contract/ loan agreement;

Non-observance of directions issued by Reserve Bank to the non-banking financial companies;

Non-adherence to any of the other provisions of Reserve Bank Guidelines on Fair Practices Code for Non-Banking Financial Companies.

The Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard which ensures that all disputes arising out of the decisions of the Company's functionaries are heard and disposed of at the next higher level.

The Board of Directors shall also periodically review the compliance of the Fair Practices Code and the functioning of the grievance redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board at periodic intervals.

In line with the captioned process, the Company follows a Two (2) tier approach for redressal of customer grievances, as detailed below:

The timeframe for addressing and resolving a complaint shall differ on a case-to-case basis, and depend upon the type and complexity of the grievance. The timelines for redressal of different kinds of complaints under this Policy are as follows:

General cases (other than the cases mentioned below). These include customer complaints pertaining to business practices, lending decisions, credit management, recovery and complaints relating to updating/altering credit information, etc.: 7 working days of receipt of complaint.

Fraud cases, legal cases and cases which require retrieval of old records and documents: 30 working days of receipt of complaint.

CIBIL-related cases: 07-21 working days of receipt of complaint.

EMI related issue cases: 7 working days from the date of receipt of complaint.

If any complaint needs additional time to reach a resolution, the Company will inform the complainant of the requirement of additional time and the expected timeline for the resolution of the issue.

All customer complaints received by the Company will be duly tracked, consolidated, and recorded, and a complete report will be presented to the Board of Directors on a quarterly basis.

The complaint review Team accumulates all the complaints on a yearly basis and reviews the process, functioning, and effectiveness of the grievance redressal mechanism and presents the report to the Board of Directors and suggests changes, if any, required for making the mechanism more efficient and timely; and on the basis of suggestions and recommendations the Policy will also be reviewed by the Board at the first meeting of the Board of Directors of each financial year.