METAFIN CLEANTECH FINANCE PRIVATE LIMITED

FAIR PRACTICE CODE

Introduction

This Fair Practices Code (this “Code”) is aimed to provide the customers with an eﬀective overview of practices, which will be followed by Metaﬁn Cleantech Finance Private Limited (the “Company”) in respect of the ﬁnancial facilities and services oﬀered by the Company to its customers. The Code will facilitate the customers to make informed decisions in respect of the ﬁnancial facilities and services to be availed by them. It will apply to any loan that the Company may sanction and disburse.

1.Objective of the Code

This Code has been developed to:

Promote good, fair and trustworthy practices by seeking minimum standards in dealing with the customers.
Increase transparency to give the customers a better understanding of what they can reasonably expect of the services.
Encourage market forces, through coemption, to achieve higher operating standards; and
Promote a fair and cordial relationship between the customers and the Company.

2.Our Key Commitments and Declarations

We shall act eﬃciently, fairly and diligently in dealings with all our customers by:

Monitoring the commitments and standards in this Code for the ﬁnancial products and services we oﬀer and the procedures and practices our staﬀ follows.
Ensuring that all the ﬁnancial services meet relevant laws and regulations.
Providing professional, courteous and speedy services; and
Providing accurate and timely disclosure of terms and conditions, costs, rights and liabilities regarding ﬁnancial transactions.

We shall help the customer understand how our ﬁnancial products and services work by:

Giving verbal information about the ﬁnancial schemes in Hindi and/or English and/or the local vernacular language as the borrower understands.
Ensuring that our advertising & promotional literature is clear and is not misleading.
Explaining ﬁnancial implications of the transactions.
Helping the customer to choose the ﬁnancial scheme.

We shall deal quickly and proactively with things that go wrong by:

Correcting mistakes quickly.
Attending to customer complaints quickly.
Telling our customers how to take their complaint forward if the customers are still not satisﬁed with our assistance; and
Reversing any charges that we apply due to our mistake.

3.Non-Discrimination Policy

We will not discriminate between our customers on the basis of gender, race or religion.

4.Applications for loans and their processing

All communications to the borrowers shall be made in a language as understood by the borrower or vernacular language.
Loan application forms issued by the Company shall include necessary information that aﬀects the interest of the borrower so that a meaningful comparison with the terms and conditions oﬀered by other non-banking ﬁnancial companies (“NBFCs”) can be made and the borrower can take an informed decision. The loan application form shall indicate the documents required to be submitted along with the application form.
The Company shall collect all necessary information from the customer only with prior customer consent, and the borrower shall be provided with an option to provide or deny consent for the use of speciﬁc data, restrict disclosure to third parties, retain data retention, or revoke consent.
The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 days from the date of receipt of the completed application form in all respects. The Company will endeavour to keep the customer/applicant informed with regard to the status of his application from time to time. The customer may also contact the Company’s customer service team at the prescribed toll-free number or email ID to obtain an update on the status of the application.
If any additional details/ documents are required, they shall be informed to the borrowers immediately.

5.Loan appraisal and terms/conditions

The Company shall conduct due diligence on the borrower's creditworthiness, which will be an important parameter for making a decision on the application. The assessment would be in line with the Company’s credit policies, norms and procedures.
The Company shall appraise through its partner to understand the customer’s business, household income, and current indebtedness and assess the customer’s loan requirement and repayment capacity.
The borrower would be informed in the vernacular language or a language as understood by the borrower of the amount of loan sanctioned or otherwise. The said communication shall contain the terms and conditions, including the annualised rate of interest and the method of application thereof.
The Company provides borrowers with the ﬂexibility to accept or reject the loan.
The Company shall, wherever applicable, have a built-in repossession clause in the contract/loan agreement so as to have legal enforceability.

6.Disbursement of loans, including changes in terms and conditions

The Company shall frame appropriate internal principles and procedures for determining and ensuring that the interest rates, processing, and other charges are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate, processing and other charges on the loan are in strict adherence to the above-referred internal principles and procedures.

The disbursement will be made immediately upon the borrower's compliance with all the terms and conditions of the loan.

The Company shall give a notice to the borrower in the vernacular language, or a language as understood by the borrower, of any change in the terms and conditions, including the disbursement schedule, interest rates, service charges, pre-payment charges, etc. The Company shall also ensure that changes in interest rates and charges are aﬀected only prospectively.

Any decision to recall/accelerate payment or performance under the loan agreement shall be in consonance with the loan agreement. The Company shall release all securities oﬀered by the borrower on repayment of all dues or on realisation of the outstanding amount of the loan subject to any legitimate right or lien for any other claim the Company may have against the borrower. If such a 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 until all the relevant claim is settled/paid.

7.Guidelines related to recovery of Loans

In the process of loan recovery, the Company shall not resort to undue harassment, such as bothering the borrowers at odd hours or using muscle power to recover loans. The Company shall ensure that its staﬀ is adequately trained to deal with customers appropriately and not rudely.
The Company or its partner shall not engage in any harsh methods towards recovery. Without limiting the general application of the foregoing, the following practices shall be deemed as harsh:
1. Use of threatening or abusive language.
2. Harassing relatives, friends, or co-workers of the borrower
3. Publishing the name of borrowers.
4. Use or threat of use of violence or other similar means to harm the borrower or borrower’s family/ assets/reputation.
5. Misleading the borrower about the extent of the debt or the consequences of nonrepayment.
The Company will call delinquent customers between 0900 hours to 1800 hours unless special circumstances of the borrower’s business require to call them otherwise outside the hours mentioned.
The Company may arrange to enforce security charged to it by the delinquent borrower, if required, with an aim only to recover dues and will not be aimed at whimsical deprivation of the property.
The Company shall ensure that the enforcement process, valuation and implementation of its security are fair and transparent.
In case of receipt of a request from the borrower for transfer of the borrower account, the consent or otherwise i.e., objection of the Company, if any, shall be conveyed within 21 working days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms in consonance with law.
The Company shall not charge foreclosure charges / pre-payment penalties on all ﬂoating rate term loans sanctioned to individual borrowers.

8.Engagement of Recovery Agent

Recovery agents shall mean agencies engaged by the Company to recover dues from its borrowers and the employees of these agencies. The Company shall have a due diligence process for the engagement of recovery agents, which shall, inter alia, cover individuals involved in the recovery process.

The Company shall ensure that the partner engaged by them for recovery carries out veriﬁcation of the antecedents of their employees, including police veriﬁcation and their periodicity. The Company shall provide the details of recovery agents to the borrower while initiating the recovery process, like the name, contact number of the agent and the partner’s name.

9.Complaint Redressal Mechanism

It is the Company’s constant endeavour to put customers’ interests ﬁrst and to provide them with ﬁnancial solutions that are right for them. In keeping with its resolve, the Company looks forward to receiving both positive and negative feedback from customers on its products and services.

The grievances of the customers will be redressed in the following manner:

The customer can register grievances through the email ID and number provided by employees or at the branches/head oﬃce and at any other place where the business of the Company is transacted.
After examining the matter, the Company will endeavour to send the customer its response expeditiously and instruct the customer on how to escalate the complaint to a higher level if he/she is not satisﬁed with the response.
The customer has to conﬁrm whether or not the grievance has been resolved to his / her satisfaction. The grievance will be deemed to be closed if the customer does not respond via the toll-free number or email.
At all branches/head oﬃce / any other place where the business of the Company is transacted, notice will be put up informing the customers about the Customer Care Executives, Escalation Mechanism and the Grievance Redressal Oﬃcer (including the name and contact details responsible for logging and resolving the grievances) who the Customer can approach for resolution of complaints against the Company.
The Company shall also request feedback on the services rendered from the customer. This can be done through direct contact by staﬀ or through speciﬁc customer satisfaction surveys that may be conducted from time to time.
A periodical review of the Fair Practices Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by the Company at regular intervals in a manner as prescribed by the board from time to time.

11.Language and mode of communicating this Code

The Company shall endeavour to translate this Code into any vernacular or other language as the borrowers understand.

12.Policy for determining Interest Rates, Processing and Other Charges

To ensure that customers are not charged excessive interest rates and charges on loans by the Company, the board of directors of the Company shall adopt an interest rate model that takes into account relevant factors such as cost of funds, margin, and risk premium to determine interest rates, processing and other charges.

13.General

The Company shall not interfere in the aﬀairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement unless information not earlier disclosed by the borrower has come to the notice of the Company. The Company shall abide by this Code, following the spirit of this Code and in the manner it may apply to its business. Further, the company will endeavor the following to be followed:

The terms of the loan sanctioned shall be conveyed to the borrower in the vernacular language in writing, and the borrower’s acceptance of such terms must be kept on the Company’s records;
A copy of the loan agreement along copy of all enclosures thereof will be furnished to the borrowers at the time of sanction/disbursement of the loan.
The penalty for non-compliance with the loan contract shall be treated as ‘penal charges’ and should be mentioned in bold in the agreement, and there shall be no capitalisation of penal charges.
No additional component to the rate of interest shall be introduced other than in the manner mentioned in the loan contract.
The quantum of penal charges shall be reasonable and not discriminatory within a particular loan/product category.
Penal charges sanctioned to individual borrowers shall not be higher than those charged to non-individual borrowers in the same category of loan.
Quantum and reason for penal charges shall be clearly disclosed to customers in loan agreement, MITC, KFS and be displayed on the Company’s website;
Penal charges, and reason thereof, shall be communicated to borrowers whenever reminders for non-compliance are sent;
A copy of the Fair Practices Code shall be put up on the website of the Company;
The rate of interest, approach for gradations of risk, and the rationale for charging different rates of interest to different categories of borrowers will be disclosed in the application form, sanction letter, the Company’s website or relevant newspapers;
The Company shall not discriminate in extending products and facilities to physically / visually challenged applicants on grounds of disability, and provided all possible assistance to such persons;
The requirements for the release of movable/immovable property documents on repayment/settlement of personal loans shall be included in the policy;
A KFS shall be provided to prospective borrowers, written in a language understood by borrowers, which shall include the APR and the amortisation schedule of the loan over the loan tenor, and subsequently an acknowledgement shall be received of the same (under the RBI Circular on Key Facts Statement (KFS) for Loans & Advances dated 15 April 2024);

The Code is subject to subject to revision as and when applicable.

14.Policy Review and Updates

The implementation of this Code shall be monitored and reviewed periodically by the board of the Company.