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EDUVANZ FAIR PRACTICES CODE

1.

Background and Objective

Eduvanz Financing Private Limited (the “Company”) registered as Non-Banking Financial Company (NBFC) with Reserve Bank of India (“RBI”) is engaged in the business of providing easy, transparent and speedy loans using innovative technology solutions (“Loan(s)”) to all deserving and needy candidates/applicants (“Customer(s)”) without any discrimination on the basis of race, caste, colour, religion, sex, marital status, age or handicap, to be fair and reasonable in all customer dealings. The Loan is provided to the Customers at low interest rates so that they can easily pursue their dream career.

2.

Eduvanz Financing Private Limited - Fair Practices Code Policy

Pursuant to the revised guidelines on Fair Practices Code (“FPC”) issued by RBI on July 1, 2015 to all NBFCs, the Company, has formulated and implemented the below detailed Fair Practice Code (“Code”). This Code which has been reviewed and approved by the Board of Directors, shall come into effect from November 1, 2018.

The Code applies to all the products and services, provided by the Company across the counter, over the phone, by post, through interactive electronic devices, on the Internet or by any other method (currently offered or introduced at a future date).

The objectives of the Code are:

a.To follow good, fair and transparent business practices by setting minimum reasonable standards;

b.To promote a fair relationship between the customer and Company;

c.To ensure compliance with legal norms in matters relating to recovery of advances;

d.To strengthen mechanisms for redressal of Customer grievances.

3.

Applications for Loans and their Processing

a.

All communications to the Customer shall be in the vernacular language or a language as understood by the Customer, as may be required, or through a counselor who can help the Customer to understand the terms of the Loan and the documents to be executed in relation to the Loan.

b.

Loan application forms issued by the Company shall include necessary information which affects the interest of the Customers so that they can do a meaningful comparison with the terms and conditions offered by other NBFCs and arrive at an informed decision.

c.

The Loan application form shall also indicate the documents required to be submitted along with the application form.

d.

If any additional details/documents are required by the Company for the purpose of processing the Loan, the Customers shall be immediately intimidated by the Company for submission of the same.

e.

The Company shall provide an acknowledgement for receipt of all Loan applications. The Loan applications shall be disposed of within the timelines indicated in the acknowledgement.

4.

Loan Appraisal and Terms/Conditions

a.

The Company shall conduct a due diligence on the credit worthiness of the Customer, which shall be an important parameter for taking decision in relation to processing of any Loan application. The assessment would be in line with the risk-based assessment policies, norms and procedures adopted by the Company which are subject to review taking into account the business exigencies, regulatory and customer sentiments and market practices

b.

Upon approval of any Loan application, the Company shall convey the applicant through an agreement cum sanction letter or otherwise. Such sanction letter shall inter alia indicate the amount of Loan, annualized rate of interest, tenor of the Loan, repayment schedule and other the terms and conditions in relation to the Loan.

c.

The Company shall obtain an acceptance from the Customer of the Loan terms and maintain a record of such acceptance.

d.

The Company shall furnish a copy of the Loan agreement as understood by the Customers along with a copy of all the annexures quoted in the Loan agreement to the Customers.

5.

Disbursement of Loans Including Changes in Terms and Conditions

a.

The Company shall give notice to all its Customers of any change in the terms and conditions of the Loan including but not limited to the disbursement schedule, interest rates, service charges, prepayment charges. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. Any changes to the above charges shall be made available at our branches/offices and also the website of the Company (www.eduvanz.com).

b.

The Company shall set out the penal interest charged for the late payment in bold in the Loan agreement. A suitable provision in this regard shall also be incorporated in the Loan agreement.

c.

Any decision to recall/accelerate payment or performance under the Loan agreement shall be in consonance with the Loan agreement.

d.

All securities pertaining to the Loan would be released on receipt of full and final payment of the Loans, subject to any legitimate right or lien, and set-off for any other claim that the Company may have against the Customers. If such right of set-off is to be exercised, the Customer 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 the relevant claim is settled / paid.

6.

Interest Charged

a.

To ensure that the Customers are not charged excessive interest rate and charges on Loans and advances by the company, the Board of the Company has adopted an Interest Rate Policy for determining interest rates, processing and other charges and the same has been put up on Company’s website www.eduvanz.com.

b.

The Company shall adopt an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, etc.and determine the rate of interest to be charged for Loans and advances.

b.

The rate of interest shall be annualized rate so that the Customer is aware of the exact rates that would be charged to the Loan account.

7.

General

a.

The Company shall not interfere in the affairs of the Customer except for the purposes provided in the Loan agreement unless new information not earlier disclosed by the Customer has come to the notice of the Company.

b.

In the matter of recovery of Loans, the Company shall follow the usual measures as per the laid down guidelines and existing provisions and would operate within the legal framework and in compliance with the applicable laws and regulations.

c.

The Company would not resort to undue harassment, viz., persistently bothering the Customers at odd hours, use of muscle power for recovery of Loans etc. In this regard, the Company has an established code of conduct for debt collection wherein our staff or any person authorized to represent the Company in collection of dues are extensively trained.

d.

Company’s collection policy is built on courtesy, fair treatment and persuasion. We believe in customer confidence and long-term relationship. Company’s staff or any person authorized to represent us in collection of dues or/and security repossession will identify himself/herself and interact with our customers in a courteous manner.

e.

The Company will provide the Customers with all the information regarding dues and will give sufficient notice for payment of dues. All customers will be contacted ordinarily at the place of their choice, in the absence of a specified place at the residence of the Customer and if the Customer is unavailable at the residence, at the Customer's place of business/occupation.

f.

The Company respects privacy of the Customer and all our interactions will be in a civil manner. All assistance will be provided to our Customers to resolve differences or disputes in a mutually acceptable manner, if any, regarding the dues.

g.

In case of receipt of a request from the Customer for transfer of the Loan 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 such request. Such transfer shall be as per transparent contractual terms in accordance with law.

h.

At our branches and offices, we display the name and contact details (Telephone / Mobile number / Email Address) of the Grievance Redressal Officer, regional office of the RBI and Grievance Redressal Mechanism adopted by the Company.

8.

Grievance Redressal Mechanism

Internal Procedure

a.

The Company has established and adopted systems and procedures for receiving, registering and disposing of complaints and grievances in each of its operating branches/offices.

b.

The Board of Directors of the Company have laid down the appropriate Grievance Redressal Mechanism within the organization to resolve complaints and grievances, and would periodically review the compliance of the Code and the functioning of the Grievances Redressal Mechanism at various levels of management.

c.

The Grievance Redressal mechanism will ensure that all disputes arising out of the decisions of the functionaries are heard and disposed of at least at the next higher level.

d.

If the Customer wants to make a complaint, then the Customer would be told where to find details of the Company’s procedure for handling complaints, fairly and quickly. The following details pertaining to complaints would be made available to the Customer:

i.How to file a complaint;

ii.Where a complaint can be made;

iii.When to expect a reply;

iv.Whom to approach for redressal;

iv.What to do if the Customer is not happy about the outcome.

e.

Grievance Redressal Procedure
In case the Customer does not receive a response within the number of days specified below for each level or if the customer is dissatisfied with the output/response received from the Company, the Customer may escalate the complaint to the next level as indicated below:

Level 1

a.

In case of any query/grievance, the Customer may contact the respective branch/office team, telephonically, by email or by visiting Branch office and register their query/complaint/grievance in the complaint register available in the branch.

b.

The Company shall Endeavour to send an acknowledgement to the Customer within 2 (two) working days of the receipt of complaint/query/grievance. The Company shall also strive to provide the Customer with a suitable response/resolution on the complaint/query/grievance within 14 (fourteen) working days.

c.

In case the Customer is not satisfied with the resolution/respond provided by the branch team/s in due course, the Customer may escalate his compliant in the following manner.

Level 2

In case the Customer is not satisfied with the resolution/respond provided by the branch team/s in due course, then such Customer may contact our Customer Response Team, the details whereof are set out below:

Person in charge : Sarmisstha Hebbar
Address: B/202, Times Square Building,
Opp. Mittal Industrial Estate,
Andheri Kurla Road, Andheri East,
Mumbai - 400 059
Email: sarmisstha.hebbar@eduvanz.com
Phone no: 022-4179 1755 / 91 8591455383
(The above number will be in service from 09.30-19.00 on daily basis except on Sunday and public holidays.)

Level 3

In case the Customer is not satisfied with the resolution/respond provided by our Customer Response Team, then the Customer may further contact our Grievance Redressal Officer at the co-ordinates set out below:

Name of the Grievance Redressal Officer: Harshvardhan Khangarot
Address: B/202, Times Square Building,
Opp. Mittal Industrial Estate,
Andheri Kurla Road, Andheri East,
Mumbai - 400 059
Email: harshvardhan.khangarot@eduvanz.com
Phone no: 022-4179 1756 / 91 7039298529
(The above number will be in service from 09.30-19.00 on daily basis except on Sunday and public holidays.)

Level 4

If the compliant/query/grievance is not redressed within a period of 1 (one) month or if the Customer is still not satisfied with the response received from the Grievance Redressal Officer, the complainant/Customer may appeal to the Officer-in-Charge of the Regional office, of the Department of Non-Banking Supervision (DNBS) of the RBI.
DNBS Officer-in-Charge Mumbai Regional Office
The contact details are outlined below:

DNBS Officer-in-Charge Mumbai Regional Office
Address: Mumbai Regional Office, Opposite Mumbai Central Station, Near
Maratha Mandir Cinema, Byculla, Mumbai 400 008.
Email: bomumbai@rbi.org.in
Phone: +91-22-24931214

For the benefit of the Customers, the name and contact details of the Officer-in-Charge of the Regional Office shall be displayed on the website of Eduvanz and the notice board at its branches where business is transacted.

9.

Review

a.

A periodical review of the Code and the functioning of the grievance redressal mechanism at various levels of management would be undertaken by the Company.

b.

The Company shall abide by this Code following the spirit of the Code and in the manner applicable to its business.

c.

The Company shall put the above Code outlined hereinabove on its website, for the information of various stakeholders. The Company would also review and refine the Code, as may be required periodically based on its own experience and/or any updated guidelines issued by the RBI in this regard.

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