Policy Name: Policy Guidelines on Fair Practices Code
Review: Annual
Owner / Contact: Compliance Department
Approver: Board of Directors
The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Financial Companies (NBFCs) vide Circular no. DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 01, 2015, laying down standards for fair business and corporate practices while dealing with their customers.
This Fair Practices Code is aimed to provide to all the stakeholders of ISHIKA CAPITAL PRIVATE LIMITED (the “Company”), especially its customers, an effective overview of the practices that it will follow while extending its financial products and services. The Company shall also make appropriate modifications in the FPC from time to time to conform to the standards that may be prescribed by RBI.
The purpose of this FPC is to ensure that the Company’s business is conducted in accordance with the prevailing statutory and regulatory requirements, with due focus on efficiency, customer-orientation and corporate governance principles. This Code ensures fair lending practices across all operations including marketing, loan origination, processing, servicing, and collections, without discrimination.
a. “Board” means Board of Directors of the Company.
b. “Company” means ISHIKA CAPITAL PRIVATE LIMITED.
c. “Directors” means individual Director or Directors on the Board of the Company.
d. “FPC” means Fair Practices Code.
The Company commits to fair and reasonable treatment of its borrowers, complying with laws, providing clear product information, resolving errors, and ensuring transparency, integrity, and ethical dealings across all customer touchpoints.
A. Loan Applications and Their Processing: The company will use standardized loan forms with transparent terms and timelines. Applications are acknowledged, processed within 90 days, and borrowers are informed of documentation requirements.
B. Loan Appraisal and Terms/Conditions: Borrowers will be notified in writing of sanctioned amounts, terms, interest rates, and penalties. A copy of the agreement will be provided.
C. Loan Disbursement and Changes in Terms and Conditions: Borrowers will be notified in advance of any changes to terms. All changes will be prospective.
D. Post-disbursement Supervision/Monitoring: The company will release securities after dues are cleared. It will give prior notice for recall or acceleration of payments.
E. Other General Provisions: The company shall not interfere in borrower affairs. It will permit transfer of accounts and ensure ethical recovery practices.
F. Confidentiality of Information: Personal data will remain confidential except when required by law or consented by the customer.
G. Language and Mode of Communicating Fair Practice Code: The policy shall be available in a vernacular language or as understood by the borrower.
H. Regulation of Rate of Interest: Interest rate models will be disclosed. Changes will be available online or in newspapers. Rates will be expressed in annualized form.
The Board shall ensure there is a robust grievance redressal mechanism. This ensures disputes related to loans or customer service are resolved efficiently and escalated where necessary.
The company shall display contact information of the Grievance Redressal Officer and RBI Regional Office prominently. A detailed grievance mechanism is laid down in the separate Grievance Redressal Policy.
In the event of unforeseen Force Majeure circumstances, some provisions of this FPC may be affected, and the Company may not be able to fulfill all objectives as intended under normal conditions.
The Board of Directors shall annually review the compliance and effectiveness of this Fair Practices Code and make appropriate updates in line with RBI guidelines or operational experience.