INTRODUCTION:

Si Creva Capital Services Private Limited is a private limited company, incorporated under the provisions of the Companies Act, 2013, having Corporate Identification Number CIN: U65923MH2015PTC266425 (“Si Creva” / “Company”). Si Creva is a Middle Layer Non-Deposit taking Non-Banking Financial Company, , registered and regulated by the Reserve Bank of India (“RBI”) bearing Registration no. N-13.02129.

The Company is in the business of providing unsecured personal and business loans via partnerships with Kissht and PayWithRing and also secured offering Loan against property.

PURPOSE AND OBJECTIVE:

• Chapter VII of RBI Master Direction on Scale Based Regulations, 2023 (SBR Master Direction) lays down regulations pertaining to Fair Practices Code to be adhered by Non-Banking Financial Companies (NBFCs). As a result, Si Creva has framed, in conformity with RBI guidelines, this comprehensive Fair Practices Code (“Code”), which is covered in this document and duly approved by the Board of Directors.
• This Code aims to inter alia provide the customers effective overview of practices, which will be followed by Si Creva in respect of the financial facilities and services offered by Si Creva to its customers. Further, the Code will also facilitate customers to take an informed decision in respect of the financial facilities and services to be availed by them and will apply to any loan that Si Creva may sanction and disburse.

• This Code has been developed to:

  • promote good, fair, and trustworthy practices by setting minimum standards in dealings with the customers.
  • increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services.
  • Promote a fair and cordial relationship between the customers and Si Creva.
  • fostering customer confidence in Si Creva.
  • To ensure compliance with legal norms in matters relating to recovery of advances.
  • To strengthen mechanisms for redressal of customer grievances.

KEY COMMITMENTS AND DECLARATIONS:

Si Creva makes the following key commitments to its customers:

• Si Creva would act fairly and reasonably in all their dealings with customers by:

  • Meeting the commitments and standards enumerated in this Code, for the
    financial products and services, Si Creva offers, and the procedures and practices its staff follow.
  • making sure that their products and services meet relevant laws and regulations.
  • carrying out dealings with customers on ethical principles of integrity and transparency.
  • providing professional, courteous, and speedy services.
  • providing accurate and timely disclosure of terms and conditions; costs, rights, and liabilities as regards financial transactions.

• Si Creva shall help the customer understand how our financial products and services work by –

  • giving verbal information about the financial schemes and all other communications in Hindi and/or English and/or local vernacular language / the language as understood by the borrower based on customer request;
  • ensuring that our advertising and promotional literature is clear and not misleading;
  • explaining the financial implications of the transactions;
  • helping the customer to choose the financial scheme.

• Si Creva shall deal quickly and proactively in case of customer feedbacks / concerns:

  • Attending to customer complaints quickly as per the Customer Grievance Redressal Mechanism laid out by the Company;
  • Telling our customers how to take their complaints forward if the customers are still not satisfied with our assistance.
• Si Creva shall publicize this Code, display it on Si Creva’s website in English and all possible major vernacular languages/ the language as understood by the borrower; and make copies available for the customer on request in vernacular languages.

LOAN APPLICATIONS AND PROCESSING

• All communications to the borrowers shall be made in English or the vernacular language upon request received from the customer or a language as understood by the borrower.
• Si Creva will offer credit to eligible qualified applicants who express their need to borrow through their loan request letter or loan application forms.
• The loan application form shall indicate the documents required to be submitted along with the application form. The Company shall collect all necessary documents to comply with Know Your Customer (‘KYC’) norms of RBI.
• Loan application forms issued by Si Creva shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the borrower.
• Si Creva shall devise a system of giving an acknowledgement for receipt of all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 (thirty) days, from the date of receipt of the application form complete in all respects. In any case, the Customer will be kept informed by the salesperson with regard to the status of his application from time to time. The Customer may also contact Si Creva’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, the same shall be intimated to the borrowers immediately.

NON-DISCRIMINATION POLICY

• Si Creva is strictly prohibited from engaging in any form of discrimination towards Si Creva’s existing as well as potential customers on the basis of gender, race, or religion.
• Si Creva shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability.

LOAN APPRAISAL AND TERMS/CONDITIONS

• Si Creva shall conduct due diligence on the creditworthiness of the borrower, which will be an important parameter for taking the decision on the application. The assessment would be in line with Si Creva’s credit policies, norms, and procedures in respect thereof.
• The company, upon approval of the loan, shall convey the applicant by means of a sanction letter or otherwise, the amount of loan sanctioned, the terms and conditions including the annualized rate of interest and the method of application thereof. Si Creva shall keep on record the acceptance of these terms and conditions by the borrower.
• To ensure that the Customers are not charged excessive interest rate, the Company shall adopt interest rate model considering relevant factors such as cost of funds, processing fee and charges for other expenses, margin & risk premium, etc., duly approved by Board. The quantum and reason for penal charges shall have to be clearly disclosed by REs to the customers upfront in the loan agreement and Most Important Terms & Conditions (MITC) / Key Fact Statement (KFS), as applicable. The Company shall also draw a reference in the sanction letter to the interest rate model policy placed on its website and communicate the rate of interest explicitly in the sanction letter, as mentioned in para 9.2 hereinbelow.
• Si Creva shall furnish a copy of the loan agreement as understood by the borrowers along with all the enclosures quoted in the loan documents to the borrowers at the time of sanction/ disbursement of loans.
• Si Creva shall ensure that the Loan Documents and all enclosures furnished to all borrowers contain the terms and conditions and the rate of interest. Further, Si Creva shall mention the penalties to be charged for late payment in bold fonts in the Loan Documents.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS / CONDITIONS

• The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower.

• Si Creva shall give notice to the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. Any changes to the above charges shall also be updated on the Company website. Si Creva shall also ensure that changes in interest rates are affected only prospectively and not introduce any additional component to the rate of interest on the existing loans.

  It is abundantly clarified that penal charges will be levied only in case of non-compliance with material terms and conditions of the loan agreement. To expressly clarify, the penal charges shall be levied where funds are involved i. e. the event of delay in repayment of Equated Monthly Instalments (‘EMIs’) or the entire loan as per terms of the loan agreement. Further, penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ and will not be added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.

POST-DISBURSEMENT SUPERVISION

• Any decision to recall/accelerate payment or performance under the Loan Documents shall be in consonance with the Loan Documents.
• 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 Si Creva may have against the borrowers, as part of the agreement. If such 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 Si Creva is entitled to retain the securities until the relevant claim is settled / paid.

RATE OF INTEREST ,PROCESSING FEE AND OTHER CHARGES:

• Si Creva shall frame appropriate internal principles and procedures for determining the interest rates and processing and other charges, if any, and also ensure that they are not excessive. Si Creva shall, at the time of disbursal, ensure that the interest rate and other charges, if any, on loans and advances are in strict adherence to the above-referred policy, internal principles and procedures.
• To ensure that the Customers are not charged excessive interest rate and charges including penal charges on loans and advances, the Board has adopted a Policy for determining Interest Rates, Processing and Other Charges named as “Interest Rate Policy” and the same has been put up on Si Creva’s website
• Si Creva shall disclose the rate of interest to the borrower in the Loan Agreement/ Key Fact Statement and explicitly communicate it in the sanction letter.
• The broad range for rates of interest and the approach for gradation of risks i.e. forming part of Interest Rate Policy shall also be made available on the Si Creva’s website. The information published on the website or otherwise published would be updated whenever there is a change in the rates of interest.
• The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be communicated explicitly in the sanction letter.
• The rate of interest would be annualized percentage rates (APR) so that the borrower is aware of the exact rates that would be charged to the account.
• An interest rate model taking into account the cost of funds, margin, and risk premium for determining the rate of interest to be charged for loans and advances shall be laid down by Si Creva.
• The rate of interest to be charged depends much upon the gradation of the risk of the borrower viz; the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower, etc.
• The processing fee, if any, shall be determined on the basis of the quantum of work involved in credit appraisal, the volume of documentation, and other expenses involved in the transaction. The rate of interest is subject to change, as the situation warrants due to market compulsions and changes in regulatory norms and is subject to the discretion of the management on a case-to-case basis.
• Foreclosure charges shall be applied as per the regulatory directions issued from time to time.

RELEASE OF IMMOVABLE PROPERTY DOCUMENTS

• Si Creva will release all original property documents and remove charges within 30 days after full loan repayment or settlement.
• Borrowers shall have the option to collect their original documents from the branch where the loan was serviced or any other Si Creva office.
• Loan sanction letters issued after the effective date must specify the timeline and location for document return.
• Si Creva will have a clear procedure for returning documents to legal heirs in case of the borrower’s demise, which will be published on their website alongside other customer information.
• Compensation in for delay in release of movable/immovable property documents shall be extended to the borrower as per the applicable regulations in case of occurrence of the same.
• In case of loss of such documents, the Company shall assist the borrowers in obtaining duplicate/certified copies of the same and bear all the additional costs in this regard.

LOANS SOURCED OVER DIGITAL LENDING PLATFORMS

Wherever digital lending platforms are engaged as agents to source borrowers and/ or to recover dues, the Company shall follow the instructions as under:

• To display on the Company’s website the names of the Digital Lending Platforms engaged as agents.
• Digital Lending Platforms engaged as agents shall be directed to disclose upfront to the customer, the Company’s name on whose behalf they are interacting with the customer.
• Immediately after sanction but before execution of the loan agreement, the sanction communication shall be issued to the borrower on the letter head of the Company
• A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement shall be furnished to all borrowers at the time of sanction/ disbursement of loans.
• Effective oversight and monitoring shall be ensured over the digital lending platforms engaged by the Company.
• Adequate efforts shall be made towards creation of awareness about the grievance redressal mechanism.
• The Company has adopted a sperate policy on Digital Lending to outline detailed guidelines for the purpose of loans issued over digital lending platforms.

GENERAL

• Si Creva shall not interfere in the affairs of the borrower except for the purposes provided in the loan agreement executed with the borrower unless new information not earlier disclosed by the borrower has come to the notice of Si Creva.
• Si Creva shall keep borrower personal information strictly confidential.

• Si Creva shall disclose borrower information to third party only under the following conditions:

  • Customer/ Borrower has been informed about such disclosure and provided his consent
  • It is legally or Regulatory required to do so.
• In the matter of recovery of loans, Si Creva shall follow the prescribed measures as per laid down guidelines and existing provisions and would operate within the legal framework and in compliance with the applicable laws and regulations and code of conduct for the recovery agents as approved by the Board. Further, Si Creva would not resort to undue harassment like bothering the borrowers at odd hours/ use muscle power for recovery of loans.
• Si Creva shall ensure that the entire process of enforcing its security, valuation and realization thereof is fair and transparent.
• Si Creva shall ensure that the staff is adequately trained to deal with the customers in an appropriate manner.
• Si Creva’s collection policy is built on courtesy and fair treatment. Si Creva believes in customer confidence and long-term relationship. Si Creva’s staff or any person authorized to represent us in collection of dues will identify himself/herself and interact with our customers in a courteous manner.
• Si Creva shall provide customers all the information regarding dues and shall give sufficient notice for payment of dues. All customers will be contacted ordinarily at the location which is stated in the loan application journey or at the place of their choice (to the extent possible), 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.
• Si Creva shall respect privacy of the customer and all interactions shall be in a civil manner. All assistance shall be provided to the customers to resolve differences or disputes in a mutually acceptable manner, if any, regarding the dues.
• In case of receipt of a request from the borrower for transfer of the borrower account, the objection, if any, by Si Creva, shall be conveyed within 21 (twenty-one) days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms in consonance with law.
• On receipt of a request from a customer to update the credit information by making an appropriate correction, addition or otherwise, and on such request the Company shall take steps to update the credit information within thirty (30) days after being requested to do so.

CUSTOMER GRIEVANCE REDRESSAL MECHANISM

The customer grievance redressal mechanism (“Grievance Redressal Policy”) has been adopted by the Board, pursuant to recommendation of the Audit Committee and has been put up for display at all the borrowers’ touch points/head office and the website of Si Creva, informing the customers about the escalation mechanism and the Grievance Redressal Officer (including the name and contact details).

INTEGRATED OMBUDSMAN SCHEME:

The Integrated Ombudsman Scheme, 2021 is effective from November 12, 2021. The Scheme adopts ‘One Nation One Ombudsman’ approach by making the RBI Ombudsman mechanism jurisdiction neutral. It integrates the existing three Ombudsman schemes of RBI namely, (i) the Banking Ombudsman Scheme, 2006; (ii) the Ombudsman Scheme for Non-Banking Financial Companies, 2018; and (iii) the Ombudsman Scheme for Digital Transactions, 2019. Relevant details of the scheme are published in the Company’s website.

REVIEW OF POLICY:

A periodical review (at least annually) of this Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by Si Creva and a consolidated report of such reviews shall be submitted to the Audit Committee at regular intervals. The same shall be reviewed and approved by the Board of Directors of the Company.

OMNIBUS CLAUSE:

All extant & future master circular/directions/guidance/guidance notes issued by RBI from time to time would be the directing force and will super cede the contents of this Code.

Si Creva shall abide by this Code following the spirit of the Code and in the manner as may be applicable to its business.