The objective of the policy:

1. To frame a mechanism for the resolution of a customer grievance, if any, in accordance with the Reserve Bank of India’s (“RBI”) ‘Integrated Ombudsman Scheme for Non-Banking Financial Companies, 2021’ as per RBI Notification dated November 12, 2021 (Ref. CEPD. PRD. No.S873/13.01.001/2021-22).
2. To help address customer concerns and disputes in a neutral and independent manner and enable orderly and timely resolution of such concerns and disputes.
3. To promote a fair system that is independent as well as easily approachable for customers.
4. To provide an alternative medium for customers to raise their issues with regard to Company’s products and services before considering more complex and time-consuming legal procedures like approaching a forum/authority/court for settlement of their disputes.
5. To assign a trained and experienced professional who can directly report to the Audit Committee and Board of Directors of Si Creva (“Board”) and raise the customers’ concerns to the Audit Committee and Board, if required, and provide adequate resolution on the same in a timely manner.

Grounds for filing a complaint by a customer under the Integrated Ombudsman Scheme:

In case of a grievance, the customer may prefer a written complaint with the Head Office of Si Creva, in respect of the following, provided the matter is not referred to any court or forum:

1. non-presentation or inordinate delay in the presentation of post-dated cheques provided by the customer;
2. failure to convey in writing, the amount of loan sanctioned along with terms and conditions including annualized rate of interest and method of application thereof;
3. failure or refusal to provide sanction letter/ terms and conditions of sanction in the vernacular language or a language as understood by the borrower;
4. failure or refusal to provide adequate notice on proposed changes being made in sanction terms and conditions in vernacular language as understood by the borrower;
5. levying of charges without adequate prior notice to the borrower/ customer;
6. non-observance of directions issued by RBI relating to the Non-Banking Financial Companies and the Integrated Ombudsman Scheme for NBFCs, 2021; and
7. non-adherence to any of the other provisions of RBI Guidelines on Fair Practices Code for Non-Banking Financial Companies.

Who can file a complaint?

Any customer who has a loan account (open or closed account) with Si Creva can file a complaint, either by herself/himself or through her/his authorised representative (other than an Advocate).

The above includes customers who have applied for a loan with Si Creva through any of the mediums available for the loan application as follows:

1. Online Channels (Kissht/PaywithRing/Mobile App/Kissht /PaywithRing Website).
2. Retail Merchants who have a valid legal agreement with Si Creva for providing loans through Kissht/PaywithRing/Si Creva.
3. Franchisee Partners who have a valid legal agreement with Si Creva for providing loans through Kissht /PaywithRing/Si Creva.
4. Third-party services/companies who have a valid legal agreement with Si Creva for referring loan applications through Kissht /PaywithRing/Si Creva.
5. Any other new medium that Si Creva may choose to introduce going forward (by means of a valid & legal agreement) for sourcing or servicing of loans to end customers.

When can the customer file a complaint with the Ombudsman?

1. Customer needs to make a written representation i.e., lodge a written complaint (written on paper and submitted to Si Creva Head Office OR Email written to Si Creva @ info@sicrevacapital.com ) either by herself/himself or through her/his authorised representative in the format enclosed as Annex II.
2. If a reply is not received from Si Creva within 30 (thirty) days, OR, if the customer remains dissatisfied with the reply, then the customer may file a complaint with Ombudsman online through the Complaint Management System portal https://cms.rbi.org.in (not later than 1 (one) year after the reply from Si Creva), provided that customer has not approached any forum/court/authority.

Grounds for non-maintainability of a complaint:

1. No complaint for deficiency in service shall lie under the policy in matters involving:

   • commercial judgment/decision of the Company;
   • a dispute between a vendor and Company relating to an outsourcing contract;
   • a grievance not addressed to the Ombudsman directly;
   • general grievances against Management or Executives of the Company;
   • a dispute in which action is initiated by the Company in compliance with the orders of a statutory or law-enforcing authority;
   • a service not within the regulatory purview of the Reserve Bank;
   • a dispute between Regulated Entities;
   • a dispute involving the employee-employer relationship of the Company;
   • a dispute for which a remedy has been provided in Section 18 of the Credit Information Companies (Regulation) Act, 2005; and
   • a dispute pertaining to customers of the Company not included under the policy.

2. A complaint under the policy shall not lie unless:

   • the complainant had, before making a complaint under the policy, made a written complaint to the Company concerned and –

   • the complaint was rejected wholly or partly by the Company, and the complainant is not satisfied with the reply; or the complainant had not received any reply within 30 days after the Company received the complaint; and
   • the complaint is made to the Ombudsman within one year after the complainant has received the reply from the Company to the complaint or, where no reply is received, within one year and 30 days from the date of the complaint.

   • the complaint is not in respect of the same cause of action which is already-

     • pending before an Ombudsman or settled or dealt with on merits, by an Ombudsman, whether or not received from the same complainant or along with one or more complainants, or one or more of the parties concerned;
     • pending before any Court, Tribunal or Arbitrator or any other Forum or Authority; or, settled or dealt with on merits, by any Court, Tribunal or Arbitrator or any other Forum or Authority, whether or not received from the same complainant or along with one or more of the complainants/parties concerned;
   • the complaint is not abusive or frivolous or vexatious in nature;
   • the complaint to the Company was made before the expiry of the period of limitation prescribed under the Limitation Act, 1963, for such claims;
   • the complainant provides complete information as specified in clause 11 of the Scheme;

   • the complaint is lodged by the complainant personally or through an authorised representative other than an advocate unless the advocate is the aggrieved person.

     Explanation 1: For the purposes of sub-clause (2)(a), ‘written complaint’ shall include complaints made through other modes where proof of having made a complaint can be produced by the complainant.

     Explanation 2: For the purposes of sub-clause (2)(b)(ii), a complaint in respect of the same cause of action does not include criminal proceedings pending or decided before a Court or Tribunal or any police investigation initiated in a criminal offence.

How does the Ombudsman take decisions?

1. The proceedings before Ombudsman are summary in nature.
2. The Ombudsman will promote the settlement of the complaint by mutual agreement between the complainant and Si Creva through conciliation or mediation.
3. If the above is not reached, then the Ombudsman can pass an Award/Order either allowing or rejecting the complaint along with reasons for passing such an Award/Order.
4. If a customer is not satisfied with the decision of the Ombudsman, he/she can file an appeal before the Executive Director- in charge of the Consumer Education and Protection Department of the Reserve Bank of India (RBI) against the Award/Order within 30 (thirty) days of the date of receipt of communication of Award/Order or Rejection of complaint.
5. Si Creva may go in for an appeal against the Award within 30 (thirty) days from the date of receipt of the letter of Award.
6. An ‘Award’ includes a direction for specific performance by the NBFC concerned. It may or may not include a direction to pay compensation for the loss, if any, suffered by the complainant. The ombudsman will not have the power to pass an Award directing payment of an amount that is more than the actual loss suffered by the complainant or INR 20,00,000 (Indian Rupees Twenty Lakhs), whichever is lower. In addition, the Ombudsman may also award compensation not exceeding INR 1,00,000 (Indian Rupees One Lakh) to the complainant, taking into account the loss of time, expenses incurred, harassment, and mental anguish suffered by the complainant.

Note:

1. The Ombudsman may reject a complaint at any stage.
2. The Ombudsman Scheme is an Alternate Dispute Resolution Mechanism.
3. The Customer is at liberty to approach any other court/forum/authority for the redressal of their disputes at any stage.

How will the award be implemented?

1. Si Creva to implement the settlement arrived with the complainant or the Award passed by the Ombudsman when it becomes final and send a report in this regard to the RBI Ombudsman within 15 (fifteen) days of the award becoming final.

Annex – I

The details of the Nodal Officers of Si Creva who can be approached by the customer as per the Integrated Ombudsman Scheme for Non-Banking Finance Companies, 2021, and the details of the RBI Ombudsman are given below:

Name and Contact details of the Nodal Officer of Si Creva to be approached by the customer

If the grievance is not redressed by Grievance Redressal Officer, within a period of 30 (thirty) days, then the Complaints can be filed, in the prescribed format (available on the RBI website – https://cms.rbi.org.in), or sent in physical mode to

The ‘Centralised Receipt and Processing Centre
Reserve Bank of India,
4th Floor, Sector 17,
Chandigarh – 160017
RBI Contact Centre – 14448

A copy of the Scheme is available on the RBI website and on the CMS portal (https://cms.rbi.org.in).

Please refer to www.rbi.org.in & https://sicrevacapital.com/ for further details of the Scheme.

For Si Creva Capital Services Private Limited

Krishnan Vishwanathan

CEO and Managing Director

Approved by the Board of Directors at its meeting dated March 04, 2024.

Annex – II

FORM OF COMPLAINT (TO BE LODGED) WITH THE OMBUDSMAN

(TO BE FILLED UP BY THE COMPLAINANT)

All the fields are mandatory except wherever indicated otherwise

To

The Ombudsman

Madam/Sir,

Sub: Complaint against ……………………(place of the Company’s branch or office) of (name of the Company)

Details of the complaint:

1. Name of the complainant …………………………………………………………….
2. Age (years)………….
3. Gender……..……….

4. Full address of the complainant ………………………………………………………
   ……………………………………………………………………………………………….
   ……………………………………………………………………………………………….

   Pin Code ………………..

   Phone No. (if available)…………….

   Mobile Number. .……………………

   E-mail (if available) …………………….

5. Complaint against (Name and full address of the branch or office of the Company)
   ………………………….………………………………………………………………
   ………………………………………………………………………………………………….
   Pin Code …………………….

6. Nature of relationship/account number (if any) with the Company
   ……………………………………………………………….…………………………………

7. Transaction date and details, if available
   ……………………………………………………………….…………………………………

   • Date of complaint already made by the complainant to the Company (Please enclose a copy of the complaint)
     ……………………………………………………………….…………………………………

   • Whether any reminder was sent by the complainant? Yes/No (Please enclose a copy of the reminder)
     ……………………………………………………………….…………………………………

8. Please tick the relevant box (Yes/No)

   Whether your complaint:

   (i) is sub-judice/under arbitration*? Yes No (ii) is made through an advocate, except when the advocate is the aggrieved party? Yes No (iii) has already been dealt with or is under process on the same ground with the Ombudsman? Yes No (iv) is in the nature of general complaint/s against Management or Executives of the Company? Yes No (v) is on account of a dispute between Regulated Entities? Yes No (vi) involves employer-employee relationship? Yes No

   Note: *Complaint is sub-judice/under arbitration if the complaint in respect of the same cause of action is already pending/dealt with on merits by any Court, Tribunal or Arbitrator or any other Authority, whether individually or jointly.

9. Subject matter of the complaint
   ………………………………………………………………………………………………….

10. Details of the complaint:
    (If space is not sufficient, please enclose a separate sheet)
    …………………………………………………………………………………………………
    …………………………………………………………………………………………………
    …………………………………………………………………………………………………
    …………………………………………………………………………………………………
    …………………………………………………………………………………………………

11. Whether any reply has been received from the Company within a period of 30 days of receipt of the complaint by it? Yes/No
    (if yes, please enclose a copy of the reply)

12. Relief sought from the Ombudsman
    …………………………………………………………………………………………………
    …………………………………………………………………………………………………
    (Please enclose a copy of documentary proof, if any, in support of your claim)

13. Nature and extent of monetary loss, if any, claimed by the complainant by way of compensation (please refer to clauses 15 (4) & 15 (5) of the Scheme)
    Rs.………………………………………………………………………………………………
    …………………………………………………………………………………….…………….

14. List of documents enclosed:

Declaration

• I/We, the complainant/s herein declare that:

  • the information furnished above is true and correct; and
  • I/We have not concealed or misrepresented any fact stated above, and in the documents submitted herewith.
• The complaint is filed before the expiry of a period of one year reckoned in accordance with the provisions of clause 10 (2) of the Scheme.

Yours faithfully

(Signature of the Complainant/Authorised Representative)

AUTHORISATION

If the complainant wants to authorise a representative to appear and make submission on her/his behalf before the Ombudsman, the following declaration should be submitted:

I/We …………….. hereby nominate Shri/Smt as my/our authorised representative whose contact details are as below:

Full Address …………………………………………………………………………………..
………………………………………………………………………………………………….
………………………………………………………………………………………………….

Pin Code ……………..……………..
Phone No:……………….…………..
Mobile Number. .……………………
E-mail ………………………..………

(Signature of the Complainant)