1.Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) has framed the Customer Service Policy (hereafter referred to as “Customer Service Policy” or “the Policy”) in accordance with the regulatory requirements specified by the Reserve Bank of India (RBI).

2.Objectives of the Policy

The objective of the Customer Service Policy is to ensure all customers are treated fairly and without bias; issues raised by customers are attended and dealt with utmost care and resolved within a reasonable time; customers are made aware of their rights and alternative remedies if they are not satisfied with the response or resolution to their complaint. 

3.Categories of Customer’s Communications

• Query - General inquiries, primarily relating to loans, interest rates, repayment terms, eligibility norms, categories of loans, eligibility criteria, terms of financing / refinancing etc.
• Request – Requests for obtaining any valid services including financing or refinancing support by the customers directly.
• Grievance – A communication by prospective / existing customers that expresses dissatisfaction because of lack of action, inadequate quality of services.
• Complaint – Related to staff misbehaviour, cheating / fraud, false commitments, mis-conduct with the customers.
• Suggestion / Feedback – suggestions / feedback with respect to its operations, policies or practices.

4.Mechanism for complaints

Customer can lodge his / her grievance through any of the following channels:

• Complaint in Person: A customer can lodge a complaint in person during working hours at any of the branches with the designated officer.
• Complaints through post / mail / email/box: Customers can also submit their grievances by post at the following address or through email at customerservice@avantifinance.in by giving full disclosures and details of the complainant and giving specific instances of the cause of complaint.

Addressed to: Head Operations, 3rd Floor Elphinstone Building, Veer Nariman Road, Horniman Circle, Fort, Mumbai 400001. Telephone - 022 62352121

5.Recording and tracking of Complaints

All the complaints received is recorded and tracked for end-to-end resolution in a spreadsheet format. Complaint MIS is published and shared to the management on quarterly basis for quality control.

6.Resolution of Complaints

• Any complaint through e-mail / letters / person shall be acknowledged promptly after receipt, at the corporate office or Regional / Branch Offices as and when set up.
• The Complaints should be registered in the Customer Grievance Register (CGR) maintained electronically and / or physically, and shall include full details of the complainant (name, address and contact details), date of receipt, fact of the complaint, category of complaint etc.
• The company has appointed Mr. Sunil Kumar Tadepalli (sunil.kumar.t@avantifinance.in) authorised official of the company as its Grievance Redressal Officer (‘GRO’). The GRO will take steps to redress the grievances with care and diligence, normally within the period of 21 working days from the date of receipt of the complaints.
• If the complainant is not satisfied with the reply / action / resolution given by Grievance Redressal Officer (GRO) (or equivalent), he / she may directly approach the Chief Executive Officer (CEO), for further action on the same.
• Anonymous complaints will not be entertained.

 6.1 Recovery Process

The staff  shall be trained in proper etiquette for recovery process as elaborated in the Fair Practice Code adopted by the company.

6.2 Internal Machineries to handle Customer complaints / grievance

1. Customer Service contact (CSC): The Customer Service contact (CSC) will be the first point of contact for the customers in most of the cases. CSC will be responsible to receive the complaint of customers by whatever means, i.e. in person, post, mail etc. If the complaints received by Nodal officers it will be forwarded to CSC with related documents / enclosures (if any) for early resolution on the next working day of receipt of the complaint.

CSC will provide an acknowledgment for the complaint received from the customer within 5 working days of the receipt, and also make necessary entries in the Customer Grievance Register (CGR) which shall include but without limitation to, full details of the complainant (name, address, and contact details), date of receipt, fact of the complaint, category of complaint etc.

1. The Company will designate a GRO (or equivalent) at its corporate office. GRO (or equivalent)will have the responsibilities of ensuring early resolution of complaints.

GRO will first examine the nature of the Complaint and initiate necessary action to address the complaint to the satisfaction of the complainant.  He / She will also ensure to record the action initiated or taken in the CGR along with the status of the complaint- resolved / unresolved or escalated to next level, as the case may be.  GRO will circulate the monthly Action Taken Report on all the complaints received, within 7 working days of the next month to the Chief Grievance Redressal Officer (or equivalent) for information / guidance. (Not regulatory , but a good practice).

6.3 Time Frame

1. The Complaints received will be analysed from all possible angles. All efforts will be made to resolve each complaint received generally within the stipulated time as per the following escalation matrix:

Within 10 working days	Customer Service contact (CSC) or Partner engagement manager (or equivalent)
Within 20 working days	Grievance Redressal Officer (GRO) or Head- Partnerships & Alliances (or equivalent)
Within 30 working days	Chief Executive Officer / Board of directors

 

1. There may be some complaints which require deeper analysis from all possible angles which may cause delayed resolution of the complaint. In such cases, the company will try to resolve the grievances at the earliest depending on the nature of the case. Such delay in addressing the complaint beyond the prescribed time limit shall be conveyed to the complainant along with reasons for the same.

If the resolution of the complaint is delayed beyond 30 days of receipt, or the complainant is not satisfied with the reasons of delay conveyed to him / her, he / she may appeal to the Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision (DNBS) of RBI, Mumbai within whose jurisdiction the registered office of the Company is situated and the following message shall be displayed at the branch and on the website of the Company: “If your complaint/dispute is not redressed within a period of 30 days, you may appeal to the officer-in-charge of the Regional Office of DNBS at RBI, at the following address: Officer-in-charge, Reserve Bank of India, Regional Office, DNBS, fourth floor, opp. Mumbai Central Station, Byculla, Mumbai – 400 008”

6.4 Reporting to Board of Directors

Summary of the customer grievance reports along with actions initiated would be reported to the Board at least once in a year. The report shall contain information like, the total no. of complaints received, disposed of and pending, with reasons thereof, which will be placed before the Board for information / guidance.

7.Regulatory References

This policy is framed as per the following regulatory references and in accordance with leading industry practice: RBI circular on Master Direction - Non-Banking Financial Company –Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016.

 

1.Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) has framed the Interest Rate Policy (hereafter referred to as “Interest Rate Policy” or “the Policy”) in accordance with the regulatory requirements specified by the Reserve Bank of India (RBI).

2.Objectives of the Policy

This document aims to establish a framework for determining interest rates, processing charges and other charges. (All charges and rates mentioned herein are exclusive of Goods and Service Tax (GST) or any other applicable tax and the company shall charge and collect such taxes wherever applicable over and above mentioned charges and rates)

3.Methodology for determining an Interest Rate

The guiding principles for determining interest rate are as follows:

• The Board of the company shall adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances. 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 disclosed to the borrower or customer in the electronic application form and communicated explicitly through electronic means.
• The rate of interest to be charged for loans and advances will be in the range of 9% to 24% p.a.
• The rate of interest shall be arrived at after taking into account relevant factors, such as cost of funds, margin and risk premium, including the following.
  • Tenor of the Loan – The rate of interest charged will depend on the term of the loan;
  • Internal and External Costs of Funds – The rate of interest charged will also be determined depending on the rate at which funds necessary to provide loan facilities to customers are sourced by the Company, normally referred to as internal cost of funds. From an external cost of funds perspective, the benchmark interest rate that may be used by the Company could be the 10 year Government of India bond rate or any other generally acceptable benchmark rate as adjusted for the rating spreads available in the markets.
  • Internal Cost Loading – The interest rate charged will also take into account costs of doing business. Factors such as the complexity of the transaction, the size of the transaction and other factors that affect the costs associated with a particular transaction will also be taken into account before arriving at the final rate of interest quoted to a customer.
  • Credit Risk – As a matter of prudence, bad debt provision cost should also be factored into all transactions. This cost is then reflected in the final rate of interest quoted to a customer. The amount of bad debt provision applicable to a particular transaction will depend on the credit strength of the customer.
  • Fixed rate versus Floating rate – The applicable rate of interest shall also be commensurate from the perspective of the fixed versus floating interest rate requirements of the customers.
  • Periodicity of Interest – Interest will be charged for the period as stipulated in the loan agreement, subject to any modifications thereto as may be agreed by and between the Company and the customer electronically.
• The rate of interest is an annualised rate so that the borrower is aware of the exact rates that would be charged to the account.

4.General Provisions 

• Changes in Terms – The Company shall give electronic notice to the borrower in English language with an option to choose a vernacular language as understood by the borrower of any change in the terms and conditions of the loan, including disbursement schedule, interest rates, service charges, prepayment charges etc. Further, any changes in the rate of interest shall be effected only prospectively and the electronic loan agreement shall contain the necessary provisions in this regard. 
• Grace Period - Interest will be payable by the customer / borrower on or before the due date stipulated therefor in the loan agreement entered into by the customer / borrower with the Company. However, the Credit Committee of Executives shall have discretionary power to grant a considered grace period to any customer / borrower. 
• Moratorium - The Company may consider necessary moratorium for payment of interest and repayment of principal amount with proper built in pricing, on a case to case basis.
• Additional Interest and other Charges - Besides the normal interest, the Company levies additional interest for delays in payment of dues by the customer / borrower or additional interest on other facilities etc (annualised interest on the outstanding balance). The Company may charge other financial charges including processing fees, cheque bouncing charges, pre-payment / foreclosure charges, RTGS or such other remittance charges, commitment fees, charges for services like issuance of “no due certificate”, security swap charges etc along with relevant taxes.

The Company shall not charge foreclosure charges / pre-payment penalties on all floating rate term loans sanctioned to individual borrowers.

• Communication of Interest Rate to the Customer – The Company shall convey electronically to the borrower in English language with an option to choose a vernacular language as understood by the borrower, by digital means, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof and shall keep an electronic record of the acceptance of these terms and conditions by the borrower. The loan agreement shall expressly stipulate the penal interest chargeable for late payment / repayment of dues by the borrower, in bold. The apportionment of the equated monthly instalments (“EMI”) amount towards the principal and interest will also be communicated by the Company to the customer / borrower by way of the repayment schedule.
• Waiver of Additional Interest / Financial Charges – Requests by the customer for waiver of additional interest / financial charges would normally not be entertained by the Company and such waiver will be at sole and absolute discretion of the Credit Head or a person of equivalent position, exercised on a case to case basis or any other person that the Board deems fit.
• Annualised Rates - The rate of interest shall be annualised rates so that the borrower is aware of the exact rates that would be charged to the account.
• Pre-Payment - Pre-payment options available to the customer and the penalty payable (only in case of Fixed rate loan) for exercise of such option shall be mutually agreed to on a case to case basis and communicated to the customer.
• Company Website: The rates of interest and the approach for gradation of risks shall be made available on the web-site of the company and literature issued by it. The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.
• Though the primary mode of all operations, processes or procedures set in this Policy are electronic or digital in nature the company may at its discretion decide to use physical/written means for all or any points covered in this Policy.

5. Regulatory Reference

This policy is framed as per the following regulatory references and in accordance with leading industry practice: 

• Master Direction - Non-Banking Financial Company –Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 

Annexure – I 

Interest rate and other charges framework:

Description	Charges
Interest Rate	Individual	Not exceeding 24% per annum on daily reducing balance
	Non-Individual	Not exceeding 18% per annum on daily reducing balance
Cheque bounce, cheque swapping	Up to a maximum of Rs. 250/- per instance
Mandate bounce	Up to a maximum of Rs. 250 /- per instance
Late Payment interest	Up to a maximum of 3% higher than the contracted rate for the period of delay.
Charges for Statement Of Account / Amortization Schedule	Nil
Prepayment charges	NIL
Stamping charges	Reimbursed on actual basis, subject to state laws-where fixed charges irrespective of loan amount, provided by IB-where ad-valorem charges as a function of loan amount, to be procured by borrower directly.

 

1. Introduction

Avanti Finance Private Limited (hereinafter referred to as ‘the Company’) strongly believes in conducting all affairs of its constituents in a fair and transparent manner by adopting the highest standards of honesty, inclusiveness, professionalism, integrity and ethical behaviour.  The whistle blower policy has been formulated as part of corporate governance norms and transparency where the employees, customers or stakeholders are encouraged to refer any complaints which have not been resolved or satisfactorily resolved within the usual applicable protocols. The employees may refer any complaints covering areas such as corruption, misuse of office, criminal offences, suspected / actual fraud, failure to comply with existing rules and regulations, conflicts of interest, related party transactions and acts resulting in financial loss/ operational risk, loss of reputation, etc. This policy shall provide a channel to the employees (including directors) and other stakeholders to report to the management or the board about unethical behaviour, actual or suspected fraud or violation of the Code of Business ethics or legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports and such other matters.

2.Objectives of the Policy

The key objectives of the policy are as under:

1. Promote a culture of speaking up/ raising red flags on matters relating to breaches/ violations of the Company’s Code of Business ethics or fraudulent transactions.
2. Provide a platform and mechanism for the employees and relevant stakeholders to voice genuine concerns of grievances about unprofessional conduct without the fear of reprisal to the employee raising the concern.
3. Provide a non-threatening environment to employees to discuss matters relating to the Code of Business ethics.
4. Adhere to the highest standards of ethical, moral and legal conduct of business operations.
5. Promote clean business transactions, professionalism, productivity, promptness and transparent practices and ensures putting in place systems and procedures to curb opportunities for corruption.
6. Sustain, strengthen and encourage a culture of integrity & compliance
7. Institutionalize a mechanism for protection of employees from reprisals or victimization, for whistle blowing in good faith as the Company strictly follows No Retaliation Policy.
8. Provide an assurance to external stakeholders that there is internal cordiality and transparency.
9. Treat the violations/ breaches/ non-compliance at various levels of the Company with vigour and due care and accordingly realign processes and take corrective actions as part of its corporate governance.

The Policy shall help the Company to create an environment where employees and relevant stakeholders feel free and secure to raise the alarm where they see a problem. It shall also ensure that whistleblowers are protected from retribution, whether within or outside the Company.

3. Applicability of the Policy

The Policy applies to all the Company’s employees. The policy shall also apply to any complaints made by other stakeholders of the Company such as outsourced agents, customers and members of public.

4. Governance Structure

Avanti Finance Private Limited has devised an effective whistle blower mechanism enabling stakeholders, including individual employees to freely communicate their concerns about illegal or unethical practices.

4.1 Nominated Director 

Dr. Vijay Kelkar, Director of the company has been nominated by the Company’s Board of Directors to review the effectiveness of the vigil mechanism and implementation of the Whistle Blower Policy to provide adequate safeguards against victimization of employees and relevant stakeholders. The details of establishment of Vigil mechanism shall be disclosed by the Company on the website, if any, and in the Board’s Report to the stakeholders. In case of repeated frivolous complaints being filed by a director or an employee, the Audit committee (when it is formed) or a director to be nominated by the Board  {(As required under Section 177 of the Companies Act, 2013 read along with Rule 7 of The Companies (Meetings of Board and its Powers) Rules, 2014} shall take suitable action against the concerned director or employee.

4.2 Whistle blowers Committee 

The Whistle-blower committee shall comprise Mr. Rahul Gupta, Mr. Manish Thakkar and Mr. Sunil Kumar Tadepalli. The Committee shall look into the complaints report prepared by the nominated officer Mr. Saikrishnan Srinivasan and can suo moto institute further investigation / call for additional documentary evidence before submitting its findings on the matter.  The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup).

5. Scope

This Policy intends to cover serious complaints that could have grave impact on the operations and performance of the business of the Company. Receipt of information about corruption, malpractice or misconduct on the part of employees, from whatever source, would be termed as a complaint. Complaints may be received from any of the following sources:

• Complaints received from employees of the organisation or from the public
• Departmental inspection reports
• Scrutiny of transactions reported under the Code of Business ethics
• Reports of irregularities in accounts detected in the routine audit of accounts, e.g. tampering with records, over-payments, misappropriation of money or materials, etc.
• Audit reports of the accounts of the Company
• Complaints and allegations appearing in the press, etc.
• Source information, if received verbally from an identifiable source, to be reduced in writing.
• Intelligence gathered by agencies like CBI, local bodies etc.

Under the Policy, employees and relevant stakeholders of the Company having sufficient grounds for a concern can lodge complaints.  The Policy intends to cover the following types of complaints:

• Fraudulent activities or activities in which there is suspected fraud
• Intentional or deliberate non-compliance with laws, regulations and policies
• Questionable accounting practices including misappropriation of monies
• Illegal activities
• Corruption and deception
• Misuse/ Abuse of authority
• Violation of the Company’s rules, manipulations and negligence
• Breach of contract
• Pilferation of confidential/proprietary information
• Deliberate violation of law/regulation
• Wastage/misappropriation of Company’s funds/assets
• Malpractices/ events) causing danger to public health and safety.

The following nature of complaints shall not be covered in the policy:

• Complaints those are frivolous in nature.
• Issues relating to personal grievance (increment, promotion, etc.)

6.Guiding Principles

To ensure that this Policy is adhered to, and to assure that the concerns raised under this Policy will be acted upon seriously, the Company will:

• • Ensure that the Whistle Blower and/or the person processing the Protected Disclosure is not victimized
  • Ensure complete confidentiality of the identity of the WhistleBlower
  • Not attempt to conceal evidence of the Protected Disclosure
  • Take disciplinary action, if any one destroys or conceals evidence of the Protected Disclosure made/to be made
  • Provide an opportunity of being heard to the persons involved, especially to the subject
  • Provide protection to Whistle Blower under this Policy provided that Protected Disclosure is made in good faith, the WhistleBlower has reasonable information or documents in support thereof and not for personal gain or animosity against the subject
  • Ensure that the Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious be liable to Disciplinary Action.
  • Take Disciplinary Action for event covered under this Policy or upon victimizing Whistle Blower or any person processing the Protected Disclosure or if any one destroys or conceals evidence of the Protected Disclosure made/to be made.
  • Ensure that any other Director/ Employee or other stakeholders assisting in the said investigation or furnishing evidence, is protected to the same extent as the Whistleblower. 

7. Procedure 

7.1 Lodging of Complaints 

The Protected Disclosure shall be submitted in a closed and secured envelope and shall be super scribed as “Protected disclosure under the Whistle Blower policy”. Alternatively, the same can also be sent through email or any other acceptable mode of communication with the subject “Protected disclosure under the Whistle Blower policy” to a functional email id of the company who’s access is only with the whistle-blower committee. If the complaint is not super scribed and closed as mentioned above, it will not be possible for the Board to protect the complainant and the protected disclosure will be dealt with as if a normal disclosure.  In order to protect identity of the complainant, the nominated officer (or designated equivalent officer) will not issue any acknowledgement to the complainants and they are advised neither to write their name/address on the envelope nor enter into any further correspondence with the nominated officer. The nominated officer shall assure that in case any further clarification is required he will get in touch with the complainant. The Company shall not entertain anonymous / pseudonymous disclosures except of such disclosures have merit shall be entertained. The Protected Disclosure shall be forwarded under a covering letter signed by the complainant. The nominated officer shall detach the covering letter bearing the identity of the WhistleBlower and process only the Protected Disclosure.   All Protected Disclosures shall be addressed to the nominated officer or Director of the Company or to the audit committee (when the committee is required to be legally setup). The Protected Disclosures shall be addressed to the following address: The Nominated officer OR the nominated Director  Avanti Finance Private Limited, Floor-3rd, 10, Elphinstone Building,  Veer Nariman Road, Horniman Circle, Fort, Mumbai Maharashtra 400001 E-mail: whistleblower@avantifinance.in

7.2 Receipt of Complaint

On receipt of the protected disclosure the nominated officer shall maintain and preserve records of the Protected Disclosure and also ascertain from the complainant whether he / she was the person who made the protected disclosure or not. The record will include: 

• Brief facts
• whether the same Protected Disclosure was raised previously on the same subject and if so, the outcome thereof
• Details of actions taken by the nominated officer (or equivalent department) or CEO for processing the complaint
• Findings of the Audit Committee (or the whistle-blower committee duly approved by the board), the recommendations of the Committee/ other action(s).

An exclusive e-mail ID under the control of the whistle-blower committee has been set up to which any Wrongful Conduct can be reported by any WhistleBlower. The said email id is: - whistleblower@avantifinance.in The nominated officer will carry out a preliminary analysis as to whether the complaint pertains to Wrongful Conduct or not or there is a prima-facie case and shall then refer the matter to the Whistleblower committee.  The Whistleblower Committee, if deems fit, may call for further information or particulars from the complainant. 

7.3 Investigation Report 

All Protected Disclosures reported under this Policy will be thoroughly investigated by the nominated officer of the Company who will investigate / oversee the investigations under the authorization of the Audit Committee. The nominated officer may at its discretion consider involving any investigators for the purpose of investigation. The decision to conduct an investigation taken into a Protected Disclosure by itself is not an acceptance of the accusation by the Authority. It is to be treated as a neutral fact-finding process because the outcome of the investigation may or may not support accusation; unless there are compelling reasons not to do so, subjects will be given reasonable opportunity for hearing their side during the investigation. No allegation of wrongdoing against a subject shall be considered as maintainable unless there is good evidence in support of the allegation. The subject shall have right to access any document/ information for their legitimate need to clarify/ defend themselves in the investigation proceedings. The nominated officer shall normally complete the investigation within 45 days of the receipt of protected disclosure. Based on a thorough examination of the findings, the nominated officer shall submit a report to the Whistleblower Committee on a regular basis about all Protected Disclosures referred to him/her since the last report together with the results of investigations, if any. The Committee shall look into the complaints report prepared by the nominated officer and can suo moto institute further investigation / call for additional documentary evidence before submitting its findings on the matter. The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup). The findings of the whistleblower committee shall be suggested to the nominated Director for his / her decision (or the audit committee when required to be setup).

7.4 Appeal and Decision

If an investigation leads the nominated officer to conclude that an improper or unethical act has been committed which would result in suggested disciplinary action, including dismissal, if applicable; the nominated officer shall recommend to the WhistleBlower Committee of the Company to take such disciplinary or corrective action as he may deem fit. All discussions would be documented and the final report will be recommended by the whistleblower committee and duly approved by the Nominated Director.   If the report of investigation is not to the satisfaction of the complainant, the complainant has the right to report the event to the appropriate legal or investigating agency. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

7.5 Confidentiality

Every effort will be made to protect the identity of the complainant, subject to legal constraints except in cases where the complainant turns out to be vexatious or frivolous and action has to be initiated against the complainant. In the event of the identity of the complainant being disclosed, the nominated officer  can initiate appropriate action against the person making such disclosure.

7.6 Protection 

The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against WhistleBlowers. Complete protection will therefore be given to WhistleBlowers against any unfair practice like retaliation, threat or intimidation of termination / suspension of service, disciplinary action, transfer, demotion, refusal of promotion or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties / functions including making further Protected Disclosure. A WhistleBlower may report any violation of the above clause to the Chairman of the Audit Committee, who shall investigate into the same and recommend suitable action to the Internal Complaint Committee. 

8. Record Keeping

All documentation pertaining to the complaint including the investigation report, corrective action taken and evidence will be maintained for a period of 8 years or such other period as specified by any other law in force, whichever is more.

9. Reporting Requirements

The following are the reporting requirements -

• The details of establishment of Vigil mechanism shall be disclosed by the Company on the website, if any, and in the Board’s Report.
• Whistle blower policy, and affirmation that no personnel has been denied access to the Board for reporting actions under the whistle blower policy.

10)Definitions

1. Audit Committee: A Committee constituted by the Board of Directors of the Company in accordance with Companies Act, 2013.
2. Protected Disclosure: a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity. Protected Disclosures should be factual and not speculative in nature
3. Subject: a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation
4. Whistle Blower/Complainant: an Employee making a Protected Disclosure under this Policy. An employee making a disclosure under this process is commonly referred to as a complainant. The complainant is not expected to prove the truth of an allegation, the complainant needs to demonstrate that there are sufficient grounds for concern and expected to provide the complete details/evidences in his possession.

1.        SCOPE AND PURPOSE OF THIS CODE

1.1   In this Code of Conduct Policy (“Code”), “we” or “us” or “our” means Avanti Finance Private Limited (“Company”), and includes our executive directors, officers, employees and those who work with us, as the context may require. 1.2   This Code sets out how we behave with:

• our employees, or those who work with us;
• our customers;
• the communities and the environment in which we operate;
• our value-chain partners, including suppliers and service providers, distributors, sales representatives, contractors, channel partners, consultants, intermediaries and agents;
• our joint-venture partners or other business associates;
• our financial stakeholders; and
• the governments of the regions where we operate.
  • This Code sets out our expectations of all those who work with us. We also expect those who deal with us to be aware that this Code underpins everything we do, and in order to work with us they need to act in a manner consistent with this Code.
  • This Code applies to following activities undertaken by us:
• providing credit services to clients individually or in groups;
• recovery of credit provided to clients;
• collection of thrift from clients, where ever applicable;
• providing insurance and pension services, remittance services or any other products and services permitted under applicable law, that will reduce vulnerability of our clients;
• formation of any type of community collectives including self-help groups, joint liability groups and their federations; and
• business development services including marketing of products or services made or extended by the eligible clients or for any other purpose for the welfare and benefit of clients.

2      OUR CORE VALUES 2.1   The core values that underpin the way we conduct our business activities are: 2.1.1 INTEGRITY: We are fair, honest, transparent and ethical in our conduct; everything we do must stand the test of public scrutiny. Our primary mission is to service financially excluded individuals and families by providing them access to financial services, which are client focused, designed to enhance their well-being, and delivered in an ethical, dignified, transparent, equitable and cost-effective manner. 2.1.2 QUALITY OF SERVICE: We are committed to ensure quality services to our clients, appropriate to their needs and delivered efficiently in a convenient and timely manner. While doing so, we agree to maintain high standards of professionalism based on honesty, equality and dedication to serve the poor. 2.1.3 TRANSPARENCY: We shall provide our clients complete and accurate information and educate them about the terms of financial services offered by us such as interest rates and all other charges as well as our policies and procedures in a manner that is understandable by them. 2.1.4 PIONEERING: We will be bold and agile, courageously taking on challenges, using deep customer insight to develop innovative solutions. 2.1.5 PRIVACY OF CLIENT INFORMATION: We will safeguard personal information of clients, only allowing disclosures and exchange of such information to others who are authorised to see it, with the knowledge and consent of clients. 2.1.6 RESPONSIBILITY: We will integrate environmental and social principles in our businesses, ensuring that what comes from the people goes back to the people many times over. 3      OUR CORE PRINCIPLES 3.1   We are committed to operating our businesses by conforming to the highest moral and ethical standards. We do not tolerate bribery or corruption in any form. This commitment underpins everything that we do. 3.2   We are committed to good corporate citizenship. We treat social development activities, which benefit the communities we operate in as an integral part of our business plan. 3.3   We seek to contribute to the economic development of the communities in regions we operate, with due respect to their culture, norms and heritage. We seek to avoid any project or activity that is detrimental to the wider interests of the communities in which we operate. 3.4   We shall not compromise safety in the pursuit of commercial advantage. We shall strive to provide a safe, healthy and clean working environment for our employees and all those who work with us. 3.5   When representing the Company, we shall act with professionalism, honesty and integrity, and conform to the highest moral and ethical standards. Our conduct shall be fair and transparent and be perceived as fair and transparent by third parties. 3.6   We shall respect the human rights and dignity of all our stakeholders. 3.7   We shall strive to balance the interests of our stakeholders, treating each of them fairly and avoiding unfair discrimination of any kind. 3.8   The statements that we make to our stakeholders shall be truthful and made in good faith. 3.9   We shall not engage in any restrictive or unfair trade practices. 3.10 We shall provide avenues for our stakeholders to raise concerns or queries in good faith, or report instances of actual or perceived violations of our Code. 3.11 We shall strive to create an environment free from fear of retribution to deal with concerns that are raised, or cases reported in good faith. No one shall be punished or made to suffer for raising concerns or making disclosures in good faith or in the public interest. 3.12 We expect the leaders of our businesses to demonstrate their commitment to the ethical standards set out in this Code through their own behavior and by establishing appropriate processes. 3.13 We shall comply with the laws of the countries in which we operate and any other laws which apply to us. With regard to those provisions of the Code that are explicitly dealt with under an applicable law or employment terms, the law and those terms shall take precedence. In the event that the standards prescribed under any applicable law are lower than that of the Code, we shall conduct ourselves as per the provisions of the Code. 4      OUR EMPLOYEES 4.1   Equal opportunity employer 4.1.1 We provide equal opportunities to all our employees and to all eligible applicants for employment in our Company. We do not unfairly discriminate on any ground, including race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, disability or any other category protected by applicable law. 4.1.2 When recruiting, developing and promoting our employees, our decisions will be based solely on performance, merit, competence and potential. 4.1.3 We shall have fair, transparent and clear employee policies which promote diversity and equality, in accordance with applicable law and other provisions of this Code. These policies shall provide for clear terms of employment, training, development and performance management. 4.2   Dignity and respect 4.2.1 Our leaders shall be responsible for creating a conducive work environment built on tolerance, understanding, mutual cooperation and respect for individual privacy. 4.2.2 Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whether sexual, physical, verbal or psychological. 4.2.3 We have clear and fair disciplinary procedures, which necessarily include an employee’s right to be heard. 4.2.4 We respect our employees’ right to privacy. We have no concern with their conduct outside our work environment, unless such conduct impairs their work performance, creates conflicts of interest or adversely affects our reputation or business interests. 4.3   Human rights 4.3.1 We do not employ children at our workplaces. 4.3.2 We do not use forced labour in any form. We do not confiscate personal documents of our employees or force them to make any payment to us or to anyone else in order to secure employment with us, or to work with us. 4.4   Bribery and corruption 4.4.1 Our employees and those representing us including agents and intermediaries shall not, directly or indirectly, offer or receive any illegal or improper payments or comparable benefits that are intended or perceived to obtain undue favours for the conduct of our business. 4.5   Gifts and hospitality 4.5.1 Business gifts and hospitality are sometimes used in the normal course of business activity. However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit payment’. Therefore, gifts and hospitality given or received should be modest in value and appropriate, and in compliance with our Company’s gifts and hospitality policy. 4.5.2 As a general rule, we can accept gifts or hospitality from a business associate, only if such a gift: (a)    has modest value and does not create a perception (or an implied obligation) that the giver is entitled to preferential treatment of any kind; (b)    would not influence, or appear to influence, our ability to act in the best interest of our Company; and/ or (c)    would not embarrass our Company or the giver if disclosed publicly. 4.5.3 The following gifts are never appropriate and should never be given or accepted: (a)    gifts of cash or gold or other precious metals, gems or stones; (b)    gifts that are prohibited under applicable law; (c)    gifts in the nature of a bribe, payoff, kickback or facilitation payment*; (d)    gifts that are prohibited by the gift giver’s or recipient’s organization; and (e)    gifts in the form of services or other non-cash benefits (e.g. a promise of employment). (*‘Facilitation payment is a payment made to secure or speed up routine legal government actions, such as issuing permits or releasing goods held in customs.) 4.6   Freedom of association 4.6.1 We recognise that employees may be interested in joining associations or involving themselves in civic or public affairs in their personal capacities, provided such activities do not create an actual or potential conflict with the interests of our Company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable Company policies and law. 4.7   Working outside employment with us 4.7.1 Taking employment, accepting a position of responsibility or running a business outside employment with our Company, in your own time, with or without remuneration, could interfere with your ability to work effectively at our Company or create conflicts of interest. Any such activity must not be with any customer, supplier, distributor or competitor of our Company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable Company policies and law. 4.8   Integrity of information and assets 4.8.1 Our employees shall not make any willful omissions or material misrepresentation that would compromise the integrity of our records, internal or external communications and reports, including the financial statements. 4.8.2 Our employees and directors shall seek proper authorization prior to disclosing Company or business-related information, and such disclosures shall be made in accordance with our Company’s media and communication policy. This includes disclosures through any forum or media, including through social media. 4.8.3 Our employees shall ensure the integrity of personal data or information provided by them to our Company. We shall safeguard the privacy of all such data or information given to us in accordance with applicable Company policies or law. 4.8.4 Our employees shall respect and protect all confidential information and intellectual property of our Company. 4.8.5 Our employees shall safeguard the confidentiality of all third party intellectual property and data. Our employees shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable Company policies or law. 4.8.6 Our employees shall promptly report the loss, theft or destruction of any confidential information or intellectual property and data of our Company or that of any third party. 4.8.7 Our employees shall use all Company assets, tangible and intangible, including computer and communication equipment for the purpose for which they are provided and in order to conduct our business. Such assets shall not be misused. We shall establish processes to minimize the risk of fraud, and misappropriation or misuse of our assets. 4.8.8 We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws. 4.9   Insider Trading 4.9.1 Our employees must not indulge in any form of insider trading nor assist others, including immediate family, friends or business associates, to derive any benefit from access to and possession of price sensitive information that is not in the public domain. Such information would include information about our Company, our clients and our suppliers. 4.10 Prohibited drugs and substances 4.10.1  Use of prohibited drugs and substances creates genuine safety and other risks at our workplaces. We do not tolerate prohibited drugs and substances from being possessed, consumed or distributed at our workplaces, or in the course of Company duties. 4.11 Conflict of interest 4.11.1  Our employees and executive directors shall always act in the interest of our Company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our Company or the operations of our Company. Further, our employees and executive directors shall not engage in any business, relationship or activity, which might conflict with the interest of our Company. 4.11.2  Should any actual or potential conflict of interest arise, the concerned person must immediately report such conflicts and seek approvals as required by applicable law and Company policy. The competent authority shall revert to the employee within a reasonable time as defined in our Company’s policy, so as to enable the concerned employee to take necessary action as advised to resolve or avoid the conflict in an expeditious manner. 4.11.3  In the case of all employees other than executive directors, the Chief Executive Officer / Managing Director shall be the competent authority, who in turn shall report such cases to the Board of Directors on a quarterly basis. In case of the Chief Executive Officer / Managing Director and executive directors, the Board of Directors of our Company shall be the competent authority. 4.11.4  Notwithstanding such or any other instance of conflict of interest that exists due to historical reasons, adequate and full disclosure by interested employees shall be made to our Company’s management. At the time of appointment in our Company, our employees and executive directors shall make full disclosure to the competent authority, of any interest leading to an actual or potential conflict that such persons or their immediate family (including parents, siblings, spouse, partner, children) or persons with whom they enjoy close personal relationships, may have in a family business or a company or firm that is a competitor, supplier, customer or distributor of, or has other business dealings with, our Company. 4.12 Examples of Potential Conflict of Interest 4.12.1  A conflict of interest, actual or potential, arises where, directly or indirectly, an employee or executive director:

• engages in a business, activity or relationship with anyone who is party to a transaction with our Company;
• is in a position to derive an improper benefit, personally or for any family member or for any person in a close personal relationship, by making or influencing decisions relating to any transaction;
• conducts business on behalf of our Company or is in a position to influence a decision with regard to our Company’s business with a supplier or customer where a relative of, or a person in close personal relationship with, an employee or executive director is a principal officer or representative, resulting in a personal benefit or a benefit to the relative;
• is in a position to influence decisions with regard to award of benefits such as increase in salary or other remuneration, posting, promotion or recruitment of a relative or a person in close personal relationship employed in our Company;
• undertakes an activity by which the interest of our Company can be compromised or defeated; or
• does anything by which an independent judgement of our Company’s best interest cannot be exercised.

4.12.2  A conflict of interest could be any known activity, transaction, relationship or service engaged in by an employee, his/her immediate family (including parents, siblings, spouse, partner, and children), relatives or a close personal relationship, which may cause concern (based upon an objective determination) that the employee could not or might not be able to fairly perform his/her duties to our Company. 4.12.3  If there is a failure to make the required disclosure and our management becomes aware of an instance of conflict of interest that ought to have been disclosed by an employee or executive director, our management shall take a serious view of the matter and consider suitable disciplinary action as per the terms of employment. In all such matters, we shall follow clear and fair disciplinary procedures, respecting the employee’s right to be heard. 4.12.4  Acceptance of a position of responsibility (whether for remuneration or otherwise) in the following cases would typically be permitted, provided the time commitments these demand do not disturb or distract from the employee’s primary duties and responsibilities in our Company, and are promptly disclosed to the relevant competent authority:

• directorships on the Boards of any of our joint ventures or associate companies;
• memberships/positions of responsibility in educational/professional bodies, where such association will promote the interests of our Company; or
• memberships or participation in government committees/bodies or organizations.

5      OUR CLIENTS AND CUSTOMERS 5.1   Transparency: To ensure that the Company maintains transparency in its operations and communications vis-à-vis its clients, Company will adhere to the following:

• disclose to clients all the terms and conditions (including changes if any) of our financial services offered in the language understood by the client;
• provide loan sanction letter or any other document clearly indicating the rate of interest, mode of charging interest, levy of any other charges, terms of repayment to the client against his/her acknowledgement;
• provide information to clients on the rate of interest offered on the thrift services, wherever applicable;
• provide information to clients related to the premium and other fees being charged on insurance services;
• provide a valid receipt for every payment received from the borrower;
• provide periodical statements of their accounts by means of a passbook or any other mechanism to the clients; and
• all the above disclosures to the client may be made digitally.

5.2   Client Protection: In protecting the interest of the clients/borrowers, the Company is committed to following fair practices built on dignity, respect, fair treatment, persuasion and courtesy to clients. 5.3   Avoiding over-indebtedness: Company will take reasonable steps to ensure that credit services are based on the need and repayment capacity of the client and that this service will not put the client / borrowers at significant risk of over-indebtedness. Accordingly, the Company will:

• undertake appropriate interaction and collection practices;
• interact with the clients in an acceptable language and dignified manner and spare no efforts in fostering clients’ confidence and long-term relationship;
• have a clearly defined and phased procedure in case of client default;
• maintain decency and decorum during the visit to the clients’ place for collection of dues;
• avoid inappropriate occasions such as bereavement in the family or such other calamitous occasions for making calls/visits to collect dues; and
• avoid any demeanor that would suggest any kind of threat or violence.

5.4   Privacy of client information: Company is committed to keep personal client information strictly confidential except in the following circumstances:

• client has been informed about such disclosure and permission has been obtained;
• it is legally required to do so;
• the party in question has been authorized by the client; or
• this practice is customary amongst financial institutions and available for a close group on reciprocal basis (such as a credit bureau).

6      OUR COMMUNITIES AND THE ENVIRONMENT 6.1   Communities: We are committed to good corporate citizenship and shall actively assist in the improvement of the quality of life of the people in the communities in which we operate. 6.1.1 We engage with the community and other stakeholders to minimize any adverse impact that our business operations may have on the local community and the environment. 6.1.2 We encourage our workforce to volunteer on projects that benefit the communities in which we operate, provided the principles of this Code, where applicable, and in particular the ‘Conflicts of Interest’ clause is followed. 6.2   The environment: In the production and sale of our products and services, we strive for environmental sustainability and comply with all applicable laws and regulations. 6.2.1 We seek to prevent the wasteful use of natural resources and are committed to improving the environment, particularly with regard to the emission of greenhouse gases, consumption of water and energy, and the management of waste and hazardous materials. We shall endeavor to offset the effect of climate change in our activities. 7      OUR VALUE-CHAIN PARTNERS 7.1   We shall select our suppliers and service providers fairly and transparently. 7.2   We seek to work with suppliers and service providers who can demonstrate that they share similar values. We expect them to adopt ethical standards comparable to our own. 7.3   Our suppliers and service providers shall represent our Company only with duly authorized written permission from our Company. They are expected to abide by the Code in their interactions with, and on behalf of us, including respecting the confidentiality of information shared with them. 7.4   We shall ensure that any gifts or hospitality received from, or given to, our suppliers or service providers comply with our Company’s gifts and hospitality policy. 7.5   We respect our obligations on the use of third-party intellectual property and data. 8      OUR FINANCIAL STAKEHOLDERS 8.1   We are committed to enhancing shareholder value and complying with laws and regulations that govern shareholder rights. 8.2   We shall inform our financial stakeholders about relevant aspects of our business in a fair, accurate and timely manner and shall disclose such information in accordance with applicable law and agreements. 8.3   We shall keep accurate records of our activities and shall adhere to disclosure standards in accordance with applicable law and industry standards. 9      GOVERNMENTS 9.1   Political non-alignment: We shall act in accordance with the constitution and governance systems of the regions/countries where we operate. We do not seek to influence the outcome of public elections, nor to undermine or alter any system of government. We do not support any specific political party or candidate for political office. Towards this end: 9.1.1 Our conduct must preclude any activity that could be interpreted as mutual dependence/favour with any political body or person, and we do not offer or give any Company funds or property or other resources as donations to any specific political party, candidate or campaign. 9.1.2 Any financial contributions considered by our Board of Directors in order to strengthen democratic forces through a clean electoral process shall be extended only through the Progressive Electoral Trust in India, or by a similar transparent, duly-authorized, nondiscriminatory and non-discretionary vehicle outside India. 9.2   Government engagement: We conduct our interactions with them in a manner consistent with our Code. 9.2.1 We engage with the government and regulators in a constructive manner in order to promote good governance. 9.2.2 We do not impede, obstruct or improperly influence the conclusions of, or affect the integrity or availability of data or documents for any government review or investigation. 10    RAISING CONCERNS 10.1 We encourage our employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of our Code, policies or law. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles. 10.2 Avenues available for raising concerns or queries or reporting cases could include:

• immediate line manager or the Human Resources department of our Company;
• designated ethics officials of our Company;
• the ‘confidential reporting’ third party ethics helpline (if available); or
• any other reporting channel set out in our Company’s ‘Whistleblower’ policy.

10.3 We do not tolerate any form of retaliation against anyone reporting legitimate concerns. Anyone involved in targeting such a person will be subject to disciplinary action. 10.4 If you suspect that you or someone you know has been subjected to retaliation for raising a concern or for reporting a case, we encourage you to promptly contact your line manager, the Company’s Ethics Counsellor, the Human Resources department or the MD/CEO. 11    ACCOUNTABILITY 11.1 This Code is more than a set of prescriptive guidelines issued solely for the purpose of formal compliance. It represents our collective commitment to our value system and to our core principles. 11.2 Every person employed by us, directly or indirectly, should expect to be held accountable for his/her behavior. Should such behavior violate this Code, they may be subject to action according to their employment terms and relevant Company policies. 11.3 When followed in letter and in spirit, this Code is ‘lived’ by our employees as well as those who work with us. It represents our shared responsibility to all our stakeholders, and our mutual commitment to each other. 12    NOTE 12.1 The Code does not provide a comprehensive and complete explanation of all expectations from a Company standpoint or obligations from a stakeholder standpoint. 12.2 Our employees have a continuing obligation to familiarise themselves with all applicable law, Company-level policies, procedures and work rules as relevant. For any guidance on interpretation of the Code, we may seek support from our Company’s Ethics Counsellor. 12.3 For any query or clarification on the Code, please contact the office of the Company’s Chief Ethics Officer via email at: Sunil.kumar.t@avantifinance.in 12.4 For further information on the Code please contact: The Ethics Office, Email: Sunil.kumar.t@avantifinance.in