Fair Practice Code (FPC)

Harshreejee Finance & Leasing Company Private Limited (HSFLCL)
Date of Board Approval: _______
Website: https://www.hsflcl.com
Approved by: Board of Directors

1. Preamble

In line with Chapter VII of the RBI (NBFC – Scale Based Regulation) Directions, 2023, HSFLCL has adopted this Fair Practice Code (“FPC”) to ensure fair, transparent, and responsible lending practices across all operations, including digital lending.

2. Purpose and Applicability

• Ensure fair and transparent dealings with customers
• Provide clarity in loan terms and pricing
• Prevent coercive recovery practices
• Ensure compliance with RBI guidelines
• Establish grievance redressal mechanisms

3. Definitions

• Board: Board of Directors of HSFLCL
• Customer/Borrower: Individual applying for or availing a loan
• APR: Annual Percentage Rate including all charges
• PNO: Principal Nodal Officer for grievance redressal

4. General Principles of Fair Lending

• Transparent and non-discriminatory practices
• Clear communication at all stages
• Respect privacy and confidentiality
• Avoid misleading marketing practices

5. Loan Application and Processing

• Clear disclosure of charges and documentation
• Defined processing timelines
• Acknowledgement of applications
• Communication of rejection reasons

6. Loan Appraisal and Sanction

Loans are approved based on internal credit policies. A sanction letter is issued including:

• Loan amount and tenure
• Interest rate and calculation method
• Charges and fees
• Borrower consent before disbursement

7. Loan Disbursement and Changes

• Disbursement as per agreed terms
• Advance notice for any changes
• Return of documents upon closure

8. Responsible Lending

• No coercive or abusive recovery practices
• Respectful customer interaction
• No discrimination

9. Interest Rate Policy

Interest rates are determined as per the Board-approved policy and disclosed clearly in KFS, agreements, and website. No hidden charges are levied.

10. Penal and Prepayment Charges

• No capitalization of penal charges
• Charges are reasonable and disclosed upfront
• No foreclosure charges on personal loans (as per RBI norms)

11. Digital Lending

Digital lending operations comply with RBI Digital Lending Guidelines. Data security and transparency are strictly maintained.

12. Recovery of Loans

• Fair and lawful recovery practices
• No harassment or intimidation
• Proper identification of recovery agents

13. Grievance Redressal

Customers may contact the Principal Nodal Officer:

Mr. Tanmay Gupta
Director & Principal Nodal Officer
Email: [Insert Email]
Phone: [Insert Number]

If unresolved within 30 days, complaints may be escalated to RBI Ombudsman: https://cms.rbi.org.in

14. Ombudsman

The Company complies with RBI Integrated Ombudsman Scheme, 2021 and will appoint an Internal Ombudsman as required.

15. Display and Communication

• Available on website and customer touchpoints
• Provided in English and local languages
• Employee training ensured

16. Board Oversight

The Board reviews implementation annually and monitors grievance handling periodically.

17. Regulatory Compliance

This Code will be updated as per RBI guidelines. Regulatory provisions will prevail in case of conflict.

Approval

Approved by the Board of Directors of Harshreejee Finance & Leasing Company Private Limited
Date: _________