BOARD APPROVED FAIR PRACTICES CODE FOR THANVIR BROS. PVT. LTD.

Revision Date 09/09/2022

Pursuant to Reserve Bank of India (RBI)'s Master Direction No.  NBR.PD.007/03.10.119/2016-17 dated 01/09/2016 (as updated from time to time) issued to Non-Banking Financial Companies (NBFC’s), the Board of Directors have adopted the Fair Practices Code to be followed by Thanvir Bros. Pvt. Ltd. in latter and spirit.

The Fair Practices Code, as adopted herein below by Thanvir Bros. Pvt. Ltd. (The Company), is in conformity with the Guidelines on Fair Practices Code for NBFCs as prescribed by the Reserve Bank of India and as contained in the aforesaid RBI Circular.

OBJECTIVES & APPLICATION

• To promote good & fair practices by setting reasonable Standards in dealing with Customers.
• To increase transparency so that the Customers can have better understanding of what they can reasonably expect of the Services and take informed decisions.
• To encourage market forces, to achieve higher Operating standards.
• To promote a fair & cordial relationship between Customer & the Company.
• To promote Customer first and provide better Customer Satisfaction and Services.
• Building customer confidence in the company 

APPLICATION OF THE FPC

The Code applies to all the Products & Services offered by The Company and all the offices and all employees of The Company or its associates or agents (as per respective applicability).

TO ACT FAIRLY AND IN A TRANSPARENT MANNER

• The Company shall act fairly and reasonably in all dealings with Customers by ensuring that.
  • The commitments and standards prescribed in this Code are met for all Products, Services, Procedures, & Practices.
  • Company’s Products & Services meet relevant Laws & Regulations in letter & spirit.
  • Company’s dealings with Customers rest on the Ethical Principles of Integrity & Transparency

• Company will transparently disclose to the applicants/borrower all information including fees / charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned / disbursed, pre-payment options and charges, if any, penalty for delayed repayment, if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest reset clause and any other matter which affects the interest of the borrower. Presently, the company will not charge any non-refundable loan application fees incase the customer don’t accept the sanction terms offered by the company.
• The Company will disclose ‘all in cost’ / ‘Annual Percentage Rate’ which will be inclusive of all charges involved in processing / sanction of loan application and charges applicable thereafter in a transparent manner except for the contingent charges/fees and interest. The Company ensures that such charges/ fees are non-discriminatory.
• The company may enter into arrangement / partnership with various Lending Service Providers (LSP)/ Digital Lending App (DLA) / Direct Selling Agents (DSA)/ Collection Agents. Their name and responsibility will be clearly communicated to respective customers/ borrowers and also made available on the website on the company.
• All the lending activities will be between the Company / NBFC and the Borrower from disbursement to collection the service providers will just act to bridge the gap between the NBFC and the borrower for effective lending and customer service. No payment is to be made to such service providers by any borrower and any such payment will be made directly from the bank account of NBFC only. All disbursement and repayment payments from borrower is to be made from/in NBFC account only. Any fees and payments to the service provider will be made from NBFC account only. The LSP/DLA, etc. has no role in credit approval process of the NBFC.

The company follows the following procedure in true spirit:

• All the communications with the proposed customer/borrower will be either in English or the vernacular language as understood/preferred/agreed by the proposed customer /borrower.

I.          Applications for loans and their processing:

a)         The Application Form of the company for products/services offered by the Company is different depending upon the requirement of each product/services and will indicate list of information/documents (including details about economic profile of borrower) that is required to be submitted by the Borrower with loan application. Loan application forms will include necessary information which affects the interest of the borrower (so that a meaningful comparison with the terms and conditions offered by other Bank/NBFC/FI’s can be made) and informed decision can be taken by the borrower.

b)         Acknowledgement receipt of all loan applications will be issued with indicative time frame for disposal of application being received.

II.         Loan appraisal and terms/conditions:

1. The company will convey in writing to the borrower by means of sanction letter, the amount of loan sanctioned along with terms and conditions including Annualized rate of interest (ROI) and method of application of ROI. Also the Panel Interest applicable on default will be mentioned in bold letters in the loan agreement.  A standardised Key Fact Statement (KFS) should be mandatorily shared as part of Sanction letter.
2. A copy of the loan agreement as understood/agreed by the borrower along with a copy each of enclosures quoted in the loan agreement will be furnished to all the borrowers at the time of disbursement of loans by email/same mode used for application of loan. Extract of Major terms and condition of sanction letter and KFS shall form part of Loan Agreement.
3. The company will send a communication of rejection of Loan Application to the customer along with the reason(s) for rejection.

III.        Disbursement and changes in terms and conditions:

1. Loan disbursement will be made in accordance with the disbursement schedule as per sanction terms and as agreed/accepted by the borrower.
2. Customers would be informed regarding changes to Terms & Conditions including disbursement schedule, interest rates, service charges, prepayment charges, other applicable charges etc.
3. Notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, processing charges, prepayment charges, etc. will be furnished by same mode by which borrower was communicated Sanction / Disbursement / Loan Agreement.
4. Any changes in interest rates and charges are affected only prospectively giving due notice.  Suitable condition in this regard will be incorporated in the loan agreement of customers.  If such change is to the disadvantage of the Customer, he / she may within 60 days & without Notice close his / her Account or switch it without having to pay any extra charges or interest
5. Decision to recall / accelerate payment or performance under the agreement
   will be in consonance with the respective loan agreement.
6. In cases where company holds Security documents/ Interest, the Company will release all securities on repayment of all dues or on realization of the outstanding amount of the loan subject to any legitimate right or lien for any other the company claim may have against borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim/all dues of the Company is settled/ paid.
7. No objection certificate will be issued to the borrower/customer on repayment of all dues within 30 workings days of completion of payment including all charges/fees, if applicable, as per the product type and will be sent to borrower though medium used for application of loan/email, unless otherwise requested by borrower/customer.
8. The following Key Fact Statement will form part of all Loan Agreement / Credit Agreement and applicable extract of the same shall also be included in Sanction letter

Key Fact Statement (KFS); Sanction Letter & terms of Sanction; Loan Type – Personal (Non Microfinance with customer household having annual household income > Rs 3,00,000/-)

Name of the Regulated entity/NBFC - Thanvir Bros. Pvt. Ltd.

Sr No	Parameter	Details
1	Loan Sanction Amount / Disbursement to Customer Account with us (amount to be disbursed to the borrower loan account)	(in Rupees)
2	Fee payable / Other up-front charges on application (all in cost for loan application /break-up of each component to be given)	(in Rupees)
a	Fees Head (if any) (details to be provided like processing Fees/Insurance charges, etc.)	(in Rupees)
	Net disbursed amount to Customer Bank Account (1-2)	(1-2)
	Total interest charges during the entire tenure of the loan	(in Rupees)
	Total amount to be paid by the borrower	(1+4)
	Annual Percentage Rate (APR) –Effective Annualised Interest rate in % Term (calculated in reducing balance method on (3))	(Bold)
	Loan tenure /term (in days/months/years)
	Repayment frequency by the borrower	(Monthly / yearly/ no of days, etc.)
	Number of instalments of repayment
	EMI payable /Amount of each instalment of repayment	(in Rupees)
	Interest type applicable for Loan Account	(floating)
	Applicable Interest in % per Annum	(Bold)
	Date of reset of interest	Yearly, March every year
	Mode of communication of changes in interest rates	Email/ Whatsapp
	Details about Contingent Charges over and above the one which is mentioned hereinabove (individually specify all type of fee/Charges) (The Rate of Annualised charges hereunder will be calculated on (3) above)
a	On Prepayment / foreclosure before due date	Nil
b	Fee refundable if loan not sanctioned/disbursed	(No fees being charged)
c	Conversion charges for switching from floating to fixed interest and vice-versa	Option Not applicable for present loan product
d	Rate of annualised penal charges in case of delayed payments (if any)	(Bold)
e	Rate of annualised other penal charges (if any); (details to be provided )
f	Rate of annualised collection charges applicable only incase of default > 7 days from EMI date (if any)
g	Rate of annualised legal charges applicable only incase of default > 30 days from EMI date (if any)
16	Details of security/collateral obtained
17	Lookup/ Cool off period when loan can be closed by Borrower by paying only Principal Amount and % of APR for loan, without any penalty => 7 days	(Disbursement time + 3 days)
18	Principal Amount and % of APR payable during lookup / cool off period	Disbursement Amount + 5% APR
19	Details of Lending Service Provider (LSP) acting as recovery agent and authorized to approach the borrower
20	Name, designation, address and phone number of nodal grievance redressal officer designated specifically to deal with Fintech/ digital lending related complaints/ issues	Fintech Grievance Redressal Officer of  LSP – of NBFC – Mr. Ravi Jain, CC Executive, Address -1 kyd street, Kolkata 700016 – Ph No.: 7003039364 / ravi @thanvirbros.in
Note : The font size of Key Fact Sheet should be minimum Arial-12

Detailed Repayment Scheduled

Instalment No.	Outstanding Principal (in Rupees)	Principal repaid (in Rupees)	Interest repaid (in Rupees)	Total Instalment / EMI (in Rupees)	Total Outstanding Loan including Non Contingent Fees / Charges (in Rupees)

IV.       General terms and condition of loan

a)         The Company will refrain from interference in the business affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement. However the company may enquire/call for information to its satisfaction/ interfere incase new information, not earlier disclosed by the borrower and has come to the notice of the Company post sanction / disbursement of loan.

b)         In case of receipt of request from the borrower for transfer of borrower
account, the consent or otherwise i.e. objection shall be conveyed within 21 days from the date of receipt of request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.

c)         In the matter of recovery of loans, the Company will not resort to undue
harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loan, etc. The staffs will be adequately trained to deal with the customers in an appropriate manner. Steps will be taken to ensure adherence to the same and number of complaints received towards harassment or rude behaviour or similar bad recovery processes will be brought to notice of the senior management of the company.

d)         The Company will not charge foreclosure / pre-payment penalties on all floating rate loans sanctioned to individual borrowers for purposes other than business with or without co-obligant(s) and such terms will be clearly be spelled out in the sanction/disbursement documents. 

e)         Customer will be educated at the application stage about the loan product features. 

V.        Board Approved policy towards Grievance Redressal Mechanism & Grievance Redressal Officers:

In the present competitive scenario, excellent customer service is an important tool for sustained business growth. Customer complaints are part of the business life in any corporate entity.

At the company, customer service and satisfaction are our prime focus. We believe that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. The Company has come up with a lot of initiatives that are oriented towards providing a better customer experience and an efficient complaints redressal mechanism with a view to providing enhanced experience to our customers.

In order to make the companies redressal mechanism more meaningful and effective, a structured system has been built. This system would ensure that the redressal sought is just and fair and is within the given frame-work of rules and regulation.

a)         The Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising out of various lending decisions/customer complaints. Such a mechanism ensures that all disputes/complaints arising are heard and disposed of at least at the next higher level.

b)         The Board of Directors will also periodical review the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board of Directors at regular intervals, as may be prescribed by it from time to time.

c)         Response to a complaint would be given within a period of one month from the date of complaint, unless the nature of complaint requires verification of facts and figures.

d)         The company will ensure that the following Grievance Redressal Mechanism with Officers details is being displayed at a prominent location of the company for benefit of the customers including its website:

“Customers are free to bring any Grievance to the notice of the following officers which will be dealt in best possible manner:

In knowledge of Customer Service Department of the company

• on  7003039364 / Email us on cc@thanvirbros.in
  • Write to us at the below mentioned address

Customer Service Department
Thanvir Bros. Pvt. Ltd.

Flat No 43, 1^st Floor, Palace court, 1 kyd street, Kolkata 700016

In case the complaint is not resolved within a period of one month or if he/she is not satisfied with the solution provided by the NBFC or its partner, the customer can approach the Complaints Redressal Officer as per followings:

• First Level Grievance Redressal Officer
  • Mr. Ravi Jain  –7003039364 / ravi@thanvirbros.in

In case the complaint is not resolved within a period of one month or if he/she is not satisfied with the solution provided, the customer can approach

Second Level Grievance Redressal Officer:

• Binod - 86977 44441 / binod@thanvirbros.in

• Incase the Complaint want to send physical complaint, he can send the same at following address of the company
  Thanvir Bros. Pvt. Ltd.

Flat No 43, 1^st Floor, Palace court, 1 kyd street, Kolkata 700016

• If the complaint/ dispute is not resolved within 1 month customer may prefer complaint with regulator under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS)        
  https://cms.rbi.org.in/

The process of the complaints redressal unit will ensure closure of all complaints to the customers’ satisfaction. They will ensure that the complaint is escalated to the appropriate levels in case it is not possible to resolve at his/her level. Whilst the ultimate endeavour is to ensure we reach a situation where our customers don’t have to complain to senior management to get an effective redressal, we have put in a robust mechanism to handle these complaints, review them from a point of view of understanding reasons for the complaint and for the escalation and working on prevention of recurrence thereof.

Further before appointment of any LSP/DSA/DLA proper due diligence of the same to be done by the company officials to its satisfaction and its to ensure that the LSP/DSA/DLA shall have a suitable nodal grievance redressal officer to deal with any complaints for customer services / sourced by them. Such grievance redressal officer shall also deal with complaints against their respective DLAs. The details of the Grievance redressal officer shall be prominently indicated on the website of company, LSP/DSA/DLA, as applicable.

VI.       Regulation of Interest/charges/fees to be charged from the borrower:

a)         At the time of availing of a loan, the Company will provide the borrowers with information on the annualised interest rate payable by them and adhere to it.

b)         The loan agreement will contain sufficient information about interest, charges, approach followed by the company towards grading of risks and rationale, etc.

c)         If Company increases any charges or introduces a new charge, shall notify the same to the borrowers and will also be placed on the website of the company and is applicable prospectively. Also no fees can be charged unless otherwise advised in Sanction letter.

d)         The company will not charge excessive interest than allowed by the regulator at any point of time.

e)         Copy of Board approved policy document adopting the interest rate model taking into account the relevant factors such as cost of funds, margin and risk premium to determine rate of interest to be charged for loans, Interest rate application as per gradation of risk and rationale for charging different rate of interest to different categories of borrowers are mentioned on interest rate model followed the company and is communicated to the borrower along with Sanction letter and also available on website of the NBFC.

VII.      Other Terms

1. The Company is not yet financing loan again vehicles. Once the company starts vehicle       finance product, it shall immediately update the FPC and include the terms and       condition and procedure for repossession of vehicle against financed loan.
2. The company is not yet lending against gold as security, once any such loan product is announced by the company, it shall adopt gold lending guideline in the FPC.

VIII.     Customer’s Data Confidentiality

The company will collect data from customer which it feels are necessary for processing the loan based on nature of product it offers. The Loan Application process/ Form will capture details of all such requirement and copy of such data being taken/captured with company from customer will be made available as part of loan agreement/ annexure thereon. All personal information of present and past customers will be treated as private and confidential. The Company will not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, other than in the following exceptional cases:

1. If the information is to be given by law.
2. If there is a duty towards the public to reveal the information.
3. If Company’s interests require them to give the information to prevent fraud etc. Customer’s information shall not be given to anyone for marketing purposes except with his/her permission.
4. If the Customer asks Company to reveal the information, or with the Customer’s permission.
5. If Company is asked to give a reference about a Customer, the Company will obtain his / her written permission before giving it.
6. If the Customer account is due / in default than his data will be shared with respective Collection Agent / Agency hired by the NBFC on need to know basis.
7. NBFC will share Customer data and information including KYC, Loan, repayment track and history with Credit Bureaus/CKYC/CERSAI or any other regulate entities. Any default / due amount will also be informed which may impact the credit score / customer’s ability to get credit from others. Customer can seek information being sent to credit bureau agencies from NBFC by writing to customer care email id. 
8. Customer data’s basic data of customer like name, id card numbers, contact information, credit rejection reason, timestamp of loan application details, etc. will be permanently stored in the companies database for future credit analysis/ learning and records.
9. For customer who avail the loan us, his data including mandatory credit data & documents will be stored during the full tenure of the loan account and 2 years thereafter.
10. For customer whose loan request are rejected or who don’t avail loan, company will usually store data for 1 year.
11. Customer will be given option to accept or deny consent for use of specific data, including option to revoke previously granted consent, besides option to delete the data collected from borrowers by the DLAs/ LSPs.
12. Company and its DLA will make its comprehensive privacy policy available in its website.

IX.       Collection of Dues

1. Whenever loans are given, the Company will inform to the customer and also include in Sanction letter the repayment process by way of amount, tenure and periodicity of repayment.
2. The Company will also inform to the customer that on non-adherence to repayment schedule, all the actions will be taken in accordance with the laws of the land, for recovery of dues such as reminding the customer by sending him / her notice or by making personal visits and / or repossession of security (if any).
3. Company’s Collection Policy is built on courtesy, fair treatment & persuasion. Company believes in fostering customer confidence & long-term relationship. Company’s Staff or any person authorized to represent in collection of dues or / & security repossession shall identify himself / herself & display the Authority Letter issued by Company & upon request, display his / her Identity Card issued by the Company or under authority of the Company. Company shall provide Customers with all the information regarding dues & shall endeavour to give sufficient Notice for payment of dues.
4. The Company will provide customers with all the information regarding dues and on case to case basis give sufficient notice for payment of dues.

All the members of the staff or any person authorized to represent the Company in collection or / and security repossession should follow the guidelines set out below:

1. Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation, from reference if customer is not reachable on contact details available with the Company.
2. Identity and authority to represent the Company would be made known to the customer at the first instance.
3. Customer’s privacy would be respected.
4. Interaction with the customer shall be made in a civil manner
5. Company’s representatives shall contact the customers between 0930 hrs and 1900 hrs, unless the special circumstances of the customer’s business or occupation require otherwise or he has specially requested to connect on other time.
6. Customer’s request to avoid calls at a particular time or at a particular place shall be honoured as far as possible.
7. Time and number of calls and contents of conversation would be documented.
8. All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
9. During visits to customer’s place for dues collection, decency and decorum would be maintained.
10. Inappropriate occasions such as bereavement in the family or such other calamitous occasions would be avoided for making calls/visits to collect dues.
11. Calls to references given by the customer during loan application will only be made incase customer is inaccessible even after various tries to connect.

Further apart from above, our person and agents abide by the following Do’s and Don’ts to help serve our customers better.

	DOs	DONTs
Appearance,  dress code	Well Groomed Clean & Tidy	No long unkempt hair Shirt sleeves rolled up
Speech	Formals Introduce yourself with identity card Use formal address Tone should be polite yet assertive and firm	No chappals or sandals Do not get tough or aggressive or abusive Do not lose temper, get angry or even irritated irrespective of reason Pitch should not be high
Belongings	Decency and decorum to be maintained Identity Card, Letter of authority Diary for writing the information gathered	Should not get personal Collector should not make any verbal or written promises to customer on matters outside his preview or on product features No personal dealings with customers
Ethics	Fair and ethical in your dealings with customers	Unauthorized information written or verbal cannot be divulged to any customer / competitor / any other person No information on the customers to be shared with other customers
Information and Confidentiality	Collection interaction should be based on courtesy, fair treatment and persuasion Present all the information required to by the customer in an orderly fashion Loan details should be shared with the customer or the person authorized by the customer only in writing	Do not share the Loan details other than customer without customer consent For Agencies only specific information to be shared which is required for collection of dues.
Process, Discipline	Collectors will perform their role within the framework of the instructions issued to them.	No physical contact with the customer
Timing	Earliest : 08.00 hours IST Latest : 20:00 hours IST	Interact with customer on other time unless customer has specifically requested any other timing.
Mode of Payment /Reconciliation	Customers should be advised to pay through electronic mode, using respective lenders virtual account / UPI links/ Payment Gateway / on Bank Account in name of Company.	No payment should be collected without issuing an authorized receipt
Contact Number	Correct contact number needs to be captured while submitting the proof of payment received. Reference no to be captured and used to get updated contact no of customer	Incorrect contact number should not be captured Contact number of self/other executives should not be captured
KYC Norms	All documents of KYC should be correct & latest details need to be provided	Do not provide any Fake / Incorrect KYC
Leave	An ID Card needs to return to the agency in case of a planned leave more than three days.
Call Recordings	Each & every call made to the customer should be through the recorded phones only & recording need to be store as per norms	Do not call the customer from numbers where a recording facility is not available
Self-Introduction	Introduce yourself & the organization before starting the customer communication during a visit or call	Do not hide your/organization name while making collection visit/call
Miscommunication	All waiver / Settlement approval should be communicated to the customer in written only after taking approval from competent authority from Company.	Do not make a wrong commitment to the customer
Data Security	All sensitive customer-related data should be in safe custody. Customer data will Agencies / others will be shared on need to know basis only	Do not share customer information through unauthorized mediums.

X.        General Terms

1. To verify the details mentioned in the Loan Application company may check about applicant by contacting them at their residence & / or on business telephone numbers & / or physically visiting their residence & / or business addresses through staff or through Agencies appointed for this purpose, if deemed necessary.
2. The customer shall be informed to co-operate if the Company need to investigate a transaction on the customer’s Account & with the police / other Investigative Agencies, if Company need to involve them.
3. Company shall advise the customer that if the customer acts fraudulently, he / she will be responsible for all Losses on his / her Account & that if the customer acts without reasonable care & this causes losses, the customer may be held responsible for the same.
4. Giving Customers information about Products & Services in any of the following Languages English or the appropriate vernacular Language as agreed by customer during application.
5. Company will not discriminate on the basis of Age, Race, Caste, Gender, Marital Status, Religion, or Disability. However, the restrictions on Age/income or any other product based distinction, if any, will be mentioned on Loan Products application form beforehand.
6. Each application shall be considered independently on merit, upon scrutiny of all the information, documents required for verifying identity/ entity and the security to be offered, including guarantees, fetching reports from Bureau’s, etc.
7. Company shall process requests for transfer of a loan account, either from the borrower or from a bank / financial institution, in the normal course.

FORCE MAJEURE

The Various commitments outlined and made by the company are applicable under the normal operating environment. In the event of Force Majeure, the Company will not be able to fulfil the commitments under the Fair Practice Code to the entire satisfaction of the customer/s and the public in general.

The Board of Directors reserves all the right to amend the code from time to time and updated copy of FPC will always be available on the website of the company.