PREAMBLE

The Reserve Bank of India (RBI) has issued guidelines on the Fair Practices Code (FPC) for Non-Banking Financial Companies (NBFCs), establishing standards for fair business and corporate practices while dealing with customers.

In accordance with these guidelines, B P Securities (India) Private Limited (“the Company”) hereby adopts and furnishes its Fair Practices Code (“the FPC”). The Company shall review and update this Code periodically to ensure continued compliance with the standards prescribed by the RBI from time to time.

Considering the nature of the Company’s business, the following Fair Practices Code has been established to govern its lending activities.

Based on the current and proposed business operations, the Fair Practices Code shall apply to the following products and services offered by the Company, both present and future:

• Personal Loan
• Retail Loan
• Business Loan
• MSME Loan
• Gold Loan
• Loan Against Property

Commitments made under the Fair Practices Code are applicable under normal operating conditions.

KEY OBJECTIVES

The key objectives of implementing the Fair Practices Code (FPC) are outlined below:

1. Fair and Reasonable Dealings with Borrowers
   The Company shall act fairly and reasonably in all its dealings with borrowers by ensuring that:
   1. Its products, services, procedures, and practices comply with the principles and standards laid down under the Fair Practices Code;
   2. Its products and services are in full compliance with applicable laws, rules, and regulations in force from time to time;
   3. All interactions with borrowers are based on ethical principles of honesty, integrity, and transparency.
2. Customer Awareness and Understanding
   The Company shall assist customers in understanding the key features, benefits, and risks associated with its financial products and services by:
   1. Providing clear and simple information about products and services;
   2. Explaining the financial implications involved in availing such products and services.
3. Customer Experience and Grievance Redressal
   The Company shall endeavor to ensure a smooth and hassle-free experience for its customers. In the event of any error, omission, or service-related issue, the Company shall:
   1. Address errors promptly and effectively;
   2. Resolve grievances in a timely and efficient manner to the satisfaction of customers;
   3. Handle complaints promptly and courteously;
   4. Maintain a defined escalation mechanism for cases where the borrower is dissatisfied with the resolution of complaints.

APPLICABILITY OF FAIR PRACTICES CODE

The Fair Practices Code (FPC) shall be applicable to the following broad areas:

1. Loan applications and processing thereof
2. Loan appraisal and applicable terms and conditions
3. Disbursement of loans, including any changes in terms and conditions
4. Post-disbursement supervision and monitoring
5. Other general provisions

Loan Applications and Processing Thereof

• Loan application forms shall be made available to prospective borrowers upon request.
• The loan documentation set shall include the key features of the loan along with the applicable terms and conditions. This shall enable borrowers to make an informed decision by comparing the Company’s offerings with those of other lenders in the market. The loan application form shall also specify the list of documents required to be submitted.
• The loan application form may additionally seek further information from borrowers and their family members, as required, to facilitate the creation and maintenance of the Company’s database.
• The loan application form shall include an acknowledgment confirming receipt of the completed application from the borrower.
• All loan applications shall be processed and disposed of within a period of 90 days from the date of receipt of duly completed loan application forms, along with all required documents, in compliance with applicable laws and regulations.
• All communications with borrowers shall be conducted in a language understood and confirmed by the borrower.

Loan Appraisal and Terms & Conditions

• The Company shall evaluate all loan applications in accordance with its risk-based assessment and credit appraisal procedures.
• Prior to sanctioning any loan, the Company shall assess the borrower’s repayment capacity based on applicable credit and financial parameters.
• Upon approval, the sanction of the loan shall be communicated to the borrower through a written Sanction Letter. The borrower shall provide written acknowledgement confirming acceptance of the loan’s terms and conditions. The Sanction Letter shall clearly specify the key terms of the loan, including the annualized rate of interest and the method of its application.
• A copy of the executed loan documents, including the loan agreement and all applicable annexures, shall be provided to the borrower for their records.
• The applicable default interest rate shall be clearly highlighted in bold within the loan agreement.
• In cases where lending is undertaken under a consortium arrangement, the participating NBFCs and/or banks shall jointly determine the timelines for appraisal of the proposal and communication of the decision. The Company shall comply with and adhere to the decision of the consortium.

Disbursement of Loans Including Changes in Terms and Conditions

• Disbursement of the sanctioned loan amount shall be made available to the borrower upon request, subject to completion of all applicable formalities, including execution of the loan agreement and related documentation.
• Any changes in the terms and conditions of the loan, including the disbursement schedule, interest rate, service charges, prepayment charges, or any other applicable fees, shall be communicated to the borrower in writing.
• Any revision in interest rates or service charges shall be applied on a prospective basis only. The loan agreement shall include a specific clause outlining the applicability of such changes.

Post-Disbursement Supervision

• Any decision of the Company to recall the loan or to accelerate the repayment or performance obligations shall be strictly in accordance with the terms and conditions specified in the Loan Agreement.
• The Company shall provide reasonable notice to the borrower before recalling the loan or demanding accelerated repayment or performance, subject to the provisions of the Loan Agreement and other related documents.
• Collaterals held by the Company shall be released upon receipt of full and final repayment of the loan, subject to any legitimate right of lien or set-off arising from other claims the Company may have against the borrower.
  
  However, where the borrower has been provided with a facility allowing drawdown within the overall sanctioned limit from time to time, the Company may retain the collateral for operational convenience and to safeguard its interests against potential default.

Other General Provisions

• The Company shall refrain from interfering in the affairs of the borrower except as expressly provided under the terms and conditions of the loan documents, unless new information, not previously disclosed by the borrower, comes to the Company’s notice.
• The Company shall generally convey its consent within a reasonable timeframe to any request made by a borrower for transfer of their loan account to another NBFC, bank, or financial institution. Such transfers shall be carried out in accordance with the contractual terms agreed with the borrower and in compliance with applicable statutes, rules, regulations, and regulatory guidelines in force from time to time.
• The Company shall not discriminate on the basis of gender, caste, or religion in its lending policies or lending-related activities.
• In matters relating to loan recovery, the Company shall adopt only lawful and legitimate measures in accordance with prescribed guidelines and shall operate strictly within the applicable legal framework.
• The Company shall provide borrowers, upon request, with complete details of the terms and conditions applicable to its lending products and services.
• Upon receipt of a borrower’s request for closure of a loan account, the Company shall process and complete the request within 21 days, subject to settlement of all outstanding dues and completion of prescribed formalities.
  
  If the request cannot be completed within the stipulated timeframe, the reasons for such delay shall be communicated to the borrower in a timely manner.

Confidentiality

• Unless expressly authorized by the borrower, the Company shall treat all personal information of the borrower as private and confidential.
• The Company shall not disclose transaction details or personal information of borrowers to any third party, except under the following circumstances:
  1. Where the Company is required to disclose information to any statutory or regulatory authority;
  2. Where disclosure is required in the discharge of a duty to the public;
  3. Where disclosure is in the interest of the borrower, such as for fraud prevention;
  4. Where the borrower has expressly authorized the Company to share such information with its group companies, associate entities, or any other person or entity, as specifically agreed upon.

Complaints

In the event of any complaint or grievance, borrowers may submit the same in writing to the Company’s Grievance Redressal Officer.

Upon receipt of a complaint, the Grievance Redressal Officer shall make all reasonable efforts to promptly and efficiently resolve the grievance.

The Company’s concerned employees shall provide necessary guidance and assistance to borrowers who wish to lodge a complaint or seek redressal.

Grievance Redressal Mechanism

The Company has established a three-tier Grievance Redressal Mechanism to address and resolve customer queries and grievances in an efficient and timely manner.

Level 1

A dedicated Customer Care facility has been established to provide information, details, data, and documents related to loan activities and to ensure immediate resolution of customer queries and complaints.

• Instant Funds Customer Care Number: +91-9818063925
• Instant Funds Email ID: info@bpsecuritiesindiapvtltd

Level 2

If a customer’s query or complaint is not resolved at Level 1, the customer may register the grievance with the Company’s Grievance Redressal Officer in relation to matters pertaining to business practices, lending decisions, credit management, recovery processes, or issues related to updation or alteration of credit information.

The contact details of the Grievance Redressal Officer are provided below:

• Name: Mr. Kaushalendra Singh
• Address: C-2, 3rd Floor, Sector-2, Gautam Buddha Nagar, Noida, Uttar Pradesh – 201301
• Telephone: +91 9205053697
• Email ID: grievance@https://instantfunds.in/

Level 3

If a customer’s complaint is not resolved within 7 days from the date of escalation at Level 2, the customer may further escalate the matter to the Company’s Nodal Officer for resolution.

The contact details of the Nodal Officer are provided below:

• Name: Rajeev
• Address: C-2, 3rd Floor, Sector-2, Gautam Buddha Nagar, Noida, Uttar Pradesh – 201301
• Telephone: 0120-4262893
• Email ID: bpsecuritiesfunds@gmail.com

Force Majeure

The commitments outlined by the Company under this Fair Practices Code are applicable under normal operating conditions. In the event of any force majeure circumstances, including but not limited to natural disasters, acts of government, or other events beyond the Company’s reasonable control, the Company may be unable to fully meet its obligations or objectives under the Fair Practices Code to the satisfaction of borrowers, stakeholders, and the public at large.

Review of Policy

The Board of Directors has approved this Fair Practices Code (FPC) Policy and holds overall responsibility for the operational oversight of B P Securities (India) Private Limited. The Board shall also ensure that this Policy is reviewed and amended in a timely manner to align with the Company’s operational requirements and any changes or new regulations issued by the Reserve Bank of India (RBI) in relation to its lending activities.