INTRODUCTION

Naman Commodities Private Limited ("the Company") has put in place the Fair Practice Code (FPC) as per the RBI directives and it has been duly approved by the Board of Directors. The Fair Practice Code sets out the principles for fair practices/ standards while dealing with its customers.
The Company has adopted this Fair Practices Code ("the Code") and have implemented it. The Code applies to all categories of products and services offered by the Company (currently offered and which may be introduced in future). This sets minimum Fair Practice Standards (FPC) for the company to follow when dealing with the customers. It provides information to the customers and explains how the company is expected to deal with them on day-to—day basis.
This is an active document and supposed to be updated as and when required. Any regulatory change would impact the Fair Practices Code aspects of the Company would be reflected here. TM FPC provides important information to customers which:

• a) helps customer to choose products and services, which meet their needs and give them clear information explaining the key features of the services and products they are interested in.
• b) inform customers about the documents and information the Company requires from them to establish customer's identity and address and, other documents to comply with legal and regulatory requirements.

OBJECTIVES OF FPC (FAIR PRATICE CODE)

The objective is to provide for transparency in transactions between the company and the end users and to provide well informed business relationships. The Fair Practices Code is adopted by the company to:

• Set minimum standards for dealing with the customers.
• Building customers confidence in the company
• Provide greater transparency enabling customers in having a better understanding of the product.
• Promote fair and cordial relationship between the customers and the company
• Encourage marked forces.

3. AVAILABLE PRODUCT'S:

• a. Personal Loans
• b. EMI Loans
• c. Mutual Funds

KEY COMMITMENTS

The Company's key commitments to customers:

• a)Act fairly and reasonably in all their dealings with customers by
  • • Meeting the commitments and standards specified in the Code, for the products and services which the Company offers and, in the procedures and practices its staff follows.
  • • Making sure that Company's products and services meet relevant laws and regulations.
  • • Company's dealings with customers will rest on ethical principles of integrity and transparency.
• b) Help customers understand how company's product work by:
  • • Explaining their financial implications
• c)Deal quickly and sympathetically with things that go wrong by:
  • • Correcting mistakes.
  • • Handling customer's complaints.
  • • Telling customers' how to take their complaint forward if they are still not satisfied
• d) Publicize the Code, put it on Company's website and have copies available for customer on request.

APPLICATIONN OF CODE (FPC)

The code shall apply to the company and all employees of the company and other persons who are authorized on behalf of the company to represent it during the business.

• A. Applications for loans and their processing
  • a) All communications to the borrower shall be in English.
  • b) The hoan application forms of the Company will include all necessary information which can facilitate the borrower, in making a meaningfül comparison with the similar terms and conditions offered by the company and taking an Informed decision can be taken by the borrower. The loan application form indicates the documents required to be submitted with the application form.
  • c) The Company will have a system of giving acknowledgement for receipt of loan applications which stipulate the time frame within which loan applications will be disposed of.
• B. Loan appraisal and terms/conditions

  The Company will convey in writing to the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application there—of and keep the acceptance of these terms and conditions by the borrower on its record.
  The Company will mention the clause of penal charge which will be charged for late repayment and / or any other default on the part of the customer, in bold in the loan agreement.
  The Company shall furnish a copy of the loan agreement preferably in the vernacular language or as understood by the borrowers along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of the loans.
  The exact due dates for repayment of a loan, frequency of repayment, breakup between principal and interest, examples of SMA/NPA classification dates, etc. shall be communicated to the borrower at the time of loan sanction and at the time of subsequent changes, if any, to the sanction terms/ loan agreement till full repayment of the loan.

• C. Rate of Interest and Penal Charges in Loan Accounts
  • a) The Company shall not introduce any additional component to the rate of interest and ensure compliance to RBI Guidelines on Fair Practice Code in both letter and spirit.
  • b) The quantum and reason for penal charges shall be clearly disclosed by the Company to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on the Company's website under Interest rates and Service Charges.

  A separate Policy on Fair Lending Practice— Penal Charges on Loan accounts has been put in place and duly approved by the Board of Directors in its meeting.
  Note: The charges are subject to revision by the company from time to time prospectively.

• D. Disbursement of loans including changes in terms and conditions
  • a) The Company shall give notice to the borrower of any change in the terms and conditions including disbursement schedule,jnterest rates, service charges, prepayment harges etc. The Company shall also ensure that changeS Winteres€rates and ChargéS are affected only prospectiüély. he loan agreement shall necessary provisions in this regard.
  • b) Decision to recall / accelerate payment or performance under the agreement shall be in accordance with the loan agreement.
  • c) The Company shall release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against borrower. If such right of set off is to be exercised, the borrower shall 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 is settled/paid.
• 6. General Provisions
  • a) The Company will not interfere in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
  • b) In case of receipt of specific request from the borrower for transfer of borrower account, the consent or otherwise i.e., objection of the Company, if any, will be conveyed within 21 days from the date of receipt of request.
  • 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 loans, etc.
  • d) To avoid rude behaviour from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner
  • e) Unless authorised by the customer, Naman Commodities Private Limited treat all personal information as private and confidential.
• 7. Grievance Redressal Mechanism
  • a) The company shall have a Grievance Redressal Forum comprising senior management team namely, managing director, and grievance/compliance officer of the company - to resolve disputes arising, if any in this regard. The said form shall meet within the period of 3 weeks from the date of receiving any grievance intimation. It shall ensure that all disputes arising out of the decision of lending by the company's functionaries are suitably heard and disposed of at least at the next higher level.
  • b) A periodical review of the compliance of the Fair Practices Code and the functioning of the grievance's redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals.
  • The following information shall be displayed prominently, for the benefit of the customers, at all branches / Vlaces Of the Compa y, where businesS istransacted:
• • i. Mrs. Mamta,Dangri; (grivence@caShpey.com) the Grievance Redressal Officer who can be approached for resolution of complaints against the Company.
  • ii. If customer is not satisfied with the compliance officer/Grievance Officer/Officer-in- charge, he/she may contact or write mail to respective Director (pno@ncplnbfc.com).
  • iii. If customer's complaint/concern is not redressed within a period of 30 days, customer can lodge a complaint on RBI CMS portal - https://cms.rbi.org.in Or send complaint form to the below mentioned address: 6, Sansad Marg, New Delhi — 110001.
• 8. Regulation of Excessive Interest Charged
  • The company shall adopt an interest rate model for determining the rate of interest to be charged on loans and advances, processing and other charges considering relevant factors such as, cost of funds, margin and risk premium, etc.
  • a) 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 application form and communicated explicitly in the sanction letter.
  • b) The rates of interest and the approach for gradation of risks shall also be made available on the website of the company. The information published on the website shall be updated whenever there is a change in the rates of interest.
  • c) The rate of interest shall be annualised rate, so that the borrower is aware of the exact rates that would be charges