Fair Practices Code

Last reviewed by the Board: [date to be supplied]. This page is a plain-language statement of our code. It must be reviewed by your compliance adviser and approved by the Board before publication.

1. Purpose

This Code sets out how Heeraa Financial Services Limited ("HFSL", "we") deals with borrowers and prospective borrowers. Its object is straightforward: that a borrower should understand, before committing, exactly what they are agreeing to, and should be treated with courtesy and fairness throughout the life of the facility.

The Code applies to every product we offer and to every member of our staff and any agent acting on our behalf.

2. Applications for loans and their processing

• All communication with a borrower will be in a language the borrower understands — English or Tamil as they prefer.
• Loan application forms will state the information we require, the documents to be submitted, and the fees payable at the time of application, including which of those fees are refundable if the application is withdrawn or declined.
• We will acknowledge receipt of every completed loan application and will indicate the timeframe within which the application will be disposed of.

3. Appraisal and terms and conditions

• Every borrower whose application is approved will receive a written sanction letter, in a language they understand, setting out the amount sanctioned, the annualised rate of interest, the method of application of interest, all charges, and the terms and conditions of the facility.
• Penal charges for late payment will be stated in bold in the sanction letter and in the loan agreement.
• We will obtain the borrower's written acceptance of these terms and retain it on record.
• A copy of the loan agreement, together with copies of every enclosure referred to in it, will be furnished to the borrower at the time of sanction or disbursement.

4. Disbursement and changes to terms

• Disbursement will be made in accordance with the sanctioned terms once the agreed conditions are satisfied.
• We will give notice in a language the borrower understands of any change in disbursement schedule, interest rate, service charges or other terms. Changes to interest rates and charges will be applied prospectively only.
• Any decision to recall or accelerate payment or performance will be taken in accordance with the loan agreement.

5. Release of security

On repayment of all dues, or on realisation of the outstanding amount of the loan subject to any legitimate right or lien we may have against the borrower, we will release all securities within the timeframe prescribed by the Reserve Bank of India. If any right of set-off is to be exercised, the borrower will be given notice with full particulars of the remaining claims and the conditions under which we are entitled to retain the security.

In the case of gold and silver pledged with us, the pledged items will be returned to the pledger against the original pledge receipt and satisfactory identification, and to no other person.

6. Interest rates and charges

• Interest rates are determined by the Board-approved interest rate model, which takes into account our cost of funds, the tenure and size of the facility, the nature and quality of the security, the borrower's credit profile and repayment record, and the applicable regulatory requirements.
• The annualised rate of interest is disclosed in the application, the sanction letter and the loan agreement, so that the borrower is aware of the exact rate being charged.
• Rates and the approach to gradation of risk are made available on this website and at our office, and are updated whenever they change.

Product	Indicative annualised rate	Processing fee
Gold & Silver Lending	[to be supplied]	[to be supplied]
Automobile Finance	[to be supplied]	[to be supplied]
Real Estate Finance	[to be supplied]	[to be supplied]
Corporate Finance	[to be supplied]	[to be supplied]
Micro-Financing	[to be supplied]	[to be supplied]

7. General undertakings

• We will not interfere in the affairs of a borrower except for the purposes provided in the loan agreement, unless information not previously disclosed by the borrower comes to our notice.
• Where a request for transfer of a loan account is received from a borrower, our consent or objection will be conveyed within twenty-one days of the request.
• In the matter of recovery, we will not resort to harassment. This means no persistent calling at odd hours, no use of intimidation, no involvement of a borrower's neighbours or relatives to apply pressure, and no use of muscle power of any description. Recovery staff and agents are trained accordingly and their conduct is our responsibility.
• We will not discriminate on grounds of caste, community, religion, gender or disability in extending credit.

8. Responsible lending conduct

• We will not levy foreclosure charges or pre-payment penalties on floating-rate term loans sanctioned to individual borrowers for purposes other than business, in accordance with RBI directions.
• Penal charges, where applicable, are levied on the amount in default and are reasonable and proportionate. They are not capitalised, and no further interest is computed on them.

9. Confidentiality

Information relating to a borrower is treated as confidential and is not disclosed to any third party except where disclosure is required by law or by a regulator, where the borrower has consented, or where disclosure is made to credit information companies as required under the Credit Information Companies (Regulation) Act, 2005.

10. Grievance redressal

A borrower who is dissatisfied with any aspect of our conduct may raise a grievance. The full procedure, escalation path and timelines are set out on our Grievance Redressal page, including the details of our Grievance Redressal Officer and the route to the RBI Ombudsman if a complaint is not resolved to your satisfaction within thirty days.

11. Review

This Code and its implementation are reviewed by the Board of Directors at least once a year. A consolidated report of such reviews is placed before the Board at regular intervals.