FAIR PRACTICES CODE

PREAMBLE

It is, and shall be, the policy of Vintage Securities Limited (VSL) to make available to all eligible qualified applicants, without discrimination on the basis of race, caste, colour, religion, sex, marital status, age or handicap all financial products, either directly or through subsidiaries and / or associates.

VSL's policy is to treat all the clients consistently and fairly. The employees of VSL will offer assistance, encouragement and service in a fair, equitable and consistent manner. VSL also communicates its Fair Practices Code (FPC) to its customers by uploading the FPC on its website.

VSL will ensure that the implementation of the FPC is the responsibility of the entire organisation. VSL's fair lending ractices shall apply across all aspects of its operations including marketing, loan origination, processing, servicing and collection activities. Its commitment to FPC will be demonstrated in terms of employee accountability, training, counselling, and monitoring, auditing programs and internal controls, and optimal use of technology.

VSL's Board of Directors and the management team are responsible for implementing the fair practices hereinafter detailed, and also to ensure that its operations reflect its strong commitment to all the stakeholders for offering in fair and equitable manner, the various financial services and products including lending and that all employees are aware of this commitment.

The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non Banking Finance Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers. The Company shall adopt all the best practices prescribed by RBI from time to time and shall make appropriate modifications, if necessary from time to time to this Code to conform to the standards so prescribed.

(1)Application for Loans and their processing

(a) Application form for loans should include necessary information which affects the interest of the borrowers. All the terms and condition for loans to be advanced should be detailed in the application form itself. The loan application form will indicate the documents required to be submitted for processing the application.

(b) The Company will issue acknowledgement for receipt of all loan applications and such acknowledgement will also indicate the date within which the application will be disposed off which in normal case shall not exceed 30 working days from the date or receipt of the completed form.

(c) The Company will inform in writing to the borrower by means of a sanction letter the amount of loan sanctioned and all the terms and conditions including annualized rate of interest and method of application thereof. The company will keep the acceptance of these terms and condition by the borrowers on its record. The loans shall be disbursed only on receipt of such disbursement.

(2)Disbursement of loan including changes in terms and condition.

(a) The Company will give notice to the borrowers of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. Any change in interest rates and charges shall be effective only prospectively. An express condition in this regard will be incorporated in the loan agreement. Any decision to recall/ accelerate payment or performance under the agreement will be in consonance with the loan agreement.

(b) The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim which, the company may have against borrower. If such right of setoff is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the condition under which the company is entitled to retain the securities till the relevant claim is settled/ paid.

(3)General

(a) The company will not interfere in the affairs of the borrowers except for the purposes provided in the terms and condition of the loan agreement (Unless new information, not earlier disclosed by the borrower, has come to the notice of the lender)

(b) In case of receipt of request from the borrower for the transfer of borrowal account the consent or otherwise i.e., the objection of the company, if any, should be conveyed with in twenty one days from the date of receipt of the request. Such transfer shall be as per transparent contractual terms in consonance with law.

(c) In the matter of recovery of loan 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) The Board of Directors of the company will constitute a grievance redressal committee comprising, among others, at least one of the director, to resolve disputes arising in this regard. Such a mechanism should ensure that all disputes arising out of the decision of lending institution functionaries are heard and disposed off at least at the next higher level. The Board of Directors should also provide for periodical review of the compliance of the fair practice code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews may be submitted to the board at regular intervals, as may be prescribed by it.


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