Grievance Redressal Policy

CASHTREE Finance Private Limited

Draft for local review. Level 1 and Level 2 contact details are pending confirmation.

INTRODUCTION

Serving customer needs satisfactorily is a top corporate priority for CASHTREE FINANCE PRIVATE LIMITED (henceforth referred to as "Company" or "CASHTREE FINANCE").

An important component of this priority is designing an efficient mechanism to address customer queries and issues.

This policy on Grievance Redressal of CASHTREE FINANCE PRIVATE LIMITED (henceforth referred to as "Company" or "CASHTREE FINANCE") is set out as a mechanism to enable the customers of the company to file their complaints or grievances or give their feedback and suggestions in relation to their dealings with the Company and to address the same promptly, by following the provisions as laid down herein. This Grievance Redressal Policy describes the various channels available to the Company’s customers for lodging their complaints, obtaining the right redressal solutions from the concerned department and the Company’s mechanism for responding to customers within the stipulated time period.

The company has laid down Grievance Redressal Policy (the “Policy”) on the basis of guidelines on Fair practice code and master direction of Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 dated September 1, 2016, issued by Reserve Bank of India (RBI) and Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023. Since RBI would issue circulars and instructions on an ongoing basis, any subsequent amendment to the above circular would update in the Policy accordingly.

1. OBJECTIVE OF THE POLICY

The company believes in providing prompt and efficient services to not only attract new customers but also retain existing ones. With this objective of serving its customers in a time- bound and efficient manner, the Company has drafted this Grievance Redressal Mechanism. The Company’s policy, on grievance redressal has been formulated taking into account the following objectives.

The Company’s policy, on grievance redressal, has been formulated taking into account the following objectives:

• To treat each customer fairly and equally at all times.

• To deal with any complaints raised by customers with courtesy and without undue delay.

• To handle the grievances of pensioners physically challenged and senior citizens on priority basis.
• To inform all customers about the various avenues to escalate their complaints/grievances within the organization and their rights to alternative remedy, if they are not fully satisfied with the response of the company to their complaints.

• To deal with all the complaints efficiently and fairly to protect the reputation and business.

• To ensure that the Company’s employees work in good faith and without prejudice in the best interest of the customers.

In order to make the Company’s redressal mechanism more meaningful and effective, a proper structure shall be implemented to ensure that the redressal sought is fair and within the given framework of rules and regulations of the Company.

The customer shall have the right to register his/her complaint if he/she is not satisfied with the services provided by the company or any other agencies associated with the company.

At CASHTREE Finance, customer service and satisfaction shall be the primary objective. Our constant efforts to ensure utmost client satisfaction will ensure that the redressal sought is just and fair and is within the given framework of rules and regulations.

2. SCOPE OF THIS POLICY

The grievance redressal processes contained in this Policy are applicable to all employees (permanent as well as contractual) and offices of the Company and to all activities where there is an interaction with prospective or existing customers.

A “Customer” is a person or entity that has availed a loan facility from the Company.

A “Complaint” is an expression of dissatisfaction or resentment either in the form of a representation or an allegation made in writing or through an approved electronic channel containing a grievance alleging deficiency in the following areas:  Services, products, policies, and procedures of the Company;

• Employee behaviour towards the customers of the Company; and

• Confidentiality and protection of the personal (including sensitive personal information) and financial information of the Company’s customers.

3.CORE COMMITMENTS

The Company is committed to its objective of ensuring the highest levels of customer satisfaction and has, therefore, set out the following guidelines to be followed for redressal of each complaint by its customers:

A. To act fairly and reasonably in all dealings with its customers by ensuring that:

• All products and services meet relevant laws and regulations, as applicable from time to time;

• Customer dealings are honest and transparent; and
• The process and procedures of the Company are in the best interest of its customers.

B. To assist customers in selecting financial products and services by:

• Providing relevant information in English and/or a local language of choice;

• Explaining the financial implications of any product and service; and

• Allowing the customer to choose the one that meets his/her needs.

C. To make every attempt to ensure that the customers have a trouble-free experience while dealing with the Company and its employees. In case of errors of commissions and/or omissions, the Company will deal with the same on priority by:

• Correcting mistakes;

• Addressing customer complaints;

• Guiding the customer on the escalation process in case of any dissatisfaction; and

• Reversing any charges including interest applied to a customer’s account due to an error or oversight by the Company.

4.GROUNDS FOR FILING COMPLAINTS

Customer can file/register compliant(s) on the following grounds mentioned under clause 8 of Ombudsman Scheme for NBFCs, 2018 In writing containing the nature of grievance/deficiency, inter alia, with regard to:

A. Failure to convey in writing, the amount of loan sanctioned along with terms and conditions including annualised rate of interest and method of application thereof;

B. Failure or refusal to provide sanction letter/ terms and conditions of sanction in vernacular language or a language as understood by the borrower;
C. Failure or refusal to provide adequate notice on proposed changes being made in sanctioned terms and conditions in vernacular language as understood by the borrower;

D. Failure or inordinate delay in releasing the securities documents to the borrower on repayment of all dues;

E. Levying of charges without adequate prior notice to the borrower/ customer;

F. Failure to provide legally enforceable built-in repossession clause in the contract/ loan agreement;

G. Failure to ensure transparency in the contract/ loan agreement regarding

(i). notice period before taking possession of security;

(ii). circumstances under which the notice period can be waived;

(iii). the procedure for taking possession of the security; (iv). a provision regarding final chance to be given to the borrower for repayment of loan before the sale/ auction of the security;

(v). the procedure for giving repossession to the borrower and

(vi). the procedure for sale/ auction of the security;

H. Non-observance of directions issued by Reserve Bank to the non-banking financial companies;

I. Non-adherence to any of the other provisions of Reserve Bank Guidelines on Fair Practices Code for Non-Banking Financial Companies.

5. COMPLAINT FILING CHANNELS

The Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard which ensures that all disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at the next higher level.

The Board of Directors shall also periodically review 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 shall be submitted to the Board at periodic intervals.

In line with the captioned process the Company follows a two-level approach for redressal of customer grievances, as detailed below:

Level 1 -

In case of any service request / complaints, the customer may contact the grievance redressal team on any of the below mentioned contact points:

Grievance Redressal Team :
Name: Pending confirmation

Telephone: Pending confirmation

Email: Pending confirmation

On receipt of service request / complaint, an acknowledgement shall be given within 3 (Three) working days by the company to the customer via e-mail/ letter by post/ SMS/any other form of legally valid electronic communication including WhatsApp. The Company shall endeavour to resolve to the same within a period of 7 (Seven) working days.

However, in case where a complaint warrants extensive investigation and/or support of the customer to identify the perpetrator, root cause analysis, or under litigation (incl. pending with local Police authorities), the TAT for responding and resolving such complaints may be more than 7 (seven) working days.

In case the customer is not satisfied with the resolution/response provided by the customer engagement team/s as above, then customer shall escalate to Level 2 as given below

Level 2 – It may be noted that the customers shall approach for resolution of their service request/complaint at the first instance to the customer engagement team as mentioned in Level 1 hereinabove, and if their request / complaint remains unresolved for a period of 7 days or they are dissatisfied with the resolution given, they are required to contact, he/she may approach the Grievance Redressal Officer (GRO) of the Company:

Name: Pending confirmation

Telephone: Pending confirmation

Email: Pending confirmation