FAIR PRACTICE CODE AND

GRIEVANCE REDRESSAL MECHANISM

Bhanix Finance and Investment Limited

Adopted/ Reviewed by Approved Version Last

Amendment Date by No. Review
by Board Date
07th October 2022 Mr. Jayesh Mr. Dhruv 3 30th
Sharma, Jain, Chief September
Compliance Executive 2022
Officer Officer
 INDEX

Sr. No. Particular Page No.

1 Introduction 3
2 Key Objectives 3
3 Documentation by Way of Electronic/Digital/App Based or Other 3
Means
4 Loan Appraisal and Terms & Conditions 4
5 Disbursement of Loans Including Changes in Terms and Conditions 4
6 Release of Securities 5
7 General 5
8 Interest Rate 5
9 Grievance Redressal Mechanism 6
10 Ombudsman for NBFCs 7
11 Regulation of Excessive Interest Charged 7
12 Confidentiality and Discrimination 7
13 KYC 7
14 Guarantors 8
15 Compliance with the FPC 8

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 FAIR PRACTICES CODE AND GRIEVANCE REDRESSAL MECHANISM
1. INTRODUCTION
The Fair Practices Code aims to provide to all those who will be associated with Bhanix
Finance and Investment Limited (‘BFIL’ or ‘the Company’) with the information about the
practices that BFIL follows in respect of the financial facilities, loans and services provided,
which will facilitate its customers/borrowers to take informed decisions in respect of the
financial facilities and services to be availed of by them. The Fair Practices Code will apply
to any loan that BFIL may sanction and disburse.

BFIL has adopted the Fair Practices Code (the ‘FPC’) pursuant to Reserve Bank of India’s
(‘RBI’) Master Direction - Non-Banking Financial Company - Systemically Important Non-
Deposit Taking Company and Deposit Taking Company (Reserve Bank) Directions, 2016
updated from time to time. The Company would update the FPC to conform with the
standards that may be prescribed by the RBI from time to time. The Company would abide
by this FPC following the spirit of the Code and applicability to its business.

The FPC has been approved by the Board of Directors of the Company and it will be
disclosed on the Company’s website.

2. KEY OBJECTIVES
a) The Company will conduct its business in accordance with prevailing rules and
regulations and corporate governance principles.
b) The Company’s dealings with its customers will rest on the principles of fairness,
transparency and honesty.
c) The Company will assist its customers in understanding the broad features of its
financial products and will provide them with key terms and conditions governing
sanction of credit facilities.
d) The Company will promote fair and cordial relations with its customers/borrowers.

3. DOCUMENTATION BY WAY OF ELECTRONIC/DIGITAL/APP BASED OR OTHER MEANS

a) All communication will be made in a language understood by the customers/borrowers
or in a vernacular language, wherever required.
b) The loan documentation set would, inter alia, include the broad features and the terms
and conditions governing the loan so that a meaningful comparison with the terms and
conditions offered by other NBFCs can be made and an informed decision can be taken
by the customers /borrowers.
c) The loan application form would indicate the documents required to be submitted by
the borrower. It would also indicate the rate of interest that will be charged to different
categories of borrowers.

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 d) An acknowledgement would be provided for all loan applications received along with
completed documents. The Company will indicate the approximate time frame within
which the loan application will be processed post the submission of a completed loan
application form and the borrowers will be informed about the status of their loan
applications within reasonable time. In case of specific app-based/paperless loans
provided, the Company would convey the details through email to the registered email
address of the borrower.

4. LOAN APPRAISAL AND TERMS & CONDITIONS

a) The loan applications would be subject to the Company’s credit appraisal process and
a due diligence on the creditworthiness of the customers/borrowers, which will form
an important parameter for taking a decision on a loan application.
b) BFIL would convey in writing to the customers/borrowers by means of a sanction letter,
the amount of loan sanctioned along with the terms and conditions including the
annualized rate of interest and method of application thereof. In case of specific app-
based/paperless loans provided, the Company would convey the details mentioned
above through email to the registered email address of the borrower.
c) BFIL would keep on its record the acceptance by the customers/borrowers of the terms
and conditions governing the sanction of the loan. In case of app-based/paperless
loans, a request by the borrower to disburse the sanctioned loan amount or part
thereof would be deemed to be acceptance by the borrower of the terms and
conditions governing sanction of loan.
d) At the time of sanction/disbursement of loans, BFIL would furnish to all
customers/borrowers a copy of the loan agreement / terms and conditions (if any)
along with a copy of all enclosures mentioned in the loan agreement.
e) The loan agreement shall expressly stipulate the penal interest chargeable for late
payment / repayment of dues by the borrower, in bold.

5. DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

a) BFIL would frame internal guidelines and procedures for determining and ensuring that
the interest rates and processing and other charges levied on the borrowers are not
excessive.
b) The disbursement will be initiated upon compliance with all the terms and conditions
of sanction of loan by the customers/borrowers. BFIL would give notice to the
customers/borrowers in the vernacular language or a language as understood by the
customers/borrowers of any change to the terms and conditions, including the
disbursement schedule, interest rates, service charges, pre-payment charges, etc.
c) Changes in the interest rates and other charges would be effected prospectively other
than under circumstances arising from regulatory instructions.
d) The decision to recall/accelerate payment or performance under the agreement would
be in consonance with the terms and conditions of the loan agreement.

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6. RELEASE OF SECURITIES
BFIL would release securities (if any) lying with it 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 that BFIL may have against the customers/borrowers. If such right of set off is to be
exercised, the customers/borrowers would be given notice about the aforesaid with full
particulars about the remaining claims and the conditions under which BFIL is entitled to
retain the securities till the relevant claim is settled/paid.

7. GENERAL
a) The Company would refrain from interference in the affairs of the
customers/borrowers, except for the purposes provided in the terms and conditions
of the loan agreement (unless new information, not earlier disclosed by the
customers/borrowers has come to the notice of the Company).
b) In case of a request from the borrower for transfer of the loan account to another
NBFC, bank or financial institution, the Company would convey its decision within 21
days from the date of receipt of request. Such transfer would be in accordance with
the contractual terms entered into with the borrower and in consonance with law.
c) In the matter of recovery of loans, BFIL would not resort to undue harassment, i.e.
persistently bothering the borrower at odd hours, using muscle power for recovery
of loans, etc. The Company would ensure that its employees / recovery agent(s) are
properly trained to deal with customers in an appropriate manner.
d) The Company may arrange to enforce the security provided, if any, by delinquent
customers/borrowers. In all such instances, the Company would ensure that the
entire process of enforcing its security, valuation and realization thereof is fair and
transparent.
e) Cooling off/look-up period means the time window which shall be given to
borrowers for exiting digital loans, in case a borrower decides not to continue with
the loan.
The Cooling off/look up shall be three days for loans having tenor of seven days or
more and one day for loans having tenor of less than seven days. For borrowers
continuing with the loan even after look-up period, pre-payment shall continue to be
allowed as per extant RBI guidelines.
The Company will give option to borrower to exit digital loan by paying principal and
proportionate Annual Percentage Rate (APR) without any penalty during Cooling
off/look up period.

8. INTEREST RATE
a) The Company would lay down appropriate internal guidelines and procedures for
determining interest rates and processing and other charges, keeping in view the
guidelines indicated in the Fair Practices Code.
b) The Company will ensure that it does not unduly charge excessive interest rates to its
borrowers. The interest rate for its customers/borrowers would be arrived at taking
into account the broad parameters such as the risk profile of the
customers/borrowers, interest rate trends prevailing in the money market, cost of
borrowings, primary and collateral security offered by customers/borrowers,
structure of the deal, interest rate charged by competitors and the historical track
record of the customers/borrowers with BFIL.
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 c) Interest rates would be intimated to the customers/borrowers at the time of sanction
/ availing of the loan. The rate of interest would be annualized so that the borrower
is aware of the exact rates that would be charged to the account.
d) The Company would not charge foreclosure charges / pre-payment penalties on all
floating rate term loans sanctioned to individual borrowers.

9. GRIEVANCE REDRESSAL MECHANISM

a) At present, there is a competitive lending business; hence, excellent customer service
is an important tool for sustained business growth. Customer complaints are a part of
business in case of any corporate entity.
b) At CASHe, customer service and satisfaction are the prime areas of focus. The company
believes that providing prompt and efficient service is essential not only to attract new
customers, but also to retain existing ones. CASHe has come up with a lot of initiatives
that are oriented towards providing a better customer experience and an efficient
grievance redressal mechanism with a view to providing an enhanced experience to
customers. In order to make the CASHe redressal mechanism more meaningful and
effective, a structured system has been built. This system would ensure that the
redressal sought is just and fair and is within the given framework of rules and
regulations.

The following is the Grievance Redressal Mechanism for customers:

Escalation of complaints: First Level
The customer/borrower may contact the CASHe officer in case of any query/problem or
grievance. The customer/borrower can:
• Write an email to the email ID: support@cashe.co.in
• Write to the Company through the official website. www.cashe.co.in

The office would be operational between 10.00 am to 6.30 pm from Monday to Friday (except
a Public Holiday)

Escalation of complaints: Second Level

If the customer/borrower is not satisfied with the response received from the Company,
he/she may raise the issue with Grievance Redressal Officer. The name and address and
contact details are as furnished below.
Mr. Prateek Saxena
Bhanix Finance and Investment Limited (CASHe)
5th Floor, Paville House, Twin Tower Lane,
Off Veer Savarkar Marg, Prabhadevi,
Mumbai – 400 025
Telephone No 022-46047350
Email ID: bhanix@cashe.co.in
CASHe shall endeavour to respond to each complaint within one month from the date
of receipt of the complaint.

Escalation of complaints: Third Level

If the complaint is not resolved within a period of 30 (thirty) days, the customer/borrower
may appeal to:
The Officer-in-Charge
Non-Banking Supervision Department, Reserve Bank of India,
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 3rd Floor, RBI Byculla Office Building
Opp. Mumbai Central Railway Station,
Byculla, Mumbai-400 008
Email ID: nbfcomumbai@rbi.org.in
Ph No. 022-2302-8140

10. OMBUDSMAN FOR NBFCs

(1) Reserve Bank – Integrated Ombudsman Scheme, 2021
BFIL covered under the Reserve Bank – Integrated Ombudsman Scheme, 2021 shall
appoint Nodal Officer and Principal Nodal Officer in accordance with directions
provided under the said Scheme.

(2) Appointment of Internal Ombudsman

BFIL may fulfill the criteria laid down under the circular on ‘Appointment of Internal
Ombudsman by Non-Banking Financial Companies’ dated November 15, 2021 shall
appoint the Internal Ombudsman and adhere to the corresponding guidelines as and
when applicable.

11. REGULATION OF EXCESSIVE INTEREST CHARGED

(1) The rate of interest and the approach for gradation of risk and the rationale for
charging a 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.
(2) The rates of interest and the approach for gradation of risks shall also be made
available on the website of the company or published in the relevant newspapers. The
information published on the website or otherwise published shall be updated
whenever there is a change in the rates of interest.

12. CONFIDENTIALITY AND DISCRIMINATION

BFIL shall treat all personal information of customers as private and confidential and shall
not divulge any information to a third person unless required by any law or government
authorities including regulators or a credit agency or where the sharing of information is
permitted by the customer.

BFIL shall not discriminate its customers on the basis of race, caste, gender, marital
status, religion or disability. However, the restrictions (if any) as mentioned in the loan
products shall continue to apply.

13. KYC
BFIL would explain the requirements of KYC Guidelines to its customers and inform them
about the documents required for establishing the identity of the customer before loan
sanctioning, account opening and operation.

BFIL would obtain only such information that is required to meet with the company's
KYC, anti-money laundering or any other statutory requirements. In case any additional
information is asked for, it will be sought separately and shall specify the objective of
obtaining such additional information.

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14. GUARANTORS
When a person is considered to be a guarantor to a loan, BFIL shall inform him/her of the
following under acknowledgement:
a. Letter/Deed of Guarantee stating the terms of liability as a guarantor.
b. BFIL shall keep him/her informed of any default in servicing of the loan by the
borrower to whom he/she stands as a guarantor.

15. COMPLIANCE WITH THE FPC

An annual review of the compliance with the FPC and the functioning of the grievance
redressal mechanism would be conducted. A consolidated report of such review would
be submitted to the Board of Directors every year.

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 Version Control

Sr. No. Version Control No. Date created/ updated

1. Version 1 21st April 2022
2. Version 2 30th September 2022
3. Version 3 07th October 2022

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