JFC LEASING PVT. LTD.

Fair Practices Code

This has reference to RBI Circular No. 2011-12/470/DNBS. CC. PD No. 266 /03.10.01/2011-12 dated March 26, 2012, wherein the Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for NBFCs to implement the same. The Fair Practices Code, as mentioned herein below, is in conformity with these Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular. This sets minimum Fair Practice standards for the Company to follow when dealing with customers. It provides information to customers and explains how the Company is expected to deal with them on a day to day basis. It is, and shall be, our policy to make loan products available to all qualified applicants without discrimination on the basis of race, caste, colour, religion, sex, marital status or handicap. Our policy is to treat all the customers consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. We will also communicate our Fair Practices Code to our customers. The code has been developed with an objective of: (a) Ensuring fair practices while dealing with customers. (b) Greater transparency enabling customers in having a better understanding of the product and taking informed decisions. (c) Building customer confidence in the company. The Fair Practice Code (FPC) covers the following areas: 1. 2. 3. 4. 5. 6. 7. Applications for loans and their processing Loan appraisal and terms/conditions Disbursement of loans, including changes in terms and conditions Confidentiality General Practices Regulation of Excessive Interest charged Grievance redressal mechanism

1) Applications for loans and their processing

(a) Loan application forms will include necessary information, which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form will indicate the documents required to be submitted with the application form. The information shall be updated whenever there is a change in the rates of interest.

(b) The company will devise a system of giving acknowledgement for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of will also be indicated in the acknowledgement. (c) Loan Application form will clearly state the information that the company requires to collect from the customer to fulfil the KYC norms and to comply with legal and regulatory requirements. We may request for additional information about the customer and his / her family to build a database; but this information is furnished by the customer only if she / he wishes to do so.

2) 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 annualized rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. The loan sanction letter and all communications to the borrower shall be in the vernacular language or a language understood by the borrower. The Company shall furnish copy of the loan agreement to the borrower at the time of sanction or disbursement of loan.

3) Disbursement of loans including changes in terms and conditions

(a) The penal interest to be charged by the company for late repayment of loan shall be mentioned in bold letters in the loan agreement. (b) The company will give notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. We will also ensure that changes in interest rates and charges are affected only prospectively. A suitable condition in this regard will be incorporated in the loan agreement. (c) Decision to recall / accelerate payment or performance under the agreement will be in consonance with the loan agreement. (d) The loan agreement shall contain a built-in re-possession clause and also contain provisions regarding notice period before taking possession, circumstances under which the notice period can be waived, the procedure for taking possession of the security, a provision regarding final chance to be given to the borrower for repayment of loan before sale/auction of the property, the procedure for giving re-possession to the borrower and procedure for sale/auction of the property. (e) The company will release all securities of its Borrower only on repayment of all dues by such Borrower, or only on realization of the outstanding amount of the Borrowers availed limit, subject to any legitimate right or lien for any other claim which company may have against its Borrower. If such right of set off is to be exercised, the Borrower will be given notice about the same with full particulars about the remaining claims and conditions under which company will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower

4) Confidentiality
(a) Unless authorized by the customer we will treat all personal information as private and confidential

(b) Unless authorized by the customer, we will not reveal transaction details to any other entity including other than the following exceptional cases: If we have to provide the information by statutory or regulatory laws If there is a duty to the public to reveal this information If our interest requires us to provide this information (e.g. fraud prevention) to Banks / Financial Institutions / Our Group and Associate Companies. We will not use this reason for giving information about customers to anyone else for marketing purposes.

5) General Practices
(a) The company will refrain from interference 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 lender). (b) In case of receipt of 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. Such transfer shall be as per transparent contractual terms in consonance with law. (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,.

6) Regulation of Excessive Interest charged

The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges. The Company has adopted an interest rate model taking into account cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances. The rate of interest to be charged depends much upon the gradation of the risk of borrower viz. the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower etc.

7) Grievances Redressal Mechanism & Complaints:

In case of any complaint/grievance, the applicant/borrowers will have to inform in writing . Borrowers and others who have grievances in respect of decisions of JFCs functionaries may address their grievances to Mr. Ashwani Bhaskar, Director, at [email protected].

The Board will periodically review the compliance of this Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.