FAIR PRACTICE CODE

FMEC International Financial Services Limited (“the Company”) is a non-deposit-taking Non-Banking Finance Company registered with the Reserve Bank of India (“RBI”). The company is presently in the business of providing financial services to its various customers.

The Company has put in place the Fair Practices Code (“FPC”) as per the guidelines issued by the Reserve Bank of India for all Non-Banking Financial Companies (NBFCs) vide RBI circular RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 1, 2015.

The FPC sets out the principles for fair practices, transparency & adequate disclosures while dealing with its customers and its stakeholders.

1. KEY COMMITMENTS

The Company’s key commitments to customers:

a) Act fairly and reasonably in all their dealings with customers by:

· Meeting the commitments and standards specified in the Code, for the products and services which the Company offers and in the procedures and practices its staff follows;

· Making sure that Company’s products and services meet relevant laws and regulations applicable to it;

· Company’s dealings with customers will rest on ethical principles of integrity and transparency

b) Help customers understand how the company’s products work by explaining their financial implications

c) Deal quickly and sympathetically with things that go wrong by:

· Correcting mistakes;
· Handling customer’s complaints;
· Telling customers how to take their complaints forward if they are still not satisfied

d) Publicize the Code, put it on Company’s website, and have copies available for customers upon request.

2. INFORMATION

a) The Company shall help its customer choose products and services, which meet their needs and give them clear information explaining the key features of the services and products they are interested in

b) Inform customers about the documents and information the Company needs from them to establish customer’s true identity and address and other documents to comply with legal and regulatory requirements via-a`-vis extent “Know Your Customer” guidelines

3. USING THE APP

a) The company has a digital platform, EmpWel, a mobile app, and web-based platform, and a cutting-edge Fintech product developed and designed to make individuals’ personal financing needs easier and faster. Our customers can avail of financial facilities from us via IOS/Android-based mobile application anytime, anywhere and the entire process starting from the registration – to – Applying for financial services – to – Processing – to – disbursement directly to the bank account of the user, is completely online.

b) All communications to the borrower shall be in English or in the vernacular language or a language as understood by the borrower

c) The application forms of the Company include necessary information 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 borrower. The application form indicates the documents required to be submitted with the application form

d) It issues a written acknowledgment for each application after receipt of the complete information as per the standard application format. Additional information and support documents may occasionally be found necessary in course of processing a customer/borrower application

e) Applications complete in all respects are processed within a reasonable time frame. In case the proposal is not approved by the Company, the borrower is intimated accordingly

4. CUSTOMER COMMUNICATION AND TERMS & CONDITIONS

The Company will convey in the form of SMS/mail to the borrower in English or the vernacular language or a language as understood by the borrower, the amount sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof and keeps the acceptance of these terms and conditions by the borrower on its record.

5. DISBURSEMENT INCLUDING CHANGES IN TERMS & CONDITIONS

a) The Company will give notice to the borrower in English or in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, etc. The Company will also ensure that changes in interest rates and charges are effected only prospectively.

b) Decision to recall/accelerate payment or performance under the agreement will be in accordance with the agreement entered.

c) The borrower shall enter into an agreement containing all standard and specific terms and conditions with Company, and execute the requisite documents, before seeking disbursement

6. INTEREST RATE MODEL & RATE OF INTEREST CHARGES

The average yields and the rate of interest under each product are decided from time to time, giving due consideration to the following factors;

a) The cost of funds on the borrowings, as well as costs incidental to those borrowings, taking into consideration the average tenure, market liquidity and refinancing avenues, etc;

b) Operating cost in our business and maintaining shareholders’ expectations for a reasonable, market-competitive rate of return;

c) Inherent credit and default risk in our business, particularly trends with sub-groups / customer segments of the loan portfolio;

d) Risk profile of customer – stability in earnings and employment, financial position, past repayment track record with us or other lenders, external ratings of customers, credit reports, customer relationship, future business potential, results from digital verifications, etc.

e) Industry trends – offerings by competition

f) Risk categorization of borrowers

1) Weighted Average cost of borrowing

2) Fundraising cost – It includes loan processing fees and brokerage charged by the bank to the company.

3) Opex Cost, It includes license cost, loan origination cost, employee expenses, marketing/advertisement expenses, and other operational costs.

4) Risk Premium, Base risk premium to cover business-related risks and would vary by business, customer segment, geography, sourcing channel, etc.

5) Base ROA, Base Return on assets is the minimum return expected by the company on its assets.

7. GENERAL

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 agreement entered (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company)

b) In the matter of recovery of money, 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. To avoid rude behavior from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner

c) The Company shall not charge foreclosure charges/ pre-payment penalties on term loans sanctioned to individual borrowers

8. GRIEVANCE REDRESSAL MECHANISM

a) The company shall set up a board of directors approved grievance redressal forum within the organization comprising Business Heads, and Heads of Operations to resolve disputes. This forum will ensure that all the disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level

b) There will be a periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals as prescribed by the board of directors

c) The following information / public notice shall be displayed prominently, for the benefit of the customers, at all branches/ places of the Company, where business is transacted:

The name and contact details of the Grievance Redressal Officer who can be approached for resolution of complaints against the Company is as follows:

Name: Mr. Apoorve Bansal
Email: help@empwel.com

9. POSTING ON THE WEBSITE

Fair Practices Code is put up on the website of the Company for the information of various stakeholders.