Fair Practices Code

1. Purpose and Scope

This Fair Practices Code sets out the standards of dealing that Aditi & Anshika Microfinance Private Limited holds itself and its staff to in every interaction with a borrower or prospective borrower. It applies to all our loan products, at every stage — enquiry, application, appraisal, disbursement, servicing, recovery and closure.

The Code is intended to promote fair and transparent dealing, to enable a borrower to make an informed decision before borrowing, and to give every borrower a clear route to complain if these standards are not met. Where this Code is more favourable to the borrower than the minimum required by any law or regulation, this Code prevails.

2. Applications and Their Processing

• All communication with a borrower is in Hindi, or in the local language the borrower understands. Where a document is in English, its contents are explained orally before signature.
• Our loan application form seeks only the information necessary for appraisal, and states the documents required.
• We acknowledge every application received and communicate a decision within a reasonable period, ordinarily within 48 working hours of complete documentation and field verification.
• No fee of any kind is collected for submitting an application or an enquiry.
• Where an application is rejected, the borrower is informed. Reasons are conveyed on request.

3. Appraisal and Terms of the Loan

• Every sanction is communicated in writing by way of a sanction letter and a loan card, in the borrower's language.
• The sanction letter states the sanctioned amount, the annualised rate of interest and the method of application, the tenure, the number and amount of instalments, the due dates, all fees and charges, and the total amount repayable.
• The loan card records all repayments received and the outstanding balance, and carries our grievance redressal contact details.
• A copy of the loan agreement, along with a copy of each enclosure quoted in it, is furnished to the borrower at the time of sanction.
• We do not require a borrower to pledge land, gold, house or other property as security for a microfinance loan.

4. Transparency in Pricing

• Interest is charged on a reducing balance basis. The annualised rate is disclosed, so that it can be compared with any other lender's offer.
• There are only three components of pricing: the interest, a one-time processing fee with applicable GST, and the actual premium for credit-linked insurance where the borrower opts for it. No other charge is levied.
• No security deposit or margin money is collected from the borrower.
• Any penal charge for a delayed payment, and any charge on prepayment or foreclosure, is disclosed in the sanction letter. Nothing that is not written in the sanction letter is payable.
• Interest and charges are not applied retrospectively.

5. Disbursement and Changes in Terms

• Disbursement is made in accordance with the terms of the sanction, ordinarily by credit to the borrower's own bank account.
• Any change in the terms and conditions, including the rate of interest or a service charge, is notified to the borrower in writing before it takes effect.
• Any change in the rate of interest or a charge is applied prospectively only.
• On full repayment, all documents are released and a no-dues confirmation is issued promptly, at no charge.

6. Conduct of Our Staff

• Our field staff carry a photo identity card issued by the company. A borrower is entitled, and encouraged, to ask to see it.
• Staff are trained in this Code, and their conduct with borrowers forms part of how they are appraised. Compensation is not structured so as to reward volume of disbursement at the cost of borrower protection.
• No staff member is authorised to collect any amount in cash for their own account, to demand any payment before sanction, or to ask for an OTP, PIN or password.
• Meetings with a borrower take place at a place and time that is convenient to the borrower, ordinarily at the borrower's residence or place of business.
• We do not use any third-party agent for recovery of microfinance loans.

7. Recovery Practices

Recovery is conducted with restraint and courtesy at all times. The following are expressly prohibited and constitute misconduct:

• Use or threat of violence, or any other conduct intended to humiliate or intimidate a borrower or their family.
• Abusive or obscene language, or persistent calling intended to harass.
• Visiting a borrower before 9:00 AM or after 6:00 PM.
• Publicising a borrower's default to neighbours, employers, relatives or on social media.
• Entering the borrower's home without permission, or removing any article from it.
• Interfering with the borrower's work or business, or approaching the borrower at a place of mourning, illness or bereavement.

Where a borrower faces genuine difficulty in repayment, we will discuss the position with them and, where the circumstances warrant it, consider a practical restructuring of the remaining instalments. A borrower in difficulty is asked to contact us early rather than avoid contact.

8. Avoiding Over-Indebtedness

• Before sanction, we assess household income and existing borrowings, including borrowings from other lenders, so that the total repayment obligation of the household stays within a level it can service.
• We do not lend for the purpose of repaying another lender's loan where doing so would only deepen the borrower's indebtedness.
• A borrower is free to decline a loan at any point before disbursement, without any consequence.

9. Confidentiality of Your Information

Information collected from a borrower is treated as confidential and is used only for credit appraisal, loan servicing, and statutory or regulatory reporting. It is not sold, and it is not shared for marketing purposes. Disclosure is made only with the borrower's consent, or where required by law or by a competent authority, or to a credit information company as permitted by law. Our full practice is set out in the Privacy Policy.

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10. Grievance Redressal Mechanism

If any dealing with us falls short of the standards in this Code, we want to know. A complaint costs a borrower nothing and does not affect the standing of their loan.

Step 1 — Raise it with us

Contact us by any of the following routes. Please give your name, mobile number, and loan account number if you have one.

Step 2 — What we will do

• Acknowledgement of your complaint within 3 working days of receipt.
• Resolution within 30 days of receipt. Where a matter needs longer, we will tell you why and give a revised date.
• A written reply stating the outcome and, where a complaint is not upheld, the reasons.
• A record of every complaint and its resolution, reviewed periodically so that recurring causes are fixed and not merely settled case by case.

Step 3 — If you remain dissatisfied

If your complaint is not resolved to your satisfaction, you may escalate it in writing to the Board of Directors at the registered office address above, marked for the attention of the Directors. You also retain every remedy available to you in law, including approaching the appropriate consumer forum or regulatory authority having jurisdiction over the matter.