Fair Practices Code

(Approved by the Board of Directors at meeting held on 10th October,2020)

Introduction

This has reference to Circular No. RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated 1st July, 2015, wherein the Reserve Bank of India (RBI) has revised the 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.

Objective of the Code

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.

(i) Applications for Loans and their processing

(a) Mitron Capital Pvt Limited (“The Company/MCL) offers various financial products including which are meant for Individuals and Businesses. All Official communications to these Borrower shall be in English and MCL will endeavour through its Staff and Partner network communicate with the Borrowers in the local vernacular language if the need be. MCL operates through a trade platforming the name of ‘Mystro’ commonly available at www.mystro.in and Mobile app on Google play store. Mystro is trade platform used for the purpose of loan origination and customer fulfilment. All Loan Underwriting and Credit dispensation is from MCL.

(b) The ‘Application Form / appropriate documents’ of MCL for each of these products offered by the Company is different depending upon the requirement of each product and will include all information that is required to be submitted by the Borrower. Necessary information will be provided by MCL to facilitate the Borrower in making a meaningful comparison with similar terms and conditions offered by other Non-Banking Finance Companies (NBFCs) and taking an informed decision based on the aforesaid comparison.

(c) The ‘Application Form/ appropriate documents’ of MCL may also indicate the list of documents required to be submitted by the Borrowers along with the Application form.

(d) MCL has a mechanism of giving an acknowledgement for receipt of Application from to its Borrower for availing loans. MCL would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.

(ii) Loan appraisal and terms & conditions

MCL shall convey in writing to the Borrower by way of a sanction letter or otherwise, the amount of limit sanctioned along with all 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 MCL’s record. Any clause relating to Prepayment Premium or Penal interest charged for late repayment is specified appropriately in the documentation. MCL at the time of Loan documentation and before disbursements of loans furnishes a copy of loan agreement to the borrower.

(iii) Disbursement of loans including changes in terms and conditions

(a) Since MCL largely is a Digital Loans player and most of its Users are Mobile centric, Users are intimated on each Loan activity including Loan Disbursement and Loan Repayments or prepayments through the Mobile app and various Notifications to the customers on the App. Where ever User are not availing the service through the Mobile app, MCL ensures that the Customers are notified over Email, telephonic intimation (Call, SMS, WhatsApp) or all of this at any time.

(b) Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective Loan Agreement.

(c) MCL 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 Borrower’s availed limit, subject to any legitimate right or lien for any other claim which MCL 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 MCL will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower.

(iv) General

(a) MCL will refrain from interference in the affairs of its Borrower except for the purposes provided in the terms and conditions of the respective loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of MCL).

(b) In case of receipt of request from the Borrower for transfer of Borrower account, the consent or otherwise i.e. objection of MCL, if any, is generally conveyed to such Borrower within 21 days from the date of receipt of the Borrower’s request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws

(c) In the matter of recovery of outstanding dues of its Borrower, MCL does not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc.

(v) Regulation of Excessive Interest charged

The Company has laid down appropriate internal principles and procedures in determining interest rates and processing fee 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 and Operates within a range

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.

(vi) Responsibility of Board of Directors

The Board of Directors of MCL’s has laid down appropriate grievance redressal mechanism in the company. The Board of Directors do periodical review of the compliance of the Fair Practices Code and the functioning of the grievance’s redressal mechanism at various levels of management.

(vi) Grievance Redressal Mechanism

Borrowers and others who have grievances in respect of decisions of MCL’s functionaries may write to us at the below mentioned address: Mitron Capital Private Limited, 904, 9th Floor, Balaji Business Park, M V Road, Opp. Mittal industrial Estates, Andheri (E), Mumbai - 400059, Maharashtra, India.

In case the complaint is not resolved within the given time or if he/she is not satisfied with the solution provided by MCL, the customer can approach the Complaints Redressal Officer. The name and contact of the Complaint Redressal Officer is as follows: Mr. Balakrishnan Nadar ,Mobile No. +91- 9324697648, Email: compliance@mitroncapital.com

In case the response received through the above channels are not satisfactory, customer can write to our Complaint Redressal Head at compliance@mitroncapital.com. We assure a response to letters / emails received through this channel within 7 working days.

If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of RBI under whose jurisdiction the Registered Office of the MCL falls. The details of DNBS are given below:

Asst. General Manager, Department of Non-Banking Supervision Reserve Bank of India, Mumbai Regional Office Third Floor, Byculla Office Building, Byculla, Mumbai 400 008 Email ld: dnbs@rbi.org.in

To register complaints, the customers may use the channels mentioned above. If the complaint has been received in writing, MCL will endeavour to send an acknowledgement / response within a week. Once the matter is examined, MCL endeavours to either send a final response to the customer or an intimation seeking more time within one month upon receipt of complaint. Complaints that are received at our end will be seen in the right perspective and would be analysed from all possible angles.

The communication of MCL’s stand on any issue will be provided to the customers. Complaints that require some time for examination of issues involved will be acknowledged promptly. The aforesaid policy will be reviewed periodically /revised as and when there are any new changes incorporated by MCL in handling complaints / grievances of the customer which includes introduction of new grievance channels, if any. This Fair Practices Code will be available on the website of the company, for the information of its Borrowers and various stakeholders. Any enhancement(s) or change(s) in the scope of this code will be uploaded from time to time in future on the said website.

Key Policy Interest Policy