Code of Conduct
This has reference to RBI Circular No. DNBS (PD) CC No. 340/03.10.042/2013-14 dated 1st July, 2013, 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 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:
- Ensuring fair practices while dealing with customers.
- Greater transparency enabling customers in having a better understanding of the product and taking informed decisions.
- Building customer confidence in the company.
APPLICATIONS FOR LOANS AND THEIR PROCESSING
- The Company offers various financial products including loans or advances to industrial enterprises and individuals, Loan with or without security, commercial loans among others.
- The ‘Application Form / appropriate documents’ of Capital Trade Links Limited 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 Capital Trade Links Limited 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.
- The ‘Application Form/ appropriate documents’ of Capital Trade Links Limited may also indicate the list of documents required to be submitted by the Borrowers along with the Application form.
- Capital Trade Links Limited has a mechanism of giving an acknowledgement for receipt of Application form to its Borrower for availing loans. Capital Trade Links Limited would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.
LOAN APPRAISAL AND TERMS/ CONDITIONS
Capital Trade Links Limited may 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 discount/ interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on Capital Trade Links Limited’s record. Any clause relating to penal interest charged for late repayment will be specified in the Loan Agreement. Capital Trade Links Limited at the time of sanction / disbursements of loans will furnish a copy of loan agreement to the borrower.
DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS
- Capital Trade Links Limited will give Notice to its Borrower(s) in the vernacular language, of any change in the terms and conditions of the sanction. It will also ensure that changes in discount/ interest rates and charges are effected only prospectively.
- The Company shall issue acknowledgement receipt for all loan applications which will also specify the time frame of issuing such acknowledgements.
- Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective Loan Agreement.
- Capital Trade Links Limited 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 Capital Trade Links Limited).
- In case of receipt of request from the Borrower for transfer of Borrower account, the consent or otherwise i.e. objection of Capital Trade Links Limited, if any, is generally conveyed to such Borrower within 21 days from the date of receipt of the Borrower’s request or within such time as may be agreed between borrower and the company. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.
- In the matter of recovery of outstanding dues of its Borrower, Capital Trade Links Limited does not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc. Training will be imparted to ensure that staff is adequately trained to deal with customers in an appropriate manner.
GRIEVANCE REDRESSAL MECHANISM
In the present competitive scenario, excellent customer service is an important tool for sustained business growth. Customer complaints are part of the business life in any corporate entity. At Capital Trade Links Limited, customer service and satisfaction are our prime focus. We believe that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. Capital Trade Links Limited has come up with a lot of initiatives that are oriented towards providing a better customer experience and an efficient complaints redressal mechanism with a view to providing enhanced experience to our clients.
In order to make Capital Trade Links Limited’s 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 frame- work of rules and regulation.
A. MACHINERY TO HANDLE CUSTOMER COMPLAINTS/ GRIEVANCES
Customers who wish to provide feedback or send in their complaint may write to company at below mentioned address:
Capital Trade Links Limited,
Capital House, B-4,
UGF, Ashoka Niketan,
We assure a response to letters received within 5 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 Capital Trade Links Limited falls. The details of DNBS are given below: Dy. General Manager, Department of Non-Banking Supervision, Reserve Bank of India, New Delhi – 110001
B. MANDATORY DISPLAY REQUIREMENTS
Capital Trade Links Limited has the following at our registered office:
- Appropriate arrangement for receiving complaints and suggestions.
- Display of the name, address and contact number of the Complaint Redressal Officer
The process of the complaints redressal unit will ensure closure of all complaints to the customers’ satisfaction.
They will ensure that the complaint is escalated to the appropriate levels in case it is not possible to resolve at his/her level. Whilst the ultimate endeavor is to ensure we reach a situation where our customers don’t have to complain to senior management to get an effective redressal, we have put in a mechanism to handle these complaints, review them from a point of view of understanding reasons for the complaint and for the escalation and working on prevention of recurrence thereof.
C. TIME FRAME
To register complaints, the clients may use channel mentioned above (refer point (a) on Internal Machinery to handle the customer complaints). If the complaint has been received in writing, Capital Trade Links Limited will endeavor to send an acknowledgement / response within a week. Once the matter is examined, Capital Trade Links Limited endeavours to either send a final response to the client 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 analyzed from all possible angles.
The communication of Capital Trade Links Limited’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 Capital Trade Links Limited in handling complaints / grievances of the customer which includes introduction of new grievance channels, if any.
D. 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.
The rate of interest will be annualized so that the borrower is aware of the exact rates that would be charged to the account.