Propelld ("Company" or "Propelld") is a series-B funded Fintech Company that enables flexible financing solutions through fully digital journeys for learners pursuing education programs at vetted partner institutions. Having vertical expertise in the education segment, Propelld provides tailored financing solutions for various educational programs and goes beyond traditional credit parameters to focus on students\' learning capabilities and employment potential to assess their eligibility for a loan, all backed by an agile tech infrastructure. As working with NBFCs is a very crucial part of the operations, Propelld endeavours to review and follow the policy guidelines laid down by RBI to set up fair business practices while dealing with its customers. Accordingly, this Fair Practices Code has been formulated pursuant to the Master Direction dated September 1, 2016 (as amended from time to time) issued by Reserve Bank of India (\"RBI\") for Systemically Important Non-Deposit taking Company and Deposit taking Non-Banking Financial Companies, as amended from time to time. Further RBI vide its Notification No. RBI/2019-20/258 DOR (NBFC) (PD) CC. No.112/03.10.001/2019-20 dated June 24, 2020 has also issued directions for sourcing of loans over Digital Lending Platforms (Digital Lending). The Company shall at all times adopt best business and customer service practices from time to time and make appropriate modifications, as necessary to this Code. The management of the Company will ensure that the implementation of this FPC becomes the responsibility of the entire organization and its employees. The fair lending practices shall apply to its entire business operations including marketing, loan origination, processing, servicing and collection activities. Its commitment to FPC will be demonstrated in terms of employee accountability, training, counselling, monitoring, auditing programs, internal controls, optimal use of technology and empathy to service the needs of its customers. At the same time, we will remain cognizant of our customer's need for privacy and confidentiality for their personal data lending practices shall apply to its entire business operations including marketing, loan origination, processing, servicing and collection activities.
a) Promote good and fair practices by setting minimum service standards in dealing with the customer;
b) Increase transparency so that the customer can have a better understanding of what they can reasonably expect from the services of the Company;
c) Encourage market forces, through competition, to achieve higher operating service standards; and
d) Promote a fair and cordial relationship with the customer.
a) This Code shall apply to all the products and services provided by the Company across the counter, over the phone, by post, through interactive electronic devices, on the internet, or by any other method.
b) This code will be applicable to all our customers (which as the context permits its shall include prospective customers, customers who have applied for loan with us but loan not sanctioned / disbursed in addition to the customers who are in receipt of loan amount from the Non-Banking Financial Companies [NBFCs]).
a) The Company shall always act fair and reasonable in dealings with its customer(s) by adhering to the principles of integrity and transparency at all times.
b) The Company shall meet all the legal and regulatory requirements and fulfil standards provided in this Code while soliciting any products and services.
c) The Company shall ensure that all advertising and promotional material is clear, and not misleading.
d) The Company shall ensure transparency in communication and provide information on interest rates, fees and charges in the loan document or on its website.
e) The Company may, from time to time, communicate to customer about various features of products/services availed by them including information about third party products/services or promotional offers after obtaining prior consent from the customer.
f) The Company shall implement transparent Code of Conduct for its Direct Selling Teams (DST's)/Tele callers/Collection Agencies in line with the FPC.
g) The Company shall always preserve the privacy and confidentiality of personal information provided by Customer as per the laws of the country.
a) As a standard process, all information required for processing the application shall be collected at the time of loan application itself. In case any additional information is required for credit and risk assessment, the customer shall be again immediately contacted.
b) The Company shall conduct a due diligence on the credit worthiness of the customer, which will be an important parameter for taking decision on the application. The assessment would be in line with the partner NBFCs credit policies, norms and procedures in respect thereof.
c) The Company shall convey in writing to the customer in English the Loan Sanctioned along with the Terms & Conditions thereof including annualized RoI, method of application, EMI Schedule, and any other charges if any.
d) The Company shall keep the written acceptance of all these terms and conditions by the customer in its records. Penal interest and late payment charges shall be highlighted in bold to sensitize and clearly convey to the Customers about consequences of delay in payment of periodic instalments and/or any breach of the terms of the loan agreement and sanction letter.
e) The Company shall provide copies of all the loan documents executed by the customer along with a copy of each of its enclosures as per the Loan Documentation to every customer, subsequent to loan disbursement.
a) At the time of giving a loan to the customer, Propelld shall explain to the customer the repayment process including instalment amount, tenure, bounce charges, penal interest and periodicity of repayment. However, if the customer does not adhere to the repayment schedule, a defined process in accordance with the laws of the land shall be followed for recovery of loan dues. The process will involve reminding the customer by sending him / her notice or by making personal visits.
b) In line with the aforesaid, a Code of Conduct which shall be adhered during collections/recovery of dues from the customers by Company's authorized personnel is provided in Annexure A.
Great services help companies to drive the customer acquisition, retention and service efficiency. In line with the said philosophy, in case of any service request/complaints, the customer may contact the customer engagement team on any of the below mentioned contact points:
Propelld Corporate Office, 1st Floor, No: 1614/1615, Enzyme 7th cross, 19th Main Rd, 1st Sector, HSR Layout, Bengaluru, Karnataka - 560102
Additionally, the Company informs the customer about the Grievance Redressal Mechanism which is provided on our partner NBFCs website. On receipt of service request / complaint, an acknowledgement shall be given within 3 working days by us to the customer via e-mail/ letter by post/ SMS/any other form of legally valid electronic communication including WhatsApp. The Company shall endeavour to respond to the same within a period of 10 working days.
However, in case where a complaint warrants extensive investigation and/or support of the customer to identify the perpetrator, root cause analysis, or under litigation (incl. pending with local Police authorities), the TAT for responding and resolving such complaints may be more than 10 working days.
(a) The Company shall not discriminate on grounds of sex, caste & religion in the matters of lending.
(b) All personal information of customer and information related to the transactions with the Company shall be treated confidential, shall not be revealed to anyone, except with customer's prior written consent and/or required by laws and regulations.
(c) The Company shall publicize the Code as under:
- Provide existing and new customer with a copy of this Code, whenever requested;
- Disclose this Code on the website of the Company; and
- Periodic trainings to all the customer facing staff about the fair business practices as mentioned in this Code.
(d) The Company shall periodically review this Code basis its business and regulatory requirements.
(e) Periodic reports on the customer complaints (entailing the number and nature of the complaints received, ageing of complaints, adherence to TATs, root cause details of the complaints in which service deficiencies are found) shall be submitted to the Board of Directors / Audit Committee at regular intervals.
Following Code of Conduct shall be adhered by all authorized personnel of the Company while engaging in any manner with the customer(s) for Collections of loan dues: