Recapita Finance
Governance & Disclosures

Fair Practices Code

How we deal fairly and transparently with customers across marketing, origination, servicing and collections.

Board-approved policy

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Approved by the Board
11 October 2024
Version
1.1
Effective
11 October 2024
Owner
Audit & Compliance Department

Regulatory reference: RBI/DoR/2023-24/106, DoR.FIN.REC.No.45/03.10.119/2023-24 — Master Direction, Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 dated 19 October 2023.

Preamble

Recapita Finance Private Limited (“Recapita Finance” or “the Company”) is a Non-Banking Financial Company registered with the Reserve Bank of India and classified as a Base Layer NBFC under the RBI Scale Based Regulation Directions, 2023. This Fair Practices Code is adopted pursuant to the RBI model guidelines and sets the standards of fair business and corporate practice the Company follows in dealing with its customers. The Code applies to all categories of products and services offered by the Company and is published on our website.

Scope

The Company’s fair lending practices apply across all operations, including:

  • Marketing
  • Loan origination
  • Processing
  • Servicing and collection activities

Objectives

  • Promote transparency in our operations.
  • Ensure fair treatment of all customers.
  • Establish a framework for ethical conduct.
  • Comply with all regulatory requirements.

Key aspects

  • Professional, efficient, courteous and speedy service.
  • No discrimination on the basis of religion, caste, sex or descent.
  • Fairness and honesty in the advertising and marketing of loan products.
  • Timely and accurate disclosure of terms, costs, rights and liabilities.
  • Assistance and advice to customers seeking loans.
  • A board-approved grievance redressal mechanism.
  • Compliance with all regulatory requirements in good faith.
  • Governance structures for oversight in audit and risk management.
  • Ensuring funds do not support companies using child or forced labour.
  • Adherence to the regulations prescribed by the Reserve Bank of India.

Guidelines on the Fair Practices Code

Loan applications and processing: All communication to the customer is in a vernacular language or a language understood by the borrower. The Company provides all necessary information along with the term sheet — including the nature of security required, fees/charges payable for processing, the non-refundable nature of fees, pre-payment options and the checklist of papers required — so that a meaningful comparison can be made and an informed decision taken. Loan applications are disposed of within 60 days of receipt of all required information, or such time as mutually agreed with the customer.

Loan appraisal, terms and conditions: Key terms and conditions are conveyed in writing through a sanction letter or term sheet, including the amount sanctioned and the annualised rate of interest. Penal charges for late repayment are stated in percentage per month/annum and are mentioned in bold in the loan agreement. Wherever possible, reasons for rejection of a loan are conveyed to the customer.

Disbursement and changes in terms: The Company gives notice of any change in the terms and conditions, including the disbursement schedule, interest rates, service charges and prepayment charges. Changes in interest rates and charges are effected prospectively. All communication relating to the sanction is in writing and preserved for a minimum of eight years.

Post-disbursement and release of securities: The Company does not interfere in the affairs of the borrower except as provided in the loan agreement. Any decision to recall or accelerate payment is in consonance with the loan agreement and preceded by notice. On repayment of all dues, all securities are released, subject to any legitimate right of set-off, of which the customer is given notice with full particulars.

Collection of dues: Where a customer does not adhere to the repayment schedule, a lawful recovery process is followed — reminders, notices and/or personal visits, and repossession of security where applicable. The Company ensures its recovery process does not involve harassment, and staff are instructed to handle customer queries and grievances cordially.

Confidentiality: All personal information of the customer is kept confidential and is not disclosed to any third party unless agreed in writing, except to law-enforcement agencies, credit information bureaus, the RBI, other regulators, or where the Company is compelled by law or it is in the public interest.

Handling complaints and grievances

Recapita Finance operates a structured grievance redressal mechanism that acknowledges and resolves customer complaints within 7 working days, keeping customers informed throughout. Grievances may be submitted to the Grievance Redressal Officer:

  • Name: CS Anshita Khare, Grievance Redressal Officer
  • Email: grievanceofficer@recapitafinance.com
  • Phone: 0755-4923303 / 9479395261

Monitoring, review and force majeure

The Company conducts regular audits and reviews to ensure compliance with this Code and RBI regulations, and is committed to continuous improvement based on customer feedback and regulatory change. This Code is reviewed at least annually. The Company shall not be held liable for any failure to perform its obligations during a Force Majeure Event (such as natural disasters, war or civil unrest, government restrictions, or epidemics/pandemics), and will take reasonable steps to mitigate the impact and keep affected customers informed.

This Code is published in English and Hindi. Approving authority: Board of Directors. Reviewing authority: Audit & Compliance Department.