FAIR PRACTICE CODE-MFI


A) PREAMBLE ⁄ INTRODUCTION

The Fair Practice Code (FPC) has been formulated by SAVE MicroFinance Pvt. Ltd (the Company) in response to guidelines issued by Reserve Bank of India titled “Guidelines on Fair Practices Code for NBFCs”.

The FPC will be applicable to all the offices of the Company including the Head Office and the Regional Offices located in various centres and the Branches located across India. The FPC shall be binding on all the employees and officers of the Company.


B) OBJECTIVES

The objectives of the FPC are as under.

  • Adopt the best practices in dealings with customers.
  • Set challenging benchmarks and strive to achieve high operating standards for ensuring customer satisfaction.
  • Follow transparent, fair, ethical and legally tenable practices while conducting business
  • Provide all necessary information and inputs to customers / prospective customers and promote a mutually beneficial long term relationship
  • Facilitate a continuously growing base of satisfied customers while scrupulously avoiding acquisition of customers having doubtful credentials or criminal background.

C) DECLARATIONS & COMMITMENTS

  • The Company undertakes to abide by all applicable laws, regulations and guidelines passed / issued by the Regulators (Reserve Bank of India, SEBI, IRDA etc.) and other competent authorities such as Government, Local Authority etc.
  • The Company commits itself to full customer satisfaction through efficient, professional and courteous services across all its offices.
  • The Company shall consistently strive to meet with and improve upon the internally set benchmarks and practices and be ahead of the standards prevalent in the industry.
  • he Company undertakes not discriminate customers on grounds of religion, caste, gender or language.
  • The Company will provide clear and full information about its products and services to its customers / prospective customers and will not resort to any misleading or potentially misguiding advertisement or publicity.
  • The Company undertakes to desist from introducing any products / services having elements of ‘hidden charges’ or lack of transparency.
  • The Company will communicate in the local language with the customer and in English at the request of the customer
  • The Company undertakes to take all possible and reasonable measures to secure the safe custody of the security pledged by the customer and to compensate the customer for any accidental, inadvertent or fraudulent loss of the security whilst in the custody of the Company.
  • The Company undertakes not to take advantage of any unintentional or clerical error made by the customer while transacting business.
  • The Company is committed to put in place a system for promptly addressing complaints and suggestions of the customers supplemented with a structured Grievance Redressal Mechanism having an escalation matrix.
  • The Company shall display the FPC on its website and also make available to the Customer, on request, a copy of the FPC on demand.

D) FAIR PRACTICES


I. LOANS, TERMS & CONDITIONS, INTEREST RATE & CHARGES

The Company shall make available loan application forms in local language to all prospective customers free of cost at the concerned branches mentioning also the supporting documents to be submitted along with. An acknowledgement for receipt of duly completed loan application forms will be given to the customer in all cases. As a matter of policy and customer service loan applications are sanctioned / rejected immediately. Disbursement of the loan and acceptance of security will be carried out nearly simultaneously.

The Company shall disclose all relevant information relating to a loan / product such as eligible loan amount, interest rate, charges, penal/overdue interest, interest calculation methodology, rebate on interest etc. before sanction of the loan to enable the customer / prospective customer to take an informed decision. The Customer / prospective customer will also be provided, on request, the detailed terms and conditions of the loan before sanction. The Company shall ensure that a loan sanction letter (pawn ticket) is given to the customer containing all the terms and conditions governing the loan facility in the local language or other language understood by the customer. The loan sanction letter (pawn ticket) will also mention the loan amount, loan account number, interest rate, charges, loan processing fees etc. The loan sanction letter (pawn ticket) which will bear the signature of the authorized official of the company will also serve as a receipt for the security (gold) pledged at the branch by the customer.

The Company shall not in the normal course make any changes / modifications in the terms and conditions of the loan, including rate of interest, which could adversely affect the customer financially or otherwise. In abnormal circumstances when such changes / modifications are inevitable, keeping in view the new circumstances, adequate and proper notice shall be given to the customer about any such change/modification.


(II) MARKETING & PROMOTION

The Company shall not deliberately promote a product with any ulterior / selfish motives or contrary to the customer requirements or expectations as disclosed by the customer. The Company will ensure that its personnel engaged in marketing and operations are suitably trained and instructed so as to preclude selling of its products by misrepresentation to the customer / prospective customer.

The Company will not indulge in profiteering by charging usurious rates of interest on loans or take undue advantage of adverse market conditions. The rates of interest will be based on variables such as cost of funds, risk premium, loan scheme, loan per gram, profit margin etc. and shall be in conformity with the Interest Rate policy of the Company and Regulatory Guidelines from time to time. It shall also, by and large, be in tune with industry practices and benchmarks.

Full and updated information regarding loan schemes, rate of interest, loan per gram, charges etc. will be displayed on the website of the Company and also displayed in the branches. Complete or select information will also be made available through various media channels, posters, brochures, notices, displays etc. based on the decisions of the management of the Company from time to time.


(III) RECOVERY OF DUES, EXERCISE OF LIEN & DELIVERY OF SECURITY

The Company will not, as a matter of fair dealing, normally recall the loan before the initially agreed tenure except in unanticipated or abnormal circumstances where the Company’s interests are adversely affected e.g. when the security value diminishes substantially, due to any regulatory / government directives etc. In all such cases proper and reasonable notice shall be given to the customer recalling the loan before expiry of the normal tenure.

The Company will make all possible soft or persuasive efforts to get the customer to repay the dues without resorting to disposal of the security. The Company does not accept nor will it encourage the use any coercive or hard measures to recover its dues from the customer.The Company will deliver the security to the customer immediately upon settlement of the loan in the same condition as was at the time of sanction of the loan. In case of any damage caused to the security due to mishandling by its employees, the Company shall at its cost get the damage repaired or alternately pay reasonable compensation to the customer on a case to case basis. If the security has signs of damage thereon, before being taken custody of by the Company at the time of sanction of loan, the fact will be briefly incorporated in the sanction letter.

The Company will exercise only legitimate right of lien over the pledged security or such cash surplus as may arise upon settlement of existing loans at any time. Such right of lien shall arise only if the customer has any other dues, either directly or as guarantor, and will be subject to proper intimation of such right of lien being given to the customer by the Company.

The Company shall issue a signed and, normally, a system generated receipt for all cash payments made by the customer immediately. The Company shall also accept payments vide cheques, demand drafts, electronic transfers etc.

Even though the loan sanction letter contains all applicable terms and conditions of the loan the Company shall, nevertheless, endeavour, on a best effort basis, to send advices, reminders etc. regarding due date for payment of interest, principal etc. by letter, courier service, telephone , SMS etc.

The Company shall, on demand, provide the customer or his duly authorized representative with a statement of the loan account at any time during the currency of the loan or immediately upon closure.

The Company will resort to disposal of security only as a last resort and that too after adequate and proper notice is served on the customer to repay the dues. Such notice will be as per the terms contained in the sanction letter and also in compliance with applicable laws and regulatory guidelines. The disposal of the security will be taken up through public auction when the customer does not positively respond to the communications sent by the Company to close the loan account along with interest and other charges.

Where the Company proposes to dispose of the security even before the normal tenure of the loan based on the rights conferred on the Company vide loan application and loan sanction letter adequate and proper notice will be served on the customer before such action is initiated for recovery of dues.

The Company prefers and encourages customers to take back delivery of the security immediately upon full settlement of all dues. However, should there be exceptional instance of the Customer being unable to take delivery of the security, not attributable to the inability of the Company, after closure of the loan account reasonable safe custody charges may be payable which will be duly advised to the customer or displayed in the branch premises and the Company’s website.

The Company will not interfere in the affairs of the customers except for the purposes mentioned in the terms & conditions of the loan or when constrained to do so due to inadequate or false disclosures made by the borrower at the time of putting through the transactions.


(IV) CUSTOMER SERVICE & GRIEVANCE REDRESSAL

The Company will implement all possible steps to prevent and minimize customer complaints / grievances

The Company will facilitate the customer to pay the whole or part of the dues at any of the branches of the Company subject to the condition that delivery of the pledged security shall be made only at the branch where loan was originally disbursed.

The Company will put in place an effective Customer Grievance Redressal mechanism details of which will be displayed on the website and in all the branches. The mechanism will specify interalia the names & designations of the officials with whom complaints can be registered, their postal address / telephone numbers/ email address, escalation matrix, time limit for acknowledging receipt of complaint, time limit for dealing with the complaint etc. It will also put in place at all offices where business is transacted, the complete contact details of the Regional Office of RBI, within whose jurisdiction the registered office of the company is situated, so that the customers may directly approach the RBI in case their grievances are not redressed within one month of the receipt of complaints by the company"

The Company will put in place an effective training system to ensure that employees of the Company are customer friendly and do not resort to rude, inappropriate or unethical behaviour.

The Company will endeavour to work out and display the time norms for putting through and completing the various transactions.

The Company will have a sympathetic approach to the problems faced by the customer especially the poor and underprivileged sections.


(V) REPOSSESSION OF SECURITY (COMMERCIAL VEHICLES)

The Company reserves the right to enforce security for recovery of dues on the terms and conditions stipulated in the loan agreement in case of default in payment or on the occurrence of any other event of default. During recovery of loans, the Company will not resort to undue harassment like bothering the borrowers at odd hours or use of force for recovery of loans.

The Company would refrain from intervening in the affairs of the borrowers except as provided in the terms and conditions mentioned in the loan agreement, unless new information, not disclosed by the borrower, has come to the notice of the Company.

The Company would not discriminate on grounds of sex, caste and religion in the matter of lending.

In case of receipt of request for transfer of borrower account, either from the borrower or from a bank/non-banking finance company, which proposes to take over the account, the consent or otherwise i.e. objection of the Company, if any, would be conveyed within 21 days from the date of receipt of request.

Repossession of security is aimed at recovery of dues and not to deprive the borrower of the security. The recovery process through repossession of security will involve repossession, valuation of security and realization of security, through appropriate means. All these would be carried out in a fair and transparent manner. Repossession will be done only after issuing proper notices. Due process of law will be followed while taking repossession of the security.

The Company will take all reasonable care for ensuring the safety and security of the collateral after taking custody, in the ordinary course of the business. An appropriate grievance redressal mechanism would be put in place whereby disputes arising out of the decisions of Company’s functionaries would be heard and disposed off.


(VI) MISCELLANEOUS

The Company shall display the normal business hours at the respective branches, the list of holidays and notify the changes, if any, by way of a notice displayed in the premises of the branch or through press notification.

Personal information of the customer will not be shared with unauthorized persons or agencies or third parties by the Company. However, the Company will be bound to honour and comply with legal or regulatory requirements, if any, in this matter obligating it to part with such information even without notice to the customer.

Wherever locker facility is extended by the Company through its branches, it shall be ensured that appropriate disclosure are in place to communicate to the customers that the activity is not regulated by the Reserve Bank.


FAIR PRACTICE CODE-NBFC


A) PREAMBLE ⁄ INTRODUCTION

The Company endeavours to review policy guidelines on ‘Fair Practices Code’ (FPC). The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Financial Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers. The Company shall adopt all the best practices prescribed by RBI from time to time and shall make appropriate modifications if any necessary to this Code to conform to the standards so prescribed.


It is, and shall be, the policy of Save Financial Services Private Limited to make available to all eligible qualified applicants, without discrimination on the basis of race, caste, colour, religion, sex, marital status, age or handicap all financial products, either directly or through subsidiaries and / or associates.


The Company’s policy is to treat all the clients consistently and fairly. The employees of the Company will offer assistance, encouragement and service in a fair, equitable and consistent manner. The Company will also communicate its Fair Practices Code (FPC) to its customers by uploading the FPC it on its website.


The Company will ensure that the implementation of the FPC is the responsibility of the entire organisation. The Company’s fair lending practices shall apply across all aspects of its operations including marketing, loan origination, processing, and servicing and collection activities. Its commitment to FPC will be demonstrated in terms of employee accountability, training, counselling, and monitoring, auditing programs and internal controls, and optimal use of technology.


The Company’s Board of Directors and the management team are responsible for implementing the fair practices hereinafter detailed, and also to ensure that its operations reflect its strong commitment to all the stakeholders for offering in a fair and equitable manner, the various financial services and products including lending and that all employees are aware of this commitment.


This Fair Practices Code applies to the following categories of products and services offered by us (currently offered or which will be introduced at a future date).

  • Loans, guarantees and other products in the nature of financial assets.
  • Products offered through a network consisting of the branches of the Company, its subsidiaries and associates.

  • The FPC is applicable to the above irrespective of whether the same is provided physically, over the phone, on the internet or by any other method whatsoever, existing or futuristic.


    Key Commitments

      The key commitments which the Company promises to follow in its dealings with its customers are:

    1. To act fairly and reasonably in all dealings with its customers by ensuring that:
      • Its products, services, procedures and practices will meet the commitments and standards in this FPC
      • Its products and services will meet relevant laws and regulations in letter and spirit as applicable.
      • Its dealings with its customers will rest on ethical principles of honesty, integrity and transparency.
    2. The Company will assist customers in understanding how its financial products and services work by:
      • Providing information about them in simple Hindi and/or English and/or the local language.
      • Explaining their financial implications and
      • Helping the customer choose the one that meets his / her needs.
    3. The Company will make every attempt to ensure that its customers have a trouble-free experience in dealing with it; but in the case of errors or commissions and omissions, the Company will deal with the same quickly and sympathetically.
      • Mistakes will be corrected quickly.
      • Complaints will be handled quickly.
      • In case a customer is not satisfied with the way a complaint is handled, the Company will guide the customer on how to take the complaint forward.
      • The Company will reverse any charges including interest applied to a customer’s account due to an error or oversight on its part.

    Sales Origination

      The Company will guide its customers in choosing products and services which meets his / her requirements

    1. Before the customer relationship is established, the Company will:
      • Give the customer information explaining the key features of the services and products the customer has shown interest in.
      • Give information on accounts, products and services which will suit the customer’s needs
      • Clearly state the information that the Company requires to collect from the customer to fulfil its ‘Know Your Customer’ norms and to comply with legal and regulatory requirements in force from time to time.
      • Request for additional information about the customer and his / her family to build a database; but this information will be furnished by the customer only if she / he wish to do so.
    2. The Company will provide information on the various channels that can be used to access its products and services. The customer will also be informed on where further information on this is available.
    3. Once a customer has chosen a product, the Company will tell the customer how it works.
    4. The Company will guide its customer on rights and responsibilities specific to the mode of operation under which the product is taken.

    Loans and Advances


    Before offering any kind of fund based or non-fund based non-banking facility the Company will assess the ability of the customer (prospective borrower) to repay.

    Application for loans and their processing

    1. Loan application forms of the Company will include necessary information which are likely to affect the interests of the prospective borrower, so that a meaningful comparison with the terms and conditions offered by other Non- Banking Financial Companies can be made and an informed decision taken by the prospective borrower.
    2. The loan application form shall indicate the documents required to be submitted along with the application form.
    3. The Company shall provide to the prospective borrower an acknowledgement for receipt of all loan applications. An indicative time frame within which loan applications will be disposed of will be mentioned in such acknowledgement.
    4. All communications to the borrower shall be in the vernacular language or a language as understood by the borrower

    Loan Appraisal & terms/ conditions

    Save Financial Services Private Limited shall convey in writing to the borrower in the vernacular language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. As complaints received against NBFCs generally pertain to charging of high interest / penal interest, Save Financial Services Private Limited shall mention the penal interest charged for late repayment in bold in the loan agreement.

    Appropriate internal principles and procedures for determining interest and other charges shall be laid down and be subjected to review keeping in view the business exigencies, regulatory and customer sentiments, market practices etc. The acceptance of the terms and conditions communicated by the borrower shall be preserved by the Company in its records.

    Save Financial Services Private Limited shall furnish a copy of the loan agreement preferably in the vernacular language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.


    Disbursement of loans including changes in terms & conditions

    1. The Company shall give notice to the borrower in the vernacular language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company shall ensure that changes in interest rates and other charges are effected only prospectively. The loan agreement shall contain a specific clause to this effect.
    2. The decision of the Company to recall / accelerate payment or performance shall be in consonance with the terms of the loan agreement.
    3. The Company shall release all securities upon repayment of all dues or on realisation of the outstanding amount of loan subject to any Legitimate right or Lien for any other claim it will have against borrower. In case such right of set off is to be exercised, the borrower shall be given due notice with full particulars about the outstanding claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/paid.

    General

    1. Save Financial Services Private Limited shall refrain from interfering in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement, unless new information, not earlier disclosed deliberately or otherwise by the borrower, has come to its notice.
    2. In case of receipt of request from the borrower for transfer of a borrower account to other NBFC, bank of financial institution, the consent or otherwise shall be conveyed within 21 days from the date of receipt of such request. Such transfer shall be in accordance with the contractual terms entered into with the borrower and in consonance with the statutes, rules, regulations and guidelines as will be applicable from time to time.
    3. In the matter of recovery of loans, the Company shall resort only to remedies which are legally and legitimately available to it and will avoid using recovery measures during odd hours of the day, undue harassment and use of muscle power for recovery of loans. Save Financial Services Private Limited shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
    4. There shall be no discrimination in extending products and facilities including loan facilities to the physically / visually challenged applicants on grounds of disability.

    Terms and Conditions

    1. When a customer accepts a product or service for the first time, the Company will provide the customer with the Rules and Regulations that are relevant to the product / service.
    2. All Terms and Conditions will be fair and will set the customers rights and responsibilities clearly and in plain language, the Company will use legal or technical language only where necessary.
    3. The Company will make available any charges applicable to products and services applicable
    4. If the Company increases any charges or introduces a new charge. The Company will notify the same to the customers.
    5. The Company will provide the terms and conditions in respect of any product or service whenever a customer requests for the same.

    Marketing and Product Synergy

    1. The Company will ensure that all advertising and promotional material is clear, fair reasonable and not misleading.
    2. The Company will provide the customers with a full range of financial products the customer is eligible for. Some of these products / services will be its own; some others will be the products of the group or associate companies and also companies with which the Company will have arrangements with.
    3. It will be the endeavour of the Company to bring synergy between the various financial services, financial products, by cross selling these products to its clientele.

    Confidentiality

    1. Unless authorized by the customer the Company will treat all personal information as private and confidential.
    2. The Company will not reveal transaction details to any other entity including within the group other than the following exceptional cases:
      • If the Company have to provide the information by statutory or regulatory laws,
      • If there is a duty to the public to reveal this information.
      • If its interest requires us to provide this information (e.g. fraud prevention).
      • The Company will not use this reason for giving information about customers to anyone else (including group companies) for marketing purposes.
      • If customer has given consent / concurrence to provide/ share such information to its group / associate / entities or companies for providing other products or services.
      • Where the customer asks us to reveal such information to its group / associate / entities or companies for providing other services or products

    Grievance Redressal Mechanism

    The Company shall also lay down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard. Such a mechanism shall ensure that all disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level. The Board of Directors shall also provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.

    1. The Company will guide customers who wish to lodge a complaint and also provide guidance on what to do in case the customer is unhappy with the outcome.
    2. After examining the matter, the Company will send a response as soon as possible; the Company will also guide a customer on how to take the complaint further if the customer is not satisfied.
    3. A nodal officer shall be appointed for the redressal of grievances of the customers including the borrowers, in connection with any matter pertaining to business practices, lending decisions, credit management and recovery. The name and contact details of the nodal officer shall be displayed in the website of the Company.
    4. Internally constituted Customer Grievance Redressal Council comprising senior management officials, to review with the Nodal Officer and oversee the Grievance Redressal Mechanism.
    5. Company shall display the following information prominently, for the benefit of the customers, at their branches / places where business is transacted:
      • The name and contact details (Telephone / Mobile nos. as also email address) of the Grievance Redressal Officer who can be approached by the public for resolution of complaints against the Company.
      • If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in-Charge of the Regional Office of DNBS of RBI (complete contact details), under whose jurisdiction the registered office of the Company falls.

    In short, the public notice shall serve the purpose of highlighting to the customers, the grievance redressal mechanism followed by the company, together with details of the grievance redressal officer and of the Regional Office of the RBI.


    Repossession of vehicles

    The Company shall have a built in re-possession clause in the contract/loan agreement with the borrower which shall be legally enforceable. To ensure transparency, the terms and conditions of the contract/loan agreement shall also contain provisions regarding:

    1. Notice period before taking possession;
    2. Circumstances under which the notice period can be waived;
    3. The procedure for taking possession of the security;
    4. A provision regarding final chance to be given to the borrower for repayment of loan before the sale / auction of the property;
    5. The procedure for giving repossession to the borrower; and
    6. The procedure for sale / auction of the property.

    Regulation of Excessive Interest Rate

    • Save Financial Services Private Limited shall adopt an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, etc. and determine the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
    • The rates of interest and the approach for gradation of risks shall also be made available on the web-site of the companies or published in the relevant newspapers. The information published in the website or otherwise published should be updated whenever there is a change in the rates of interest.
    • The rate of interest should be annualised rates so that the borrower is aware of the exact rates that would be charged to the account.
    • As per circular issued on RBI/ 2014-15/12/DNBS (PD).CC.No. 399/03.10.42/2014-15 dt. July 14, 2014, the Company shall not charge foreclosure charges / Pre payment penalties on all floating rate term loans sanction to Individual Borrower.


    Lending against collateral of gold jewellery

      While lending to individuals against gold jewellery, Save Financial Services Private Limited shall adopt the following in addition to the general guidelines as above.


    • Save Financial Services Private Limited shall put in place Board approved policy for lending against gold that should inter alia, cover the following:
      1. Adequate steps to ensure that the KYC guidelines stipulated by RBI are complied with and to ensure that adequate due diligence is carried out on the customer before extending any loan,
      2. Proper assaying procedure for the jewellery received,
      3. Internal systems to satisfy ownership of the gold jewellery,
      4. The policy shall also cover putting in place adequate systems for storing the jewellery in safe custody, reviewing the systems on an on-going basis, training the concerned staff and periodic inspection by internal auditors to ensure that the procedures are strictly adhered to.As a policy, loans against the collateral of gold should not be extended by branches that do not have appropriate facility for storage of the jewellery,
      5. The jewellery accepted as collateral should be appropriately insured,
      6. The Board approved policy with regard to auction of jewellery in case of non-repayment shall be transparent and adequate prior notice to the borrower shall be given before the auction date. It shall also lay down the auction procedure that would be followed. There shall be no conflict of interest and the auction process must ensure that there is arm’s length relationship in all transactions during the auction including with group companies and related entities,
      7. The auction shall be announced to the public by issue of advertisements, one in vernacular language and another in national daily newspaper.
      8. As a policy the NBFCs themselves shall not participate in the auctions held,
      9. Gold pledged will be auctioned only through auctioneers approved by the Board.
      10. The policy shall also cover systems and procedures to be put in place for dealing with fraud including separation of duties of mobilization, execution and approval.
      11. The Company would put in necessary framework and processes for ensuring compliance with the recommendations of the Working Group on NBFC lending against collateral of gold jewellery as enumerated under RBI Circular.
    • The loan agreement shall also disclose details regarding auction procedure.
    • As per Circular No. DNBR.CC.PD.036/03.10.01/2014-15 dated May 21, 2015, the valuation of gold jewellery for arriving at loan to value shall be done at the average cost of closing price of 22 carat for proceeding 30 days as quoted by Bombay Bullion Association (BBA) or the historical spot gold price data publically disseminated by a commodity exchange regulated by Forward Market Commission (FMC)

    • The Company will abide by all guidelines, directives, instructions and advices of Reserve Bank of India as will be in force from time to time. The contents in this document shall be read in conjunction with these guidelines, directives, instructions and advices. The Company will apply better practice so long as such practice does not conflict with or violate Reserve Bank of India regulations.