1. PREAMBLE

FMEC International Financial Services Ltd. (“Company”) is a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI) and is engaged in providing retail lending solutions, including Personal Loans and Business Loans, to eligible customers.

The Company is committed to providing fair, transparent and responsible lending services while ensuring compliance with applicable RBI guidelines and regulatory requirements.

This Fair Practices Code (“Code”) has been adopted to promote ethical business practices, transparency, accountability and customer-centric service throughout the lending process.

The Company endeavors to ensure that customers are treated fairly and respectfully at every stage of their relationship with the Company.

2. INTRODUCTION

In compliance with the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 and other applicable guidelines issued by the Reserve Bank of India (RBI), FMEC International Financial Services Ltd. has adopted this Fair Practices Code to ensure fairness, transparency and accountability in its lending operations.

The Code aims to promote ethical lending practices and ensure fair treatment of customers across all stages of the loan lifecycle, including:

• Loan application and processing.

• Credit appraisal and sanction.

• Documentation.

• Disbursement.

• Servicing of loans.

• Changes to loan terms and conditions.

• Collection and recovery.

• Grievance redressal.

• Closure and release of securities, wherever applicable.

3. OBJECTIVE

The primary objectives of this Fair Practices Code are to:

• Ensure fair, transparent and responsible lending practices.

• Provide customers with clear and adequate information regarding loan products, terms and conditions, interest rates, fees and other applicable charges to enable informed financial decisions.

• Promote ethical business practices and enhance customer confidence.

• Foster a fair, transparent and respectful relationship between FMEC International Financial Services Ltd. and its customers.

• Ensure compliance with applicable guidelines and directions issued by the Reserve Bank of India (RBI).

• Protect the legitimate interests and rights of customers throughout the lending relationship.

4. KEY CONSIDERATIONS

This Fair Practices Code is aligned with applicable RBI guidelines and covers essential principles for fair dealings between the Company and its customers.

The key considerations include:

• Transparency in lending and pricing.

• Clear communication of loan terms and conditions.

• Protection of customer rights.

• Responsible and ethical lending practices.

• Non-discriminatory treatment of customers.

• Appropriate grievance redressal mechanisms.

• Responsible recovery and collection practices.

• Compliance with applicable regulatory requirements.

• Periodic review and monitoring of the Company's lending practices.

5. FAIR PRACTICES CODE

FMEC International Financial Services Ltd. is committed to conducting its business in accordance with prevailing statutory and regulatory requirements, with a focus on efficiency, customer orientation, transparency and sound corporate governance.

This Fair Practices Code shall guide the Company's operations and ensure fair treatment of all customers throughout the lending lifecycle.

6. POLICY / PROCESS / GUIDELINES & PROCESS FLOW

6.1 Applications for Loans and Their Processing

Language and Information

All communications with customers shall be made in a language understood by them.

Loan application forms shall contain necessary information to enable customers to make an informed comparison with similar products and offerings of other lenders.

The application form shall also specify the documents required to be submitted by the customer along with the application.

Acknowledgement and Verification

A digital acknowledgement of receipt shall be provided for loan applications, wherever applicable.

Loan applications shall be verified and processed within a reasonable period.

Where an application is rejected, the Company shall communicate the reasons for such rejection to the customer, wherever applicable.

6.2 Loan Appraisal and Terms & Conditions

Approval Communication

Where a loan is approved, the Company shall provide the customer with written communication containing the material terms and conditions of the loan, including, as applicable:

• Sanctioned loan amount.

• Applicable interest rate.

• Tenure of the loan.

• Repayment schedule.

• Applicable fees and charges.

• Penal charges / penal interest, where applicable.

• Other material terms and conditions.

The Company's acceptance of these terms and conditions shall be appropriately documented.

The Company shall provide the relevant loan documentation to the customer and maintain appropriate records of such communication.

6.3 Disbursement of Loans Including Changes in Terms and Conditions

Notice of Changes

All customers shall be notified of any applicable changes to the terms and conditions of their loan, including changes relating to:

• Disbursement schedules.

• Interest rates.

• Service charges.

• Fees and other applicable charges.

• Repayment terms.

• Other material conditions of the loan.

Such changes shall be applied prospectively and shall be incorporated into or communicated in accordance with the applicable loan documentation.

No change shall be made applicable on a retrospective basis, except where expressly permitted under applicable law or regulatory requirements.

Security Release

Upon full repayment or settlement of the loan, securities charged to the Company shall be released, subject to any legitimate right, lien or other claim that the Company may have against the borrower in accordance with applicable law and contractual terms.

Where the Company intends to exercise any right of lien or retain securities, the customer shall be provided with appropriate notice regarding the outstanding claim and the conditions under which the relevant securities may be retained.

6.4 GENERAL

Borrower Affairs

The Company shall refrain from interfering in the affairs of the borrower except where such intervention is:

• Permitted under the terms and conditions of the loan agreement; or

• Required for legitimate credit, servicing, compliance, fraud prevention, recovery or regulatory purposes; or

• Necessary where new information or circumstances affecting the credit relationship come to the Company's knowledge.

The Company shall respect the customer's privacy and shall not unnecessarily interfere in the customer's business or personal affairs.

Transparency

The Company shall ensure transparency in its lending practices.

Material changes to loan terms and conditions shall be communicated prospectively to customers through appropriate and permissible modes.

Salient features of loan products, applicable interest rates and the principles of risk gradation shall be made available through the Company's website and other appropriate customer communication channels, as applicable.

Non-Discrimination

The Company shall not discriminate against customers in its lending practices on the basis of sex, caste or religion.

The Company shall endeavor to ensure that customers are treated fairly and consistently based on objective lending, credit and risk assessment criteria.

Staff Training

The Company shall ensure that its employees and relevant personnel receive appropriate training to handle customer interactions professionally.

Staff shall be trained to deal with customers in a courteous, professional and respectful manner, both before and after loan sanction.

6.5 RESPONSIBILITY OF THE BOARD OF DIRECTORS

The Board of Directors shall have overall responsibility for overseeing the implementation of this Fair Practices Code.

The Board shall:

• Establish an appropriate grievance redressal mechanism.

• Ensure periodic review of compliance with the Fair Practices Code.

• Review relevant reports relating to customer complaints and grievances.

• Ensure that corrective measures are taken wherever necessary.

• Review compliance reports and provide appropriate guidance.

Reports arising from periodic reviews of compliance with the Fair Practices Code shall be submitted to the Board at appropriate intervals.

6.6 GRIEVANCE REDRESSAL OFFICER

Contact Information

The Company shall prominently display the name, designation, contact details and email address of the Grievance Redressal Officer at its business locations and on its website.

This is intended to enable customers to easily lodge complaints, raise concerns or seek grievance redressal.

Grievance Redressal Officer

Mr. Aman Kumar

Email: compliance@fmecinternational.com

Contact: 9458569447

Address:
908, Mercantile House,
Kasturba Gandhi Marg,
New Delhi - 110001

Escalation Process

Customers who are not satisfied with the Company's response, or whose complaints remain unresolved within 30 days from the date of receipt, may escalate their grievances through the Company's prescribed escalation mechanism.

Where applicable, and subject to eligibility and the prevailing regulatory framework, customers may thereafter approach the Reserve Bank of India under the applicable RBI Integrated Ombudsman Scheme.

6.7 LANGUAGE AND MODE OF COMMUNICATING THE FAIR PRACTICES CODE

The Fair Practices Code shall be made available in English and, wherever considered necessary, in other languages understood by the customers.

The Code shall also:

• Be displayed on the Company's website.

• Be made available at the Company's business locations upon request.

• Be communicated through appropriate customer communication channels wherever required.

The Company shall endeavor to ensure that customers are able to understand the key terms and principles governing their lending relationship.

6.8 WIDE DISSEMINATION AND PERIODIC REVIEW

The Fair Practices Code shall be made available on the Company's website for easy access by customers and other stakeholders.

The Code shall be reviewed periodically to incorporate:

• Changes in applicable regulatory requirements.

• Updates issued by the Reserve Bank of India.

• Changes in the Company's lending practices.

• Lessons and observations arising from customer interactions and complaints.

• Other relevant operational or business developments.

Any necessary amendments shall be made in accordance with the Company's internal governance and approval framework.

6.9 COMPLAINTS ABOUT EXCESSIVE INTEREST CHARGED BY THE COMPANY

The Company shall ensure that the interest rates and other applicable charges levied on its loan products are reasonable, transparent and commensurate with the relevant risks and costs.

The Company shall maintain appropriate principles and processes for determining interest rates and charges.

Customers shall be provided with appropriate information regarding applicable interest rates, fees and charges through relevant loan documentation and communication channels.

6.10 REGULATION OF EXCESSIVE INTEREST CHARGED BY THE COMPANY

The Company shall adopt a risk-based interest rate model for determining the applicable interest rates on its lending products.

The pricing framework may consider factors including:

• Cost of funds.

• Credit risk.

• Borrower profile.

• Loan amount.

• Loan tenure.

• Repayment profile.

• Security / collateral, where applicable.

• Operating and administrative costs.

• Prevailing market conditions.

• Other relevant business and risk factors.

The applicable interest rate and the principles governing risk-based pricing shall be appropriately disclosed to customers.

The Company may also publish relevant information relating to its interest rate model and pricing approach on its website in accordance with applicable regulatory requirements.

6.11 CLARIFICATION REGARDING REPOSSESSION OF HYPOTHECATED ASSETS FINANCED BY THE COMPANY

Repossession Procedures

The Company's loan agreement shall contain appropriate provisions relating to the repossession and sale of hypothecated assets, wherever applicable.

Such provisions shall include, as applicable:

• Circumstances under which repossession may be initiated.

• Applicable notice requirements.

• Procedure for taking possession of the secured/hypothecated asset.

• Conditions relating to sale or disposal of the asset.

• Applicable timelines and procedures.

• Rights and obligations of the borrower and the Company.

The terms relating to repossession and sale of hypothecated assets shall be transparent and clearly communicated to customers through the relevant loan documentation.

The Company shall follow applicable laws, contractual terms and regulatory requirements while undertaking any repossession or recovery action.

6.12 CUSTOMER COMPLAINTS & GRIEVANCES

The Company is committed to providing customers with accessible and effective channels for raising complaints and grievances.

Communication Channels

Customers may raise complaints through the following channels:

🏢 Walk-In

Customers may submit their complaints by visiting the Company's designated service hubs or business locations.

✉️ Email

Customers may submit their complaints through the Company's designated customer support or grievance email channels.

📮 Letter

Customers may submit written complaints by sending a letter to the Company's registered/correspondence office.

Address:
908, Mercantile House,
Kasturba Gandhi Marg,
New Delhi - 110001

ESCALATION MATRIX

If a customer is not satisfied with the response or resolution provided, the complaint may be escalated through the following levels:

LEVEL 1 — HEAD, CUSTOMER SERVICE

In case the Customer is not satisfied with the response from the Customer Care Team, he/she may escalate the matter to:

Head – Customer Service

Email: info@fmecinternational.com

Address:
908, Mercantile House,
Kasturba Gandhi Marg,
New Delhi - 110001

Depending on the nature of the query, dispute or grievance, a written reply/resolution shall be provided to the customer within 15 working days at his/her registered email address with the Company.

LEVEL 2 — GRIEVANCE REDRESSAL OFFICER

A customer who is not satisfied with the response provided at Level 1 may further escalate the matter, query or complaint to:

Grievance Redressal Officer – Mr. Aman Kumar

Email: compliance@fmecinternational.com

Contact: 9458569447

Address:
908, Mercantile House,
Kasturba Gandhi Marg,
New Delhi - 110001

LEVEL 3 — RESERVE BANK OF INDIA

If the complaint is not resolved within 1 (One) month from the date of receipt of the complaint with complete details, the customer may approach the concerned office of the Reserve Bank of India, subject to the applicable regulatory framework.

Reserve Bank of India
Department of Non-Banking Supervision
6, Parliament Street,
New Delhi - 110001

Email: dnbsnewdelhi@rbi.org.in

Customers may also use the applicable RBI grievance redressal mechanism, including the RBI Integrated Ombudsman Scheme, wherever eligible.

7. RESOLUTION TURNAROUND TIME

The Company is committed to resolving overall customer complaints within 1 (One) month from the date of receipt of the complaint with complete details.

Where additional information, documentation, verification or investigation is required, the Company shall communicate with the customer regarding the status and expected timeline, wherever applicable.

8. SUPERVISION AND REPORTING

8.1 Reporting

A complaints Management Information System (MIS) and reporting mechanism is maintained by the Company.

The reports generated through this mechanism serve as inputs for:

• Analysis of customer complaints.

• Monitoring of grievance trends.

• Identification of recurring issues.

• Periodic management review.

• Evaluation of the effectiveness of the grievance redressal mechanism.

• Identification of areas requiring corrective action.

The reporting mechanism may include information relating to the total number of complaints received, complaints disposed of, complaints pending and reasons for pending complaints.

8.2 Supervision

A summary of the customer grievance report along with its status report, including the actions taken for resolution of complaints, shall be placed before the Board of Directors for review on a semi-annual basis.

The report shall contain information including:

• Total number of complaints received.

• Number of complaints disposed of.

• Number of complaints pending.

• Reasons for pending complaints.

• Actions taken for resolution.

• Other relevant information required for Board review.

The report shall be placed before the Board of Directors for their information, review and guidance.

CUSTOMER COMMITMENT

FMEC International Financial Services Ltd. is committed to conducting its lending operations with fairness, transparency, integrity and accountability.

The Company shall endeavor to ensure that customers receive clear information about loan products, applicable interest rates, fees, charges, terms and conditions and available grievance redressal mechanisms.

Customers are encouraged to contact the Company through the prescribed channels whenever they have any query, concern or grievance relating to the Company's products or services.

KEY CONTACT DETAILS

FMEC International Financial Services Ltd.

Customer Service / Head – Customer Service
Email: info@fmecinternational.com

Grievance Redressal Officer
Mr. Aman Kumar
Email: compliance@fmecinternational.com
Contact: 9458569447

Registered / Correspondence Address
908, Mercantile House,
Kasturba Gandhi Marg,
New Delhi - 110001, India.

Note: This Fair Practices Code shall be read together with the applicable RBI directions, regulations, statutory requirements and other Board-approved policies of FMEC International Financial Services Ltd., as amended from time to time.