Grievance Redressal Policy

1. PREAMBLE

As per extant guidelines from Reserve Bank of India (RBI), all NBFCs should ensure that a suitable mechanism exists for receiving and addressing complaints from its customers / constituents with specific emphasis on resolving such complaints fairly and expeditiously regardless of source of the complaints.

Accordingly, the Company proposes to adopt this Grievance Redressal Policy (the “Policy”), as per RBI/DNBR/2016-17/44 Master Direction DNBR.PD. 007/03.10.119/2016-17 dated September 1, 2016 (Updated as on February 17, 2020) as applicable to NBFC - ND-NSI issued by Reserve Bank of India (RBI) and latest notification Ref. CEPD. PRD. No. S 873/ 13.01.001/ 2021-22 dated 12-11-2021 on Reserve Bank - Integrated Ombudsman Scheme, 2021. Since RBI would issue circulars and instructions on an on-going basis, any subsequent amendment to the above circular would update in the Policy accordingly. This Policy applies to all products offered by the Company and to all Customer interactions.

2. BRIEF DESCRIPTION OF THE POLICY

Customer service is the very core of our organization’s philosophy. We consider it to be extremely important for sustained business growth. We strive to ensure that our customers receive exemplary service across different touch points. As we deal with human beings, difference of opinion and friction may arise out of interactions and our customers may express their dissatisfaction as complaints.

A complaint is an opportunity for LoanTap, not only to do the service recovery & win the customers’ trust back in us, but also to improve the product, process, technology and people aspects at the LoanTap. Grievances, therefore, are a great source of the voice of customers. The policy framework lays down requirements related to grievance assessment, registration of complaints, escalation of complaints, redressal, resolution of complaints and periodic review of records.

3. OBJECTIVE

The objective of this policy is to ensure that:

> All customers are treated fairly at all times

> All grievances raised by customers are responded with courtesy and as per defined timelines

> Customers are fully informed of avenues to escalate their grievances within the LoanTap and their right to escalate further, if they are not satisfied with the LoanTap’s response

> All complaints are dealt with efficiency and equitably

> LoanTap employees approach the grievances in good faith and without prejudice

4. SCOPE

In order to make the LoanTap’s grievance redressal mechanism more meaningful and effective, a structured system has been built covering all areas of services provided by the LoanTap, its Subsidiaries, Business/Lending Partners and associates, including Business Correspondents, DSAs or any other outsourced services engaged by the LoanTap.

This system ensures that the redressal sought is just and fair and is within the given framework of rules and regulations applicable to the LoanTap. All our employees are aware of the Grievance Redressal Process of the LoanTap.

5. PRINCIPLES OF GRIEVANCE REDRESSAL

The guiding principles of the approach to grievance redressal are as follows:

> Accessibility: The LoanTap provides to our customers information on various avenues (such as its offices, contact centre, email ids, etc.) to register their grievance and assist the customers in raising their concerns at appropriate forums within the LoanTap.

> Acknowledgment and Resolution of Grievances: The LoanTap shall acknowledge the receipt of complaints received through published channels and arrange to communicate the resolution within the defined time frame.

> Transparency: The LoanTap shall acknowledge the receipt of the complaint appropriately and will communicate the turn-around-time for issues to be redressed. Investigation and resolution time will be communicated transparently.

> Escalation: The LoanTap shall make the information, on the process of escalation of complaints to the next level in case the customer is not satisfied with the resolution provided by the current level in the LoanTap, available at its offices, website & at the call centre.

> Customer Education: The LoanTap, through various forums and means shall endeavour to make continuous efforts to educate its customers to enable them make informed choices regarding its available products, services, other facilities to reduce errors in process and transactions.

> Review: The LoanTap shall have forums at various levels to review customer grievances and enhance the quality of customer service.

6. INTERNAL MACHINERY FOR HANDLING GRIEVANCES

LoanTap has the appropriate grievance redressal process and the levels of escalation for the customers to escalate their complaints or grievances if any in case they are not satisfied with the response received.

The detailed escalation matrix is displayed at the LoanTap’s website and offices.

> Mandatory requirements, including display of the information on grievance redressal mechanism LoanTap has the following in place-

- Appropriate process for receiving complaints and suggestions

- Display of the name, address and contact number of the Principal Nodal Officer(s) with an Escalation matrix.

- Contact details of RBI’s Ombudsman of the respective geography

> Resolution of Grievances

- Customer Care and service is our priority, and we are committed to provide our customers with services bench-marked with Best in the Industry. Whilst all efforts are taken to give customers the best services to avoid any grievances, the customers are intimated that they can record their grievances; if any; in writing or verbally.

- Being a digital platform, the Customer Service Department is primarily made responsible for the resolution of all types of customers complaints and grievance. They are responsible to ensure closure of all complaints received within a given timeframe. It is a foremost duty of Customer Service Officials to see that the complaint is resolved completely to the customer’s satisfaction and if the customer is not satisfied, then he / she is provided with alternate avenues to escalate the issue.

- Likewise, each channel /service touch points (call center, escalation level, etc.) of receiving customer grievance has senior staff responsible for ensuring timely resolution of the grievances raised by the customers at such channels.

> Service Touch points are as indicated below

- Phone: Customer can call our dedicated Customer Contact Center Helpline number +91 7888040000 between 09:30 to 18:00 from Monday to Saturday (except second and fourth Saturdays of a month and public holidays)

- Email: Customers can write to us at the following email id for their CS.LoantapCredit@help.loantap.in

- Post Mailer/Letter to Branch/Offices: Customers can visit our branch/offices as per address mentioned below and handover a complaint letter to the Customer Service Manager or any other LoanTap Official/Personnel by taking an acknowledgement of receipt with date from the branch/office/official/personnel whom he/she is handing over the complaint letter. Also, can write a letter to below mentioned address-

To, The Head, Customer Service,
LoanTap Credit Products Pvt Ltd
Hermes Waves, Office No 103, Central Avenue Road,
Kalyani Nagar, Pune 411014, Maharashtra

- Suggestion/Complaint Box: Suggestion or Complaint boxes are put up at all our branch/offices. Customer may drop in their suggestions and/or complaints in these boxes. These boxes are opened on periodic intervals by the Customer Service team for action/resolution.

- Complaints Register: A complaint registers is made available at LoanTap’s offices/branches. Customer may write down their complaint or concern in the said Complaints Register. The complaint register is checked by the Customer Service Manager on regular basis for immediate action / resolution.

- The Principal Nodal Officer and other designated officials to handle complaints and grievances

- The LoanTap has appointed a senior most official as its Principal Nodal Officer responsible for the implementation of the complaint handling process for the LoanTap. The name and contact details of these designated officials are displayed on LoanTap offices notice boards and on the website.

- The Principal Nodal Officer, before communicating a negative decision / or partial relief to the complainant, will refer the case internally for final views. If the customer is still not satisfied with the response of the LoanTap, then he / she has an option to approach the RBI Ombudsman with his / her complaint or to other avenues available for grievance redressal.

> Time frame

- Specific time schedules are set up for handling complaints and disposing them at all levels including branches/offices, contact center and other avenues of escalations. Efforts are made at all levels of the grievance redressal mechanism to resolve the complaints within specified time frames defined by the LoanTap.

- Communication of LoanTap’s stand on any issue to the customer is of vital importance. Complainants whose complaints require more time for examination of the issues involved are kept informed of the progress on the grievance being handled by the LoanTap.

> Integrated Ombudsman Scheme

LoanTap is covered under the Integrated Ombudsman Scheme (as amended from time to time) of the Reserve Bank of India. As per this scheme, any customer who does not receive a 'final response' within 30 days from the date when the issue was raised, or within 1 year of LoanTap’s response, if the complainant is dissatisfied with the LoanTap’s response, can approach the Integrated Ombudsman of RBI for an independent review.

7. INTERNAL REVIEW MECHANISM AND ESCALATION MATRIX

In case the customer does not receive a response within the number of days indicated below for each level or if the customer is dissatisfied with the response received from the LoanTap, the customer may escalate the complaint to the next level as indicated below –

A) Level-1

If the customer is not satisfied with the resolution received from above channels/service touch points, or if the customer does not hear from us in 14 days, the customer can write to the Grievance Redressal Officer at gro.loantapcredit@loantap.in by mentioning their complaint reference number provided to them in their earlier interactions, along with their loan account number to help us understand and address specific concerns.

The customer would receive a response within 14 business days and due efforts will be taken to resolve the complaint well before that.

B) Level-2

Complaints addressed to and received by the LoanTap, which are rejected and / or where partial relief is provided to the complainant are forwarded to this authority for examination. You may write to Principal Nodal Officer at pno.loantapcredit@loantap.in

C) Level-3

If the customer is not satisfied with the resolution received or if the customer does not hear from us in 30 days, then he may escalate his grievance to the regulator at the below address in prescribed form:

To, The Ombudsman
Reserve Bank of India, RBI Byculla Office Building,
Opp. Mumbai Central Railway Station, Byculla,
Mumbai-400 008, Maharashtra
Ph: 022- 2300 1280 Fax: 022-23022024
E-mail : cms.nbfcomumbai@rbi.org.in

Alternatively, the complainant may raise the complaint electronically on RBI’s Complaint Management platform: https://cms.rbi.org.in

8. INTERACTION WITH CUSTOMERS

The LoanTap recognizes that customers’ expectations / requirements / grievances can be better appreciated through personal interaction with customers by the LoanTap’s staff. Structured internal meets with senior management and stakeholders gives a message to the internal employees and customers as well that the LoanTap cares for customers and values their feedback / suggestions for improvement in customer service.

Many complaints arise on account of lack of awareness among customers about LoanTap’s services and such interactions help the customers to understand and appreciate LoanTap’s services better. Feedback from customers are valuable inputs for reviewing our products and services to meet their requirements.

9. TRAINING OF OPERATING STAFF ON HANDLING COMPLAINTS

Operating Staff from Customer Service and Contact Center are properly trained to handle customer grievances and complaints. During the interaction with customers, difference of opinion and areas of friction can arise. Imparting soft skills required for handling irate / agitated customers is an integral part of the training programs for staff. The LoanTap ensures that the internal machinery for handling complaints / grievances operates smoothly and efficiently at all levels.

10. REVIEW AND REVISION OF THE POLICY

The policy is reviewed and effective from 01st January 2022 and further will be reviewed -

> As and when changes are implemented by the LoanTap with respect to handling customer complaints / grievances. Changes include introduction of new grievance redressal channel or any recommendation / suggestion by the regulators from time to time.

> Every year and in the interim, in the event of any revision / amendment recommended by the LoanTap’s board and or RBI.