Swastik Finance — Fair Practice Code

Swastik Finance Private Limited

Fair Practice Code
Swastik Finance Private Limited (“Swastik Finance” or “the Company”) is a Non-Banking
Financial Company (NBFC) committed to maintaining high standards of transparency,
customer-centricity, and fairness in all its ﬁnancial dealings. The following Fair Practice
Code (FPC) has been adopted by the Board of Directors to ensure transparent and fair
lending practices across all aspects of our operations, including loan origination,
processing, disbursement, and recovery. Swastik Finance’s commitment to the FPC is
reﬂected through employee accountability, monitoring and auditing programs, and
continuous training.
1. Applications for Loans and Their Processing
1. All communications with the borrower shall be conducted in the vernacular
language or a language understood by the borrower.
2. All necessary documents will be collected in compliance with the RBI’s KYC norms.
3. The loan application form will include comprehensive information to allow
borrowers to compare terms and conditions with other NBFCs and make informed
decisions. The form will also list the required documents for submission.
4. The Company shall provide an acknowledgment receipt for all loan applications. An
internal timeframe will be adopted for processing loan applications, and the
approximate time frame for processing will be communicated post-submission of a
complete application.
2. Loan Appraisal and Terms & Conditions
1. Loan applications will be subject to Swastik Finance’s credit appraisal process.
2. The sanctioned loan, along with the terms and conditions, shall be communicated
through a Sanction Letter in vernacular language. The borrower’s consent will be
obtained by securing their signature on a copy of the Sanction Letter, which will be
retained by the Company.
3. Borrowers will receive a loan card containing the repayment schedule in vernacular
language. The loan card will also list key terms, including the annual e Ưective rate
of interest, processing fees, insurance premiums, and other relevant charges.
4. The Company shall provide a standardized and simpliﬁed factsheet disclosing all
pricing information to prospective borrowers. No fees will be charged that are not
explicitly mentioned in the factsheet.

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5. A copy of the loan agreement in vernacular language, along with all enclosures, will
be provided to the borrower.
6. The Company shall not charge any pre-payment penalty for microﬁnance loans.
Any penalty for delayed payments will only be applied to the overdue amount and
not the total loan balance.
3. Disbursement of Loans Including Changes in Terms & Conditions
1. Any changes to the terms and conditions, including disbursement schedules,
interest rates, or service charges, shall be communicated in vernacular language.
Such changes will be implemented prospectively, except under regulatory
instructions.
2. Any decision to recall or accelerate payment under the loan agreement will be in
accordance with the agreed terms.
3. Security against loans, if any, shall be released upon full repayment of dues,
subject to any legitimate lien or claim the Company may have against the borrower.
If such a right is exercised, the borrower will be notiﬁed with full details of the
remaining claims.
4. Borrowers will receive training to clearly understand the terms and conditions of
the loan.
4. General Principles
1. Swastik Finance will hold itself accountable for any inappropriate behaviour by its
employees or outsourced agents and provide a timely grievance redressal
mechanism.
2. The Company will avoid undue interference in the borrower’s a Ưairs except as
provided in the loan agreement.
3. Loan recovery shall not involve undue harassment, including but not limited to
repeated contact at odd hours or the use of coercion.
4. Employees will receive adequate training to engage with customers in a courteous
and professional manner.
5. A statement articulating Swastik Finance’s commitment to transparency and fair
lending practices shall be prominently displayed at all branches, in loan cards, and
at the head o Ưice.
6. Information on the minimum, maximum, and average interest rates charged for
microﬁnance loans shall be displayed prominently in all branches, head o Ưice, and
on the Company’s website.
5. Disclosures in Loan Agreement / Loan Card
1. The Board-approved standard loan agreement and loan card format, in vernacular
language, shall be used.
2. The loan agreement shall clearly disclose:

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o All terms and conditions of the loan,
o Pricing details,
o No pre-payment penalty for microﬁnance loans,
o No security deposit/margin collected from the borrower,
o The moratorium period before the ﬁrst instalment is due,
o Assurance of borrower data privacy.
3. The loan card shall include:
o Borrower identiﬁcation details,
o Simpliﬁed factsheet on pricing,
o Terms and conditions of the loan,
o Acknowledgment of payments, including instalments,
o Grievance redressal details, including the contact information of the nodal
oƯicer,
o Information about non-credit products, if any, with the borrower’s consent
and the associated fee structure.
6. Non-Coercive Methods of Recovery
1. Recovery shall be conducted only at designated locations. Field sta Ư may visit the
borrower’s residence or workplace only if the borrower fails to appear at the
designated location on multiple occasions.
2. Harsh recovery practices are strictly prohibited, including:
o The use of threatening or abusive language,
o Repeated calls at inconvenient hours,
o Harassment of the borrower’s relatives, friends, or co-workers,
o Publication of borrower details,
o The use or threat of violence,
o Misleading the borrower about the debt or consequences of non-repayment.
3. A Board- approved policy regarding ﬁeld sta Ư conduct, recruitment, training, and
supervision will be in place. Training programs will emphasize appropriate
behaviour and prohibit coercive collection practices.
4. StaƯ compensation will prioritize customer service and satisfaction over loan
mobilization and recovery rates. Non-compliance with the Code of Conduct may
result in penalties.
5. Mechanisms will be in place to identify borrowers facing repayment di Ưiculties,
oƯer guidance, and provide recourse options.

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7. Customer Protection Principles
1. Swastik Finance will ensure that customers have the capacity to repay without
becoming over-indebted.
2. Loan pricing, terms, and conditions will be transparent and clearly disclosed in an
understandable format.
3. Employees will uphold high ethical standards in customer interactions, with
safeguards against corruption and mistreatment.
4. Recovery practices will be fair and legally compliant.
5. Borrower privacy will be respected, with customer data treated as conﬁdential.
6. The Company will comply with RBI’s KYC guidelines and maintain a comprehensive
KYC-AML policy.
7. Disclosure of client data sharing with credit bureaus, statutory bodies, group
companies, or third parties will be included in the loan agreement, with borrower
consent obtained.
8. Grievance Redressal Mechanism
1. A multi-tier grievance redressal mechanism is in place for resolving borrower
complaints:
o First Level: Customers can register complaints or suggestions with the
Branch Manager. A resolution timeframe of 7 days will be provided.
o Second Level: Customers can escalate unresolved complaints to the toll-
free number .i.e. 1800-889-7071. The contact details of the branch, center,
and nature of the complaint will be recorded, with a deﬁned turnaround
time of 7 days.
o Third Level: If still unresolved, complaints can be escalated to the Grievance
Redressal O Ưicer at the head o Ưice.

Principal Nodal offcer Name: MR, Rohit Sahani
Contact No. : 9991148797
Email : Nodalofficer@swastikﬁnance.in
Grievance offiicer : Mrs. Monika Sahani
Contact No. : 1800-889-7071
Email : Info@swastikﬁnance.in

Note:- If the complaint remains unresolved within 30 days, the customer may approach the
Reserve Bank of India (RBI) for further redressal.