Fair Practice Code

This Fair Practice Code is being published by Shabri Investments Private Limited (the “Company”/“We”/“Us”/“Ours”) as required in the RBI Master Directions 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 and is based on requirements under RBI/2011-12/470 DNBS.CC.PD.No.266 /03.10.01/2011-12.

This Fair Practice Code covers the principles of general disclosures of the terms and conditions of the loan agreement and adopting a non-coercive method of recovery.
We will strive to ensure that all the dealings with Our customers rest on the principles of honesty, integrity, and transparency and ensure that Our customers have a trouble-free experience while availing of Our facilities.
If the customer has not received any response or is dissatisfied with the responses received from the personnel at Level 1, the customer may write to our Grievance Redressal Officer, the details of whom are mentioned below:

1. Objectives of this Fair Practice Code:

1. To Promote fair practices by setting minimum standards while We deal with Our Customers
2. Increase transparency which will enable Our customers to have a better understanding of what types of service levels can be expected from us.
3. Foster customer confidence in Our Company.

2. Application and Scope of the Fair Practice Code:

1. This Fair Practice Code shall apply to all our products and offerings that we provide at present and any products or offerings that we may introduce from time to time.

3. Applications for loans and their processing:

1. We shall ensure that loan application forms include the necessary information that affects the interest of Our customers so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decisions can be taken by Our Customers. The loan application form will indicate the documents required to be submitted with the application form.
2. We shall endeavor to devise a system of giving acknowledgment for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of will also be indicated in the acknowledgment.
3. All communications to Our Customers shall be in the vernacular language or a language as understood by Our Customers.

4. Loan appraisal and terms and conditions:

1. We will convey in writing to our customers in the vernacular language as understood by Our Customers by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including the annualized rate of interest and method of application thereof and keep the acceptance of these terms and conditions by our customers on its record.
2. We shall mention the penal interest charged for late repayment in bold in the loan agreement.
3. We will furnish a copy of the loan agreement to the borrower in the language as understood by the borrower as soon as the loan agreement is fully executed.
4. In addition to the loan agreement, We will also furnish to the borrower a copy of the loan repayment schedule which indicates the principal amount and the interest payable on each EMI along with a copy of the statement of key facts.
5. The rate of interest should be annualised rate so that Our Customers are aware of the exact rates that would be charged to the account.

5. Disbursement of loans including changes in terms and conditions:

1. We will give notice to Our Customers in the vernacular language or a language as understood by Our Customers of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, etc.
2. We would also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard is incorporated in the loan agreement.
3. The decision to recall/accelerate payment or performance under the loan agreement should be in consonance with the loan agreement.
4. We will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim, We may have against Our Customers. If such right of set-off is to be exercised, Our Customers shall be given notice about the same with full particulars about the remaining claims and the conditions under which We are entitled to retain the securities till the relevant claim is settled/paid.

6. General:

1. We would refrain from interference in the affairs of Our Customers except for the purposes provided in the terms and conditions of the loan agreement (unless information not earlier disclosed by Our Customers has been noticed).
2. In case of receipt of a request from Our Customers for transfer of their/borrower account, the consent or otherwise i.e., objection of the Company, if any, should be conveyed within 21 (twenty-one) days from the date of receipt of the request. Such transfer shall be as per transparent contractual terms in consonance with law.
3. In the matter of recovery of loans, we will not resort to undue harassment viz; persistently bothering Our Customers at odd hours, using muscle power for recovery of loans, etc. We shall further ensure that Our staff/ authorized agents behave in a professional manner and shall not be rude to Our Customers. To ensure this, adequate training and sensitization programs are to be conducted by the Company’s concerned departments routinely.
4. With due regard to RBI’s circular no. DNBS.CC.PD.No. 191/03.10.01/2010-11 dated July 27, 2010, We will ensure that there is no discrimination in extending the facilities to the physically / visually challenged applicants on grounds of disability.
5. As per circular issued on RBI/ 2014-15/12/DNBS (PD).CC.No. 399/03.10.42/2014-15 dated July 14, 2014, We shall not charge foreclosure charges / pre-payment penalties on all floating rate term loans sanction to Individual Borrower.

7. Grievance Redressal Mechanism:

1. We have set in place a grievance redressal mechanism to efficiently address the grievances of Our Customers in a time–bound manner.
2. We shall display the following information prominently, for the benefit of Our customers, at Our branches/places where business is transacted:
3. The name and contact details (Telephone / Mobile nos. as well as email address) of the Grievance Redressal Officer who can be approached by the public for resolution of complaints against Us.
4. If the complaint/dispute is not redressed within a period of 1 (one) month, the customer may appeal to the Officer-in-Charge of the Regional Office of DNBS of RBI, Bengaluru, Karnataka, under whose jurisdiction the registered office of the NBFC falls.
5. This public notice should serve the purpose of highlighting to Our Customers, the grievance redressal mechanism followed by Us, together with details of Our grievance redressal officer and of the Regional Office of the RBI.

8. Language and mode of communication of the Fair Practice Code:

1. This Fair Practice Code shall be disseminated primarily in English language and other vernacular languages as understood by Our customers. Further, We shall publish this Fair Practice Code on our website – www.shabri-investment.com for the ready and easy reference of all our stakeholders.​

9. Regulation of rate of interest:

1. We have adopted an interest rate model taking into account relevant factors such as cost of funds, margin, and risk premium and have accordingly determined the rate of interest to be charged for loans and advances issued by Us. We shall disclose the rate of interest and if applicable, the approach for gradations of risk and rationale for charging different rate of interest to different categories of Our Customers in the application form and communicated explicitly in the sanction letter.
2. The rates of interest and if applicable, the approach for gradation of risks shall also be made available on Our website or published in the relevant newspapers. The information published on Our website or otherwise published shall be updated whenever there is a change in the rates of interest.
3. The rate of interest is annualized rates to ensure that Our customers are aware of the exact rates that would be charged to their account.

10. Repossession of vehicles in case of default in repayment:

1. We have a built-in re-possession clause in the loan agreement with Our customers which is legally binding and legally enforceable. To ensure transparency, the terms and conditions of Our loan agreement 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 vehicles;
4. A provision regarding the final chance to be given to Our Customers for repayment of the loan before the sale/auction of the vehicles;
5. The procedure for giving repossession to Our customers;
6. The procedure for the sale/auction of the vehicles.
2. A copy of the above terms and conditions will be made available to Our Customers.

11. Responsibility of the Board of Directors:

1. The Board of Directors of Our company has laid down the appropriate grievance redressal mechanism within the organization to 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.
2. The Board of Directors periodically reviews the compliance of this Fair Practice Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews is submitted to the Board at regular intervals.