Consumer Awareness

Lending Service Providers (LSP)

Financing Partners

Details of redressal officer

Name of the Grievance Redressal Officer: Tushita Rastogi

Address: i2iFunding, Ground Floor, A-217, Sector 69, Noida, 201301

Telephone: +91 97174 20307

E-mail id: [email protected]

Website link with redressal policy: https://www.i2ifunding.com/grievance-redressal-policy

FIU Participation Policy

Sahamati Account Aggregator Ecosystem Participation Terms

DigiSahamati Foundation, established as a not-for-profit company under Section 8 of the Companies Act, 2013, (Sahamati), as an organisation comprising Account Aggregators (AAs), Financial Information Providers (FIPs), Financial Information Users (FIUs), technology service providers and other persons, is fostering the establishment and development of the Sahamati Account Aggregator Ecosystem (Sahamati AA Ecosystem) which facilitates interoperability and related standards for AAs, FIPs and FIUs, manages the Sahamati AA Ecosystem and enforces compliance with Sahamati AA Ecosystem Participation Terms.

This document sets out Sahamati AA Ecosystem Participation Terms, Version 1.0  (the Terms), as amended from time to time, upon which the participants in the Sahamati AA Ecosystem have agreed to participate.

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1. Ecosystem Participants

1.1  Sahamati AA Ecosystem shall have the following participants (Participants):

(a) Financial Information Providers (FIP) - any entity that is registered with a Financial Sector Regulator and/or approved by the Financial Sector Regulator to be a provider of financial information;

(b) Financial Information Users (FIU) - any entity that is registered with a Financial Sector Regulator and regulated by such Financial Sector Regulator to be a consumer of the financial information; and

(c) Account Aggregators (AA) – any non-banking financial company that has been registered with the RBI to undertake the business of an account aggregator as defined in the AA Master Directions (as defined below).

1.2  In consideration for the mutual rights and obligations set out in these Terms, as amended from time to time, all Participants shall indicate their acceptance of these Terms by furnishing to Sahamati, an electronic copy of the declaration contained in Annex 1 on which shall be affixed the digital signature of its authorised signatory. These Terms shall supersede and prevail over any bilateral agreements or arrangements among or between Participant/s on matters specified in these Terms upon such Participant/s indicating their acceptance of these Terms.

1.3 Customers shall indicate acceptance of these Terms, as amended from time to time, by accepting these Terms on the AA Client Interface (as defined below) and the AAs shall ensure that their AA Client Interface enable such acceptance and retain a record thereof. FIUs and FIPs should display these Terms for information of their customers in relevant sections of their websites or mobile apps.

1.4.These Terms may be amended from time to time and such amended Terms shall remain binding upon the Participants and the Customers, with the continuing participation, usage or access of the Sahamati AA Ecosystem by the Participants and the Customers signifying and constituting their respective acceptance of the amendments and amended Terms. Sahamati shall, prior to effecting the amendments to these Terms, undertake due consultations to the extent necessary and appropriate. The amendments and the amended Terms shall be provided to all the Participants and the Customers at least 30 days prior to such amendments and amended Terms becoming effective, with versioning of amendments being reflected appropriately. Only in the event of a complete overhaul and restatement of these Terms, the Participants and the Customers may be required to indicate their acceptance afresh to the restated Terms in the mode and manner specified in 1.2 and 1.3 respectively, for continuing within the Sahamati AA Ecosystem in accordance with the restated Terms and which shall become effective as provided in such restated Terms, with versioning of restatements being reflected appropriately. All communications with the Customers as contemplated in this section shall be undertaken by the AAs.

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2. Defined Terms

1. AA Client Interface shall have the meaning set out in 4.1 below;

2. AA Master Directions means the Master Direction - Non-Banking Financial Company - Account Aggregator (Reserve Bank) Directions, 2016 issued by RBI and as amended from time to time;

3. AA Technical Standards means the technical standards issued by ReBIT or any other competent authority from time to time as applicable to AAs;

4. Applicable Law means the AA Master Directions and all relevant technical specifications as well as any applicable law, regulation, ordinance, rule, judgment, notification, order, decree, bye-law, directive, framework or guideline issued by a competent government authority and having the force of law;

5. Customer means any person, who has entered into a contractual arrangement with the AA to avail services provided by the AA for transfer of data from FIPs to an FIU or from FIPs to the Customer;

6. Central Registry or Central Registry APIs means the service offered by Sahamati, as part of Sahamati Technical Services, to participants for discovery of public information such as API endpoints and public keys.

7. Data means any data that has been permitted, under the AA Master Directions, to be transferred from FIPs to FIUs and/or from FIPs to Customers;

8. Financial Sector Regulator means any of RBI, SEBI, IRDAI or PFRDA;

9. Force Majeure Event means any event beyond the reasonable control of a Participant which adversely impacts the ability of the Participant to perform its role contemplated under these Terms, which events include but are not limited to: non-availability of any communication or electronic services due to an act of god, on account of relevant authorities requiring suspension of any activity or operation, or on account of pandemic or other infectious or contagious disease;

10. IRDAI means the Insurance Regulatory and Development Authority of India;

11. ODR Institution means an independent neutral institution that provides online dispute resolution as a service or as a platform, encompassing online arbitration, online mediation or online conciliation or a combination thereof, and which has been empaneled by Sahamati from time to time;

• PFRDA means the Pension Fund Regulatory and Development Authority;

1. RBI means the Reserve Bank of India;

• ReBIT means Reserve Bank Information Technology Private Limited;

• Sahamati Certification Framework means a set of tests designed and administered by Sahamati, or its empaneled certifiers, to verify the adherence to the AA Technical Standards and with such standards as may be specified by Sahamati from time to time including but not limited to standards specified for availing of Sahamati Technical Services or standards specified for other matters as relevant to the role of the Participant in the Sahamati AA Ecosystem being performed in a standardized and/or interoperable manner;

1. Sahamati AA Ecosystem means the ecosystem comprising the Participants and the Customer/s designed to facilitate the consented flow of Data from FIPs to FIUs as enabled by AAs or from FIPs to Customer/s as enabled by AAs;

2. Sahamati Technical Services means services such as Central Registry or Central Registry APIs, Token Service APIs and any other services that Sahamati may provide to the Participants from time to time;

3. SEBI means the Securities and Exchange Board of India; and

4. Token Service APIs means the service offered by Sahamati, as part of Sahamati Technical Services, for participants to obtain a short-lived access token and present it to other Participants for authorizing access to their resources.

3. Commencement of Services by AAs, FIUs and FIPs

3.1 The detailed onboarding plan for AAs, FIUs and FIPs has been set out in Annex 2.

3.2 Every entity desirous of becoming a Participant in the Sahamati AA Ecosystem, will be assessed in accordance with the Sahamati Certification Framework, as relevant to the role it desires to perform in the Sahamati AA Ecosystem. Once a Participant has been so certified and has indicated its acceptance of these terms under 1.2 above, then such Participant shall be allowed to commence performing its role in the Sahamati AA Ecosystem.

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4. AA Client Interface

4.1 All AAs will create one or more front-end interfaces through which Customers will be able to link their accounts in order to manage their consent for Data transfers from FIPs to FIUs and/or from FIPs to the Customer, as the case may be (AA Client Interface).

4.2 The AA Client Interface should, at the very least, support the following features:

(a) Consent management including but not limited to account discovery, account linkage and activity logs;

(b) Profile management including registration of users resulting in the issuance of Virtual User Addresses; and

(c)Complaint management including the ability to raise a complaint and receive updates as to the progress of the complaint till final resolution.

4.3 The AA shall ensure that the AA Client Interface is designed to use authentication measures as prescribed in the AA Technical Standards, from time to time, for all actions or transactions between the Customer and the AA, including but not limited to all consent management actions and all profile management actions.

4.4 At least one or more of AA Client Interface/s of an AA should offer a Customer the ability to check the status of a Data request and to view the entire history of their consents and Data flows at any point in time.

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5. Customer Onboarding

5.1 The AA will onboard Customers using a process that shall comprise the following steps:

(a) The Customer shall provide to the AA the Customer’s mobile number, email address, or any other identifier that has been declared to be suitable for digital verification in the AA Technical Standards, from time to time.

(b) The AA shall verify that the identifier provided is valid and verified and that it is in fact being solely operated by the Customer.

(c) Upon conclusion of such verification, the AA will issue to the Customer a virtual address that uniquely identifies the Customer in the following format:

<customer_identifier>@<AA_identifier>

Where:

(a) customer_identifer> is a word/alphanumeric that uniquely identifies the Customer in the AA system and which may either be selected by the customer or issued by the AA. The AA shall, at its discretion, be free to suggest a unique default identifier (such as mobile number or last name)

(b) AA_identifer> is the unique identifier that has been provided to the AA by Sahamati at the time of on-boarding that uniquely identifies the AA among all AAs in the ecosystem.

(c) The entire Virtual User Address, also known as the VUA or the AA Handle, should only contain “a-z, A- Z, 0-9,.(dot), - (hyphen), @", as currently defined in the AA Technical Standards and subject to any modifications in such standards, from time to time.

5.2  At the time of Onboarding and thereafter whenever initiated by the Customer, the AA Client Interface will facilitate discovery of accounts held by the Customer with one or more FIPs in the following manner:

(a) The AA Client Interface will offer the Customer the opportunity to provide strong identifier(s) that the Customer’s FIP will recognise. The AA will relay such identifier/s to the FIP. The FIP shall, if such identifier/s correspond with a customer record within its system, provide to the AA a set of account numbers matching the Customer identifier so provided.

(b) The AA Client Interface shall display the account numbers discovered in this manner from all FIPs in a masked format and in a manner that will allow the Customer to make a selection of those accounts that the Customer wishes to link.

(c)By selecting the accounts that the Customer wishes to link on the AA Client Interface, the Customer authorises the AA to relay to the FIP the Customer’s consent to link the specified accounts to the Customer’s profile with the AA.

(d) The FIP shall, after independently authenticating the Customer as specified in the AA Technical Standards, complete the linking request.

5.3 The process and steps outlined in 5.1 and 5.2 above are not prescriptive as regards user experience that an AA may provide while adhering to such process or steps.

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6. Process for Data Transfer

6.1 The process for transfer of Data from an FIP to an FIU and/or from an FIP to a Customer as the case may be, shall involve the following parties – the Customer, FIPs, the FIU (if any) and an AA.

The FIU may initiate the request for Data by submitting a consent request to the Customer through the AA. The AA will forward the consent request to the Customer and once such consent has been obtained, the AA shall convey the Customer’s consent request to the relevant FIPs. The FIPs shall, after verifying the consent, transfer the required Data to the AA . The AA shall facilitate the transfer of such Data from the FIPs to the FIU. 

In the event, the Customer declines consent, the AA will convey information of such decline to the FIU, and accordingly no transfer of Data will take place.

The Customer may initiate a request for Data by submitting a request and consent to the AA. The AA shall convey the Customer’s consent request to the FIPs for the Data. The FIP shall, after verifying the consent, transfer the required Data to the AA. The AA shall facilitate the transfer of such Data from the FIPs to the Customer.

t is noted that in course of transfer of Data as envisaged in these Terms, the relevant FIP continues to retain the Data as available with itself

6.2 ReBIT is authorized to publish technical specifications, from time to time, to achieve the process described above. All Participants undertake to ensure that their systems are and for as long as these Terms continue to apply to them will hereafter be compliant with such specifications.

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7. Obligations and Responsibilities

7.1  All Participants shall:

(a) undertake certification at the stage of joining the Sahamati AA Ecosystem and obtain certification whenever required and remain duly certified on an on-going basis in accordance with the Sahamati Certification Framework;

(b) implement the security measures issued by ReBIT from time to time;

(c) save and except as provided in 7.3 (d), ensure that no Data transferred through the Sahamati AA Ecosystem is shared with any third party unless required by law;

(d) ensure that their systems and infrastructure are compliant with the application programming interface (API) change management policies issued by ReBIT from time to time;

(e) ensure that their systems and infrastructure remain operational, at uptimes and standards as Sahamati may specify from time to time, in order to carry out the transactions contemplated under these Terms, and where any system or infrastructure needs to be taken offline, the relevant Participant shall give prior advance notice to Sahamati, in accordance with the standards specified by Sahamati from time to time;

(f) respond to unscheduled shutdowns and other disruption to the services expeditiously and notify Sahamati and the Central Registry of such shutdown or disruption;

(g) comply with all service level obligations, uptimes and standards as Sahamati may specify from time to time, as applicable;

(h) retain all consent logs and Data flow logs for such period(s) as may be required by Applicable Law, in a readily accessible and searchable format that allows for retrieval as per internal policies of the Participant; on demand by the Customer or any other Participants involved in the transaction; as required for audit or regulatory inspection in accordance with Applicable Law; or in the event of a grievance by a Customer or a dispute with any Participant;

(i) ensure that an audit is conducted by a qualified security assessor (QSA) approved by RBI at such frequency/intervals as specified by RBI from time to time;

(j) appoint grievance redressal officers whose responsibility it shall be to resolve Customer grievances and coordinate amongst themselves to collate all the Data transfer and consent logs or other information as may be necessary;

(k) agree and acknowledge that Data through the Sahamati AA Ecosystem is on an “as is” and “as available” basis only, disclaim any warranty or assurance as to the completeness or accuracy of any Data transferred and any reliance that may be placed on such Data;

(l) Ensure due adherence of commercial arrangements and duly discharging payment obligations as arising on account of the Sahamati AA Ecosystem, (including the payment of membership or other fees as applicable to Sahamati as notified from time time), and

(m) inform Sahamati and all other Participants of any change in the status of its operating license including but not limited to any cancellation, revocation or suspension thereof.

7.2 All AAs shall:

(a) support requests to transfer data which are initiated by the Customer or by FIUs;

(b) ensure that appropriate measures have been implemented to ensure proper Customer identification and authentication and ensure that the consent obtained is in accordance with the AA Technical Standards;

(c) not undertake any other business other than the business of an account aggregator;

(d) not use the services of any third party service provider to undertaking its business;

(e) ensure that no Customer information when received from an FIP is retained by the AA for longer than is necessary for such Data to be transferred to the Customer or FIU or 6 hours from time of receipt, whichever is earlier;

(f) ensure that the AA is blind to and does not share, view or access any of the contents of such Data from the moment of receipt till its delivery to the FIU or to the Customer, as the case may be, or for the period it retains the Data;

(g) educate Customers on informed consent, significance and possible result/s of consenting, and the possible implications of consenting without the Customer properly evaluating the consequences or results;

(h) enable a Customer who seeks to port to another AA to do so seamlessly;

(i) put in place and keep current a Disaster Recovery or a Business Continuity management plan for all their operations;

(j) not be held responsible for any loss or damage that may arise due to a Customer’s account being disabled or suspended for any reason or due to unauthorized use of such account (other than on account of failure of the AA to comply with these Terms or Applicable Laws);

(k) comply with the various duties and responsibilities of an AA as set out in the Master Directions; and

(l) be entitled to take appropriate action to prevent harm to the Sahamati AA Ecosystem, including but not limited to, disabling or suspending a Customer’s account in order to prevent unauthorized access to the Customer’s account.

7.3   All FIUs shall:

(a) ensure that their systems are wholly interoperable and capable of working with every AA in the ecosystem;

(b) set up and continue to operate their systems so that the FIU also functions as an FIP, when holding the types of Data notified by RBI as eligible for transfer through an AA, in the Sahamati AA Ecosystem on the principle of reciprocity;

(c) ensure that any Data received from an FIP through an AA is only used for the express purpose mentioned in the consent artefact under which such Data was requested;

(d) not transfer, share or otherwise disclose any Data collected from an FIP to any third party whatsoever except with the specific prior consent of the Customer Provided that an FIU may share data in an aggregated and anonymised form with contracted third parties and with due notice to the Customer that it is so sharing the data; and

(e) only retain any Data received from an FIP for as long as is necessary for the FIU to fulfil the purpose for which such Data was obtained and for no longer, save and except as required in order to comply with Applicable Laws.

(f) immediately notify the relevant AA about any consent revocation initiated by the Customer through the FIU and desist from further fetching of any Data from an FIP through an AA using the consent so revoked by the Customer.

7.4   All FIPs shall:

(a) ensure that their systems are wholly interoperable so that they can work with every AA in the Sahamati AA Ecosystem;

(b) permit the AAs to use its name or logo in the AA Client for customer ease and convenience, permit all AAs to discover the accounts that the Customer has with them, and permit the linking of these accounts using standard protocols specified by ReBIT from time to time;

(c) on receipt of a consented Data request from an AA, verify its validity (including with respect to the mode of operation specified by the customer for the accounts) before proceeding to collate and furnish any Data in response to such request;

(d) once a Data request and consent has been validated, collect all Data under its possession and control that responds to such Data request, store it in an encrypted format, inform the AA that it is ready for collection and facilitate its collection by the AA for delivery to the FIU and/or the Customer, as the case may be;

(e) ensure that its systems implement any revocation of consent by a Customer that has been communicated to such FIP by an AA;

(f) set up and continue to operate their systems so that they also function as an FIU, if permitted by the Master Directions to do so, in the Sahamati AA Ecosystem on the principle of reciprocity; and

(g) may reject any such request for Data sharing received from the AA if it fails to meet the criteria for obtaining instruction or consent of the Customer, as specified under consent artefact and the Applicable Law or is not as per the mode of operation specified by the customer for the accounts.

7.5   All Customers shall:

(a) review the details of all requests that they receive from FIUs through AAs to transfer Data from FIPs to such FIU in order to verify the nature and quantum of Data requested, the purpose for which such Data is being collected and the duration for which it will be retained by the FIU;

(b) only provide their consent after having duly verified the details of the request to transfer Data and any consent so provided shall be binding on the Customer;

(c) be entitled to revoke their consent for requests to transfer Data that have not yet been fulfilled.

For requests to transfer Data that have been fully or partially fulfilled, and the FIU has received the Data and not (for any reason whatsoever) provided any service or product to the Customer: be entitled to revoke their consent for such requests and the revocation shall take effect without any consequences. The FIU shall in this situation, purge the Customer’s Data unless required to be retained in accordance with Applicable Laws.

For requests to transfer Data that have been fully or partially fulfilled, the FIU has received the Data and provides service or product to the Customer (which continues to subsist): be entitled to revoke consent in respect of any further Data requests being performed subject to the Customer acknowledging and confirming to the AA that all or any consequences or measures as may arise on account of the revocation (as may be specified between the FIU and the Customer in such situations, which the AA is not privy or party to) may become applicable or operational, and accordingly that the revocation will be at the risk, costs and consequences of the Customer.

The AA will immediately update the relevant FIPs and the FIU of such revocation and give effect to the revocation.

(d) be responsible for the confidentiality, safekeeping and security of their account details, including but not limited to, login and other credentials, required to access and use their account on the Sahamati AA Ecosystem;

(e) be solely responsible for all communications exchanged between Customer and AA through the Sahamati AA Ecosystem and/or any transaction or activity conducted, or purported to be conducted with the AA;

(f) duly discharge payment obligations as arise on account of the Sahamati AA Ecosystem, and

(g) notify AA immediately if upon becoming aware of any unauthorised access to or use of their accounts.

7.6 Sahamati shall:

(a) maintain and operate Sahamati Technical Services, as per standards notified by Sahamati from time to time;

(b) design and administer the Sahamati Certification Framework to ensure that all entities seeking to be Participants are duly assessed and certified, from time to time, and also design and administer the Sahamati Certification Framework  as relevant to the mode, manner, role and function that Participants perform in the Sahamati AA Ecosystem, perform necessary assessments and certify the Participants at specified intervals for continuing participation in the Sahamati AA Ecosystem;

(c) design and maintain such additional technical services as may required by the Participants from time-to-time;

(d) institute processes, reporting requirements and/or measures for proactively monitoring performance of respective obligations by the Participants to the extent technically feasible, providing assurance of due adherence, and shall deal with breach of obligations, if any identified, in accordance with these Terms,

(e) implement and enforce these terms and take all other actions necessary for the orderly development of the Sahamati AA Ecosystem, and

(f) be able to undertake such activities, operations or services as are required, relevant or useful for the Sahamati AA Ecosystem or in accordance with these Terms, or empanel service providers for rendering such services.

8. Customer Rights

A Customer shall have the right:

(a) to be informed of all the attributes specified in the consent artefact in relation to any consent sought to be obtained from such Customer for the transfer of Data from FIPs to the FIU through the AA and/or for transfer of Data on Customer’s own request from FIPs to Customers through the AA, as the case may be;

(b) to access a record of all the consents provided, the details of the subsequent Data flows and the FIUs with whom the corresponding Data has been shared for such period of time as specified under Applicable Laws from time to time;

(c)  to raise a grievance with the grievance resolution officer of the Participants in accordance with 14 below;

(d) subject to 7.5(c) above, to any time revoke any consent that has been provided to an FIU; and

(e) to deregister from any AA at any time by following a simple process that allows the Customer to delink all connected accounts, revoke all active consents subject to 7.5(c), and download the consent and transaction history.

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9. Withdrawal of AA

9.1 No AA shall exit the Sahamati AA Ecosystem without first making appropriate arrangements to either: (a) assign its rights and obligations under these Terms to another AA; or (b) ensure that it no longer owes any obligations to any Participant.

9.2 Subject to 9.1 above, an AA may withdraw from the Sahamati AA Ecosystem by following the process set out below:

(a)The AA shall submit a notice to Sahamati in writing of its intention to withdraw from the Sahamati AA Ecosystem along with the reasons, at least ninety (90) days before such withdrawal;

(b) Sahamati shall process the withdrawal request and inform all other Participants of the Sahamati AA Ecosystem of the date on which such AA shall cease to be a part of the Sahamati AA Ecosystem; and

(c) The withdrawing AA shall take all reasonable necessary and appropriate measures to ensure that all Customers who have active consents with respect to such AA do not suffer any hardship, cost or inconvenience on account of such withdrawal.

9.3 Once the AA has completed all the obligations set out herein, such AA’s entry in the Central Registry shall be removed and thereafter the AA shall no longer be a Participant in the Sahamati AA Ecosystem or have access to the Sahamati AA Ecosystem.

10. Suspension

10.1  Sahamati may suspend a Participant from the Sahamati AA Ecosystem in the event:

(a) such Participant commits a material breach of any of these Terms;

(b) such Participant commits a breach of Applicable Laws; or

(c)  the operating license of such Participant is temporarily suspended by a Financial Sector Regulator,

10.2  Any such suspension shall remain in force until the event/s mentioned above have been duly rectified or compounded and/or its operating license restored, as the case may be. No such suspension of a Participant shall affect any of its accrued obligations to the Customer including but not limited to the obligation to provide access to the Data or perform its role and function as envisaged in these Terms.

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11.Termination

11.1  A Participant shall, forthwith, cease to be a participant in the Sahamati AA Ecosystem, in the event:

(a) its operating license is cancelled or revoked by a Financial Sector Regulator, or

(b) it ceases or is unable to carry on its business, or

(c) it is or appears likely to be unable to pay its debts or upon admission of a petition for its winding-up, dissolution, administration, bankruptcy or insolvency or the appointment of a liquidator, receiver, resolution professional or other similar officer in respect of any of its assets and/or any analogous procedure or step is taken in any jurisdiction in relation to the foregoing.

11.2   Upon the termination of a Participant:

(a) Sahamati shall inform all other Participants thereof and shall specify the date on which such termination would take effect and a separate date by when all the other Participants shall settle accounts, if any, with the terminated Participant (or the receiver, resolution professional or liquidator or other similar officer thereof, as the case may be);

(b) All other Participants shall ensure that they settle their accounts, if any, with the terminated Participant (or the receiver, resolution professional or liquidator or other similar officer thereof, as the case may be) on or before the date specified by Sahamati for settling of accounts;

(c) The terminated Participant (or the receiver, resolution professional or liquidator or other similar officer thereof, as the case may be) shall take all reasonable necessary and appropriate measures to ensure that all Customers who have active consents with respect to such Participant do not suffer any hardship, cost or inconvenience on account of such withdrawal.

11.3 Once the terminated Participant (or the receiver, resolution professional or liquidator   or other similar officer thereof, as the case may be) has completed all the obligations set out herein to the satisfaction of Sahamati, reference to such terminating Partner in the Central Registry shall be removed and the terminating Participant shall no longer be a Participant of the Sahamati AA Ecosystem.

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12. Liabilities

12.1  In the event any Data in the possession or control of a Participant is lost, damaged or otherwise rendered unusable, then such Participant alone shall be liable for the consequences of such event.

12.2  A Participant shall be liable for any loss or damage notwithstanding the fact it was caused due to gross negligence or willful misconduct of the Participant’s employees or agents, representatives or contractors or because it arose on account of its gross negligence or willful misconduct.

12.3 No Participant shall be liable to any other party/ies for: (a) any third party claims, indirect or consequential loss or damage, or special or punitive or exemplary damages, or loss of profit, business, revenue, goodwill of the other party/ies, (b) an amount exceeding the annual total revenue (attributable to its participation in the Sahamati AA Ecosystem) in the year in which the claim or dispute arises unless the liability is on account of gross negligence or willful misconduct by such Participant (or its employees or agents, representatives or contractors) or when such liability arises on account of breach of applicable laws.

12.4 Notwithstanding anything contained in these Terms, no Participant shall be liable for a failure to participate on account of:

(a)any act or omission attributable to any other Participant (including, but not limited to, any rejection, downtime or negligence, or any malfunction of its technical systems or its incompatibility or failure to comply with the technical specifications and/ or Applicable Laws),

(b) any delay, revocation or suspension of consent on the part of a Customer to transfer Data from FIPs to FIUs or to the Customer, as the case may be,

(c) any Force Majeure Event, or

(d) any change in Applicable Laws.

12.5 Notwithstanding anything contained in these Terms, FIPs or FIUs shall not be held liable for any breach, loss, damages that may arise out of or result on account of transfer of Financial Information based on the consent obtained and shared under the consent artefact in the manner and mode provided for under the Applicable Laws. Provided that nothing contained herein will absolve the FIP or the FIU, as the case may be, from any gross negligence or willful misconduct.

12.6 In case of a failure by any Participant to comply with their respective roles and obligations, the defaulting Participant shall be liable for such penalties and consequences as prescribed under these Terms or Applicable Laws. Notwithstanding anything contained herein, no Participant shall be held liable for any breach, non-compliance, failure (including but not limited to data security breach) if such Participant complied with Applicable Laws (including the technical specifications issued by ReBIT, from time to time).

13. Indemnification

Subject to these Terms, each Participants shall indemnify and keep indemnified every other Participants, their respective officers, directors, personnel, representatives from and against any and all direct loss suffered or incurred (including but not limited to liabilities, judgments, awards, damages, losses, claims, costs and expenses, etc.), arising out of breach of any provisions under these Terms and/or violation of any applicable laws. The indemnity obligations set out herein shall survive the termination or exit of any indemnifying party from the Sahamati AA Ecosystem for a period of three (3) years after such termination or exit.

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14. Grievance Redressal & Dispute Resolution

14.1  Customer complaints, claims, disputes or grievances (together termed ‘grievance/s’) involving factual matters capable of being ascertained as fully or partially valid (or not) in an automated mode or manner by checking the relevant records of the concerned Participant/s, shall be so ascertained, and the accepting or rejecting such grievance/s (fully or partially) shall be duly notified to the claimant or the aggrieved person on so being ascertained. Where the grievance/s has been accepted as fully or partially valid, the Participant will undertake due measures to redress the grievance or make payment of the specified compensation to the claimant or the aggrieved person. Sahamati shall identify and notify from time to time the types of grievance/s which shall be attended to in this manner, and the appropriate amount, level or range compensation that shall be payable by the relevant Participant when a grievance/s has been ascertained to be fully or partially valid.

14.2 Customer grievances that are unresolved by the automated mode specified in 14.1, or if the Customer is not satisfied with the resolution provided through the automated mode specified in 14.1, or which arise before the automated mode becomes effective for specified types of grievances as envisaged in 14.1, shall be addressed in the following manner and sequence:

1. by placing the grievance for redress by the Grievance Redressal Officer of the Participant, as applicable, and/or the Internal Ombudsman of the Participant (if any), whose determination will be binding on the Participant.

1. If the Customer is not satisfied by the determination made by the Grievance Redressal Officer or the Internal Ombudsman of the Participant, as applicable, and subject to applicability of the respective Ombudsman Scheme specified by a Financial Sector Regulator governing the Participant, or appeal process, if any specified in Applicable Laws to deal with the matter, the grievance or appeal in relation to the determination shall be referred to an ODR Institution, empaneled by Sahamati from time to time, which shall facilitate online mediation or online conciliation.

The ODR Institution shall accordingly appoint a mediator or a conciliator, in accordance with its mediation or conciliation rules and the process shall be administered in accordance with such mediation or conciliation rules.

If such mediation or conciliation is unsuccessful in resolving the grievance as well as if the Customer is not satisfied with the determination made in terms of the Ombudsman Scheme or the appeal process as laid down, if applicable, then the grievance or appeal in relation to the determination shall be referred to an ODR Institution, empaneled by Sahamati from time to time, which shall appoint an independent sole arbitrator, in accordance with its arbitration rules to adjudicate the grievance.

The grievance shall be resolved by means of arbitration in terms of the applicable rules of the ODR Institution, and in accordance with the Arbitration and Conciliation Act, 1996. Such a process shall be conducted (including for recording of evidence or tendering of documents), concluded and administered online by the ODR Institution through its website/platform or its mobile application, and the determination made by such process shall be binding on such Customer and the Participant. The seat of arbitration proceedings shall be city and state where Sahamati is headquartered. The procedural law of arbitration shall be the rules of the ODR Institution.

Sahamati will also explore the possibility of creating APIs for ease of reference of grievances to ODR Institutions as envisaged in this section.

14.3  Any complaints, claims, disputes or grievances (together termed ‘dispute’) arising out of or in connection with these Terms between two or more Participants shall be referred to an ODR Institution, empaneled by Sahamati from time to time, which shall facilitate online mediation or online conciliation. The ODR Institution shall accordingly appoint a mediator or a conciliator, appointed in accordance with the applicable mediation or conciliation rules of the ODR Institution for such dispute. The process shall be administered in accordance with the applicable mediation or conciliation rules of the ODR Institution.

If such mediation or conciliation is unsuccessful in resolving the dispute, then the ODR

Institution shall appoint an independent sole arbitrator, in accordance with the applicable arbitration rules of the ODR Institution, to adjudicate the dispute.

The dispute shall be resolved by means of arbitration in terms of the applicable rules of the ODR Institution, and in accordance with the Arbitration and Conciliation Act, 1996. Such a process shall be conducted (including for recording of evidence or tendering of documents), concluded and administered online by the ODR Institution through its website/platform or its mobile application, and the determination made by such process shall be binding on such Participants. The seat of arbitration proceedings shall be city and state where Sahamati is headquartered. The procedural law of arbitration shall be the rules of the ODR Institution.

​

15. Confidentiality Obligation

All the Participants recognise that in the course of their participation in the Sahamati AA Ecosystem they will gain access to confidential information and agree to adhere to the same standard of care that it uses for its own confidential materials or for personal data as required by Applicable Laws.  The Participants agree that they will use such confidential information only in accordance with the terms of the contractual arrangements with the Customer and shall not use this confidential information for any purpose that has not been specifically permitted.

16. Privacy

All the Participants shall adhere to all applicable laws governing privacy, and hereby agree to utilize any Customer information which is received, provided or in the possession of the Participant only as approved or authorized by the Customer, these Terms or as per applicable laws, and not utilize the same in any other mode or manner. Sahamati will further evolve the privacy obligations of the Participants from time to time and publish the Privacy Policy required to be adhered to by the Participants.

17. Miscellaneous

17.1 Any delays or failure in performance by a Participants under these Terms shall not constitute a default hereunder if and to the extent caused by a Force Majeure Event.

17.2 All notices or other communications under these Terms shall be in writing and, unless otherwise specified, may be sent by email, speed post or courier or any other acceptable mode of electronic communication. Any such notice or other communication will be deemed to be effective: (i) if delivered in person, at the time of such delivery; (ii) if dispatched by speed post or courier, when recall of the letter is outside the control of the sender; (iii) if sent by email, when such email enters the sent items folders.

17.3  No delay by a Participant in enforcing any provision of these Terms shall be construed to be a waiver of any of the rights under such provision.

17.4  If any provision of these Terms is held to be invalid or unenforceable by a court or tribunal of competent jurisdiction or by the dispute resolution mechanism specified in these Terms, then the remaining Terms shall remain in full force and effect as if the invalid or unenforceable provision had never been part of these Terms.

17.5 Nothing in these Terms shall be deemed to be a transfer, license or assignment of any right, title, interest or claim in relation to intellectual property rights of any Participant, and any such transfer, license or assignment should be between or among the parties thereto in writing.

 Annexure 1: Declaration

This declaration is executed by [___][Name of Organisation] having its registered office at [___][registered office address] (hereinafter the Acceptor).

The Acceptor, having reviewed the Sahamati Account Aggregator Ecosystem Participation Terms (version 1.0), wishes to participate in the Sahamati Account Aggregator Ecosystem as a [choose any one of the following: AA, FIP, FIU]

The Acceptor hereby agrees the Sahamati Account Aggregator Ecosystem Participation Terms, as amended from time to time, shall be binding on it and commits to perform all the obligations required of it, in accordance with the terms thereof. The Acceptor acknowledges that its continued participation in the Sahamati Account Aggregator Ecosystem is conditional upon its continued compliance with the Sahamati Account Aggregator Ecosystem Participation Terms, as amended from time to time.

This declaration is made by the Acceptor on this the [___] day of [___], 20__.

Executed by

______________________________

Name

______________________________

Designation

Affix the digital signature, here.

Annexure 2: Onboarding Process for Participants into the Sahamati AA Ecosystem

Every participant, be it an FIP, FIU or an AA, can onboard itself into the Sahamati AA Ecosystem using the process described below:

1. Become a member of the Sahamati AA ecosystem by agreeing to and accepting the Sahamati AA Ecosystem Participation Terms in the manner specified.

1. Be ready with its technical implementation of the AA Technical Standards, as relevant to the role (FIP/FIU/AA) it wishes to play in the Sahamati AA ecosystem.

1. Be ready with its technical implementation to integrate Sahamati Technical Services (such as the Central Registry APIs, Token Service APIs) as relevant to its role.

Details of Technology Service Providers (TSPs) who offer technical services for the above can be found on the Sahamati website. Sahamati, however, has no role to play in facilitating any commercial arrangements between participants and TSPs.

Details of Sahamati Technical Services can be obtained by writing in to [email protected].

1. Test its technical implementations using UAT environments for access to Sahamati Technical Services and AA Sandboxes (relevant only for FIP / FIU participants).

Details for accessing the UAT environment of Sahamati Technical Services can be obtained by writing an email to [email protected].

Details of AA sandboxes can be found on the Sahamati website.

Sahamati, however, has no role to play in facilitating any commercial arrangements between participants (FIPs/FIUs) and AAs.

1. Undergo the Certification process, as defined in the Sahamati Certification Framework.

Details of the Sahamati Certification Framework and entities empaneled by Sahamati as Certifiers can be found on the Sahamati website.

Sahamati, however, has no role to play in facilitating any commercial arrangements between participants and empaneled certifiers.

1. Once certified, gain access to the production environment of Sahamati Technical Services and other participants in the Sahamati AA ecosystem.

Details for accessing the production environments can be obtained by writing an email to [email protected].

Privacy Policy

Arthmate Financing India Private Limited

(Formerly known as Mamta Projects Private Limited) (CIN: U23209WB1994PTC063940)

Regd. Office: EM03, Unit 1528, 15th Floor, Bengal Eco Intelligent Park, Sector V, Saltlake, Kolkata WB 700091

Email: [email protected]

Document Control

Change Control, Review and Approval

This Privacy Policy (“Policy”) governs the use of this website www.arthmate.com (Website/Site) of Arthmate Financing India Private Limited (Formerly known as Mamta Projects Private Limited) [herein also referred to as “AFIPL” or “the Company”] for your information and communication. By availing any service / credit facility being provided by AFIPL directly or indirectly including by utilising the Site (“Services”) you have agreed to each and all of the terms and conditions of this Privacy Policy as set forth below and waive any right to claim ambiguity or error in the same.

"AFIPL" refers to Arthmate Financing India Private Limited including its affiliates and subsidiaries (also referredto as "we", "us" or "our").

1. INTRODUCTION

   All services provided by AFIPL through the Website shall be governed by this Policy. This Policy seeks to help you understand:

   • The type of personal or sensitive personal data or information collected by AFIPL;

   • The purpose of collection of personal information, the manner of collection, storage, retention and use of such information;

   • The parties to whom such personal information is disclosed; and

   • The security practices and procedures and management of personal information adopted by AFIPL to protect User’s personal information collected by AFIPL.

     By accessing and using the Website, you accept the terms of, and be bound by this privacy policy. This privacy policy may be updated from time to time at our sole discretion or on account of changes in law. Unless otherwise specified, such revisions shall take effect from the day and date they are posted on the Website. AFIPL shall be under no obligation to notify the User about the changes. You are advised to consult this privacy policy regularly for any changes, as your continued access and use of the Website shall be deemed to be your approval and acceptance of all changes to this privacy policy.

     Any User who does not consent to this Policy or any part thereof is required to leave the Website immediately. Should you disagree with this Policy and still continue to access the Website, AFIPL disclaims all liabilities arising from your use of the Website in accordance with this Policy.

     
     

2. COLLECTION OF INFORMATION

   
   

   The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 defines “Personal Information” as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

   AFIPL may collect, store and use information about you when you (a) visit, use, view, and/or otherwise utilise this Site including filling out any form and subscribing to any newsletter and/or (b) fill any loan application form online or otherwise when you apply for a loan from AFIPL and this loan application form called by whatever name, may be provided directly by AFIPL or through any outsourcing partner of AFIPL and may or may not specify the name of AFIPL as the lender and/or (c) through any other

   modes and includes the information that you submit directly or indirectly to us for availing the

   Services. Further, the information provided by you may be further utilised to procure more information.

   In the course of using this Site or availing the Services, AFIPL collects various information including your name, address, email address, phone number, date of birth, occupation and job position, financial information (such as income, income sources, assets, details of debit cards, credit cards, bank account details etc.), medical records, biometric information, documents that you provide to us to verify your identity or in terms of KYC requirements (such as copies of your Aadhaar card, PAN card, passport, utility bills, and/or bank statement or your company incorporation details). Also, once any loan has been granted to you, AFIPL may from time to time undertake your credit evaluation including taking out your CIBIL Score, statement of accounts etc.

   AFIPL may also collect some information automatically each time you use the Site which may include:

   • IP address;

   • Information about your web browser software and version;

   • General geographic location indicated by your IP address;

   • Website that referred you to us, and similar information.

   • Your device’s metadata.

     We may also collect information about your activity on our Site, which might include:

   • Frequency of visits to our Site;

   • Average length of visits;

   • Pages viewed during a visit.

   We may use various technologies to collect information about your activities on our Site, including Cookies and beacons. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow and if not selected it may affect certain or all functionalities) that enables the sites or service providers’ systems to recognise your browser and capture and remember certain information. We may combine information collected from you, automatically gathered information and the information we collect through cookies / web beacons / web bugs, including information that we have collected about you, or information that we have obtained from other sources. We may aggregate any statistics or data that are collected, but we are under no obligation to do so. By accessing and using the Site, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned herein.

   
   

3. USE OF COLLECTED PERSONAL INFORMATION

   AFIPL may use the personal information that is collected from you to provide various Services and for our internal business purposes, including, but not limited to:

   • Responding to your requests for our products and services;

   • Grant of credit facility and to ensure due repayment of the same;

   • To undertake your credit evaluation from time to time to ensure due payment of any loan facility granted to you;

   • Responding to your requests for information;

   • Maintaining and managing your account with us;

   • To personalise your experience (your information helps us to better respond to your individual needs);

   • To improve our Site (we continually strive to improve our Site offerings based on the information and feedback we receive from you);

   • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);

   • To process transactions and to provide you with transaction and post transaction-related services;

   • To administer a contest, promotion, survey or other site feature;

   • For advertising, such as providing customised and personalised advertisements, sponsored content and sending you promotional or marketing communications;

   • To send periodic emails;

   • The email address and phone number you provide may be used to send you information, respond to inquiries, and/or other requests or questions, and/or to intimate through phone, e-mail etc. the due date of payments or breach of any contract entered by you for grant of any Service by AFIPL;

   • For Internal business purpose, such as Data analysis, research, developing new features, enhancing and improving the experience, identifying usage trends, etc.

   • Otherwise with your consent.

     In addition, certain information we collect, such as the IP address of any computer or other device that you use to access our Site and any other domains that may be operated by AFIPL, will be used to monitor and investigate possible violations of and to enforce any terms and conditions associated with our Services or other applicable agreements / contract between you and AFIPL / any service provider of AFIPL.

     By availing any Service, using the Site and / or providing AFIPL with your information, you consent to the storing of information by AFIPL and the third parties as mentioned herein in a manner as they deem fit and you also consent to collection, transfer, storage and processing of your information outside of India, by AFIPL or any third party and you understand that AFIPL will not be able to ensure the same level of data protection that is adhered to by AFIPL by such third party.

4. SHARING OF INFORMATION

   AFIPL may share your personal information with:

   Service Providers: We may disclose your information to companies that provide services for or on behalf of AFIPL. There are certain third parties that source customers to AFIPL and directly interact with the customers before introducing them to AFIPL and such third parties may separately collect information from you which may or may not be shared with AFIPL. It is suggested that you go through their privacy policy before providing them such information and AFIPL shall not be responsible for use and disclosure of any such information by such third parties / service providers. By using the Site and our Services you authorize us to exchange, share, part with all information related to your details and transaction history to such service providers /insurance providers/credit bureaus / agencies and / or

   for participation in any telecommunication or electronic clearing network as may be required by

   applicable law, customary practice, credit reporting, statistical analysis and credit scoring, verification or risk management and you shall not hold us liable for use or disclosure of this information.

   Business Partners: We may share your information with business partners. These entities may use your information to provide you with services you request, make predictions about your interests and may provide you with promotional materials, advertisements and other materials.

   Group Companies: AFIPL may share collected personal information with group companies / subsidiaries / affiliates whose products and services we believe you may find of interest. If you would prefer that we not share your personal information with any third parties for the third parties’ marketing purposes, you can notify us of your preference by contacting us as described in the “Contact Us” section.

   Statutory and other Disclosures: There may be instances when we disclose your information to other parties (including government/regulatory bodies or agencies):

   • to comply with the law or respond to compulsory legal process (such as a search warrant or other court order) or when we believe release is appropriate to comply with applicable law, enforceable governmental request, enforce our Site policies and terms of Service (including investigation of potential violations), detect, prevent, or otherwise address fraud, security or technical issues or protect ours or other’s rights, property, or safety as permitted by law;

   • for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences;

   • to verify or enforce compliance with the policies governing the Services;

   • to protect the rights, property, or safety of AFIPL, or any of AFIPL’s respective affiliates, business partners, or customers or employees. However, this does not include use of your information (including sensitive data or information) for any commercial purposes which is inconsistent with any of the practices described in this Policy);

   • for enforcement of any rights of AFIPL / service provider under any contract / agreement executed by you;

   • to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

   You agree and consent to our collection, storage, processing, transfer and sharing of information (including sensitive personal data or information) about you or your use of Services with third parties or service providers identified above. When we share, process or transfer your information (including sensitive personal data or information), we will ensure that it is shared, processed or transferred in compliance with applicable laws.

   Our use and sharing of your personal information in the manner described in this Privacy Policy may involve the transfer of your personal information to third parties that are in countries outside your country of residence, which may not have the same privacy legislation as your country of residence.

   Transactions: AFIPL may share personal information in connection with a substantial corporate transaction, such as mergers, acquisition, the sale of its business, a divestiture, consolidation, or asset sale, or in the unlikely event of bankruptcy.

   Other Purposes: AFIPL may share personal information pursuant to your consent.

   
   

   Marketing: Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

   Third Parties: For our Site users’ convenience, AFIPL may provide links or otherwise refer you to third parties, such as operators of internet services linked to from our Site, that may collect personal information from you. In addition, AFIPL may invite your participation in various promotional initiatives through its presence on social networking Sites and blogs operated by third parties, such as LinkedIn, Facebook, Twitter, Wordpress etc. Personal information collected by these third parties is not covered by this Policy and AFIPL shall not be liable for such information being provided by you or collected by such third parties.

   In addition, AFIPL may provide you with links to “share” any AFIPL content with other third parties via email or certain social networking websites for your convenience. Data transmitted during such linking, including but not limited to your email address or the email address of the party receiving such data, shall not be tracked by AFIPL. Use of AFIPL data by any third party shall be at their discretion and risk. Personal information collected by these third parties is not covered by this Privacy Policy, and AFIPL shall not be bound in any manner by any claims and/or liabilities arising thereto.

   It is clarified that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of this Privacy Policy.

5. PROTECTION OF INFORMATION

   
   

   We take the safety of your Personal Data and its confidentiality very seriously and we provide reasonable security safeguards commensurate to the sensitivity of the Persona Data being handled and have implemented security practices including but not limited to technical, operational and physical safeguards to protect your information. We implement a variety of security measures when a User enters, submits, or accesses their information to maintain the safety of your Personal Data.

   The Website is scanned on a regular basis for any known vulnerabilities in order to make your use as safe as possible.

   Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems or otherwise require the Personal Data for the purposes enlisted in this policy. These persons are also under an obligation to keep such Personal Data confidential.

   Please be aware that, although we endeavour to provide reasonable security for your Personal Data, no security system can prevent all potential security breaches.

   We endeavour to ensure to the best of our ability that all third party service providers whose services which we may use, maintain security standards that are equivalent to our security standards and commensurate with market practices, in the context of the kind and nature of Personal Data being stored or handled.

   
   

6. RETAIN INFORMATION:

   We will retain your information for as long as your account is active or as needed to provide you Services and till it is required to be retained to comply with our legal obligations, resolve disputes, and enforce our agreements and to comply with statutory and regulatory obligations and guidelines.

7. CHANGES TO YOUR INFORMATION

   
   

   If the information provided by you has changed, then you may update it by contacting us on the details provided below. You are also entitled to review the information provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient be corrected or amended as feasible. However, AFIPL shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by you.

   
   

8. NO CONTRACTUAL OBLIGATION:

   Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

   
   

9. USER’S CONSENT

   By using our Services, you consent to this Privacy Policy. You hereby expressly and irrevocably authorise AFIPL / its partners / affiliates to collect, store, share, obtain and authenticate any aspect of your personal information / KYC either directly or through any of the authorized agencies and disclose such information to our agents /contractors / service providers and to also use such information in the manner that may be required by AFIPL / its partners / affiliates including for the purposes of grant of credit facility and for purposes of its business and for such time period as we may deem fit. In this regard, you expressly and irrevocably authorise AFIPL / its partners / affiliates to collect, use, verify and authenticate your personal identity information / KYC in any manner without any notice to you.

10. GOVERNING LAW AND JURISDICTION

    
    

    The terms of this privacy policy are governed by and shall be interpreted in accordance with the laws of India, without regard to the choice or conflicts of law provisions of any jurisdiction. In the event of any dispute arising between AFIPL on one hand and the User and/or any third party on the other hand, in relation to the terms of this policy, whether in contract or tort or otherwise, such User and/or third party hereby agree to submit to the jurisdiction of the courts located at Delhi, India for the resolution of all such disputes.

11. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

If the User has any grievance under this Privacy Policy, the User may contact the grievance officer appointed in accordance with the Information Technology Act, 2000 and Rules made thereunder and pursuant to the RBI guidelines:

Mr. Yogesh Rohilla

Arthmate Financing India Private Limited The Circle Work, 3rd Floor,Huda City Center, Sector – 29,Gurugram, Haryana – 122002 Email: [email protected]m Tel. +91 – 7835009643

If the User is dissatisfied or if the complaint isn’t redressed within 1 (one) month, the User may lodge a complaint over the Complaint Management System (CMS) portal under Reserve Bank – Integrated Ombudsman Scheme (RB-IOS).

******************************END OF THE DOCUMENT**********************************

Board Members

Board of Directors - Arthmate

Board of Directors - Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) (Arthmate’s NBFC)

Interest Rate Policy

1.Introduction & Scope

To ensure healthy and sustainable growth of the Company as well as highest standard of Customer satisfaction & confidence in our Financial Services, we are setting Principles, Procedures and System for determining the Rate of Interest / Business Schemes, processing fee and other charges.

In addition to our internal policy, this is also in compliance with 'Master Direction - Non-Banking Financial Company - Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 issued by RBI vide Circular No. DNBR. PD. 008/03.10.119/2016-17 dated September 01, 2016' (as amended from time to time) read with RBI Circular No. DNBS.PD/CC. No 95/03.05.002/2006-2007 dated May 24, 2007 & Notification No. DNBS.204/CGM (ASR) - 2009 dated January 2, 2009 (hereinafter "RBI Directions"), in respect of Appropriate Internal Principles and Procedure in determining the Rate of Interest and fixing of Processing and other Charges and appropriate systems for implementation thereof (hereinafter "Policy").

To ensure healthy and sustainable growth of the Company as well as highest standard of Customer satisfaction & confidence in our Financial Services, we are setting Principles, Procedures and System for determining the Rate of Interest / Business Schemes, processing fee and other charges.

In addition to our internal policy, this is also in compliance with 'Master Direction - Non-Banking Financial Company - Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 issued by RBI vide Circular No. DNBR. PD. 008/03.10.119/2016-17 dated September 01, 2016' (as amended from time to time) read with RBI Circular No. DNBS.PD/CC. No 95/03.05.002/2006-2007 dated May 24, 2007 & Notification No. DNBS.204/CGM (ASR) - 2009 dated January 2, 2009 (hereinafter "RBI Directions"), in respect of Appropriate Internal Principles and Procedure in determining the Rate of Interest and fixing of Processing and other Charges and appropriate systems for implementation thereof (hereinafter "Policy").

2. Application

This policy applies to ALCO ( Asset-Liabilities committee), Wholesale Risk/Retail Risk teams, Sales and Product Teams. They are required to acknowledge having read the policy document and sign a letter of spirit of adherence to the policy in the normal course of business. 

3. Principles for determining interest rates

Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), follows a discrete interest rate model / policy whereby the rate of interest for same product and tenor availed during same period by customers would not be a standardized one but could be different for different customers depending upon consideration of any or combination of, but not only restricted to the factors which are listed below- 

The interest rates would be offered on fixed, floating - (variable) basis. The floating rates would be decided on periodic intervals at monthly / bi monthly / quarterly intervals depending upon various market factors and also on an ad-hoc basis, in case of some specific events leading to a change in the cost of borrowing or profitability of the company. Any revision in the Company’s interest rates applicable to business would be reviewed and approved by the ALCO Committee.

While determining Business Schemes, Rate of Interest (ROI), Processing Fees (PF), Documents Charges and other Charges, following factors will be considered:

1. Weighted Average Cost of Funds/Borrowings – incremental and overall; Fixed &   Variable Costs; Reasonable Margin to cover regulatory requirements of provisioning, Capital charge & Profit margin to sustain in the business; Risk Premium; Prevailing Competitive Economic and Financial Scenario; Conformity to Asset Liability Guidelines of the Company.

2.  Profile of the customers, qualification, Subventions, Schemes, Promotion Campaign, Subsidies available, permitted deviations, Ancillary business opportunities and the future potential business anticipated by the Management.

3. Group strength and value to lender group, overall customer yield, nature and value of primary and collateral security, past repayment track record of the customers; Risk strategy of each business and product vertical, prevalent market trends on interest rates and charges; 

4. Various risk factors associated with each customer segment; overall micro and macroeconomics pertinent from time to time; forward looking forecast basis past trends; the overall behaviour of the portfolio, its bucket movements and collections efficiencies; losses arising out of recoveries and repossession cum sale of assets; customer segment and individual customer level profitability, 

5. Fixed and Floating rates both to be considered and reviewed /reset every month/bi-monthly/quarter considering the strategy, company performance, market dynamics and Risks (market, operational, customer risks). 

6. The benchmark for floating interest rates would be the FRR (Floating Rate Reference), which would be SBI MCLR rate and is proposed at SBI MCLR + 900 basis points, which is to be reviewed from time to time. Fixed rate of interest for some products would be decided based on the customer segment, product tenure, and product specific risks, besides being in line with market rates being offered to similar customer segment on these product categories. 

4. Internal Procedure/Appropriate System for Determining the ROI

To decide ROI and Schemes, periodically ALCO will review various factors (as mentioned above) and will decide Company's benchmark lending rates. 

5. Principles of Transparency, Fairness, Incentive to Service the Debt on Time

1. Interest rates would be intimated to the customers in English and in vernacular or in the language understood by the customer at the time of sanction/ availing of the loan.

2. Interest rate would also be mentioned  in the Statement of Account sent to the Customer from time to time . 

3. The interest reset period in case of variable loans would be decided by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), from time to time. At the time of interest reset, wherever applicable (for instance in Floating Home loan rates), the customer would be offered either a change in tenor or a change in the EMI amount, as decided by the ALCO or prevalent regulatory guidelines. 

4. The interest could be charged on either daily, or monthly or longer rests based on the product, market dynamics, competitive practices and risk strategy of the company. 

5. The interest shall be deemed payable immediately on the due date as communicated and no grace period for payment of interest is allowed unless communicated to the customer explicitly in the sanction letter, specific to some products, with a defined period of any principal and/or interest moratorium. 

6. Interest changes would be prospective in effect and intimation of change of interest or other charges would be communicated to customers in a mode and manner deemed fit by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), as also in line with any regulatory conditions and in case of the Floating interest rate, change of interest will be communicated one month in advance in a mode and manner deemed fit by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), as also in line with any regulatory conditions, and the revised rates will be applicable from subsequent month.

7. Uniformity in the Schemes will be maintained for the rate of interest & charges for all the Customers covered under particular scheme, profile and category. However, they may vary based on Risk Gradation, Portfolio Performance etc.

8. In case of staggered disbursements, the rates of interest would be subjected to review and the same may vary according to the prevailing rate at the time of disbursements or as may be decided by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd).

6. Default in Payment of Instalments / Other Dues

Customers shall be liable to pay all applicable charges including but not limited to Cheque Bouncing Charges (CBC), Late Payment Penalty (LPP), Recovery / Legal Charges etc., in case of default in payment of Instalments / other dues. Company shall disclose these charges to its Applicants / Borrowers via various types of documents like Application Form, Sanction Letter, and Loan Agreement, which would also be displayed on the company’s website in the Schedule of charges.

If any change is introduced in the above charges based on economic or financial scenario etc., Company shall notify the Customer in the language as understood by the Customer about such changes as also the effective date from when the revised rates are being made applicable.

7. Schemes as per Credit worthiness of the Customer

On the basis of credit worthiness of the Customer, Quantum of Loan, Interest, Charges and Schemes prevalent shall be disclosed to the Customer with a view to help them in choosing the Scheme as per their interest. The company endeavours to have a risk-based pricing which could lead to different rates for different customers for the same product offering.

8.Processing / Documentation and Other Charge

All processing / documentation and other charges recovered are expressly stated in the Sanction Letter and Loan Agreement. They vary based on the asset financed, the exposure limit, tenor, expenses incurred in the geographical location, customer segment and generally represent the cost incurred in rendering services to the customers. 

Besides interest and Processing / Documentation fees, other financial charges like origination fees, cheque bouncing charges, late payment charges, re-scheduling charges, pre-payment / foreclosure charges, part disbursement charges, cheque/NACH swap charges, security swap charges, charges for issue of statement account etc., would be levied by the company wherever considered necessary. Besides these charges, stamp duty, Goods and Service Tax and other cess would be collected at applicable rates from time to time as communicated in the documentation provided. Any revision in these charges would have a prospective effect and will be communicated with the borrower, in line with the RBI guidelines.  While deciding the charges, the practices followed by the competitors in the market would also be taken into consideration in addition to the factors listed in Clause 3 above.

9. WAIVERS/REFUNDS

No claims for refund or waiver of such charges/ penal interest / additional interest would normally be entertained by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), and it is the sole discretion of Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) to deal with such requests, if any, which would be decided by authorised officials/committees on a case to case basis. 

10. EXCEPTION APPROVAL & REVIEW

The Board of Directors of Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) would review the policy based on business requirements. Any deviations to the policy would be approved as per Board approved Delegation of Authority. Claims for refund or waiver of charges / penal interest / additional interest would normally not be entertained by the company and it is at the sole discretion of the company to deal with such requests.

11. DISPLAY

In conformity to the Fair Practice Code, this policy shall be displayed at the Company’s website for the information of the Customers of the Company. 

Grievance Redressal Policy

Arthmate Financing India Private Limited

(formerly known as Mamta Projects Private Limited)

(CIN : U23209WB1994PTC063940)
Regd. Office : EM03, Unit 1528, 15th Floor, Bengal Eco Intelligent Park, Sector V,
Saltlake, Kolkata West Bengal – 700091
Email: [email protected] [email protected]
Mob.: 07835009643 Website: www.arthmate.com

Policy on Grievance Redressal Mechanism

Arthmate Financing India Private Limited

(Formerly known as Mamta Projects Private Limited)
(CIN: U23209WB1994PTC063940)

Regd. Office: EM03, Unit 1528, 15th Floor, Bengal Eco Intelligent Park, Sector V, Saltlake, Kolkata

West Bengal – 700091

Email: [email protected]

Document Control

Change Control, Review and Approval

Table of Contents

1.    Introduction

Arthmate Financing India Pvt. Ltd. (hereinafter referred to as “Company”) endeavors to be a customer centric organization. In keeping with this value, we have devised a mechanism that aims at minimizing the instances of customer complaints and grievances, whilst ensuring prompt redressal. In order to make the Company's redressal mechanism more meaningful and effective, a structured system has been put in place.

2.    Objective of the policy

The Policy on Grievance Redressal Mechanism (hereinafter referred to as “Policy”) is being formed with an aim to provide quick amends to customer issues. In case of a complaint, we have a detailed review mechanism to identify the company’s shortcomings and overcome them quickly, reducing as far as possible inconvenience to our customers. This Policy also covers issues relating to services provided by the outsourced agency, engaged by the Company for providing some of the services.

3.    Key Commitments

Arthmate Financing India Pvt. Ltd., through its management, intends to uphold the following commitments:

• 3.1.    To act fairly and reasonably in all dealings with its customers by ensuring that:
• 3.1.i.    It’s products and services will meet all relevant laws and regulations as applicable, for the time being in force
• 3.1.ii.    Its dealings with its customers will be based on principals of transparency and fairness
• 3.2.    The Company will assist its customers in understanding its products and services by
• 3.2.i.    Providing information in Hindi, English, or few other local languages.
• 3.2.ii.    Explaining their financial implications and helping the customer choose the one that best meets his / her needs.
• 3.3.    The Company will make every attempt to ensure that its customers have a trouble free experience in dealing with us. However, in case of any instances of disagreement with the service provided by the Company to its customers, the same will be dealt with utmost care and in a reasonable time frame.
• 3.4.    In case the customer is not satisfied with the way their complaint is handled, to provide detailed procedure of grievance redressal.

4.    Redressal Mechanism

“Complaint”- A complaint means an expression of dissatisfaction made to the Company by any borrower or someone legally representing their interests, about our products, services or our complaint-handling process, where a response or resolution is explicitly or implicitly expected.

4.1    Escalation Matrix

• The company has a structured grievance redressal mechanism in practice where all complaints/grievances will be attended as per a defined time schedule. Customers may follow the below mentioned matrix in order to escalate their concerns. This facility has been provided to the customers to register complaints for speedy redressal.
• Level 1 Escalation: Customers are requested to follow either of the below mentioned steps for any complaints / grievances:
  

  Email us at	[email protected] [email protected]
  Call us at*	07835009643
  Write / Meet us at*	Customer Service Cell, Arthmate Financing India Pvt. Ltd., The Circle Work, 3rd Floor, Huda City Center, Sector – 29, Gurugram, Haryana – 122002

• *Monday to Friday during 10:00 AM to 6:00 PM
• Level 2 Escalation: If the complaint/grievance addressed to the Customer Service is not taken up or resolved within 15 days or customer is not satisfied with response received from the Customer Service, may approach the Grievance Redressal Officer / Principal Nodal Officer.:

• Grievance Redressal Officer	Principle Nodal Officer
  Ms. Deepika Rawat Arthmate Financing India Private Limited The Circle Work, 3rd Floor, Huda City Center, Sector – 29, Gurugram, Haryana – 122002 Email: [email protected]	Mr. Yogesh Rohilla Arthmate Financing India Private Limited The Circle Work, 3rd Floor, Huda City Center, Sector – 29, Gurugram, Haryana – 122002 Email: [email protected]

• Level 3 Escalation: If the complaint/grievance/dispute is not redressed within a period of one month after the date of representation or complaint to the Company, the borrower / customer may approach to the Ombudsman of RBI (not later than one year after the reply received from the Company).
  

  Details of RBI Ombudsman available on:
  https://rbi.org.in/Scripts/AboutUsDisplay.aspx?pg=BankingOmbudsmen.htm

5.    Responsibilities of the Grievance Redressal Officer / Principal Nodal Officer

• 5.1.    After receiving customers’ complaint through e-mail or written letters, or calls at the designated Customer Service number the GRO (Grievance Redressal Officer) / PNO (Principal Nodal Officer) will examine the matter and respond to all complaints within 30 days from the date of receipt of such complaint.
• 5.2.    Ensure adherence to the process laid down in this Policy and process laid down in this document, monitor its implementation and initiate corrective action wherever needed.
• 5.3.    Decide upon matters requiring immediate attention and follow up for timely redressal of grievances wherever delay is observed.
• 5.4.    Take appropriate action to avoid any such delays in future, through a monthly report submission to the management and a quarterly submission to the Board of the company.

6.    Internal machinery to handle Customer complaints

6.1 Resolution of grievances

• 6.1.a.    The Customer Service Cell is responsible for the resolution of concerns/grievances at the earliest. They would be responsible for sending an acknowledgment to the customers with Service Request Number and tentative timelines for resolution, with timely updates to the customer on the progress of the complaint.
• 6.1.b.    It is their foremost duty to see that the concern should be resolved completely to the customer's satisfaction and if the customer is not satisfied, then he should be provided with alternate avenues to escalate the issue.
• 6.1.c.    If the customer service manager feels that it is not possible at his level to solve the problem, he may refer the case to Customer Service Head / GRO / PNO for the resolution.
• 6.1.d.    Upon resolution, a reply will be sent to the customer through telephone, email or post

6.2 Time Frame

• 6.2.a.    If a complaint is received from a customer through any of the above channels, Company shall send an acknowledgement within two days
• 6.2.b.    After examining the matter, the company will send final response or explain the reason for taking more time to respond with expected time lines for resolution, and shall endeavor to do so within 5 working days of receipt of complaint.

7.    Monitoring

• 7.1    The customer complaints received along with resolution TAT and ageing analysis. shall be placed before the Customer Service Committee.
• 7.2    Complaints received through the Reserve Bank of India along with resolution TAT shall be placed before the Customer Service Committee.
• 7.3    Grievance Redressal Officer/Principal Nodal Officer shall place the Grievance Redressal report before the Customer Service Committee.
• 7.4    Summary Analysis of Customer Complaints received directly and through Reserve Bank of India and the Grievance Redressal Report, shall be placed before the Board of Directors on quarterly basis for its review.

Financial Disclosure

Corporate Social Responsibility

1. Introduction

a.As per Section 135 of the Companies Act, 2013 and rules made thereunder, every Company having net worth of rupees Five Hundred Crore or more, or turnover of rupees One Thousand Crore or more or a net profit of rupees Five Crore or more during the immediately preceding financial year shall constitute a Corporate Social Responsibility (CSR) Committee of the Board consisting of two or more directors.The CSR Committee shall formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company in areas or subject, specified in Schedule VII of the Companies Act.

The CSR Committee shall formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company in areas or subject, specified in Schedule VII of the Companies Act.

b.The Board's report under sub-section (3) of section 134 shall disclose the composition of the Corporate Social Responsibility Committee. 

c.The Corporate Social Responsibility Committee shall,—

i. formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities  may be undertaken by the company in areas or subject, specified in Schedule VII;

ii. Recommend the amount of expenditure to be incurred on the activities referred to in clause (i); and

iii. Monitor the Corporate Social Responsibility Policy of the company from time to time.

d. The Board of every company referred to in sub-section (1) shall,— 

i. after taking into account the recommendations made by the Corporate Social Responsibility Committee, approve the Corporate Social  Responsibility Policy for the company and disclose contents of such Policy in its report and also place it on the company's website, if any, in such manner as may be prescribed; and 

ii. Ensure that the activities as are included in Corporate Social Responsibility Policy of the company are undertaken by the company. 

e. The Board shall ensure that the company spends, in every financial year, at least two percent of the average net profits of the company made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy: 

Provided that the company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for Corporate Social Responsibility activities: 

Provided further that if the company fails to spend such amount, the Board shall, in its report made under clause (o) of sub-section (3) of section 134, specify the reasons for not spending the amount.

i.Explanation.—for the purposes of this section “average net profit” shall be calculated in accordance with the provisions of section 198 of the Companies Act, 2013 or such other amended provisions/rules as are promulgated from time to time.

f.If Company ceases to fulfil the eligibility criteria as laid down in a) above for three consecutive years, then the company is not required to comply with CSR policy until the company will meet the eligibility criteria once again.

2. Policy Objectives

This policy, which reflects the Company’s and its parent entity Sadhan Enterprise’s philosophy and mission is designed to portray its commitment to be a responsible corporate citizen and presents the strategies and methods for undertaking social programs for well-being and sustainable development of the local community in which it operates. 

This policy applies to all CSR initiatives and activities taken up by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), for the benefit of various segments of the society, with the emphasis on the under privileged.

This policy, which reflects the Company’s and its parent entity Sadhan Enterprise’s philosophy and mission is designed to portray its commitment to be a responsible corporate citizen and presents the strategies and methods for undertaking social programs for well-being and sustainable development of the local community in which it operates. 

This policy applies to all CSR initiatives and activities taken up by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), for the benefit of various segments of the society, with the emphasis on the under privileged.

 2.a The objectives of CSR Policy of the Company are to: 

1. objectives, which also benefits the organization at large; 

2. shape sustainability for the organization by 'Engaging the Community'; 

3. build a corporate brand through CSR; and 

4. for other stakeholders, make it "an integral part of the Company's DNA, so much so that it has tbuild a framework of CSR activities with a philanthropic approach in line with business unit o be an organic part of the business".

2.b Implementation of CSR Activities / Projects

Each CSR activity/project of the Company to be undertaken/executed either directly by the Company or channelized through implementing agencies, to be approved by the Board. 

Planning and implementing various CSR activities shall be in line with the established objectives of the Company and its CSR Policy. 

3.CSR Activities

1. Enhancing environmental and natural capital 

2. Supporting rural development 

3. Promoting education 

4. Providing preventive healthcare

5. Creating livelihoods for people, especially those from disadvantaged sections of society

6. Women Empowerment and upliftment of the under-privileged children

7. Any such other matter as mentioned in Schedule VII of the Companies Act, 2013 read with rules made thereunder and as amended from time to time.

Preference shall be given to local area and areas around Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) for spending the amount earmarked for CSR. 

Aligning with its vision, Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), will continue to increase  value creation in the community in which it operates, through its services and CSR initiatives planned and implemented, so as to stimulate wellbeing for the community, in fulfilment of its role as a responsible, corporate citizen.The over-arching framework of CSR activities will guarantee full compliance with the CSR requirements mandated by the new CompaniesAct, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014. The planning and execution of various CSR activities and projects shall involve, to the extent possible, the participation of staff members and customers of the Company and its parent Sadhan Enterprise. Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) will apply its CSR activities in a way that also contributes to India’s progress towards achieving the millennium development goals by skills improvement, entrepreneurship development, employment generation, health care improvement and application of environmental by sustainable growth

The below activities doesn’t include under the CSR activities of the Company

1. Business run in the normal course.

2. Outside the territory of the India or abroad.

3. For the welfare of the employees and their families.

4. Political party contribution of any amount directly and indirectly as defined u/s 182 of the Companies Act

4. Implementation

The above described CSR activities will be implemented by Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) either directly or through other implementing agencies and in collaboration with other non-profit organisations. The duration of any project or program will be related to the nature of that project or program and their impact on the society. It is to be ensured that the CSR programs of Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), will be executed in the areas where the Company has business presence. The programs will be implemented either directly or in collaboration with specialised organisations or with its other group companies.

4.a. Process of Implementation: 

i. Map existing eco system: Thorough evaluation of the existing scenario in which the Company operates. This step is crucial in order to assess the existing potential and find relevant partners to collaborate with in line with this revised CSR Policy. 

ii. Create: Designing programs, selecting partners and empaneling them. 

iii. Enable: Commencing collaboration with the selected actors, investing the resources needed to shift from the planning to the action phase. 

iv. Monitoring: Monitor the CSR Budget and the spends.

4.a. Process of Implementation: 

i. Map existing eco system: Thorough evaluation of the existing scenario in which the Company operates. This step is crucial in order to assess the existing potential and find relevant partners to collaborate with in line with this revised CSR Policy. 

ii. Create: Designing programs, selecting partners and empaneling them. 

iii. Enable: Commencing collaboration with the selected actors, investing the resources needed to shift from the planning to the action phase. 

iv. Monitoring: Monitor the CSR Budget and the spends.

4.b Powers for Approval

CSR programmes for each financial year as may be identified by the Company will be considered, reviewed by the CSR Committe and recommend to the Board for approval. After Board’s approval, the CSR programme shall be implemented. Any change in such programme shall be approveby the Board. 

For meeting the requirements arising out of immediate and urgent situations of  Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), CSR Committee is authorised to approve the proposals in terms of the powers accorded to the Committee by the provisions of the Companies Act, 2013.

4.c Criteria for Identifying Implementing Organisations

The Company may identify other external executing organisations that will implement the CSR programs. Each executing organisation (NGOs/Voluntary organisations) needs to fulfil the following requirements: 

1. has been in existence for a minimum period of 3 years from date of registration; 

2. is registered as a Trust/Society/Section 8 (Charitable) Company; 

3. the physical address given by the organisation is verifiable. 

4. possesses a valid Income Tax exemption certificate; 

5. the antecedents of the NGO/Organisation are verifiable/subject to confirmation; 

6. has sufficient infrastructure facilities like office, e-mail etc. and necessary resources to implement the projects; 

7. has prior experience in service activities in the specified areas as covered under CSR, as per Schedule VII of the Companies Act, 2013; 

8. located in the area of planned activities with local knowledge; and 

9. has articulated shared vision/purpose beyond the registration documents. 

After the approval of the CSR programs, the Company and the NGO/Organisation will be required to enter into a formal written agreement with each other.

5.Governance

A meaningful engagement of the Board of Directors and Management in CSR will be ensured so that Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd),’s Leadership recognizes the Company’s social concerns and the strategic value of its CSR initiatives

5.a. Board & CSR Engagement

​Responsibilities of Board of Directors (BOD) include: 

1. To constitute the CSR Committee, from amongst itself and fill vacancy in case of resignation by any director/ member of the CSR Committee. 

2. To approve the CSR policy for the Company formulated by the CSR Committee. 

3. To ensure that only the activities that are in line with the CSR Policy of Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) and are related to the activities included in Schedule VII of the Companies Act are undertaken.

4. To approve the CSR Budget in line with regulations. 

5. To ensure that funds committed by the company for CSR activities are utilized effectively and monitored regularly.

6. To ensure that the reasons for any under spending and / or not spending of the allocated CSR budget are explained in the Directors Report.

7.  Disclosing the content of the policy in its report and placing the policy on the Company’s website in the manner prescribed under section 135 of the Act read with CSR Rules.

5.b. CSR Committee

The Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) CSR Committee consists of the following 3 Members: 

To be constructed

The terms of reference of the Committee are as under: 

1. Formulate and recommend to the Board, a CSR policy which shall indicate the activities that may  be Undertaken by the Company as specified in Schedule VII of the Companies Act, 2013;

2. Identify the projects/activities to be undertaken by the Company for CSR 

3. Recommend to the Board CSR Activities to be undertaken along with detailed plan, modalities of execution, implementation schedule, monitoring process and amount to be incurred on such activities; 

4. Monitor the CSR Policy of the Company from time to time; 

5. Constitute a transparent monitoring mechanism for ensuring implementation of CSR Projects

6. Ensure compliance of CSR Policy and the Rules;

7. To be directly responsible to the Board for any act that may be required to be done by the CSR Committee in furtherance of its statutory obligations, or required by the Board fromtime to time. 

6.CSR Team

The Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), CSR Team will consist of a minimum of three members and maximum of seven members. Three departments namely - Human Resources, Compliance and Accounting will have permanent representation in the team. CSR Team members (except permanent members) will function for two continuous fiscal years. The Human Resource department will initiate new appointment process basis requirement so that the term of new team will start at the beginning of the new fiscal year. The existing members can re-nominate themselves for selection. The nomination of the new team will be recommended by the existing team and then approved by the CSR Committee.

The CSR team will be responsible: 

1. To execute and monitor the CSR activities approved by the Company’s Board of Directors. 

2. To ensure systematic development of a set of processes, procedures and guidelines for CSR activities.

3. To submit an annual comprehensive report of all the activities and projects to the CSR Committee.

4. To submit a quarterly progress report of the CSR activities and projects to the CSR Committee. 

5. To monitor the budget and spends.

6. To seek guidance from the CSR Committee whenever needed. 

7. Monitoring and Feedback

The comprehensive monitoring mechanism that will be followed shall ensure that the CSR process functions as mandated by the Act and the Rules, ensuring that all Projects/ Programmes are duly implemented as budgeted. 

The following forms the basis of the monitoring mechanism: 

1. Allocation of a separate budget for setting up and running the monitoring system; 

2. Installation of an electronic MIS and human architecture that shall work together to ensure a firm check on spends and the actual implementation of activities as planned; and 

3. Release of funds only against verified utilizations. 

The CSR Committee will be responsible for monitoring approved projects/programmes. The monitoring system will include: 

i. Regular field visits to project/programme sites by designated teams; 

ii. Comprehensive documentation/compilation of field reports; 

iii. Regular interaction with beneficiary communities to obtain feedback; 

iv. Monitoring of timely fund utilization to ensure that projects/programmes as budgeted are actually being carried out and/or; and 

v. Any other activity that the CSR Committee may deem necessary in the larger initiatives. 

Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) will conduct impact studies on a regular basis, especially on the “flagship programs”. Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) will communicate with the beneficiaries in order to obtain feedback about the programs. The CSR programs and their impact will also be reported in the Annual Report of Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd)

7.a. Impact Assessment / Evaluation of CSR 

In order to assess the impact of its CSR projects and programmes, maximize outcomes and build-in sustainability, scalability and replicability, Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) shall undertake the following activities:

i.Ensure that the projects/programmes undergo concurrent and final evaluation; and 

ii. Engage credible third parties to undertake evaluation of all or selected projects/ programmes.

iii.  And in case of evaluation not being satisfactory to consider alternate agencies and / or revised programs in line with the provision of                      Schedule VII of Companies Act, 2013.

7.b. Documentation

Meticulous documentation of projects/programmes is the only way to ensure that progress is continuously tracked, course corrections are provided, lessons learnt and objective feedback received. 

Good quality documentation enables Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), to effectively address questions and queries and also to prepare instructive and good quality case studies. 

Keeping this end in sight, Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd), will endeavour at all times to put in place, for all projects/programmes, an effective documentation process. 

Comprehensive documentation will include printed materials, audio recordings, video recordings, etc. This will also be of great value to Arthmate Financing India Private Limited (Formerly Mamta Projects Pvt Ltd) in brand building, market positioning, enhancing its competitive advantage and embedding CSR values within the organization. 

8. Amendments to the Policy 

The Board on its own and/ or as per the recommendations of CSR Committee can amend this Policy, as and when required as deemed fit. All or any of the provisions of CSR Policy would be subject to revision/amendment in accordance with the Regulations on the subject as may be issued from relevant statutory authorities, from time to time.

9.General

Any term or aspect not specifically defined or set out in this Policy shall be construed to mean what is laid down in respect thereof under the Company Act or the CSR Rules, as the case may be.

Fair Practices Code Policy

Arthmate Financing India Private Limited

(formerly known as Mamta Projects Private Limited)

(CIN : U23209WB1994PTC063940)
Regd. Office : EM03, Unit 1528, 15th Floor, Bengal Eco Intelligent Park, Sector V,
Saltlake, Kolkata West Bengal – 700091
Email: [email protected] / [email protected]
Mob.: 07835009643 Website: www.arthmate.com

Fair Practices Code
Arthmate Financing India Private Limited

(Formerly known as Mamta Projects Private Limited)
(CIN: U23209WB1994PTC063940)
Regd. Office: EM03, Unit 1528, 15th Floor, Bengal Eco Intelligent Park, Sector V, Saltlake, Kolkata West Bengal – 700091
Email: [email protected]

Document Control

Document Name	Fair Practices Code
Version No.	5.0
Document Status	Released
Compliance Status	Mandatory

Change Control, Review and Approval

S. No	Change Description	Change Date	Approved by
1	Version 1	14-05-2019	Board
2	Version 2	23-11-2020	Board
3	Version 3	07-01-2022	Board
4	Version 4	03-05-2023	Board
5	Version 5	28-03-2024	Board

1.    Introduction

Arthmate Financing India Pvt. Ltd. (formerly known as Mamta Projects Private Limited) herein referred to as “AFIPL” or “the “Company”, a Non-Banking Finance Company (“NBFC”) registered with Reserve Bank of India (“RBI”) is presently in the business of offering various kinds of financial products and services to its customers. The Fair Practice Code (“Code”) will facilitate the customers to take informed decisions in respect of the financial products and services to be availed by them from the Company and will apply to all loan that the Company may sanction and disburse.

The standards set out in this Code are minimum requirements based on applicable legal and regulatory requirements as issued by Reserve Bank of India.

Pursuant to the Notification issued by the Reserve Bank of India by its Circular no. RBI/2015-16/16 DNBS (PD) CC No. 054/03.10.119/2015-16 dated July 01, 2015, and Master Direction DNBR.PD.008/03.10.119/2016-17 (circular no. RBI/DNBR/2016-17/45) dated 1st September,2016 (as amended from time to time) and Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 dated October 19, 2023 (as amended from time to time) has prescribed the guidelines on fair practices that are to be framed and approved by the Board of Directors of all NBFC’s. The Fair Practices Code so framed and approved by the Board of Directors should be published and disseminated for the information of the public at the website of the Company as well as at the Registered / Corporate offices of the Company in English in the vernacular language of the place where the Registered / Corporate offices is located.

This Fair Practice Code is aimed to provide to all the stakeholders, especially customers effective overview of practices followed by the Company in respect of the financial facilities and services offered by the Company to its customers.

2.    The objectives of the Code are:

1. a.   To promote and ensure good business practices in dealing with its customers, during on-boarding, loan processing, disbursal and loan service period up to the termination of the loan;
2. b.   To promote a fair relationship and transparency between the customer and the Company; so that customer can have a better understanding of the level of service that can be expected from our Company, and the charges inclusive of Interest rates, processing fees and all other charges levied by the Company.
3. c.   To ensure compliance with legal norms in matters relating to recovery of loan amount with other charges including delays and late payments charges, re-possession of assets and repayment mechanism charges;
4. d.   To strengthen mechanisms for redressal of customer grievances;
5. e.   To foster customer confidence in the Company.

3.    Applications for loans and their processing

This Code applies to financial products and services offered by the Company currently or which may be introduced at a future date.

1. a.   All communications to the borrower will be in the vernacular language or a language as understood by the borrower or with an undertaking that the borrower has understood all terms in totality, irrespective of the language in which he has signed the documents, after going through the same in his vernacular language.
2. b.    Loan application forms would include necessary information related to the loan being advanced to the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs and lenders can be made and an informed decision can be taken by the borrower. The loan application form would indicate the documents required to be submitted with the application form as also required later for sanctioning and disbursal of the loan/facility.
3. c.   The Company will have a system of giving acknowledgment for receipt of all loan applications. The time frame within which loan applications will be disposed of will be indicated in the acknowledgment.
4. d.   The Company will also communicate to the borrower if the loan is rejected.

4.    Loan appraisal and terms/conditions

1. a.    The Company will ensure that there is a proper assessment of credit applications made by borrowers. The assessment would be in line with the Company's credit policies and procedures.
2. b.    The Company will convey in writing to the borrower in the vernacular language or a language as understood by the borrower by means of sanction letter, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record.
3. c.    The Company will mention the processing fees, other charges, rate of interest and penal interest charged for late repayment in bold in the loan agreement.
4. d.    The Company will make available a copy of the loan agreement along with a copy of all enclosures quoted in the loan agreement in a vernacular language or a language as understood by the borrower on the Company’s website which can be referred to the borrowers at the time of sanction/disbursement of loans.

The Code is applicable to all the loan products of the Company irrespective of whether the product/service is provided at the dealer point or any agency premises or the Company’s own offices or group.

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

1. a.    The Company will ensure timely disbursement of loans sanctioned in conformity with the terms and conditions governing such sanction. The Company will give notice to the borrower in the vernacular language or a language as understood by the borrower, of any change in the terms and conditions, including disbursement schedule, interest rates, service charges, prepayment charges, etc.

2. b.    The Company will ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard shall be incorporated in the loan agreement.

3. c.    Decision to recall/accelerate payment or performance under the agreement will be in consonance with the loan agreement.

4. d.    The Company will release all securities on repayment of all dues or on the realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim that the Company may have against the borrower. If such right of set-off is to be exercised, the borrower will be given notice about the same in writing with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.

6.    General:

1. a)    The Company will refrain from interference 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 by the borrower, has come to the notice of the Company), or in line with any compliance or regulatory requirement of inspection and audit of the borrowers business activities.
2. b)    In case of receipt of a request from the borrower for transfer of borrower’s account, the consent or otherwise i.e. objection of the Company, if any, will be conveyed within 21 days from the date of receipt of the request. Such transfer shall be as per transparent contractual terms in consonance with law.
3. c)    In the matter of recovery of loans, consistent with its policy, the Company will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc.
4. d)    The Company will adequately train the collection executives and other staff to deal with the customers in an appropriate manner.
5. e)    The Company will call delinquent customers only between 0700 hrs. to 1900 hrs., unless under special circumstances, as decided by the Company, require calling customers outside the hours mentioned above.
6. f)    The Company may initiate such actions as required for enforcing security charged to it of the delinquent borrower, if required, with the aim only to recover dues, cost and expenses incurred of such enforcement action.
7. g)    The Company shall ensure that the entire process of enforcing its security, valuation, and realization thereof would be fair and transparent.
8. h)    With respect to the collection of amounts due from the customers, the Company shall ensure compliance with Code and shall not employ any harsh methods of recovery. Without limiting the general application of the foregoing, the following practices shall be deemed as harsh:
   1. (i)    Use of threatening or abusive language;
   2. (ii)    Persistently calling the Customer and/ or calling the Customer before 7:00 a.m. and after 7:00 p.m.;
   3. (iii)    Harassing relatives, friends, or co-workers of the Customer;
   4. (iv)    Publishing the name of Customers;
   5. (v)    Use or threat of use of violence or other similar means to harm the Customer or Customer’s family/ assets/ reputation;
   6. (vi)    Misleading the Customer about the extent of the debt or the consequences of non-repayment;
   7. (vii)    Any kind, either verbal or physical, against any Customer in the debt collection efforts, including acts intended to humiliate publicly or intrude the privacy of the Customer’s family members, referees and friends, making threatening and anonymous calls or making false and misleading representations.

7.    Responsibility of Board of Directors

1. a)    A grievance redressal mechanism within the organization has been set up to resolve the disputes with the customers arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level.
2. b)    There will be a periodical review of the compliance of the Fair Practices Code and the functioning of the grievance redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals, as may be prescribed by it.

8.    Grievance Redressal Mechanism

The Company has formulated the “Policy on Grievance Redressal Mechanism” outlining the procedures for addressing customer/borrower grievances. This Policy is available on Company’s website, www.arthmate.com , and also prominently displayed at all branches / places of the Company where business is transacted

9.    Regulation of rate of interest

a.    The Board of Directors has adopted an interest rate model for determining the rate of interest to be charged on loans and advances, processing and other charges taking into account relevant factors such as, cost of funds, margin and risk premium, etc. 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, as also displayed on the company’s website and updated from time to time.

b.    The rates of interest and the approach for gradation of risks shall also be made available on the website of the Company. The information published in the website or otherwise published would be updated whenever there is a change in the rates of interest.

c.    The rate of interest would be annualized rates so that the borrower is aware of the exact rates that would be charged to the account.

d.    As a measure of customer protection, Company shall not charge foreclosure charges/ pre-payment penalties on all such floating rate term loans sanctioned to individual borrowers, as prescribed by the concerned regulatory authorities from time to time.

10.    Repossession of vehicles and properties or other moveable assets financed

The Company should include a built-in re-possession clause in the loan agreement with the borrower which must be legally enforceable.

To ensure transparency, the terms and conditions of the loan agreement will contain provisions regarding:

1. (a)   Notice period before taking possession of the security;
2. (b)   Circumstances under which the notice period can be waived;
3. (c)   The procedure for taking possession of the security;
4. (d)   A provision regarding the final chance to be given to the borrower for repayment of the loan before the sale/auction of the property;
5. (e)   The procedure for giving repossession to the borrower; and
6. (f)   The procedure for the sale/auction of the property.
7. (g)   Any settlement of the dues, either before or post a re-possession will be at the sole discretion of the Company.
8. (h) Pursuant to the provisions of SARFAESI Act 2002, notice and the incident of repossession shall be published in any Newspaper and/or media (print, social etc.).

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