Fair Practices Code

Pursuant to Reserve Bank of India (RBI) ‘s Circular DNBS (PD) CC NO.80/03.10.042/2005-06 of 28 September 2006, issued to Non-Banking Financial Companies (NBFCs), the Board of Directors have adopted a Fair Practices Code for Sirius Capital Services Limited (“Company”).

Further, RBI vide Circular DNBS.CC.PD.No.266/03.10.01/2010-11 dated March 26, 2012 and vide Circular DNBS.CC.PD.No.320/03.10.01/2012-13 dated February 18, 2013, had revised guidelines on Fair Practices Code for NBFCs.

The Fair Practices Code, as adopted herein below, is in conformity with the Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular.
The Company’s business will be conducted in accordance with prevailing statutory and regulatory requirements, with due focus on efficiency, customer-orientation and corporate governance principles. In addition, the Company will adhere to the Fair Practices Code in its functioning, the key elements of which are as follows:

• To ensure Fair Practice while dealing with the customers
• Greater transparency enabling customers in having a better understanding of the product and taking informed decisions
• Building customer confidence in the company

• The Company offers various financial products including Loan against securities, IPO financing, Bills/ Invoice discounting, Project loan, Working capital loan, Term loan, Loan against property, Lease rental discounting, Loan for purchase of commercial property purchase among others.
• The ‘Application Form / appropriate documents’ of SCSL for each of these products offered by the Company is different depending upon the requirement of each product and will include all information that is required to be submitted by the Borrower. Necessary information will be provided by SCSL to facilitate the Borrower in making a meaningful comparison with similar terms and conditions offered by other Non Banking Finance Companies (NBFCs) and taking an informed decision based on the aforesaid comparison.
• The ‘Application Form/ appropriate documents’ of SCSL may also indicate the list of documents required to be submitted by the Borrowers along with the Application form.
• SCSL has a mechanism of giving an acknowledgement for receipt of Application form to its Borrower for availing loans. SCSL would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.

SCSL shall convey in writing to the Borrower by way of a sanction letter or otherwise, the amount of limit sanctioned along with all the terms and conditions including annualized rate of discount/ interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on SCSL’s record. Any clause relating to penal interest charged for late repayment will be specified in bold in the Loan Agreement. SCSL at the time of sanction / disbursements of loans will furnish a copy of loan agreement to the borrower.

• Through its published website or as appropriate if specific to a customer, SCSL will give Notice to its Borrower(s), of any change in the terms and conditions of the sanction. SCSL will also ensure that changes in discount/ interest rates and charges are effected only prospectively.
• Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective loan Agreement.
• SCSL will release all securities of its Borrower only on repayment of all dues by such Borrower, or only on realization of the outstanding amount of the Borrower’s availed limit, subject to any legitimate right or lien for any other claim which SCSL may have against its Borrower. If such right of set off is to be exercised, the Borrower will be given notice about the same with full particulars about the remaining claims and conditions under which SCSL will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower.

• SCSL will refrain from interference in the affairs of its Borrower except for the purposes provided in the terms and conditions of the respective loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of SCSL).
• In case of receipt of request from the Borrower for transfer of Borrowal account, the consent or otherwise i.e. objection of SCSL, if any, is generally conveyed to such Borrower within 21 days from the date of receipt of the Borrower’s request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.
• In the matter of recovery of outstanding dues of its Borrower, SCSL does not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc. Training will be imparted to ensure that staff is adequately trained to deal with customers in an appropriate manner.

The Company has designated Mr. Nihir K Sheth, as Officer in Charge for receiving and resolving complaints from customers.

The contact details of the Officer are:
Mr. Nihir K Sheth,
Sirius Capital Services Ltd
Corporate Office,
1, Devraj Niwas, 7th Road TPS III,
Santacruz (E), Mumbai 400055
Tel: 022-67513070

The customers having grievance/complaint about our services/products may inform in writing to the Officer for immediate resolution of the same. The Officer will provide the highlights of the complaints received and redressal to the Board of Directors for their review and compliance at each subsequent meeting.

In case customers are not satisfied with the resolution provided by the company, they may further approach:
Regional Director – Maharashtra and Goa
Reserve Bank of India,
Main Building, P.O.Box 901,
Shahid Bhagat Singh Road,
Fort, Mumbai – 400 001, India.
Tel: +91 22 – 2266 0500
Fax: +91 22 – 2266 0817
Email: rdmumbai@rbi.org.in

• The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.
• The Company has adopted an interest rate model taking into account cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances.
• The rate of interest to be charged depends much upon the gradation of the risk of borrower viz. the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower etc.
• The rate of interest will be annualised so that the borrower is aware of the exact rates that would be charged to the account.