Grievance Redressal Policy

Introduction:

Rang De’s primary goal is to bridge the socio-economic gap that prevails in the nation. It brings together individuals that are in need of monetary assistance and those that have the financial capability to provide such assistance (“Participants”), through its peer-to-peer lending platform (“Rang De”/ “Platform”). The Platform enables lenders to provide micro credits to rural and other below poverty line communities for their education, business, health and other socio-economic requirements.

Objective:

The objective of this Grievance Redressal Policy (“Policy”) is to ensure that:

• all genuine issues raised by Participants are dealt with swiftly and efficiently; and
• Participants are made aware of the rights and remedies available to them.

This Policy provides the structure and procedures for receiving and addressing grievances from Participants, in accordance with the guidelines prescribed by the Reserve of Bank of India (“RBI”).

Applicability:

The Policy is applicable to:

• Individuals who register themselves on the Platform to provide micro-credit to eligible borrowers (“Lender(s)”); and
• Individuals who register themselves on the Platform to avail micro-credit from the Lenders (“Borrower(s)”).

Principals Of Grievance Redressal:

• The Policy provides the procedures to be undertaken by the Participant and the various redressal forums available to the Participants.
• The Policy indicates the mode of raising complaints/ grievances available to the Participants.
• This Policy provides that the issues raised by the Participants, are treated with utmost respect and are resolved fairly and equitably to ensure that the issues are sorted out and communicated to the Participant in a transparent manner.
• The Policy and the grievances / issued raised by the Participants shall be regularly reviewed at multiple levels to mitigate and reduce Participant grievances and thereby enhance functionality.

Grounds For Filing A Complaint:

The Lender and/or the Borrower shall be entitled to raise a complaint against Rang De and/or its Outsourcing Partner on any of the below mentioned grounds:

By the Lender:

• non-payment or inordinate delay in the repayment of the loan and/or interest;
• non-adherence to the RBI directives, if any, applicable to rate of interest;
• non-presentation or inordinate delay in the presentation of post-dated cheques, if any, provided by the Participant;
• failure to convey in writing, the amount of loan sanctioned along with terms and conditions including annualised rate of interest and method of application thereof;
• failure or refusal to provide sanction letter/ terms and conditions of sanction in vernacular language or a language as understood by the Borrower;
• failure or refusal to provide adequate notice on proposed changes being made in sanctioned terms and conditions in vernacular language or a language as understood by the Borrower;
• levying of charges without adequate prior notice to the Lender;
• failure to ensure transparency in the loan agreement regarding (i) terms of repayment; (ii) interest rate; or (iii) any other charges;
• non-observance of directions issued by RBI to the non-banking financial companies; and
• non-adherence to the RBI guidelines on Fair Practices Code for non-banking financial companies.

By the Borrower:

• non-payment or inordinate delay in disbursal of the loan amount;
• non-adherence to the RBI directives, if any, applicable to rate of interest;
• non-presentation or inordinate delay in the presentation of post-dated cheques, if any, provided by the Participant;
• failure to convey in writing, the amount of loan sanctioned along with terms and conditions including annualised rate of interest and method of application thereof;
• failure or refusal to provide sanction letter/ terms and conditions of sanction in vernacular language or a language as understood by the Borrower;
• failure or refusal to provide adequate notice on proposed changes being made in sanctioned terms and conditions in vernacular language or a language as understood by the Borrower;
• failure or inordinate delay in issuing a confirmation of closure of the loan to the Borrower on repayment of all dues;
• levying of charges without adequate prior notice to the Borrower;
• failure to ensure transparency in the loan agreement regarding (i) terms of repayment; (ii) interest rate; or (iii) any other charges;
• non-observance of directions issued by RBI to the non-banking financial companies; and
• non-adherence to the RBI guidelines on Fair Practices Code for non-banking financial companies.

Procedure To Attend To Customer Grievance:

Step 1: Registering a Grievance:

A Participant should register their grievance through any one of the following modes:

• Customer care number: +91 80 42756643
• Official Website: www.rangde.in
• E-mail: [email protected]

Step 2: Acknowledgement of Grievance:

Upon receipt of a grievance Rang De shall issue the Participants with a grievance acknowledgement number (“GAN”) and inform the Participant as to the approximate time it will take to address the grievance (“TAT”).

Step 3: Tracking of Grievance:

The Participant shall be able to view the status of the grievance on the website of Rang De with the GAN.

Step 4: Resolution of Grievance:

1. Grievance Redressal Officer
   
   A registered grievance shall be dealt with by the designated Grievance Redressal Officer of the Grievance Redressal Cell of Rang De.
   The Grievance Redressal Officer for Rang De is:
   Mrs. Swati Dubey
   Email id: [email protected]
   Phone Number: +91 80 42756643
   
   The Grievance Redressal Officer shall be responsible to attend to and resolve the matters raised by the Participant within 10 (ten) days from the date of registering the grievance.
   
   The Grievance Redressal Officer shall:
   • deal sympathetically and expeditiously with the grievance raised by the Participant;
   • correct mistakes promptly; and
   • cancel any charge that has been applied wrongly and by mistake.
   
   
   
2. Senior Grievance Redressal Officer
   
   In the event the grievance of the Participant is not resolved within 10 (ten) days from the date of registering the grievance, the grievance shall be automatically escalated to the Senior Grievance Redressal Officer of the Grievance Redressal Cell, who shall address the grievance within 10 (ten) days from the date of escalation.
   
   The Senior Grievance Redressal Officer of Rang De is:
   Ms.Smita Satish
   Email id: [email protected]
   Phone Number: +91 80 42756643
   
   
3. Customer Education and Protection Department of RBI / Banking Ombudsman (“RBI Customer Resolution Forum”)
   
   In the event a grievance is not resolved to the satisfaction of the Participant within a period of 30 (thirty) days from the date of registering the grievance, then the Participant shall have the right to appeal to the Customer Education and Protection Department of RBI or the Banking Ombudsman in accordance with the Ombudsman Scheme for Non-Banking Financial Companies, 2018 dated February 23, 2018 (the “Scheme”) implemented by RBI.
   
   The Scheme is available at www.rangde.in. A copy of the Scheme may be perused at the office of Ms. Smita Satish located at Rang De P2P Financial Services Private Limited WeWork, Salarpuria Symbiosis, Begur Hobli, Bannerghatta Main Road, Arekere, Bengaluru, Karnataka-560076, India.
   
   The jurisdictional Ombudsman for Rang De is:
   
   Office of NBFC Ombudsman, Chennai
   C/o Reserve Bank of India
   Fort Glacis,
   Chennai - 600 001
   Tel. No. 044 25395964
   Fax No. 044 25395488
   Email: [email protected]
   
   Referral of a grievance by the Participant to RBI Customer Resolution Forum shall be:
   
   
   • Upon satisfaction of the pre-conditions contained in Annexure A.
   • In accordance with procedures set out in Annexure A.
   
   
   
4. Appeal before the Appellate Authority:
   
   Any person aggrieved by an Award of the Ombudsman allowing the complaint or rejecting the complaint, may within 30 (thirty) days of the date of receipt of communication of Award or rejection of complaint, prefer an appeal before the Appellate Authority.
   
   
5. Enforcement of the Award:
   
   Rang De shall implement the settlement arrived with the complainant or the Award passed by the Ombudsman when it becomes final and send a report in this regard to RBI within 15 (fifteen) days of the award becoming final. In the event of non-implementation of settlement or the Award, the complainant may represent to RBI and RBI may initiate such action as it deems fit.
   
   

Training:

Rang De ensures that its employees and members of the Grievance Redressal Cell receives periodic training for handling a Participant’s grievance in an efficient and courteous manner.

Review Of Participant Grievance Redressal Mechanism:

• The Grievance Redressal Cell of Rang De shall analyse the grievances raised by Participants on a monthly basis and attempt to implement a preventive and permanent measure to avoid recurring grievances.
• The Grievance Redressal Cell of Rang De shall monitor and analyse the timelines for redressal of grievances to ensure prompt and apposite redressal.
• The Grievance Redressal Cell of Rang De shall prepare a quarterly summary report of the grievances received and closed. The summary report shall be placed before the Board of Rang De.
• Rang De may conduct feedback surveys with Participants who have raised a grievance/ complaint to ensure Participants are satisfied with the redressal mechanism of Rang De.

ANNEXURE A:

Relevant Extracts of the Scheme

Pre-conditions to referring a compliant

1. The complainant, before making a complaint to the Ombudsman, shall have registered a grievance with Rang De and Rang De shall have rejected or not provided a satisfactory resolution for the grievance for 30 (thirty) days from the date of registering the grievance with Rang De.
2. The complaint is made not later than 1 (one) year after the complainant has received the reply of the NBFC to his representation or, where no reply is received, not later than 1 (one) year and 1 (one) month after the date of registering the grievance with Rang De;
3. The complaint is not in respect of the same cause of action which was settled or dealt with on merits by the Ombudsman in any previous proceedings whether or not received from the same complainant or along with one or more complainants or one or more of the parties concerned with the cause of action;
4. The complaint does not pertain to the same cause of action, for which any proceedings before any court, tribunal or arbitrator or any other forum is pending or a decree or Award or order has been passed by any such court, tribunal, arbitrator or forum;
5. The complaint is not frivolous or vexatious in nature;
6. The complaint is made before the expiry of the period of limitation prescribed under the Indian Limitation Act, 1963 for such claims; and
7. The complainant has filed along with the complaint, copies of the documents, if any, which he intends to rely upon, and a declaration that the complaint is maintainable under Clause 9-A.

Procedure to refer a complaint:

Any person who has a complaint against a Rang De on any one or more of the Grounds mentioned above may, himself or through his authorised representative (other than an Advocate), make a complaint to the Banking Ombudsman indicated above.

1. The complaint, when in writing, shall be duly signed by the complainant or his authorized representative and shall be, as far as possible, in the format appended at Annex II of the Scheme or as near as thereto as circumstances admit, stating clearly:
   1. the name and address of the complainant,
   2. it should indicate Rang De P2P Financial Services Private Limited having its registered office at WeWork, Salarpuria Symbiosis, Begur Hobli, Bannerghatta Main Road, Arekere, Bengaluru, Karnataka-560076, India and mention the name and address of the Outsourcing Partner of Rang De (if applicable);
   3. the facts giving rise to the complaint,
   4. the nature and extent of the loss caused to the complainant, and
   5. the relief sought for.
2. A complaint made through electronic means shall also be accepted by the Ombudsman and a print out of such complaint shall be taken on the record of the Ombudsman.
3. The Ombudsman shall also entertain complaints covered by this Scheme received by the Central Government or Reserve Bank or other financial regulators and forwarded to him for disposal.