Nightingale

General

(a) A statement articulating our commitment to transparency and fair lending practices shall be issued in the language understood by the Borrower and the same shall be displayed in the premises.

(b) The KYC-AML Guidelines of RBI shall be complied with. Due diligence shall be carried out to ensure the repayment capacity of the borrowers.

(c) The effective rate of interest charged and the grievance redressal system etc shall be prominently displayed in all our offices and on website.

(d) The Company will be accountable for preventing inappropriate staff behavior and timely grievance redressal.

(e) A microfinance loan will be a collateral-free loan given to a household having annual household income up to ₹3,00,000. For this purpose, the household shall mean an individual family unit, i.e., husband, wife and their unmarried children.

(f) All collateral-free loans, irrespective of end use and mode of application/ processing/ disbursal (either through physical or digital channels), provided to low-income households, i.e., households having annual income up to ₹3,00,000, shall be considered as microfinance loans.

(g) NFPL has formulated assessment of household income in line with the indicative methodology for assessment of household income as per guideline provided by RBI.

(h) NFPL shall mandatorily submit information regarding household income to the Credit Information Companies (CICs). Reasons for any divergence between the already reported household income and assessed household income shall be specifically ascertained from the borrower/s before updating the assessed household income with CICs.

(i) There shall be no pre-payment penalty on microfinance loans. Penalty, if any, for delayed payment shall be applied on the overdue amount and not on the entire loan amount.

Applications for loans and their processing
(a) All communications to the borrower shall be in the vernacular language or a language as understood by the borrower. Procedure for application of loan shall not be cumbersome.
(b) Loan application forms shall include necessary information affecting the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form shall indicate the documents required to be submitted with the application form.
(c) A system of giving acknowledgement for receipt of all loan applications, preferably, the time frame within which loan applications will be disposed shall be indicated in the acknowledgement.

Loan appraisal and terms/conditions

(a) The Company’s field officers are trained to make necessary enquiries with regard to existing debt of the borrowers. This is done to ensure that Nightingale is either the 1st lender or at most the 2nd, with the overall indebtedness of borrower household not exceeding Rs. 1,25,000/-.

(b) The Company shall convey in writing to the borrower in the vernacular language as understood by the borrower by means of sanction letter or otherwise, 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.

(c) The Company shall furnish a copy of the loan agreement, /loan card preferably in vernacular language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction/disbursement of loan.

(d) The limit on the outflows on account of repayment of monthly loan obligations of a household as a percentage of the monthly household income. This shall be subject to a limit of maximum 50 per cent of the monthly household income.

(e) The computation of loan repayment obligations shall take into account all outstanding loans (collateral-free microfinance loans as well as any other type of collateralized loans) of the household. The outflows capped at 50 per cent of the monthly household income shall include repayments (including both principal as well as interest component) towards all existing loans as well as the loan under consideration.

(f) Existing loans, for which outflows on account of repayment of monthly loan obligations of a household as a percentage of the monthly household income exceed the limit of 50 per cent, shall be allowed to mature. However, in such cases, no new loans shall be provided to these households till the prescribed limit of 50 per cent is complied with.

Disbursement of loans

(a) All sanctions and disbursement of loans shall be done only at a central location and more than one individual shall be involved in this function. In addition, there shall be close supervision of the disbursement function.

(b) Loan disbursements are done as per pre-determined time structure.

(c) The loan card (passbook) should reflect the following details as specified in the Non-Banking Financial Company –Micro Finance Institutions (Reserve Bank) Directions, 2011.

• Information which adequately identifies the borrower;
• Simplified factsheet on pricing;
• All other terms and conditions attached to the loan;
• Acknowledgements by NFPL of all repayments including installments received and the final discharge; and
• Details of the grievance redressal system, including the name and contact number of the nodal officer of NFPL.

(d) Issuance of non-credit products shall be with full consent of the borrowers and fee structure for such products shall be explicitly communicated to the borrower in the loan card itself.

(e) The Company shares complete customer data with Equifax and High Mark (both RBI approved Credit Bureaus).

(f) In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of the Company, if any, should be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms inconsonance with law.

Pricing of loans
(a) The Pricing of Loans of the company shall be done in accordance with the RBI guideline. The same has been prepared and accordingly the Pricing Policy of the Company has been approved by the Board on 31st March,2022.
(b) The Pricing of Loans of the company shall, inter alia, cover the following:

• A well-documented interest rate model/ approach for arriving at the all-inclusive interest rate;
• Delineation of the components of the interest rate such as cost of funds, risk premium and margin, etc. in terms of the quantum of each component based on objective parameters;
• The range of spread of each component for a given category of borrowers; and a ceiling on the interest rate and all other charges applicable to the microfinance loans.

(c) NFPL shall disclose pricing related information to a prospective borrower in a standardized simplified factsheet as per RBI guideline.
(d) Any fees to be charged to the microfinance borrower by the RE and/ or its partner/ agent shall be explicitly disclosed in the factsheet. The borrower shall not be charged any amount which is not explicitly mentioned in the factsheet.
(e) NFPL shall prominently display the minimum, maximum and average interest rates charged on microfinance loans in all its offices, in the literature (information booklets/ pamphlets) issued by it and details on its website. This information shall also be included in the supervisory returns and subjected to supervisory scrutiny.
(f) Any change in interest rate or any other charge shall be informed to the borrower well in advance and these changes shall be effective only prospectively.

Recovery of loans 
The company has in place a board approved Recovery Policy prepared in accordance with RBI guideline including the following:-
(a) Recovery will normally be made only at a central designated place. Field staff shall be allowed to make recovery at the place of residence or work of the borrower only if borrower fails to appear at central designated place on two or more successive occasions.
(b) In the matter of recovery of loans, the Company shall not resort to:

• Use of threatening, use of muscle power for recovery of loans, or abusive language etc.
• Persistently calling the borrower and/ or calling the borrower before 9:00 a.m. and after 6:00 p.m.
• Harassing relatives, friends, or co-workers of the borrower
• Use or threat of use of violence or other similar means to harm the borrower or borrower’s family/ assets/ reputation

(c) NFPL shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
(d) The Company releases all securities (i.e. documents) on repayment of all securities (i.e. documents) on repayment of all dues or on realization of the outstanding amount.

Staff Training
(a) The Company shall ensure that a Board approved policy is in place with regard to Code of Conduct by field staff and systems for their recruitment, training and supervision. The Code will lay down minimum qualifications necessary for the field staff and shall have necessary training tools identified for them to deal with the customers.
(b) Training to field staff shall include programs to inculcate appropriate behaviour towards borrowers without adopting any abusive or coercive debt collection / recovery practices. Compensation methods for staff will have more emphasis on areas of service and borrower satisfaction than merely the number of loans mobilized and the rate of recovery. Penalties may also be imposed on cases of non-compliance of field staff with the Code of conduct. Generally only employees and not out sourced recovery agents are used for recovery in sensitive areas.
(c) Field Staff shall be trained so as to refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the borrower, has been noticed).
(d) Field staff will be trained properly to make necessary enquiries with regard to existing debt of the borrowers.
(e) Field staff may also be trained to offer training, if required to the borrowers, so that they are fully aware of the procedure and systems related to loan/other products.
(f) Conduct of employees towards customers shall also be incorporated appropriately in their compensation matrix.

Training of Clients
a. NFPL will take steps to educate the client about the implication of the non-repayment including impact on the credit score and try to convince the Client for repayment.
b. Group training is necessary for developing group solidarity and the necessary skills to develop strict credit discipline. Prospective members undergo approximately 3 hours of group training over a period of 2 days. Compulsory Group Training has been properly described in the Operations Manual.
c. The Company shall provide training to the Borrowers with regard to the terms and conditions of the Loan, the re-payment Schedule and explain them the various components of the pricing of their loan and also educate them about the Grievance Redressal System and how to report grievances.
d. The Company shall provide such training to the Clients and Borrowers, absolutely free of cost.

Responsibility of Board of Directors
(a) The Board of Directors of the Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard.
(b) Such a mechanism ensures that all disputes arising out of the decisions of lending institutions functionaries are heard and disposed of at least at the next higher level.
(c) The Board of Directors periodically reviews the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board quarterly.
(d) The Company has made organizational arrangements to assign responsibility for compliance to designated individuals within the company and establish systems of internal control including audit and periodic inspection to ensure the same.
(e) A declaration is given in the loan agreement that the Company is accountable for preventing inappropriate staff behaviour and timely grievance redressal be made and also in FPC displayed in Company’s office/branch premises.

Grievance Redressal Officer
At the operational level, the Company has displayed the following information prominently, for the benefit of the customers, at all branches /places where business is transacted:

a) The name and contact details (Telephone / Mobile nos. as also email address) of the Grievance Redressal Officer who can be approached by the customers for resolving the complaints against the Company.
b) b) If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in-Charge of the Regional Office of DNBS of RBI (complete contact details),under whose jurisdiction the registered office of the Company (NBFC) falls. The complete contact details of the said Officer-in-Charge will be available at the branch premises.
Compliant/Grievances calculation matrix:

Level	Time lapse since 1st complaint	Contact person’s Name/Designation	Contact Details
1 Branch level	3 days	Branch Head	Printed on the loan card at Branch Office & Premises
2. Grievance Redressal Officer	2 days	Shri Mrigen Sharma, Adviser	Administrative Office, ChakradharVilla,Chandmari,Guwahati-781003, Assam, Mobile No.9957573677 E-mail: nightingale20006@gmail.com
3. Customer Care Executive	2 days	Shri Pratap Chakravarty, Director  (Operation)	Administrative Office, Chakradhar Villa,Chandmari,Guwahati-781003, Assam,  MobileNo.9957573677  E-mail: nightingale20006@gmail.com
4.Managing Director	1 day	Mantu Nath Sarma, Managing Director	Administrative Office, Chakradhar Villa, Chandmari, Guwahati-781003,Assam,  Mobile No.9954758857
5. RBI	30 days	Officer-in-Charge, Regional Office,  Department of Non Banking Supervision  Reserve Bank of India	Reserve Bank of India,  Pan Bazaar, Station Road,  Guwahati - 781 001,  Tel: 91361-2540256

Internal Audit System
The Company has established an internal audit team for periodic inspection of the branches, ensuring compliance with the Fair Practice Code and proper functioning of the Grievance Redressal Mechanism implemented by the Company.

The Fair Practice Code prepared in accordance with the guideline as per RBI circular No. DoR.FIN.REC.95/03.10.038/2021-22 is placed and approved by the Board of Directors of Nightingale Finvest Private Ltd. in its meeting held on 31st March,2022.