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Aurum Capital Projects Limited (hereafter referred to as (‘the ACPL’/ ‘the Company’) is a Public limited company incorporated under the provisions of the Companies Act, 1956 and is a Reserve Bank of India (RBI) registered Non-Banking Financial Company.

The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non Banking Financial Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers. Master Direction – Non-Banking Financial Company – Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 ("the Directions") issued by RBI provides that all the applicable NBFCs shall put in place Fair Practices Code based on the guidelines outlined in the said directions.

In terms of the RBI Directions and considering the nature of the business, the company shall adopt the following Fair Practice Code (Code) for ACPL lending activities under all categories of products.

2.Obiective of lhe Code

The Key objeclive of the Code

a) Ensuring Fair Practices while dealing with the customers.

b) Clients are advised and assist in understanding of the key terms and conditions of services provided for their consideration prior to commitment of a transaction.

c) Monitoring and administration of client accounts is carried out in a fair and transparent manner consistent with the terms and conditions of the facility provided.

d) Recovery and enforcement, where necessary is conducted following due process of law.

3. Applicability of the Fair Practice Code:

Applications for loans and their processing:

The borrower shall be provided with the loan application form inter alia, include broad features, terms and conditions governing the loan, indicating the primary list of documents including KYC documents required to be submitted with the application form. Any other documents required to be submitted with the loan application will be informed to the borrower separately.

b) Loan application of ACPL will include necessary information which affects 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.

c) ACPL shall provide to the prospective borrower an acknowledgement for receipt of all loan applications. The time frame, within which loan applications will be disposed of, will be indicated in the acknowledgement.

d) All communications to the borrower shall be in English or in vernacular language / the language as understood and confirmed by the borrower.

2 Loan appraisal and terms/conditions:

1) ACPL shall appraise loan applications considering the risk based approach and credit policy of the Company.

b) ACPL shall convey in writing to the borrower in English or in vernacular language / the 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.

c) The acceptance of the terms and conditions communicated by the borrower shall be preserved by ACPL on its record.

d) ACPL shall mention the penal interest charged for late repayment in bold in the sanction letter and loan agreement.

e) ACPL will furnish a copy of loan agreement along with a copy of each enclosures quoted in the loan agreement to all clients at the time of sanction/disbursement of loan.

3. Disbursement of loans, including changes in terms and conditions:

a) ACPL shall give notice to the borrower in English or in vernacular language / the language as understood by the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. Changes in interest rates and charges shall be effected prospectively and a suitable condition in this regard shall be incorporated in the loan agreement.

b) Decision to recall / accelerate payment or performance under the agreement shall be in consonance with the Loan Agreement.

c) ACPL shall release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim ACPL may have against borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which ACPL are entitled to retain the securities till the relevant claim is settled/paid.

lV. General provisions:

a) ACPL shall refrain from interference in the affairs of its borrowers except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of ACPL).

b) In case of receipt of request from the borrower for transfer of borrower’s account, the consent or otherwise, i.e. objection of ACPL, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms entered into with the borrower and in consonance with statutes, rules, regulations and guidelines as may be applicable from time to time.

c) In the matter of recovery of loans, ACPL shall resort only to remedies which are legally and legitimately available to it and will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans etc.

d)ACPL shall ensure that its staff is adequately trained to deal with the customers in an appropriate manner.

e) ACPL shall not charge foreclosure charges/ pre-payment penalties on floating rate term loans sanctioned for purpose other than business to individual borrowers with or without co-obligant (s).

V. Responsibility of Board of Directors:

The Board of Directors of ACPL has adopted the appropriate grievance redressal mechanism within the organization. Such a mechanism shall ensure that all disputes arising out of the decisions of lending institutions' functionaries, complaints relating to updating/alteration of credit information and complaints pertaining to outsource services are heard and disposed of at least at the next higher level. The Board of Directors shall also provide for periodical review of 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 at regular intervals, as may be prescribed by it.

Vl. Grievance Redressal:

A Grievance Redressal mechanism has been incorporated in the Stake holder Relationship Committee of the Company to resolve all disputes arising in this regard. The mechanism will ensure that all the disputes arising out the decisions of lending institution's functionaries are heard and disposed of at least at the next higher level. The Board of Directors will periodically review the compliances of Fair Practice Code and the functioning of the grievances redressal mechanism at the various levels of Management.

For grievances, customers can write to:

Grievance Redressal Officer Details:

CS Geetanjali
(Company Secretary cum Compliance Officer)
Aurum Capital Projects Limited
2nd Floor, YMCA Complex. 13 Rana Pratap Marg, Lucknow-226001
Contact No: 0522 – 2209402
Email Id: admin@aurumcapitalprojects.com

Vll. Regulation of excessive interest charged

a) ACPL will ensure that it will not charge excessive interest rates to its borrowers.

b) ACPL would arrive at the interest rate for its clients taking into account the following broad parameters such as risk profile of the client, interest rate trends prevailing in the money market, cost of funds, collateral security offered by client/ structure of the deal and Interest rate charged by competitors.

c) Interest rates would be on an annualized basis and would be communicated explicitly in the sanction letter so that the Borrower is aware of the exact rates that would be charged to the account

d) ACPL has adopted an Interest Rate Policy taking into account relevant factors such as cost of funds, margin and risk premium, etc. to determine the rate of interest to be charged for loans and advances.

vlll. Language and mode of communicating Fair Practice Code

a) Fair Practice Code as established by ACPL has been established in English language and is based on the guidelines as outlined by the RBI.

b) ACPL shall also have its FPC in regional/vernacular languages for customers who are unable to read the same in English.

lX. Complaints about excessive interest rates charged

Board of ACPL shall lay out an interest rate policy mentioning internal principles and procedures in determining interest rates, processing charges and other charges.

X. Clarification regarding repossession of vehicles financed

ACPL does not provide vehicle finance directly but may do it through its intermediaries therefore the following points as prescribed by RBI shall be followed.

ACPL will have an in-built re-possession clause in the loan agreement with the borrower which must be legally enforceable.

ACPL will ensure transparency in the terms and conditions of the loan agreement regarding:

1. Notice period before taking possession
2. Circumstances under which notice period will be waived
3. Procedure for taking possession of security of vehicle
4. A provision regarding final chance to be given to the borrower for repayment of loan before the sale/auction of the property
5. The procedure for giving repossession of the vehicle
6. Procedure for sale/auction of the property

ACPL shall make sure that a copy of such terms and conditions is made available to the borrower in the loan agreement along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans, which may form a key component of such contracts/loan agreements.