Grievance Redressal Policy
Preamble
The quick and effective handling of complaints, as well as prompt corrective & preventive actions to improve processes, are essential to provide excellent customer service to all segments of customers. To achieve this, the Company has a clearly documented policy for redressal of customer grievances, in line with RBI guidelines. This policy is being suitably revised and is being tabled for the approval of the Board.
Through this policy, the Company shall ensure that a suitable mechanism exists for receiving and addressing complaints from its customers/constituents, with specific emphasis on resolving such complaints fairly and expeditiously, regardless of sources of the complaints. The policy seeks to ensure that:
- Adequate information shall be made available to all customers, at all branches, about the various channels available for seeking redressal of grievances arising out of any perceived deficiency in service by the Company. Such information shall include the name and contact number of grievance redressal officer, with whom such complaints can be addressed, and escalated thereafter. This will be updated as and when any change occurs in the process emerging out of internal reasons or change in guidelines from the regulators.
- Any complaint received - either verbally, via e-mail or in writing - from the customers, shall be logged into a tracker. With this, the Company shall not only ensure that all the complaints received are recorded and resolved, but also facilitate effective monitoring / escalation mechanism to the senior functionary responsible so as to make sure that none of the complaints remain unresolved.
- The grievance redressal channels of the Company will also deal with the issues relating to services provided by Outsourced Agencies and shall sensitize the respective outsourcing service providers to resolve customer issues expeditiously
- All complaints received through the below mentioned channels shall be handled centrally by a dedicated resource under compliance department:
- Reserve bank of India complaints received at corporate office
- Government of India complaints received at corporate office
- All complaints received shall be handled as below:
- First level - Branch Manager / In-charge
- Next Level - Grievance Redressal Officer
- In case a customer is not satisfied with the resolution provided by the front office staff, the customer shall be provided an option to write to the Grievance Redressal Cell either through an e-mail or letter. The contact details of the Grievance Redressal Cell shall be displayed at all the branch premises of the Company, as well as on the website. The Unit shall be responsible for providing adequate resolution to all escalated complaints received at their end.
- Complaints shall be resolved in a proper and time bound manner, with detailed advice to the customer. In case the resolution needs time, an interim response, acknowledging the complaint, shall be issued.
- Customer Complaints received through e-mails shall be responded through e-mail only. Company’s E-mail Management Unit shall be responsible for providing the final resolution response to customers raising complaints via e-mail.
Reporting of complaints shall be placed, at least once , before the board, at half-yearly intervals, or as may be required from time to time, in line with various business and regulatory requirements.
Responsibility of Board of Directors
As per RBI directives, the board of directors of NBFCs should lay down an appropriate grievance redressal mechanism within the organization. Such a mechanism should ensure that all disputes arising out of the decisions of lending institutions' functionaries are heard and disposed of, at least at the next higher level. The board of directors should also provide for 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 may be submitted to the board at regular intervals, as may be prescribed by it.
Grievance Redressal Officer
At the operational level, the Company has to display the following information prominently, for the benefit of their customers, at their branches / places where business is transacted:
- the name and contact details (Telephone / Mobile nos., as also email address) of the Grievance Redressal Officer who can be approached by the public, for the resolution of complaints against the Company.
- 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 NBFC falls.
In short, the public notice should serve the purpose of highlighting to the customers, the grievance redressal mechanism followed by the company, together with details of the grievance redressal officer and of the Regional Office of the RBI.
Accordingly, the following contact details will be published:
- The name and contact details of the Grievance Redressal Officer who can be approached by the public for resolution of complaints against the Company are given below:
Mr. Pathrose P P
Grievance Redressal Officer
LuLu Financial Services (India) Private Ltd
Y Tower, 12/971-B
Civil Lane Road
Kakkanad, Kochi 682 030
E-mail: grievance@lulufinserv.com
Tel: +91 90483 38786
- 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 Department of Non-Banking Supervision of the Bank, under whose jurisdiction the registered office of the company falls. The details are given below:-
Key Parameters of the Grievance Redressal Mechanism
A grievance against the Company, on any one or more of the grounds mentioned below, may be made by the complainant (himself or through his authorised representative - other than an Advocate), to the NBFC Ombudsman within whose jurisdiction the Branch / Registered Office of the Non-Banking Financial Company complained against, is located:
- Non-presentation or inordinate delay in the presentation of post-dated cheques provided by the customer.
- 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 as understood by the borrower.
- Failure or inordinate delay in releasing the securities documents to the borrower on repayment of all dues.
- Levying of charges without adequate prior notice to the borrower / customer.
- Failure to provide legally enforceable built-in repossession clause in the contract / loan agreement.
- Failure to ensure transparency in the contract / loan agreement regarding
- notice period before taking possession of security;
- circumstances under which the notice period can be waived;
- the procedure for taking possession of the security;
- a provision regarding final chance to be given to the borrower for repayment of loan before the sale / auction of the security;
- the procedure for giving repossession to the borrower and
- the procedure for sale / auction of the security;
- Non-observance of directions issued by Reserve Bank to the non-banking financial companies;
- Non- adherence to any of the other provisions of Reserve Bank Guidelines on Fair Practices Code for Non-Banking Financial Companies.
Conclusion
The Board shall review the Policy annually, or earlier if found necessary and the changes, if any, approved by the Board, shall be incorporated in the Policy Document. The revised guidelines shall be effective / enforceable from the date of approval by the Board. Nevertheless, the Policy shall stand modified in accordance with any statutory / regulatory changes made by Government / RBI during the intervening period, from the date advised in the guidelines, for which no further approval from the Board shall be necessary. The Policy shall be updated with such changes as and when notified by the Government / RBI, and the modified guidelines shall be circulated to all offices / branches concerned. The relevant extracts from this policy will be published in the Company's website.
