Code of Conduct

Our commitment to ethical practices and fair dealings with all stakeholders.

Preface

FriendLoan seeks to create social benefit and promote financial inclusion by providing financial services to low income and Mid income group/individuals. The Company is a NBFC registered with Reserve Bank of India (RBI). The Company follows various guidelines issued by RBI and has also adopted Industry Code of Conduct.

Objective

  • Promote and strengthen ethical Digital lending movement in the country by bringing low and Mid income clients to mainstream financial sector.
  • Build progressive, sustainable, and client-centric systems and practices to provide a range of financial services to clients.
  • Promote cooperation and coordination among themselves and other agencies to achieve higher operating standards and avoid unethical competition.

Applicability

This Code applies to: Providing credit services to clients, Recovery of credit, Formation of community collectives including SHGs and JLGs, Business development services.

Core Values of Company

INTEGRITY

To provide low-income clients with access to financial services that are client focused and designed to enhance their well-being, delivered in a manner that is ethical, dignified, transparent, equitable, and cost-effective.

QUALITY OF SERVICE

To ensure quality services to clients, appropriate to their needs, delivered efficiently in a convenient and timely manner. To maintain high standards of professionalism based on honesty, non-discrimination, and customer-centricity.

TRANSPARENCY

To provide complete and accurate information to clients regarding all products and services offered. To create awareness and enable clients to understand information provided with respect to financial services.

FAIR PRACTICES

To ensure clients are protected against fraud, misrepresentation, deception or unethical practices. To ensure all practices related to lending and recovery maintain respect for client's dignity.

PRIVACY OF CLIENT INFORMATION

To safeguard personal information of clients, allowing disclosures only with authorized personnel and with knowledge and consent of clients.

INTEGRATING SOCIAL VALUES INTO OPERATIONS

To ensure high standards of governance and management. To monitor and report social as well as financial data.

FEEDBACK AND GRIEVANCE REDRESSAL MECHANISM

To provide formal and informal channels for feedback. To consistently assess impact of services. To provide formal grievance redressal mechanism.

Policy

INTEGRITY AND ETHICAL BEHAVIOUR

  • Design appropriate policies to treat clients and employees with dignity
  • Incorporate transparent and professional governance system
  • Educate clients on the Code of Conduct

TRANSPARENCY

  • Disclose all terms and conditions prior to disbursement via individual sanction letter or loan schedule
  • Communicate in official regional language or language understood by client
  • Minimum disclosures: Rate of interest (reducing balance), Processing fee, Other charges, Insurance charges
  • Communicate charges in writing; fees on non-credit products only with prior declaration
  • Declare all interest and fees as Annual Percentage Rate (APR) and equivalent monthly rate
  • Follow RBI guidelines on interest charges and security deposits
  • Maintain formal records of all transactions

CLIENT PROTECTION

Fair Practices:

  • Services as per RBI guidelines
  • Standard KYC document copies; additional documents must be reasonable
  • Products should not be bundled

Avoiding Over-indebtedness:

  • Proper due diligence per internal credit policy
  • Must not breach total debt limit prescribed by RBI

Appropriate interaction and collection practices:

  • Clearly defined guidelines for employee-client interactions
  • Use courteous language, maintain decorum, respect cultural sensitivities
  • DO NOT indulge in threatening behavior
  • DO NOT contact clients at odd hours
  • DO NOT visit during bereavement, sickness etc.
  • Provide valid receipt for every payment
  • Board approved process for dealing with defaults
  • Must not collect shortfalls from employees (except proven fraud cases)

Privacy of client information:

  • Keep personal client information strictly confidential
  • Disclosure to third party only with: client informed and permission obtained in writing, party authorized by client, legally required, or customary among financial institutions on reciprocal basis

GOVERNANCE

  • Transparent and professional governance system
  • Persons with good reputation on Board of Directors
  • At least 1/3rd independent Board members
  • Transparency in books of accounts and financial statements
  • Follow ICAI Audit and Assurance Standards
  • Annual compliance report to Board

RECRUITMENT

  • Free and fair recruitment practice
  • Reference check mandatory when recruiting from another NBFC
  • Honor one-month notice period
  • Require relieving letter from previous employer (exception after 30 days non-response)

CLIENT EDUCATION

  • Dedicated process to raise client awareness of financial products/services
  • New clients informed about organization's policies and procedures
  • Regular checks on client awareness and understanding

DATA SHARING

  • Share complete client data with all RBI approved Credit Bureaus as per prescribed frequency

FEEDBACK/GRIEVANCE REDRESSAL MECHANISM

  • Dedicated feedback and grievance redressal mechanisms
  • Inform clients about existence and access of these mechanisms
  • Designate at least one grievance redressal official
  • Appropriate compliance mechanism for Code of Conduct
  • Complainants notified of right to refer to industry association grievance mechanism