BACKGROUND, OBJECTIVES AND SCOPE

Background

At Godrej Housing Finance Limited (“GHFL” or “the Company”), is a part of the Godrej Group which has an established reputation of honesty, integrity and sound governance over the years. The Company is, therefore, committed to maintaining the highest standards of Corporate Governance in its conduct towards shareholders, employees, regulators, customers, suppliers, lenders and other stakeholders. The Company’s philosophy of corporate governance is to achieve business excellence by enhancing the long-term welfare and value for its various stakeholders. The Company believes that corporate governance is about creating organisations that succeed in the marketplace with the right approach and values.

The Reserve Bank of India vide Paragraph 55 of Annexure IX of Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated 17th February 2021 (Directions) has prescribed that Housing Finance Companies (‘HFCs’) should frame their Internal Guidelines on Corporate Governance with the approval of the Board of Directors and host it on website.

Accordingly, the Company has framed its Internal Guidelines on Corporate Governance (“Guidelines”) with the approval of its Board of Directors

Objective

The objective of the Guidelines is to adopt the best standards of Corporate Governance through transparency in business ethics, accountability & required disclosure to its customers, the government/ regulatory authorities and other stakeholders.

Approval and Review of the Policy

• There shall be an annual review of the Policy by the Board of Directors

• Board of Directors can at any time modify or amend, either the whole or any part of Policy

BOARD OF DIRECTORS

COMMITTEES CONSTITUTED BY THE BOARD

Brief details of various committees to be constituted by the Board are as follows:

DISCLOSURE AND TRANSPARENCY

ROTATION OF PARTNERS OF THE STATUTORY AUDITORS AUDIT FIRM

The Company shall rotate the partner/s of the Statutory Auditors firm conducting the audit, every 3 years so that same partner shall not conduct audit of the Company continuously for more than a period of 3 years. However, the partner so rotated shall be eligible for conducting the audit of the Company after an interval of 3 years. The Company shall incorporate appropriate terms in the letter of appointment of the firm of auditors to ensure compliance.

INTRODUCTION
 

Pursuant to Section 178 of the Companies Act, 2013 (the “Act”) and the Rules framed thereunder (as amended from time to time), the Board of Directors of every listed public Company and the following classes of companies are required to constitute a Nomination and Remuneration Committee ("The Committee") of the Board and is required to formulate a policy ensuring the criteria for evaluation of performance and determination of remuneration based on the performance of Directors, KMPs and Senior Management.
 

• The public companies with a paid up capital of ten crore rupees or more;
• the public companies having turnover of one hundred crore rupees or more;
• the public companies, having in aggregate, outstanding loans or borrowings or debentures or deposits exceeding fifty crore rupees or more.

Further, Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2016 as updated from time to time also require an HFC to constitute a Nomination Committee
 

SCOPE & APPLICATION
 

PURPOSE
 

DEFINITIONS
 

APPOINTMENT & REMOVAL OF DIRECTORS, KMP & SENIOR MANAGEMENT
 

Evaluation
 

Removal
 

Retirement
 

POLICY RELATING TO THE REMUNERATION FOR THE MANAGERIAL PERSONNEL, KMP & SENIOR MANAGEMENT
 

Remuneration to Non- Executive / Independent Director:
 

GOVERNANCE FRAMEWORK
 

PREAMBLE

The Company has adopted the Code of Ethics & Business Conduct, which lays down the principles and standards that should govern the actions of the Company and its employees.

In order to comply with the provisions of Section 177 of the Companies Act, 2013 and Rule 7 of the Companies (Meetings of the Board and its Powers) Rules, 2014 eligible company needs to have a Vigil Mechanism to enable the employees and the directors to report their genuine concerns or grievance.

Accordingly, this Whistle Blower Policy (“the Policy”) has been formulated with a view to provide a mechanism for employees of the Company to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.

PURPOSE

The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees / Directors to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc

DEFINITION

“Disciplinary Action” means any action that can be taken on the completion of /during the investigation proceedings including but not limited to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.

“Employee” means every employee of the Company (whether working in India or abroad)

“Director” means Director on the Board of Directors of the Company.

“Protected Disclosure” means a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity. Protected Disclosures should be factual and not speculative in nature.

“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation under this Policy

“Whistle blower” is someone who makes a Protected Disclosure under this Policy.

“Whistle Officer” means an officer who is nominated/ appointed to conduct detailed investigation of the disclosure received from the whistle blower and recommend disciplinary action. Currently, Mr. V Swaminathan, Head of Corporate Audit & Assurance is nominated as Whistle Officer.

“Whistle Committee” or “Committee” means a Committee of persons who are nominated/appointed to conduct detailed investigation of the disclosure received from the whistle blower and recommend disciplinary action. The Committee, if appointed, should include Senior Level Officers of Personnel & Admin, Internal Audit and a representative of the Company / Division/ Department where the alleged malpractice has occurred.

“Company” means, “Godrej Housing Finance Limited.”

“Good Faith”: An employee shall be deemed to be communicating in ‘good faith’ if there is a reasonable basis for communication of unethical and improper practices or any other alleged wrongful conduct. Good Faith shall be deemed lacking when the employee does not have personal knowledge on a factual basis for the communication or where the employee knew or reasonably should have known that the communication about the unethical and improper practices or alleged wrongful conduct is malicious, false or frivolous.

“Policy or This Policy” means, “Whistle Blower Policy.”

SCOPE AND APPLICABILITY

Various stakeholders of the Company are eligible to make Protected Disclosures under the Policy. These stakeholders may fall into any of the following broad categories:

• Employees of the Company

• Employees of other agencies deployed for the Company’s activities, whether working from any of the Company’s offices or any other location

• Contractors, vendors, suppliers or agencies (or any of their employees) providing any material or service to the Company

• Customers of the Company

• Any other person having an association with the Company

A person belonging to any of the above-mentioned categories can avail of the channel provided by this Policy for raising an issue covered under this Policy.

The Policy covers malpractices and events which have taken place/ suspected to take place involving:

• Abuse of authority

• Breach of contract

• Negligence causing substantial and specific danger to public health and safety

• Manipulation of company data/records

• Financial irregularities, including fraud or suspected fraud or Deficiencies in Internal Control and check or deliberate error in preparations of Financial Statements or
  Misrepresentation of financial reports

• Statements or Misrepresentation of financial reports

• Any unlawful act whether Criminal/ Civil

• Pilferage of confidential/propriety information

• Deliberate violation of law/regulation

• Wastage / misappropriation of company funds/assets

• Bribery or corruption

• Sexual Harassment

• Retaliation

• Breach of IT Security and data privacy

• Social Media Misuse

• Breach of Company Policy or failure to implement or comply with any approved Company Policy

The Policy should not be used in place of the Company grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.

OWNERSHIP

The responsibility for overall implementation and upkeep of this policy rests with the Whistle Blower committee.

RESPONSIBILITY FOR IMPLEMENTATION

Compliance with this policy is mandatory and the task of implementation of the policy is with the Human Resource team. Chief Human Resource Officer may delegate specific responsibilities of this policy to a specific employee of the company on the recommendation of leaders.

REVIEW & DEVIATIONS

• There shall be an annual review of the Policy by the Board of Directors

• Board of Directors can at any time modify or amend, either the whole or any part of Policy

COMMUNICATION

The policy is communicated by the CHRO to the entire organization as deemed necessary.

POLICY

In this section, specific policies are defined which form the foundation of the Fair Practice Code for GHF. This policy is supported by other policies, additional templates, configuration documents and standard operating procedures where required.

WHISTLE BLOWER COMMITTEE

MD & CEO can setup a Whistle Blower committee to whom Directors and employees shall address their serious concerns arising from irregularities, malpractices and other misdemeanors committed by the Company’s personnel.

Role of Whistle Blower Officer

Any employee who has a genuine complaint or concern about any fraud or violation of any law, rule or regulation or unacceptable/improper practice and/or any unethical practice may complain about this to his superior or to the designated person to attend to Whistle officer as mentioned below, or to the Audit Committee.

Mr. V. Swaminathan, has been appointed as the “Whistle Officer”, for Godrej Group with effect from May 1, 2010, and can be contacted in writing at Pirojshanagar, Eastern Express Highway, Vikhroli-East, Mumbai 400 079 or on telephone at +91 22 25194403 or on email at ve.swaminathan@godrejinds.com.

To keep consistency with the group policy and to have an external assured person to manage the sensitive function the company also appoints him as a “Whistle Officer” for GHF.

He shall be responsible for the following functions:

• To receive and record any complaints under this policy.

• To ensure confidentiality of any “Whistle Blowing” complainant who requests that their complaint be treated in confidence.

• To prepare a report of any whistle blowing complaint and send the report promptly to the Audit Committee Members. A copy of the report shall be simultaneously sent to the Managing Director / Executive Director for investigation. The Managing Director/Executive Director after investigation shall place a report to the Audit Committee for discussion and decision. The Audit Committee Members shall then discuss the same and take necessary action.

• The Whistle Blowing Officer shall communicate the Audit Committee’s decision to the complainant for his information.

Role of the Whistle blower Committee

• The Committee will consider the credibility of the complaint submitted through the Protected Disclosure, the gravity of the issue raised and the likelihood of proving the allegation(s) from independent, verifiable sources. This is to be bifurcated into two parts:
  • Complaint against Non-GLF members: Ethics team under Corporate audit will do investigation and if the allegations are true then the committee members (BU Head, HR Head and Head – Corporate audit and assurance) will take necessary decision.

   

  • Complaint against GLF members: In case of a complaint against GLF members or the BU head and HR head, the group CHRO and Chairman (Mr. Pirojsha) will be updated on the investigation findings and basis which necessary action will be taken.

• The ethics team under Corporate Audit shall submit reports with the Whistle Blower committee for their review and shall assist them in manner required. Basis the report and inputs, the committee shall decide the next course of action..

The Committee will decide on carrying out further investigation upon the receipt of the report of the official undertaking the preliminary investigation

ROLE OF A WHISTLE BLOWER

• A Whistle blower is a person who will merely report a misdemeanor, as stated earlier, without acting as an investigator and will not, therefore, act on his own in conducting an investigative activity, other than as requested by the Designated Authority or the Audit Committee of the Board.

• Following from the above, on detecting a wrong-doing or misdemeanor, the Whistle blower will not determine corrective or remedial action that may be warranted under the circumstances.

• The Whistle blower should provide specific and verifiable details in the Protected Disclosure in appropriate language that is not offensive.

• The Whistle blower can discuss all matters related to the Whistle blower Policy, including his role and the implications of submitting the Protected Disclosure with the Ethical Counselor. The final decision to submit information under Protected Disclosure will, however, be the sole decision of the whistle blower.

• Though they would not necessarily be required to conclusively prove the points contained in the Protected Disclosure, in order to support their disclosure, the Whistle blower should provide sufficient evidence to establish a prima facie case for investigation.

• The Whistle blower can report instances of leak of any unpublished price sensitive information by any insider in contradiction of the Securities Dealing Code of the Company.

PROTECTION TO WHISTLE BLOWER

• The identity of the Whistle blower shall be kept confidential and will not be revealed unless required in terms of an order of a court of law.

• Complete protection will be given to the Whistle blower against retaliation or retribution consequent upon his/her having reported a Protected Disclosure.

• A Whistle blower will not get protection under the Policy if he is himself found guilty of misconduct. In other words, while the Committee will take cognizance of the Protected Disclosure, the Director’s or employee’s misconduct will be dealt with separately.

• The Company will take steps to minimize difficulties that a Whistle blower may face in the submission of a Protected Disclosure. For instance, he will be reimbursed expenses incurred in travel, boarding and lodging for tendering evidence, if warranted.

Suitable disciplinary action (including termination of service) may be taken against the Subject in case he is found guilty of misconduct against the Whistle blower, in retaliation of a complaint submitted.

• In case any action has been initiated against the Whistle blower (for acts of omission or commission attributed to him) the disciplinary authority in such cases would be one level higher than the disciplinary authority in the normal course of action.

• Any Director or employee who assists in investigating a Protected Disclosure will also be protected to the same extent as the Whistle blower.

• In case the protection to the Whistle blower as well as Director or employees assisting in the investigation (as outlined above) is violated in any manner, the same may be reported to the Whistle blower Committee or the Chairman of the Audit Committee.

ETHICAL COUNSELLOR

Head - HR shall assist Directors or employees who have witnessed offences and are in need of counselling about their roles and responsibilities in seeking a redressal of the wrongdoings. Interested concerns can reach out on ruhie.pande@godrejhf.com

WHISTLE BLOWER REPORTING

• All Protected Disclosures reported against officials should be addressed to the Whistle blower Committee which may be reported through the following channels:

• Email to the Whistle blower Committee at ethicsindia@godrejinds.com or call on Hotline number 1800 225 548 or

• Email to any of the members of the Committee 
  • manish.shah@godrejhf.com or
  • ruhie.pande@godrejhf.com or
  • ve.swaminathan@godrejinds.com

• Employees/Directors are also free to communicate their complaints directly to the Audit Committee Members. They can communicate their complaints to the nominated Audit Committee Member. Till the time an Audit Committee member is nominated the complain can be shared with whistle blow officer:
  Mr. V Swaminathan
  Head - Corporate Audit & Assurance,
  Pirojshanagar, Eastern Express Highway,
  Vikhroli (East) Mumbai – 400079
  Email id: ve.swaminathan@godrejinds.com

• There may be occasions when a Whistle blower submits a complaint to a person in the Company other than the members of the Whistle blower Committee. It is proposed that Protected Disclosures received by officials, in the rank of VP and above, be forwarded to the Whistle blower Committee for necessary action.

• Protected disclosures should preferably be reported in writing in order to ensure a precise understanding of the issues raised and should either be typed or written in legible handwriting in English, Hindi or in the regional language of the place of employment of theWhistle blower.

• It is suggested that the Protected Disclosure be forwarded under a covering letter (or as an attachment to the email message) such that only the covering letter/email message bears the identity of the Whistle blower. The Whistle blower should, preferably, not disclose personal details in the Protected Disclosure that may identify him.

• In case the Whistle blower has a personal interest in the matter, it should be disclosed at the outset in the forwarding letter/email message

• The covering letter/email message should prominently indicate that the Protected Disclosure/complaint is being made under the “Whistle blower Policy”.

• Copies of documents that may help in establishing the veracity of the Protected Disclosure report/complaint may be attached to the Protected Disclosure.

• The envelope containing the Protected Disclosure/complaint (when made in paper form) should be marked “Confidential”.

• The Designated Authority shall detach the covering letter/email message and forward only the Protected Disclosure to the Investigators for investigation.

• In order that the confidentiality of the Whistle blower (in case of Director or an employee who has revealed his/her identity) is maintained, an acknowledgement of receipt of the Protected Disclosure/complaint will be sent to the Whistle blower only through email.

OUTCOME OF THE INVESTIGATION INTO ALLEGATION UNDER A WHISTLE BLOWER POLICY

If an investigation leads the Designated Authority to conclude that an improper, unethical, fraudulent act or misconduct has been committed, the Designated Authority shall recommend to the management of the Company to take such disciplinary or corrective action against the erring officials (Subjects) as the disciplinary authority may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject(s) as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or Staff Conduct and Disciplinary Procedures.

REPORTING TO THE AUDIT COMMITTEE BOARD

A quarterly report on the findings under the Whistle blower Policy will be submitted to the ACB for information. The Corporate Audit department will be the convener of the Whistle blower Committee and will monitor and will submit the quarterly reports to the ACB.

DISPLAY AND NOTIFICATION

The Whistle blower Policy shall be displayed on the Company’s intranet, and a paper copy of this will be made available to any person on demand from any of the offices of the Company. New employees in the Company will be informed about the Policy as part of their joining formalities.

INTRODUCTION

Godrej Housing Finance Limited (“Godrej” or “GHF” or “Company”) conducts itself with highest standard of integrity and has always followed both letter and spirit of the law.

Related party transactions can present a potential or actual conflict of interest which may be against the best interest of GHF and / or its shareholders. GHF does not promote any transaction which may be at variance with the established principles of Corporate Governance or which does not meet the highest standard of ethics or integrity.

SCOPE & APPLICATION

This policy shall regulate transactions between the Company and its Related Parties based on the laws and regulations applicable to the Company.

REGULATORY REQUIREMENT

In terms of the provisions of Section 188 of the Companies Act, 2013 (“the Act"), the Company is required to follow the procedure as prescribed for the Related Party Transactions for which inter alia it is required to draft a Related Party Transaction Policy ("Policy") as per the extant law and adhere to it for operations.

The Reserve Bank of India vide Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated 17th February 2021 prescribed that Housing Finance Companies (HFCs) with asset size of Rs. 50 crore and above should evolve a Related Party Transaction Policy ("Policy") and share the same in public domain.

PURPOSE

This Policy is intended to ensure due and timely identification, approval, disclosure and reporting of transactions between GHF and any of its Related Parties in compliance with the applicable laws and regulations as may be amended from time to time.

The provisions of this Policy are designed to govern the approval process and disclosure requirements to ensure transparency while conducting Related Party Transactions and to comply with the statutory provisions in this regard.

DEFINITIONS

“Act” means Companies Act, 2013 and rules made thereunder, as amended from time to time.

“Arm’s Length Transaction” means a transaction between two related parties that is conducted as if they were unrelated, so that there is no conflict of interest

“Associate” means an enterprise in which the Company has a significant influence, but which is not a subsidiary company of the Company having such influence and includes a joint venture company and the term “Associate Company” shall be interpreted accordingly. For the purpose of this definition, “Significant Influence” means control of at least twenty percent of total share capital, or of business decisions under an agreement.

“Board” means the Board of Directors of the Company.

“Committee” means Audit Committee of the Company as constituted or reconstituted by the Board of Directors of the Company in accordance with the Section 177 of the Act, read with the rules framed thereunder.

“Company” means Godrej Housing Finance Corporation Limited.

“Company Secretary” means a person who is appointed by the Company to perform the functions of the Company Secretary under provisions of the Act, ;

“Directors” means Directors appointed by the Board including executive, non-executive and independent directors.

“Ordinary course of business” means the usual transactions, customs and practices undertaken by the Company to conduct its business operations and activities and includes all such activities which the Company can undertake as per Memorandum & Articles of Association. The Board and Audit Committee may lay down the principles for determining ordinary course of business in accordance with the statutory requirements and other industry practices and guidelines.

“Independent Director” means a director referred to in Section 149(6) of the Act.

“KMP” or “KMPs” means the following key managerial personnel:

• Chief Executive Officer and / or Managing Director or Manager of the Company;

• Chief Financial Officer of the Company;

• Company Secretary of the Company;

• Whole Time Director of the Company; and

• Such other officer of the Company as may be decided by the Nomination and Remuneration Committee.

“Member” means a Director of the Company appointed as member of the Committee.

“Material Related Party Transaction” means a transaction with a Related Party in relation to –

• sale, purchase or supply of any goods or materials, directly or through appointment of agent amounting to 10% or more of the Annual Turnover of the Company; or

• selling or otherwise disposing of, or buying, property of any kind directly or through appointment of agent, amounting to 10% or more of Net Worth of the Company as defined under Section 2(75) of the Act; or

• leasing of property of amounting to 10% or more of the Annual Turnover of the Company; or

• availing or rendering of any services, directly or through appointment of agent, amounting to 10% or more of the Annual Turnover of the Company, or

• appointment to any office or place of profit in the Company, its subsidiary company or associate company at a monthly remuneration exceeding Rs. 2.5 lakhs; or

• underwriting the subscription of any securities or derivatives thereof, of the Company exceeding 1% of the Net Worth.

“NHB Guidelines” means and includes NHB Act, 1987, NHB Directions, 2010, NHB Notifications, Circulars and others such communications thereto.

“Relative” with reference to a Director or KMP means persons as defined under Section 2(77) of the Act and rules prescribed thereunder.

“Related Party” have the meaning as defined in Section 2(76) of the Act, Regulation 2(1)(zb) of the Securities and Exchange Board of India (Listing Obligations And Disclosure Requirements) Regulations, 2015.

"Related Party Transaction" means the transaction under Section 188 of the Act, encompasses all contracts or arrangements with a Related Party and have the meaning as defined under Regulation 2(1)(zc) of the Securities and Exchange Board Of India (Listing Obligations And Disclosure Requirements) Regulations, 2015 as means transfer of resources, services or obligations between a listed entity and a related party, regardless of whether price is charged and a transaction with a related party shall be construed to include a single transaction or a group of transactions in a contract, including but not limited to the following –

• sale, purchase or supply of any goods or materials;

• selling or otherwise disposing of, or buying, property of any kind;

• leasing of property of any kind;

• availing or rendering of any services;

• appointment of any agent for purchase or sale of goods, materials, services, property;

• appointment to any office or place of profit in the company

• underwriting the subscription of any securities or derivatives thereof, of the company

A transaction shall be construed to include a single transaction or a group of transactions in a contract.

“Senior Management Personnel / Senior Management” means personnel of the company who are members of its core management team excluding Board of Directors comprising all members of management one level below the executive directors, including the functional and departmental heads.

Unless the context otherwise requires, words and expressions used in this policy and not defined herein but defined in the Companies Act, 2013 or NHB Act, 1987, NHB Directions, Notifications, Circulars or guidelines as may be amended from time to time shall have the meaning respectively assigned to them therein.

KEY PRINCIPLES FOR RELATED PARTY TRANSACTIONS

Identification of Related Parties

All Directors and Key Managerial Personnel (KMPs) shall be responsible for informing the Company of their interest (including interest of their Relatives) in other companies, firms or concerns at the beginning of every financial year and any change in such interest during the year, immediately on occurrence. Further, Directors and KMPs should disclose to the Board whether they, directly, indirectly, or on behalf of third parties, have interest in any transaction or matter directly affecting the Company.

In addition, all Directors and KMPs are responsible for giving notice to the Company Secretary of any potential Related Party Transaction involving them or their Relatives.

Also, every officer of the Company entrusted with the authority to enter into any transaction shall be responsible for providing notice to the Board or Audit Committee, through the Company Secretary of the Company of any Related Party Transaction involving the Company. The Board / Audit Committee, through the Company Secretary will determine whether the Transaction does, in fact, constitute a Related Party Transaction requiring compliance with this Policy.

Such notice of any Related Party Transaction should be given at least 1 week in advance so that the Company Secretary (or such other person who may be entrusted for this purpose by the Audit Committee) has adequate time to obtain and review information about the proposed transaction and place the same before the Audit Committee.

The relevant Director/ KMP will also be required to provide any additional information about the transaction that the Board/Audit Committee may reasonably request. The Board/ Audit Committee will determine whether the transaction does, in fact, constitute a Related Party Transaction requiring compliance with the Policy.

Ordinary Course of Business

The phrase Ordinary Course of Business is not defined under the Act or Rules made thereunder. The Company shall adopt a reasonable approach / methodology to demonstrate ‘Ordinary Course of Business’ which shall, inter alia, include the nature of the transaction, the frequency / regularity / length of time the company is engaged in such transaction, such transaction / action is consistent with the past practices and was taken in the ordinary course of the normal day-today operations of such company, common commercial practice i.e. customarily taken, in the ordinary course of the normal day-to-day operations of other companies that are in the same / similar line of business.

Arms-Length Transaction

For transactions between two related parties to be considered to be at Arm’s Length Pricing, the transaction should be conducted between the two parties as if the parties were unrelated, so that there is no conflict of interest i.e. Arm’s Length Pricing is the condition or the fact that the two related parties transact as independent (un-related) parties and on an equal footing from one or more of the following aspects viz. nature of goods / services, risk assumed, assets / resources employed, key terms / covenants.

In the absence of any guidelines on Arm’s Length Pricing in the Act, the Company shall adopt reasonable approach / methodology to demonstrate Arm’s Length Pricing for the specified Related Party Transactions identified, which shall, inter alia, include, the nature of the transaction, description of functions to be performed, risks to be assumed and assets to be employed, key terms / special terms in the arrangement forming part of a composite transaction;

The Company shall adopt an appropriate framework to assess whether transactions with related parties are done at an Arm’s Length and Company adopts generally accepted practices and principles in determining whether the transaction is at “Arm’s Length”.

Materiality Threshold for Related Party Transaction

The Company follows Materiality Thresholds for Related Party Transactions as defined under Definition section of this Policy, which are not in the ordinary course of business and/or not at arm’s length basis.

Guiding Principles for Approval of Related Party Transactions

For seeking approval of Audit Committee and the Board of Directors, as the case may be, for Related Party Transaction(s), all relevant material information of the Related Party Transaction(s), including the terms of the transaction, the business purpose of the transaction, the benefits to the Company etc. will be provided to the Board/ Audit Committee. In determining whether to approve or reject a Related Party Transaction, the Board/ Audit Committee will consider the following factors, among others, to the extent relevant to the Related Party Transaction:

• Whether the transaction is in the ordinary course of business of the Company;

• Whether the terms of the Related Party Transaction are fair to the Company and would apply on the same basis if the transaction did not involve a Related Party;

• Whether there are any compelling business reasons for the Company to enter into the Related Party Transaction and the nature of alternative transactions, if any;

• Whether the Related Party Transaction would impair the independence of an otherwise Independent Director or Nominee of a Director;

• Whether the Related Party Transaction would present an improper conflict of interest for any Director, Nominee for Director or KMP of the Company, taking into account the size of the transaction, the overall interest of the Director, Nominee for Director, Executive Officer or other Related Party, the direct or indirect nature of the Director’s Nominee, Executive Officer’s or other Related Party’s interest in the transaction and the ongoing nature of any proposed relationship and any other factors the Board/Committee deems relevant.

Related Party Transaction not approved under the policy

In the event the Company becomes aware of a Related Party Transaction with a Related Party that has not been approved under this Policy prior to its consummation, the matter shall be reviewed by the Committee / Board.

The Committee / Board shall consider all the relevant facts and circumstances regarding the Related Party Transaction, and shall evaluate all options available to the Company, including ratification, revision or termination of the Related Party Transaction.

The Committee / Board shall also examine the facts and circumstances pertaining to the failure of reporting such Related Party Transaction to the Committee under this Policy and shall take any such action it deems appropriate.

In any case, where the Committee / Board determines not to ratify a Related Party Transaction that has been commenced without approval, the Committee / Board, as appropriate, may direct additional actions including, but not limited to, immediate discontinuation or rescission of the transaction.

In connection with any review of a Related Party Transaction, the Committee / Board has authority to modify or waive any procedural requirements of this Policy.

APPROVAL PROCESS FOR RELATED PARTY TRANSACTIONS

Approval of the Audit Committee

Every related party transaction shall be approved by the Audit Committee (“Committee”) as required in terms of the provisions of the Companies Act, 2013 and the Directions. The Audit Committee of the Board will review and, if appropriate, approve Related-Party Transactions. Accordingly, management shall present to the committee the following information with respect to all Related Party Transactions expected to be entered into during that financial year:

• the name of the Related Party;

• the Related Party’s interest in the transactions, including the Related Party’s position or relationship with, or ownership of, any entity that has an interest in the transactions;

• the estimated rupee value of the transactions;

• a general description of the transactions, including material terms and conditions;

• in case of loans, the aggregate amount of loans and the rate of interest payable on such loans;

• in case of guarantees issued, the aggregate amount of guarantees, nature of guarantee and commission to be payable on such guarantees;

• an assessment of whether the transactions are on terms that are comparable to the terms available to unrelated third parties or to employees generally; and

• any other material information regarding the transaction(s) or the Related Party’s interest in the transaction(s).

After reviewing such information and being satisfied that there is a need for such approval, the members of the Audit Committee (without the participation of the Committee member(s) interested in the transaction, if any) shall approve or disapprove such transactions.

Omnibus Approval to transactions

The Committee may consider to grant Omnibus approval of such transactions only if it is determined by the Committee that such transactions are:

• Repetitive in nature and that such approval is in (or not inconsistent with) the best interests of the Company and its shareholders;

• Compliant with requirement of the Arm’s length transaction;

• In the ordinary course of the business of the Company.

Such omnibus approval shall specify:

• the name/s of the related party;

• nature of transaction, period of transaction, maximum amount of transaction that can be entered into, and

• the indicative base price / current contracted price and the formula for variation in the price if any

Provided that where the need for Related Party Transaction cannot be foreseen and aforesaid details are not available, Audit Committee may grant omnibus approval for such transactions subject to their value not exceeding Rs.1 crore per transaction.

The Audit Committee shall review, on a quarterly basis, the details of Related Party Transactions entered into by the Company pursuant to each of the omnibus approval given. Such omnibus approvals shall be valid for a period not exceeding one financial year and shall require fresh approvals after the expiry of one financial year.

No member of the Audit Committee shall participate in the review, consideration or approval of any Related-Party Transaction with respect to which such member or any of his or her relatives is a Related Party.

If any material information with respect to such transactions shall change subsequent to the Committee’s review of such transactions, management shall provide the Committee with updated information at a subsequent meeting and will get the changes approved afresh by the Committee.

All the directors are required to declare and disclose their concerns or interests in any company or companies or bodies corporate at the first Board meeting in every financial year and subsequently whenever there is any change therein.

Omnibus approval shall not be made for the transactions in respect of selling or disposing of the undertaking of the Company.

Approval of the Board of Directors

All Related Party Transactions that are not in the ordinary course of business or not on arm’s length basis shall be referred to the Board of Directors for their approval.

Any member of the Board who has a potential interest in such Related Party Transaction will recuse himself or herself and abstain from discussion or voting on the approval of such Related Party Transaction.

In addition to the above, the following kinds of transactions with related parties are also placed before the Board for its approval:

• Transactions which may be in the ordinary course of business and at arm’s length basis, but which are as per the policy determined by the Board from time to time (i.e. value threshold and/or other parameters) require Board approval in addition to Audit Committee approval;

• Transactions in respect of which the Audit Committee is unable to determine whether or not they are in the ordinary course of business and/or at arm’s length basis and decides to refer the same to the Board for approval;

• Transactions which are in the ordinary course of business and at arm’s length basis, but which as per Audit Committee requires Board approval;

• Transactions meeting the materiality thresholds laid down under approval of Shareholders part of the Policy, which are intended to be placed before the shareholders for approval.

Approval of Shareholders

Any such Related Party Transactions shall also be placed for prior approval of shareholders by way of resolution, if it exceeds the thresholds as defined under the definition of Material Related Party Transactions under this Policy.

All entities falling under the definition of Related Parties shall not vote to approve the said resolution being placed before the shareholders, irrespective of whether the entity is a party to the transaction or not.

Related Party Transaction not requiring Approval

The following Related Party Transactions shall not require any separate approval under the Policy:

• Any transaction that involves the providing of compensation to a director or Key Managerial Personnel in connection with his or her duties to the Company or any of its subsidiaries or associates, including the reimbursement of reasonable business and travel expenses incurred in the ordinary course of business;

• Transactions that have been approved by the Board under specific provisions of the Act,

• Payment of Dividend;

• Transactions involving corporate restructuring, such as buy-back of shares, capital reduction, merger, demerger, hive-off etc. which are approved by the Board and carried-out in accordance with the specific provisions of the Act, or the applicable regulations;

• Contribution towards Corporate Social Responsibility (CSR) within the overall limits approved by the Board that require approval of the CSR Committee.

• Where the transactions are entered into by the Company in its ordinary course of business and are on arms’ length basis; or

• Where the transactions are entered into by the Company in its ordinary course of business and are on arms’ length basis; or

• Any related party transaction not requiring approval as per extant applicable law / guidelines.

Approval Matrix:

DISCLOSURE

All Related Party Transactions will be disclosed in Annual Report, Results and other filings made by the Company, to the extent required as per the applicable provisions of the laws and regulations. Further, as required in the NHB Directions, the Company will disclose the Policy on its website as well as in its Annual Report

REVIEW, MODIFICATION & CHANGES

• There shall be an annual review of the Policy by the Board of Directors;

• Board of Directors can at any time modify or amend, either the whole or any part of Policy;

Privacy Policy

Godrej Housing Finance Limited (hereinafter referred to as “GHFL” ), a company incorporated under the provisions of Companies Act, 2013, having our registered office at Godrej One, Pirojshanagar, Vikhroli (East), Mumbai – 400079 and having corporate identity number U65100MH2018PLC315359, value your trust and respect your right to privacy.

General

This Privacy Policy provides you with details about the manner in which your data is collected, stored and used by us. You are advised to read this Privacy Policy carefully. If you do not agree to the terms of this Privacy Policy, do not further use or access GHFL website, GHFL applications or its digital assets (Website content/Journeys/Applications/Mobile, tablet apps/Digital and SMS Communication).

For the purpose of this Privacy Policy, the term "You" or "User" shall mean any natural or legal person/entity including online and offline clients visiting this website and the term "We", "Us", "Our" shall mean GHFL along with its Subsidiaries.

Use of this Website/digital asset/communication signifies your acknowledgement and consent to this Privacy Policy. If, however, you object to Your Information being used, collected, stored, processed and transferred by GHFL in any way, please do not share your information on the Website or any Platform or with any representative of GHFL. If you would like to make a complaint about a possible breach of local privacy laws, please do so by calling us on 8657764527 or email at the following address: nodalofficer@godrejhf.com

This privacy statement is applicable to website and applications (mobile and hybrid, hereinafter referred to “applications”) of GHFL. This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, or television or any other media or computer resource or any other medium digital or otherwise to access our Services. It also applies to those who register on our website/applications in connection with use of our services, or whose data GHFL otherwise receives in connection with its services. It is important that you read the Privacy Policy carefully because whenever you use our website/applications, your personal data will be processed (if at all) in accordance with this Policy.

For purposes of this Policy, the term “representative” shall include employees, authorised agents of GHFL.

Personal Data and its collection

Personal Data, means and includes, any data relating to a natural person and is capable of identifying such person (‘data subject’ here in referred as you/your’) including but not limited to, name, address, mailing address, telephone number, email ID, PAN, bank account details including bank statements, linked to credit/debit payment instruments, information about your mobile phone, any personal details that may have been voluntarily provided by the customer, whether to Unique Identification Authority of India (UIDAI), Credit Information Bureau of India Limited (CIBIL) or any other agency including but not limited to any other Credit Information Companies (CIC). Personal data shall also include all Personally Identifiable Information (PII) and Sensitive Personal Information (SPI).

i. Information Collected when you use our website: We collect data about you or your usage for the purpose of providing loan / other financial services to all of our users and such information is kept protected at all times. We may collect data in the following ways. Many of our services require you to register/sign up for an account on GHFL. When you do, we will ask for Personal Data, such as, but not limited to your name, email address, contact number, country, address to create/ update your account.

When you use the GHFL websites, GHFL mobile applications,  or request for more information or request assistance or when you apply for  loans, GHFL would request for and collect  Personal Data (Personally Identifiable Information (PII) or Sensitive Personal Information (SPI) ), including but not limited to Name, Email ID, Contact number, address, financial information, bank statements, bank account details, credit information, family information, employment information, property details, ongoing loan details, business information, PAN card, Aadhar card, Passport, Driving license, other forms of identification proofs and such other required information and their supporting documents . Personal data may be collected by authorized representatives or mediums. We may collect  personal/any and all forms of data for business purposes, sanctioning loan, processing loan cases, further providing assistance or services, service offerings, maintaining an audit trail as per regulatory and statutory requirements. This personal data may be collected, stored, processed, transferred between GHFL and its third party service providers for business purposes. Data security shall be maintained throughout the life cycle of the data/processes.

In the event that any data is shared by customers over unofficial channel such as:

• Social media platforms,
• Whatsapp application,
• Telegram application, 
• Media sharing applications other than provided by GHFL
• Email IDs domains other than GHFL domain (such as @gmail / @yahoo / @Rediff / other non-GHFL domain)

GHFL will not be responsible for the data privacy and security. Users are advised to share data only with authorized representatives via official channels.

In case any representative suggests any unauthorised alternate medium for data collection, GHFL shall not be responsible for the data privacy and security of such data/information.

When you use the GHFL Website or GHFL Mobile Applications to provide feedback, we collect your Personal Data including but not limited to name, title, Email ID, contact number, address and country. We collect data about the services that you use and how you use them. This data includes, but not limited to, log data and location data . We may collect your data through marketing campaigns and publicly available sources.

When you communicate with GHFL or use the GHFL platform to communicate with other members, we collect data about your communication and any data you choose to provide. If you choose to sign in with your social media account to access GHFL, or otherwise connect your social media account with the services of GHFL, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the data that you make available to us through the social media interface.

ii. Information Collected when you use our applications: When you download our mobile application or use our hybrid application (related to our various services) we collect the below information, but not limited to –

• Email ID
• Name
• Address
• Country/City
• Mobile Number

GHFL does not collect Personal Data about individuals except when such individuals specifically provide such data on a voluntary basis. Upon such voluntary disclosure of Personal Data, we may further verify, collate or receive data about you from publicly and commercially available sources (in accordance with applicable law), which we may combine with other data we receive from you. We may also receive data about you from third-party social networking services, wherein you have provided such consent to those third-party platforms, if you are already connected with those services.

GHFL has adopted the ‘Fair Practice Code’ and has grievance redressal mechanism which can be accessed at https://www.godrejcapital.com/GHF/about-us.html

Lawful Basis of Processing

The information is collected for a lawful purpose connected with a function or activity of GHFL or any person on its behalf; and the collection of the sensitive personal data or information is considered necessary for that purpose. We may process your data because:

• You would have given us permission to do so
• We have provided services to you or because you have availed/shown interest for one of our offers/products
• To comply with the law
• We have a contract with you

Use of Personal Data

We use Personal Data to provide you with any service you explicitly requested for, to resolve disputes, troubleshoot concerns, help promote safe services, assess your interest in our services, inform you about offers, products, services, updates, customize your experience, detect and protect us against errors, fraud and other criminal activity, enforce our terms and conditions, etc.

We may also use your Personal Data to send you offers regarding various services/facilities which GHFL or its group companies may, from time to time, launch. Your consent will be taken before we send you any such communication.

Cookies and Other Tracking Technologies

Some of our Web pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect data about website activity. Some cookies and other technologies may serve to recall Personal Data previously indicated by a Web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Web site.

Tracking technologies may record data such as Internet domain and host names; Internet protocol (IP) addresses; browser software, co-browsing services, and operating system types; clickstream patterns; and dates and times that our site/application is accessed. Our use of cookies and other tracking technologies allows us to improve our website/applications and your Web experience. We may also analyse information that does not contain Personal Data for trends and statistics.

Information Sharing and Disclosure

We provide  access of your Personal Data to few employees who we believe reasonably need to know that data in order to fulfil their jobs to provide, operate, develop, or improve our products or services.

GHFL does not rent, sell, or share Personal Data about you with other people or non-affiliated companies except:

• to provide products or services you've requested
• when we have your permission
• as required by law or legal process
• or for services and offerings

Sharing of Data with Third Parties

We provide the data to trusted partners who work on behalf of or with GHFL under confidentiality agreements. These companies may use your Personal Data to help GHFL communicate with you about offers from GHFL and our marketing partners. However, these companies do not have any independent right to share this data.

We may disclose your personal data to agents or contractors of GHFL and/or its group companies/affiliates to enable processing of transactions or communications with you “on need” basis. Your aforesaid data may be further used for assessment and analysis of our market, customers, products, and services and to understand the way people use our Services so that we can improve them and develop new products and services. However, it shall be on the basis that the agents are required to keep the data confidential and will not use the data for any other purpose other than to carry out the services they are performing for GHFL and/or its group companies/affiliates.

With your permission we may share your personal data with Godrej group and/or its affiliates or providing details on latest offers from our other entities.

Third-Party Links and Content on Services

Our Services may link to third-party websites/applications and services that are outside our control. Further, GHFL, its group companies, its affiliates, and their directors and employees (“Godrej Group”) accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of any application or any website, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy with any online application, its contents (material, data, money market movements, news items, etc.) or associated services, or due to unavailability of any application or any part thereof or any contents or associated services even if GHFL  is advised of the possibility of such damages, losses or expenses.

Minors

To use the website/Application you agree that you must be the minimum age (described in this paragraph below) or older.

The minimum age for these purposes shall be 18, however if local laws require that you must be older in order for GHFL to lawfully provide the services mentioned on the Website/Application to you then that older age shall apply as the applicable minimum age.

Data Retention

Your personal data processed by GHFL, or its third-party service providers shall be kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data was collected/stored/processed in line with legal, regulatory, contractual or statutory obligations as applicable.

Your personal data and all data collected during the information gathering, sanctioning of loan, processing of loan, and any other process of providing services, shall be retained for tenure of the loan. Post loan closure the personal data shall be retained for statutory retention period as per the regulatory requirements and applicable law. The regulatory requirement and applicable law for personal data retention may change from time to time and the retention period would be amended from time-to-time to comply with the rules and regulations.

Data Purging Protocol

At the expiry of retention period, your personal data may be purged or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory retention periods, as applicable at that point in time.  Certain minimal personal data may be retained after the data purging/archival process to comply with internal policy or statutory or legal or regulatory requirements at that point in time. Customers would have the option to grant/revoke consent based on which data retention or data purging guidelines would be followed as per the regulatory or statutory requirements.

Security and Confidentiality

GHFL would implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection and safeguarding of personal data. At GHFL, we are strongly committed to protecting the personal and financial data that is submitted to us.

GHFL shall ensure to safeguard the security and confidentiality of any data shared with us. Any personal data obtained by us shall not be used or shared other than for the purposes to which you provide your consent. However, despite our utmost efforts to protect your Personal Data, GHFL cannot warrant the security of any data you transmit to us through our online services/ applications. By accepting this Privacy Policy, you accept that such transmission of your Personal Data is done at your own risk.

Lastly, you are requested to help us protect your data privacy by maintaining the secrecy of the username and password you use for any of our Services.

Any breach of data or personal information shall be handled as per the regulatory or statutory requirements as may be applicable. Personal data shall be stored in systemswithin India as per regulatory and statutory requirements.

Social media

GHFL operates channels, pages and accounts on some social media websites/platforms/ public websites to inform, assist and engage with customers. GHFL monitors and records comments and posts made on these websites/platforms/public websites about GHFL in order to improve its products and services.

Please note that you must not communicate to GHFL through such social media sites the following information:

• Sensitive personal data
• Excessive, inappropriate, offensive or insulting information towards individuals.

GHFL is not responsible for any information posted on public websites/ social media websites other than the information posted by its authorized representatives/employees on GHFL’s behalf. GHFL is only responsible for its own use of the personal data received through such websites.

Disclaimer

GHFL shall not be liable for any loss or damage sustained by reason of disclosure (inadvertent or otherwise) of any data concerning the user's account and / or data relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any data so disclosed and used whether or not in pursuance of a legal process or otherwise. GHFL does not store any Credit / Debit card details. Any other personal and sensitive Personal Data shared by you which is not asked by GHFL during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing of data/information ; and GHFL will not be liable for breach of such data.

No contractual obligation

Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

Intellectual Property Rights

Please note that GHFL retains all rights (including copyrights, trademarks, patents as well as any other intellectual property right) in relation to all information provided on or via this web site/applications (including all texts, graphics and logos).

Changes to this Privacy Policy

GHFL reserves the right to change or update this Privacy Policy or any other of our policies/practices at any time without giving any prior notification; hence, you are requested to review the Privacy Policy periodically, to make sure that you are aware of any such changes. This Privacy Policy shall apply uniformly to GHFL website and GHFL applications or any other media used by GHFL for its Services. Any changes or updates will be effective immediately upon posting the same on our web site at https://www.godrejcapital.com/GHF/about-us.html. If you have any questions or concerns or require any clarifications with respect to this Privacy Policy, please do so by calling us on 8657764527 or email at the following address: nodalofficer@godrejhf.com.

Annexure A: Third Party Service Providers

This annexure consists of a list of Third-Party service providers/vendors/partners/contractors who have been authorized by Godrej Housing Finance Limited to support in business operations.

Background

Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, is required to comply with the ‘Guidelines on Fair Practices Code’ issued by the Reserve Bank of India (“RBI”) under Chapter XIII of Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 issued on 17th February 2021.

Accordingly, it is proposed to adopt Fair Practice Code with the approval of the Board.

Objectives

a)To promote good and fair practices by setting minimum standards in dealing with customers;

b)To increase transparency so that the customer can have a better understanding of what he/she can reasonably expect of the services;

c)To promote a fair and cordial relationship between customer and the Company;

Review of the Code

a)The Code shall be reviewed Annually by the Board of Directors.

b)Board of Directors can at any time modify or amend, either the whole or any part of Policy

c)Compliance with Fair Practice Code shall be provided on Annual basis to the Board of Directors,

d)Half-Yearly report on grievance redressal mechanism be put to the Board of Directors

Application of the Code

This Code shall apply to all the products and services, whether they are provided by the GHFL, its subsidiaries or Digital Lending Platforms (self-owned and/or under an outsourcing arrangement) across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.

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.

b)Company shall transparently disclose to the borrower all information about fees/ charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned/ disbursed, pre-payment options and charges, if any, penal interest/ penalty for delayed repayment, if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest reset clause and any other matter which affects the interest of the borrower. Company shall disclose ‘all in cost’ inclusive of all charges involved in processing/ sanctioning of loan application in a transparent manner.

c)All such charges/ fees which are levied on the Borrower are non-discriminatory,

d)Loan application forms include necessary information which affects the interest of the borrower which enable a meaningful comparison with the terms and conditions offered by other Finance Companies and aid borrower in making an informed decision.

e)The Company has a system of giving acknowledgement for receipt of all loan applications.

Loan appraisal, terms/ conditions and communication of rejection of loan application

a)Company endeavours to collect all particulars required for processing the loan application shall be collected by the Company at the time of application. However, in case we need any additional information, we shall endeavour to inform the customer should be told immediately that he would be contacted again.

b)Company shall convey in writing to the borrower in the vernacular language or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges, penal interest (if any) and keep the written acceptance of these terms and conditions by the borrower on its record.

c)Company shall mention the penal interest charged for late repayment in bold in the loan agreement.

d)Company shall furnish a copy of the loan agreement along with a copy of each of the enclosures quoted in the loan agreement to every borrower at the time of disbursement of loans through its Customer Portal which can be accessed by the Borrower.

e)If Company cannot provide the loan to the customer, it shall communicate in writing the reason(s) for rejection.

Disbursement of loans including changes in terms and conditions

a)Disbursement shall be made in accordance with the disbursement schedule / Disbursement terms advised to the Borrower as per Finance Documents.

b)The Company shall give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, penal interest (if any), service charges, prepayment charges, other applicable fee/ charges etc. by the mechanisms informed in MITC or Loan Agreement.

c)Company will ensure that changes in interest rates and charges are effected only prospectively.

d)If such change is to the disadvantage of the customer, he/ she may within 60 days and without notice close his/ her account or switch it without having to pay any extra charges or interest.

e)Decision to recall/ accelerate payment or performance under the agreement or seeking additional securities, will be in consonance with the loan agreement.

f)Company 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 Company 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 Company are entitled to retain the securities till the relevant claim is settled/ paid.

Loans sourced over Digital Lending Platforms (DLP)

Company does not intend to extend loans through Digital Lending Platforms. However, in event a partnership is undertaken by the Company where its loans are extended through DLP either to source borrowers and/ or to recover dues, Company shall follow the following instructions:

Responsibility of Board of Directors

a)The Board of Directors of Company have laid down a Grievance Redressal mechanism within the organization to resolve complaints and grievances which is enunciated in the Grievance Redressal Policy for the Organization.

b)This mechanism ensures that all disputes arising out of the decisions of lending institution’s functionaries are heard and disposed of at least at the next higher level.

c)The Board of Directors of shall conduct an annual review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.

Complaints and Grievance Redressal

Guidelines for complaint and grievance redressal are contained in Grievance Redressal Policy of the Company.

Mode of Communication

Language and mode of communicating Fair Practice Code, which shall be in the vernacular language or a language as understood by the borrower, shall be put up on Companies website, for the information of various stakeholders.

Interest charged by Company

a)The Board of Company has adopted an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium which helps in determining the rate of interest to be charged for loans and advances.

b)The rate of interest and the approach for gradation of risk and rationale for charging different rate of interest to different categories of borrowers is disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.

c)The Board of the GHFL has laid down policy for penal interest/ charges under its Interest Rate and Charges Policy. The rate of interest and penal interest (if any) is annualised rate so that the borrower is aware of the exact rates that would be charged to the account.

d)The rates of interest and the approach for gradation of risks, and penal interest (if any) shall also be made available on the website of the companies. The information published in the website published shall be updated whenever there is a change in the rates of interest.

e)Repayment Schedule which is shared with Borrowers clearly indicates the bifurcation between interest and principal in repayment schedule of Company.

f)Company sets its Interest Rate / Charges as per principles enshrined in Interest Rate & Charges Policy,

g)Grievance Redressal Committee, inter alia, monitors the process and the operations to ensure adequate transparency in communications with the borrowers.

Advertising, Marketing and Sales

Company shall:

a)Ensure that all advertising and promotional material is clear, and factual.

b)In any advertising in any media and promotional literature that draws attention to a service or product and includes a reference to an interest rate, Company shall also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request or on the website.

c)Company shall provide information on interest rates, common fees and charges (including penal interest, if any) through putting up notices in their branches; through telephone or help-lines; on the company’s website; through designated staff/ help desk; or providing service guide/ tariff schedule.

d)If Company avail of the services of third parties for providing support services, Company shall require that such third parties handle customer’s personal information (if any available to such third parties) with the same degree of confidentiality and security as the Company would.

e)Company may, from time to time, communicate to customers various features of their products availed by them. Information about their other products or promotional offers in respect of products/ services, may be conveyed to customers only if he/ she has given his/ her consent to receive such information/ service either by mail or by registering for the same on the website or on customer service number.

f)Company has prescribed a code of conduct for their Direct Selling Agencies (DSAs) whose services are availed to market products/ services which amongst other matters require them to identify themselves when they approach the customer for selling products personally or through phone.

g)Company has adopted the Model Code of Conducts for Direct Selling Agents (DSAs)/ Direct Marketing Agents (DMAs) as part of outsourcing policy with the approval of our Board,

h)In the event of receipt of any complaint from the customer that Company’s representative/ courier or DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.

Guarantors

When a person is considering being a guarantor to a loan, he/ she is being informed about following:

a)his/ her liability as guarantor;

b)the amount of liability he/ she will be committing him/herself to the company;

c)circumstances in which HFC will call on him/her to pay up his/ her liability;

d)whether HFC has recourse to his/her other monies in the company if he/ she fail to pay up as a guarantor;

e)whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and

f)time and circumstances in which his/ her liabilities as a guarantor will be discharged as also the manner in which HFC will notify him/ her about this.

g)In case the guarantor refuses to comply with the demand made by the creditor/ lender, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter.

Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower to whom he/ she stands as a guarantor.

Privacy and Confidentiality

a)All personal information of customers, both present and past, shall be treated as private and confidential and shall be guided by the following principles and policies.

b)Company shall not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other companies/ entities in their group, other than in the following exceptional cases:

c)If Company are asked to give a reference about customers, they shall obtain his/ her written permission before giving it.

d)The customer shall be informed the extent of his/ her rights under the existing legal framework for accessing the personal records that GHFL holds about him/ her, through the Privacy Policy which is available on Company’s website,

e)Company shall not use customer’s personal information for marketing purposes by anyone including Company, unless the customer specifically authorizes them to do so.

Guidelines for pre-payment of loans

a)Company shall not charge pre-payment levy or penalty on pre-closure of housing loans under the following situations:

a. Where the housing loan is on floating interest rate basis and pre-closed from any source.

b. Where the housing loan is on fixed interest rate basis and the loan is pre-closed by the borrower out of their own sources.

b)The expression “own sources” for the purpose means any source other than by borrowing from a bank/ HFC/ NBFC and/or a financial institution.

c)Company shall not impose foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).

d)All dual/ special rate (combination of fixed and floating) housing loans will attract the pre-closure norms applicable to fixed/ floating rate depending on whether atthe time of pre-closure, the loan is on fixed or floating rate. In case of a dual/ special rate housing loans, the pre-closure norm for floating rate will apply once the loan has been converted into floating rate loan, after the expiry of the fixed interest rate period. This applied to all such dual/ special rate housing loans being foreclosed hereafter. It is also clarified that a fixed rate loan is one where the rate is fixed for entire duration of the loan.

General

a)Company does not extend any loan to any micro-finance borrower.

b)Company does not interfere 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).

c)In case of receipt of request from the borrower for transfer of borrower’s account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.

d)Whenever loans are given, Company shall explain to the customer the repayment process by way of amount, tenure and periodicity of repayment through Repayment Schedule.

e)Company has formulated a Collection Policy which contains guidelines with respect to repayment process and for engaging Recovery Agents.

f)To facilitate quick and good understanding of the major terms and conditions of housing loan agreed upon between Company and the individual borrower, Company shall obtain a document containing the most important terms and conditions (MITC) of such loan in all cases as per format provided in Annex I. The document will be in addition to the existing loan and security documents being obtained by the Company.

g)Company has prepared MITC in language understandable by the borrower and a copy duly executed between the Company and the borrower is uploaded on the Customer Portal.

h)Display of various key aspect such as service charges, interest rates, Penal interest (if any), services offered, product information, time norms for various transactions and grievance redressal mechanism, etc. is required to promote transparency in the operations of Company. Company shall follow the instructions on “Notice Board”, “Booklets/ Brochures”, “Website”, “Other Modes of Display” and on “Other Issues” as per the prescribed guidelines.

i)HFC shall display about their products and services in English on its website.

j)Company does not discriminate on grounds of sex, caste and religion in the matter of lending. Further, Company shall also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude Company from instituting or participating in schemes framed for different sections of the society.

k)To publicise the Code, Company shall:

a. provide existing and new customers with a copy of the Code;

b. make this Code available on request either over the counter or by electronic communication or mail;

c. make available this Code at every branch and on their website; and

d. ensure that their staff are trained to provide relevant information about the Code and to put the Code into practice.

Click here to view in Marathi, Hindi, Kannada, Telugu, Tamil, Gujarati

CODE FOR INDEPENDENT DIRECTORS
 

The Code is a guide to professional conduct for Independent Directors. Adherence to these standards by Independent Directors and fulfilment of their responsibilities in a professional and faithful manner will promote confidence of the investment community, particularly minority shareholders, regulators and companies in the institution of independent directors. The said Code is aligned pursuant to Section 149 (8) read with Schedule IV of the Companies Act, 2013.
 

Guidelines of professional conduct:
 

• uphold ethical standards of integrity and probity;
• act objectively and constructively while exercising his duties;
• exercise his responsibilities in a bona fide manner in the interest of the company;
• devote sufficient time and attention to his professional obligations for informed and balanced decision making;
• not allow any extraneous considerations that will vitiate his exercise of objective independent judgment in the paramount interest of the company as a whole, while concurring in or dissenting from the collective judgment of the Board in its decision making;
• not abuse his position to the detriment of the company or its shareholders or for the purpose of gaining direct or indirect personal advantage or advantage for any associated person;
• refrain from any action that would lead to loss of his independence;
• where circumstances arise which make an independent director lose his independence, the independent director must immediately inform the Board accordingly;
• assist the company in implementing the best corporate governance practices.
   

Role and functions:
 

• help in bringing an independent judgment to bear on the Board’s deliberations especially on issues of strategy, performance, risk management, resources, key appointments and standards of conduct;
• bring an objective view in the evaluation of the performance of board and management;
• scrutinize the performance of management in meeting agreed goals and objectives and monitor the reporting of performance;
• satisfy themselves on the integrity of financial information and that financial controls and the systems of risk management are robust and defensible;
• safeguard the interests of all stakeholders, particularly the minority shareholders;
• balance the conflicting interest of the stakeholders;
• determine appropriate levels of remuneration of executive directors, key managerial personnel and senior management and have a prime role in appointing and where necessary recommend removal of executive directors, key managerial personnel and senior management;
• moderate and arbitrate in the interest of the company as a whole, in situations of conflict between management and shareholder’s interest.

Duties :
 

• undertake appropriate induction and regularly update and refresh their skills, knowledge and familiarity with the company;
• seek appropriate clarification or amplification of information and, where necessary, take and follow appropriate professional advice and opinion of outside experts at the expense of the company;
• strive to attend all meetings of the Board of Directors and of the Board committees of which he is a member;
• participate constructively and actively in the committees of the Board in which they are chairpersons or members;
• strive to attend the general meetings of the company;
• where they have concerns about the running of the company or a proposed action, ensure that these are addressed by the Board and, to the extent that they are not resolved, insist that their concerns are recorded in the minutes of the Board meeting;
• keep themselves well informed about the company and the external environment in which it operates; not to unfairly obstruct the functioning of an otherwise proper Board or committee of the Board;
• pay sufficient attention and ensure that adequate deliberations are held before approving related party transactions and assure themselves that the same are in the interest of the company;
• ascertain and ensure that the company has an adequate and functional vigil mechanism and to ensure that the interests of a person who uses such mechanism are not prejudicially affected on account of such use;
• report concerns about unethical behaviour, actual or suspected fraud or violation of the company’s code of conduct or ethics policy;
• acting within his authority, assist in protecting the legitimate interests of the company, shareholders and its employees;
• not disclose confidential information, including commercial secrets, technologies, advertising and sales promotion plans, unpublished price sensitive information, unless such disclosure is expressly approved by the Board or required by law.
   

Manner of appointment:
 

• Appointment process of independent directors shall be independent of the company management; while selecting independent directors the Board shall ensure that there is appropriate balance of skills, experience and knowledge in the Board so as to enable the Board to discharge its functions and duties effectively.
• The appointment of independent director(s) of the company shall be approved at the meeting of the shareholders.
• The explanatory statement attached to the notice of the meeting for approving the appointment of independent director shall include a statement that in the opinion of the Board, the independent director proposed to be appointed fulfills the conditions specified in the Act and the rules made thereunder and that the proposed director is independent of the management.
• The appointment of independent directors shall be formalized through a letter of appointment, which shall set out: 
  • the term of appointment;
  • the expectation of the Board from the appointed director; the Board-level committee(s) in which the director is expected to serve and its tasks;
  • the fiduciary duties that come with such an appointment along with accompanying liabilities;
  • provision for Directors and Officers (D and O) insurance, if any;
  • the Code of Business Ethics that the company expects its directors and employees to follow;
  • the list of actions that a director should not do while functioning as such in the company; and
  • the remuneration, mentioning periodic fees, reimbursement of expenses for participation in the Boards and other meetings and profit related commission, if any
• The terms and conditions of appointment of independent directors shall be open for inspection at the registered office of the company by any member during normal business hours.
• The terms and conditions of appointment of independent directors shall also be posted on the company’s website.
   

Re-appointment:
 

The re-appointment of independent director shall be on the basis of report of performance evaluation.
 

Resignation or removal:
 

• The resignation or removal of an independent director shall be in the same manner as is provided in sections 168 and 169 of the Act.
• An independent director who resigns or is removed from the Board of the company shall be replaced by a new independent director within three months from the date of such resignation or removal, as the case may be.
• Where the company fulfils the requirement of independent directors in its Board even without filling the vacancy created by such resignation or removal, as the case may be, the requirement of replacement by a new independent director shall not apply.

Separate meetings:
 

• The independent directors of the company shall hold at least one meeting in a financial year, without the attendance of non-independent directors and members of management;
• All the independent directors of the company shall strive to be present at such meeting;
• The meeting shall: 
  • review the performance of non-independent directors and the Board as a whole;
  • review the performance of the Chairperson of the company, taking into account the views of executive directors and non-executive directors;
  • assess the quality, quantity and timeliness of flow of information between the company management and the Board that is necessary for the Board to effectively and reasonably perform their duties.
     

Evaluation mechanism:
 

• The performance evaluation of independent directors shall be done by the entire Board of Directors, excluding the director being evaluated.
• On the basis of the report of performance evaluation, it shall be determined whether to extend or continue the term of appointment of the independent director.

APPLICABILITY

These Terms & Conditions are applicable to all marketing and promotional material (Content) issued by GHF in any form and media, physical or digital or any other platform. This shall be considered a General Disclaimer for all the Content.

Please read the Terms and Conditions (“Terms”) provided below carefully as they will govern conduct, rights, responsibility, and obligations of a User with regard to website of Godrej Housing Finance Limited (“GHF”).

INTRODUCTION

Godrej Housing Finance Limited is a Non-Banking Financial Company - Housing Finance Company (NBFC-HFC) registered with Reserve Bank of India (RBI) engaged in the business of providing finance solutions to the eligible applicants. For acquainting prospective borrowers about its brand, its products, and offerings GHF has issued various types and kinds of material on its website.

RBI DISCLAIMER

“Godrej Housing Finance Limited” is having a valid Certificate of Registration (Without permission to accept Public Deposits) dated 26th October 2020 issued by the Reserve Bank of India under Section 29 A of the National Housing Bank Act, 1987. However, the Reserve Bank of India/National Housing Bank does not accept any responsibility or guarantee about the present position as to the financial soundness of the Company or for the correctness of any statements or representations made or opinions expressed by the Company and for repayment of deposits/discharge of liabilities by GHF.

DEFINITIONS

Content means and includes any material, information, advisory, calculators, FAQs, data or graphs, money market movements, interactive media, marketing material, news items, texts, graphics, links etc., whether belonging to GHF or to its associates, partners and other group entities, which is available either directly or through marketing or Promotional Material of GHF, displayed, hosted on the Website or on any other website or available in print / digital, audio, video or any other media anywhere.

Consumer/User refers to the person (s) who is / are viewing/exposed to the Content through any media form or manner. In the document all reference to “You”, “Us”, “Me”, “We” and “I” shall be to Consumer/User.

Website shall refer to any website on which Content is being displayed/hosted.

DECLARATION & USE OF CONTENT

• I have willingly and with my consent agreed to visit this Website.

• I / we understand that GHF uses a third party offering for Website and GHF does not represent them or assures their service or any performance standard and in case of any dispute we would have to approach them with no recourse to GHF

• I / we understand that the financial products / services provided through Website on acceptance will lead creation of financial liability towards GHF.

• I/We agree and understand that GHF may collect information provided by me/ us during visit to Website and I/ We shall not dispute this retention.

• I/We agree and declare that we shall keep all details, documents and media or any other information related to the Website as confidential and will take prior permission from GHF before sharing it with any third party

• The user acknowledges that in order to fully access the Website he would require an active internet connection which can be Wi-Fi or the Local Area Network (LAN) connection. GHF does not assume any responsibility/liability if the User is not able to go through the Website due to absence/ insufficiency of the required internet connection.

• GHF will not be concerned with any dispute between the user and the Internet Service Provider and/or any third party providing the internet connection or any other services responsible to run the website and will not be a party to same.

• The User shall be responsible in obtaining and maintaining all computer hardware and other equipment needed for access to this Website.

DECLARATION FOR MARKETING MATERIAL

• I / we understand that hosting of any residential / non-residential Project details / any other product offering or branding in Website is not endorsement of it by GHF and its responsibility of the User to ascertain its details and its selection is on risk and judgement of User.

• Content shall not be regarded as an offer, solicitation, invitation, advice or recommendation to buy/sell financial products of GHF or any of its group entities.

• Content is designed for informative purposes only. User is advised to go through Finance Documents before taking any product or service from GHF.

• Decision to offer any Product to Consumer shall be solely of GHF.

• Periodicity of any offer shall be decided by the GHF and any offer declared may be closed without further notice.

• The User acknowledges that all rates, charges and fees quoted / stated for various financial products and schemes and interest rates cited as examples of rates which may be in effect from time to time are indicative rates only and are subject to change at any time at the sole discretion of GHF and its group entities as the case may be, and applicable Indian laws. These charges, fees and rates may change depending upon the assessment made by GHF in individual cases upon receiving necessary information and documents.

• You are advised to verify any information / details regarding any project or site including RERA details from the official sources.

• GHF shall be liable and responsible only for the Content which it has issued in its name and in event, the logo, branding name or any other determinative or identifier related to GHF is used by any other entity, with or without GHF permission, for any purpose including for offering any loan through any partnership or otherwise, the Consumer is advised to review the veracity of claim before making any decision. No liability and responsibility shall accrue to GHF.

• Any Content which conflicts with any provision of law or regulation shall be considered to be null and void ab initio

• Adjectives are to be understood in a broader term and not literally. Easy to understand language has been used for delivery of messages and difficult / industry parlance has been avoided. In case of doubt, please contact branch or contact centre

INTELLECTUAL PROPERTY

The Content belongs to GHF and cannot be used by Consumer in any manner without prior express written permission of GHF. Hosting of Content on a public forum does not dilute the ownership of GHF.

NO REPRESENTATION OR WARRANTY 

No information sent to any User through the Content shall constitute any representation, warranty by GHF regarding creditworthiness, financial performance or prospects, solvency, of any User or any other legal entity.

GHF may at any time update, remove, replace, edit, alter any information in whole or in part forming part of Content & shall not be held responsible for any matters arising out of said.

In the event, the Website contains links to other Websites of affiliate or group company of GHF, the content, products, services offered on such linked websites, or any quality of the products/services are not endorsed, verified, or monitored by GHF.

DAMAGES & LIMITATION OF LIABILITY

In no event shall GHF, its Directors, employees or its affiliates be liable for any direct, indirect punitive, incidental, special, consequential damages of any nature whatsoever arising or connected with use or performance of Website including but not limited to any loss, damage, expense arising from any defect, error, omission, interruption, fault, mistake or inaccuracy.

AMENDMENT

GHF reserves the right to change the information provided on or via Content, at any time and without notice. GHF shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this Content.

GOVERNING LAW

The Website and terms and conditions shall be governed by and construed in accordance with applicable laws of India. All disputes arising out of or in connection with these terms and conditions shall be submitted to exclusive jurisdiction of Courts of Mumbai.

Please read the Terms and Conditions provided below carefully as they will govern the “Instant Sanction” & “Digital Journey” which an User will have with Godrej Housing Finance Limited (“GHF”)

DEFINITIONS

Acceptance is acceptance to any type of terms & conditions will be usage of the Digital Sanction. For application form and sanction letter or offering of any kind which is made to the User by the Company through any of the mode (a) OTP, (b) email acceptance, (c)e-sign or (d) any other mode introduced by company.

Co-Applicant is an applicant whose name comes post Main Applicant in the order of applicants. However, the order of name does not impact either the liability or responsibility of the User. A co-applicant will act as an agent of main applicant. There may be multiple co-applicants. Main applicant and co-applicants are together referred to as applicants.

Content means and includes any material, information, advisory, calculators, FAQs, data, or graphs, money market movements, interactive media, marketing material, news items, texts, graphics, links etc, whether or not belonging to GHF, which is available hosted, displayed either directly or through a link or pathway in Website.

Digital Journey is a process hosted on digital media,which may or may not have support of (a) in-person GHF employee /representative, (b) tele-support by GHF employee / representative or (c)co-browsing chat bot, through which GHF allows User to participate inits Risk Qualification Process wherein he may be offered to opt for different loan products / other products by GHF subject to User qualifying to the internal policies of GHF. In the event, User qualifies, a Sanction Letter shall be shared with them, however, acceptance of Sanction Letter is the sole decision of User.

Digital Sanction: Digital Journey together with Instant Sanction is referred to as Digital Sanction.

E-Sign is an IT enabled facility provided with the help of independent Telecom Companies which is one of the facilities used bythe User to give their acceptance to the Company.

Godrej Housing Finance Limited is a Housing Finance Company registered with Reserve Bank of India as a Non-Banking Finance Company – Housing Finance Company (NBFC-HFC). It may be referred to as either GHF or Company interchangeably.

Instant Sanction is a process which may or may not have support of (a) in-person GHF employee / representative, (b) tele-supportby GHF employee / representative or (c) co-browsing chat bot, wherein GHF will convey a to the User sanctioned amount which will be anin-principle non-binding sanction on either party basis the limited information shared by the customer and qualify him to participate further in Digital Journey / normal loan process leading to full appraisal of his credit eligibility.

Main Applicant is the applicant whose name comes first in the order of applicants. However, the order of name does not impact either the liability or responsibility of the User. A main applicant will act as an agent of co-applicant. Main applicant and co-applicants are together referred to as applicants.

OTP or One Time Password is a SMS based confirmation facility provided with the help of independent Telecom Companies whichis one of the facilities used by the User to give their acceptance to the Company.

Risk Qualification Process is the internal credit process of the company which is proprietary to the Company which is to be decided solely by the company.

Sanction Letter is a document containing terms and conditions specific to the grant of loan amount to the User.

User refers to the person (s) who is / are submitting their personal information on own consent with GHF for the purpose of participating in Instant Sanction & Digital Journey and who shall be bound by the Terms and Conditions mentioned herein. The applicants working either individually or together for going through Instant Sanction or Digital Journey will be referred collectively as User. In the document all reference to “You”, “Us”, “Me”, “We” and “I” shall be to User.

INTRODUCTION

This is a binding arrangement between you, the user, and GHF, establishing the terms and conditions under which the Digital Sanction may be undertaken by the User. By accessing, through any means and media this Digital Sanction, you agree to be bound irrevocably by these terms and conditions. In the event of any conflict between the terms and conditions of specific products or services and terms and conditions of Digital Sanction, the conditions specific to such products or services shall prevail.

USER DECLARATION

I declare that I having willingly and with my consent agreed to be part of the “Digital Experience” and that I will share all the particulars and information as is required in this Digital Experience in truthful,accurate and complete manner and understand that they shall form the basis of any decision of the Company to consider me for grant of any loan / credit facility / other offering which GHF may decide to grant me.

I/We expressly authorise GHF or any of its group entities / authorised agents & representatives to carry out the all requisite checks by such processes as may be permissible under law for considering my application for loan including but not limited to

• KYC checks and / or KYC processes such as Video KYC, Aadhar offline verification or any other approved KYC mechanism,

• Obtaining credit history from Credit Information Companies,

• Obtaining / conducting credit verification checks,

• Accessing my Bank records,

• Verifying my income and expenses

• Verifying my contact details

• Employment verification,

• Accessing and procuring data from databases maintained by statutory or other authorities constituted by law

• Authentication / verification of documents submitted by me or which comes into possession of company during Risk Qualification Processor

• Any other details submitted during the journey, and

• Any other check which the GHF may deem fit and necessary

I /we understand that hosting of any Content/residential/non-residential project details/any other product offering or branding on Website is not endorsement of it by GHF and its responsibility of the User to ascertain its details and its selection is on risk and judgement of User.

I / we understand that we may have to use any third party offering during this Digital Sanction process and GHF does not represent them or assures their service or any performance standard and in case of any dispute we would have to approach them with no recourse to GHF.

I / we understand that the financial products / services provided through Digital Sanction on acceptance will lead creation of financial liability towards GHF.

I/We agree and understand that GHF reserves its right to retain the documents / information provided by me/ us even in case I / we do not qualify under the Risk Qualification Process and I/ We shall not dispute this retention.

I/We agree and declare that we shall keep all details, documents and media or any other information related to the Digital Sanction processas confidential and will take prior permission from GHF before sharing it with any third party.

The user acknowledges that in order to fully access the Digital Sanction he would require an active internet connection which can be Wi-Fi or the Local Area Network (LAN) connection. GHF does not assume any responsibility/liability if the User is not able to go through the Digital Sanction due to absence/ insufficiency of the required internet connection.

GHF will not be concerned with any dispute between the user and the Internet Service Provider and/or any third party providing the internet connection or any other services responsible to run the website and will not be a party to same.

The User acknowledges that all rates, charges and fees quoted / stated for various financial products and schemes and interest rates cited as examples of rates which may be in effect from time to time are indicative rates only and are subject to change at any time at the sole discretion of GHF and its group entities as the case may be, and applicable Indian laws. These charges, fees and rates may change depending upon the assessment made by GHF in individual cases upon receiving necessary information and documents.

The user shall be responsible in obtaining and maintaining all computer hardware and other equipment needed for access to and use this Digital Sanction.

I / We agree that the Digital Sanction shall be governed by the rules, guidelines, directives etc. issued by the Reserve Bank of India (RBI) or National Housing Bank (NHB) or any other competent authority.

USE OF INFORMATION AND MATERIALS

You are advised to exercise due caution and/or seek independent advice before availing any facility or entering into any financial obligation based on the Content you will come across in Digital Sanction. The Content which you will receive in Digital Sanction or other terms are provided on an “as is”, “as available” basis and are protected by copyright. You cannot distribute the Content to others without the express written consent of GHF. You cannot copy, download, publish, distribute or reproduce any of the Content which you will receive in Digital Sanction in any form without prior permission of GHF.

The Content which you will receive in Digital Sanction should not be regarded as an offer, solicitation, invitation, advice or recommendation to buy or sell investments, securities or any other instrument or financial products / schemes of GHF, or any of its group entities. Use of the products or services described in Digital Sanction may not be permitted in some countries and if in doubt, you should check with your local regulator or authority before requesting further information on such products/ services. Products and Services are available only at the discretion of GHF and its group entities, subject to the individual contractual terms and conditions of products and services on which they are offered and such products and services may be withdrawn or amended at any time without notice. The full range of products or services may not be available in all locations.

The user acknowledges and declares that Third parties assistance, by both User and GHF, may be required for using the Digital Sanction and GHF does not provide any assurance or warranty for the standard or continuance of their service.

NO REPRESENTATION OR WARRANTY

No information sent to any user through this Digital Sanction shall constitute any representation or warranty by GHF regarding the credit-worthiness, financial performance or prospects, solvency, or viability of any company or other legal entity or the business carried on by such entity.

All information in this website is being provided under the condition and understanding that the same is not being interpreted or relied on as legal, accounting, tax, financial, investment or other professional advice, or as advice on specific facts or matters. GHF may at any time (without being obliged to do so) update, edit, alter and or remove any information in whole or in part that may be available on this Digital Sanction process and shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability. Nothing contained herein is to be construed as a recommendation to use any product or process, and GHF makes no representation or warranty, express or implied that, the use thereof will not infringe any patent, or otherwise. The User is expected to keep abreast of any changes made in this website and the information available on it on a regular basis and GHF and its group entities undertake no responsibility about advising the user/clients about any such changes.

GHF makes no warranties as to the confidentiality or security of the information or messages whether personal or otherwise received through Digital Sanction unless otherwise specified expressly and bound through applicable law.

Though GHF will endeavour to ensure that information contained on this Digital Sanction Process is obtained from sources which, it considers, are reliable, GHF and its subsidiaries do not warrant such information’s completeness or accuracy.

Though reasonable efforts are maintained by GHF to ensure that Digital Sanction process is free from all viruses no representation is being made that it is free from all defects and User is accessing it at his own risk.

LIMITATION OF LIABILITY

GHF, its directors and employees accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of this Digital Sanction process, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy, its Contents or associated services, or due to any inaccessibility of this Digital Sanction process or any part thereof or any contents or associated services even if the Users are advised of the possibility of such damages, losses or expenses.

ACCEPTANCE

As part of Digital Sanction Process the user may be asked to sign the documents such as Application form, Sanction letter etc with the aid of OTP, E-sign facility, email acceptance or any other which will lead to acceptance of the terms and is equal to the acceptance of documents in written form. Users may be asked to input their aadhar number for e-sign and share OTP for e-sign. The company does not store the AADHAR number or OTP. A copy of the signed document will be shared with the User for his record.

INTELLECTUAL PROPERTY RIGHTS

All rights relating to this Digital Sanction process as well as its functionalities are the exclusive property of Godrej Housing Finance Limited (particularly including but not limited to copyrights, trademarks, source code, patents as well as any other intellectual property right). All the information provided on or via this Digital Sanction process (including all texts, graphics, design or logos) shall be the intellectual property of GHF and/ or its group entities. You agree not to copy, forward, download or share content without obtaining the necessary rights or permissions to do so. You also agree not to abuse the use of this Digital Sanction Process.

In the event any content on the Digital Sanction process or any intellectual property of GHF are copied / used by the user for any profit or non-profit venture then the User shall be liable to pay for damages as set out by GHF.

LINKED WEBSITES

This Digital Sanction Process may contain links to other websites of affiliate companies or group entities of GHF. This Digital Sanction Process may also contains links to external websites, having further linked websites, controlled or offered by third parties (Non-Affiliates of GHF), in order to help you find relevant websites, services and/or products which may be of interest to you, quickly and easily. The contents displayed or products / services offered on such linked websites or any quality of the products/ services are not endorsed, verified or monitored by GHF. GHF is also not responsible for the owners or operators of such external links or websites or for any products or services they supply or for the contents of their websites and do not give or enter into any conditions, warranties, express or implied; or other terms or representations in relation to any of these or accept any liability in relation to any of these (including any liability arising out of any claim that the content of any external websites to which this website includes a link infringes the intellectual property rights of any third party).

RBI DISCLAIMER

“Godrej Housing Finance Limited (“GHF”) is having a valid Certificate of Registration (Without Permission to accept Public Deposits) dated …………… issued by the Reserve Bank of India under Section 29A of the National Housing Bank Act, 1987. However, the Reserve Bank of India/ National Housing Bank does not accept any responsibility or guarantee about the present position as to the financial soundness of the company or for the correctness of any of the statements or representations made or opinions expressed by the company and for repayment of deposits / discharge of the liabilities by GHF”.

GOVERNING LAW

This website and the terms and conditions shall be governed by and construed in accordance with all applicable laws of India, unless stated otherwise. All disputes arising out of or in connection with these terms and conditions or use of this website shall be submitted to the exclusive jurisdiction of the courts of Mumbai. The Laws of India shall apply.

LEGAL PROCEEDINGS

You confirm that you have/had no insolvency proceedings against you nor have you ever been adjudicated insolvent by any court or other authority.

AMENDMENTS

GHF reserves the right to change the information provided on or via this Digital Sanction Process, including these terms and conditions or to charge for its services, at any time and without notice. It is recommended that you periodically review the information provided on or via this Digital Sanction Process, including these terms and conditions, periodically for changes. GHF shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this website.

SUSPENSION AND CANCELLATION

GHF can at any time, without the need to give a reason, notice or compensation, suspend your ability to use this Digital Sanction process. The suspension or cancellation of the licence to use this Digital Sanction process will mean that you will no longer have any access to your data, without you having any recourse against GHF or any of its subsidiaries or its affiliates.

ACCURACY AND CORRECTNESS OF INFORMATION

You confirm that any information provided by you or any details shared for the Digital Sanction process are correct and you undertake to pass on any modifications to GHF. You shall indemnify and hold GHF harmless against any loss, damage or costs suffered / incurred by GHF as a result erroneous information supplied by you or your authorized Users. Specifically, you are responsible for the confidentiality of any codes and passwords allowing you to use this Digital Sanction process, and access to your information as well as this use and this access by any third party, whether or not they are authorised by you.

COMMUNICATION

You agree that GHF or its group entities or their employees or agents may share all information and details as provided by you in your application in relation to your existing loans and/ or repayment history to any third party including but not limited to its group companies, service providers, banks, financial institutions, credit bureaus, telecommunication companies, statutory bodies etc. for customer verification, personalisation of products and services, credit rating, data enrichment, marketing or promotion of the products or services of Godrej Housing Finance Limited or its group entities or of any other service provider.

You agree that you consent to receiving any other information through telephone / e-mail / SMS / WhatsApp or any other electronic / digital medium for marketing purposes from any GHF / its group entities or other service provider even though your name appears in the National Customer Preference Registry (Do Not Disturb Registry). You expressly agree that any such calls/SMS/e-mails/WhatsApp messages or electronic/ digital messages will not cause any inconvenience to you or your family members.

You expressly and irrevocably consent that for any claim against the service providers, GHF or its group entities shall not be liable and your claim on this account shall be against the service providers and/or tele-callers. You agree to the use of WhatsApp or other electronic/ digital media for communication or sharing of information or documents or for sending notices, agree to abide by the terms and conditions of such applications and agree to the risks associated with such applications or sharing of information or issuance of notices through them. Further, you agree that any acceptance of terms & conditions by you through / e-mail/ SMS/WhatsApp or any other electronic/ digital medium will be binding on you.

An amount of INR 10,000/- will be applied towards IMD Fees (non-refundable) from the Processing Fees paid.

1. For Semi-fixed pre-payment charges to be levied as per prevailing rate at time of closing
2. Refund of Fee: No refund of fee shall be allowed in any case at any point of time
3. Please note : In addition to the above fee and charges, GST, any cess & other taxes, levies etc. prescribed by the Government of India or respective state will also be charged. Further the above fee and charges are subject to change and will be at the sole discretion of GHF.
4. The Company has adopted an interest rate model based on cost of funds, cost of operations, various risks associated with the loan & security etc. An additional spread, based on the overall risk perceived, is factored in the pricing, which is function of income, credit history, credit information, profile of the borrower, internal assessment of the Company etc. Accordingly, the applicable rate of interest may be different for different customers’ loan exposures.

Godrej Housing Finance Limited has the following Prime lending Rates:

Annual Percentage Rate (APR):

For details – kindly refer Terms & Conditions

* TAT to be calculated from the date when complete information with respect to service respect has been provided

List of Documents considered valid for verifying identity and proof of address of prospective customers

Any customer having a grievance/ complaint/ feedback with respect to the product and services offered by Godrej Housing Finance Limited (“GHFL” or “the Company”) may write to the Company’s Customer Service Department in following manner:

How a complaint should be made

For proper resolution, the customer is requested to provide necessary loan details i.e. Loan Account Number, Details of Feedback/ Suggestion/ Complaint and valid Contact Information including phone no. & e-mail ID while lodging communicating with the Company.

Whom to approach for redressal

Customers are requested to first raise their concerns through any of channels mentioned above. In case no response is received, or you have not received a satisfactory response for your grievance within 7 days, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:

When to expect a reply The Company shall endeavor to address/respond to all queries/grievances within reasonable time and keep the customer in informed about the status of their complaints. Each customer query/ complaint being unique in nature, may take up to 4 weeks for complete resolution after investigation.

Whom to approach for Escalation

In case your grievance is not addressed within 28 working days of registering with us, you may approach the National Housing Bank at the address given below:

Click here to view form in Marathi, Hindi, Kannada, Telugu, Tamil, Gujarati

Most important terms and conditions of the loan agreed between __________________________________________________(hereinafter referred to as “the Borrower”) and Godrej Housing Finance Limited (“the Company” or “GHF”) having registered office at Godrej One, Pirojshanagar, Eastern Express Highway,Vikhroli (East), Mumbai, Maharashtra- 400079 are as under:

LOAN DETAILS

DETAILS OF RATE OF INTEREST

OTHER TERMS RELATED TO LOAN FACILITY

INSURANCE OF THE PROPERTY AND THE BORROWER

NOTICE/ COMMUNICATION RELATING TO RATE OF INTEREST, FEE AND CHARGES

SECURITY/ COLLATERAL FOR THE LOAN

CONDITIONS FOR THE DISBURSMENT OF LOAN

PROCEDURE OF RECOVERY OF OVERDUES ARE AS FOLLOWS

CUSTOMER SERVICES

CUSTOMER GRIEVANCE MECHANISM

Important Points to Note :

For accurate and timely resolution, customers are requested to provide all the necessary details like the Customer Relationship Number (CRN), Loan Account Number (LAN), details of the feedback, suggestions, complaint and valid contact Information including phone number & e-mail ID while first contacting with the Company.

DECLARATION/UNDERTAKING BY THE BORROWER

Background

Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, is required to comply with the ‘Guidelines on Fair Practices Code’ issued by the Reserve Bank of India (“RBI”) under Chapter XIII of Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 issued on 17th February 2021.

Accordingly, it is proposed to adopt Fair Practice Code with the approval of the Board.

Objectives

a)To promote good and fair practices by setting minimum standards in dealing with customers;

b)To increase transparency so that the customer can have a better understanding of what he/she can reasonably expect of the services;

c)To promote a fair and cordial relationship between customer and the Company;

Review of the Code

a)The Code shall be reviewed Annually by the Board of Directors.

b)Board of Directors can at any time modify or amend, either the whole or any part of Policy

c)Compliance with Fair Practice Code shall be provided on Annual basis to the Board of Directors,

d)Half-Yearly report on grievance redressal mechanism be put to the Board of Directors

Application of the Code

This Code shall apply to all the products and services, whether they are provided by the GHFL, its subsidiaries or Digital Lending Platforms (self-owned and/or under an outsourcing arrangement) across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.

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.

b)Company shall transparently disclose to the borrower all information about fees/ charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned/ disbursed, pre-payment options and charges, if any, penal interest/ penalty for delayed repayment, if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest reset clause and any other matter which affects the interest of the borrower. Company shall disclose ‘all in cost’ inclusive of all charges involved in processing/ sanctioning of loan application in a transparent manner.

c)All such charges/ fees which are levied on the Borrower are non-discriminatory,

d)Loan application forms include necessary information which affects the interest of the borrower which enable a meaningful comparison with the terms and conditions offered by other Finance Companies and aid borrower in making an informed decision.

e)The Company has a system of giving acknowledgement for receipt of all loan applications.

Loan appraisal, terms/ conditions and communication of rejection of loan application

a)Company endeavours to collect all particulars required for processing the loan application shall be collected by the Company at the time of application. However, in case we need any additional information, we shall endeavour to inform the customer should be told immediately that he would be contacted again.

b)Company shall convey in writing to the borrower in the vernacular language or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges, penal interest (if any) and keep the written acceptance of these terms and conditions by the borrower on its record.

c)Company shall mention the penal interest charged for late repayment in bold in the loan agreement.

d)Company shall furnish a copy of the loan agreement along with a copy of each of the enclosures quoted in the loan agreement to every borrower at the time of disbursement of loans through its Customer Portal which can be accessed by the Borrower.

e)If Company cannot provide the loan to the customer, it shall communicate in writing the reason(s) for rejection.

Disbursement of loans including changes in terms and conditions

a)Disbursement shall be made in accordance with the disbursement schedule / Disbursement terms advised to the Borrower as per Finance Documents.

b)The Company shall give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, penal interest (if any), service charges, prepayment charges, other applicable fee/ charges etc. by the mechanisms informed in MITC or Loan Agreement.

c)Company will ensure that changes in interest rates and charges are effected only prospectively.

d)If such change is to the disadvantage of the customer, he/ she may within 60 days and without notice close his/ her account or switch it without having to pay any extra charges or interest.

e)Decision to recall/ accelerate payment or performance under the agreement or seeking additional securities, will be in consonance with the loan agreement.

f)Company 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 Company 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 Company are entitled to retain the securities till the relevant claim is settled/ paid.

Loans sourced over Digital Lending Platforms (DLP)

Company does not intend to extend loans through Digital Lending Platforms. However, in event a partnership is undertaken by the Company where its loans are extended through DLP either to source borrowers and/ or to recover dues, Company shall follow the following instructions:

Responsibility of Board of Directors

a)The Board of Directors of Company have laid down a Grievance Redressal mechanism within the organization to resolve complaints and grievances which is enunciated in the Grievance Redressal Policy for the Organization.

b)This mechanism ensures that all disputes arising out of the decisions of lending institution’s functionaries are heard and disposed of at least at the next higher level.

c)The Board of Directors of shall conduct an annual review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.

Complaints and Grievance Redressal

Guidelines for complaint and grievance redressal are contained in Grievance Redressal Policy of the Company.

Mode of Communication

Language and mode of communicating Fair Practice Code, which shall be in the vernacular language or a language as understood by the borrower, shall be put up on Companies website, for the information of various stakeholders.

Interest charged by Company

a)The Board of Company has adopted an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium which helps in determining the rate of interest to be charged for loans and advances.

b)The rate of interest and the approach for gradation of risk and rationale for charging different rate of interest to different categories of borrowers is disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.

c)The Board of the GHFL has laid down policy for penal interest/ charges under its Interest Rate and Charges Policy. The rate of interest and penal interest (if any) is annualised rate so that the borrower is aware of the exact rates that would be charged to the account.

d)The rates of interest and the approach for gradation of risks, and penal interest (if any) shall also be made available on the website of the companies. The information published in the website published shall be updated whenever there is a change in the rates of interest.

e)Repayment Schedule which is shared with Borrowers clearly indicates the bifurcation between interest and principal in repayment schedule of Company.

f)Company sets its Interest Rate / Charges as per principles enshrined in Interest Rate & Charges Policy,

g)Grievance Redressal Committee, inter alia, monitors the process and the operations to ensure adequate transparency in communications with the borrowers.

Advertising, Marketing and Sales

Company shall:

a)Ensure that all advertising and promotional material is clear, and factual.

b)In any advertising in any media and promotional literature that draws attention to a service or product and includes a reference to an interest rate, Company shall also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request or on the website.

c)Company shall provide information on interest rates, common fees and charges (including penal interest, if any) through putting up notices in their branches; through telephone or help-lines; on the company’s website; through designated staff/ help desk; or providing service guide/ tariff schedule.

d)If Company avail of the services of third parties for providing support services, Company shall require that such third parties handle customer’s personal information (if any available to such third parties) with the same degree of confidentiality and security as the Company would.

e)Company may, from time to time, communicate to customers various features of their products availed by them. Information about their other products or promotional offers in respect of products/ services, may be conveyed to customers only if he/ she has given his/ her consent to receive such information/ service either by mail or by registering for the same on the website or on customer service number.

f)Company has prescribed a code of conduct for their Direct Selling Agencies (DSAs) whose services are availed to market products/ services which amongst other matters require them to identify themselves when they approach the customer for selling products personally or through phone.

g)Company has adopted the Model Code of Conducts for Direct Selling Agents (DSAs)/ Direct Marketing Agents (DMAs) as part of outsourcing policy with the approval of our Board,

h)In the event of receipt of any complaint from the customer that Company’s representative/ courier or DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.

Guarantors

When a person is considering being a guarantor to a loan, he/ she is being informed about following:

a)his/ her liability as guarantor;

b)the amount of liability he/ she will be committing him/herself to the company;

c)circumstances in which HFC will call on him/her to pay up his/ her liability;

d)whether HFC has recourse to his/her other monies in the company if he/ she fail to pay up as a guarantor;

e)whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and

f)time and circumstances in which his/ her liabilities as a guarantor will be discharged as also the manner in which HFC will notify him/ her about this.

g)In case the guarantor refuses to comply with the demand made by the creditor/ lender, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter.

Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower to whom he/ she stands as a guarantor.

Privacy and Confidentiality

a)All personal information of customers, both present and past, shall be treated as private and confidential and shall be guided by the following principles and policies.

b)Company shall not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other companies/ entities in their group, other than in the following exceptional cases:

c)If Company are asked to give a reference about customers, they shall obtain his/ her written permission before giving it.

d)The customer shall be informed the extent of his/ her rights under the existing legal framework for accessing the personal records that GHFL holds about him/ her, through the Privacy Policy which is available on Company’s website,

e)Company shall not use customer’s personal information for marketing purposes by anyone including Company, unless the customer specifically authorizes them to do so.

Guidelines for pre-payment of loans

a)Company shall not charge pre-payment levy or penalty on pre-closure of housing loans under the following situations:

a. Where the housing loan is on floating interest rate basis and pre-closed from any source.

b. Where the housing loan is on fixed interest rate basis and the loan is pre-closed by the borrower out of their own sources.

b)The expression “own sources” for the purpose means any source other than by borrowing from a bank/ HFC/ NBFC and/or a financial institution.

c)Company shall not impose foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).

d)All dual/ special rate (combination of fixed and floating) housing loans will attract the pre-closure norms applicable to fixed/ floating rate depending on whether atthe time of pre-closure, the loan is on fixed or floating rate. In case of a dual/ special rate housing loans, the pre-closure norm for floating rate will apply once the loan has been converted into floating rate loan, after the expiry of the fixed interest rate period. This applied to all such dual/ special rate housing loans being foreclosed hereafter. It is also clarified that a fixed rate loan is one where the rate is fixed for entire duration of the loan.

General

a)Company does not extend any loan to any micro-finance borrower.

b)Company does not interfere 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).

c)In case of receipt of request from the borrower for transfer of borrower’s account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.

d)Whenever loans are given, Company shall explain to the customer the repayment process by way of amount, tenure and periodicity of repayment through Repayment Schedule.

e)Company has formulated a Collection Policy which contains guidelines with respect to repayment process and for engaging Recovery Agents.

f)To facilitate quick and good understanding of the major terms and conditions of housing loan agreed upon between Company and the individual borrower, Company shall obtain a document containing the most important terms and conditions (MITC) of such loan in all cases as per format provided in Annex I. The document will be in addition to the existing loan and security documents being obtained by the Company.

g)Company has prepared MITC in language understandable by the borrower and a copy duly executed between the Company and the borrower is uploaded on the Customer Portal.

h)Display of various key aspect such as service charges, interest rates, Penal interest (if any), services offered, product information, time norms for various transactions and grievance redressal mechanism, etc. is required to promote transparency in the operations of Company. Company shall follow the instructions on “Notice Board”, “Booklets/ Brochures”, “Website”, “Other Modes of Display” and on “Other Issues” as per the prescribed guidelines.

i)HFC shall display about their products and services in English on its website.

j)Company does not discriminate on grounds of sex, caste and religion in the matter of lending. Further, Company shall also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude Company from instituting or participating in schemes framed for different sections of the society.

k)To publicise the Code, Company shall:

a. provide existing and new customers with a copy of the Code;

b. make this Code available on request either over the counter or by electronic communication or mail;

c. make available this Code at every branch and on their website; and

d. ensure that their staff are trained to provide relevant information about the Code and to put the Code into practice.

Click here to view in Marathi, Hindi, Kannada, Telugu, Tamil, Gujarati

• Annual Percentage Rate (APR):
  
  

  Particulars	Insurance Funded		Insurance Self Funded		Unsecured
  	HL	LAP	HL	LAP
  Annual Percentage Rate	6.85%	8.06%	6.95%	8.16%	7.01%

  
  For details – kindly refer Terms & Conditions

 

• Asset Classification Concepts

• Pune Branch
  • English
  • Marathi
• Bengaluru Branch
  • English
  • Kannada

• 2022 - 23
  • March 31, 2023
  • December 31, 2022
  • September 30, 2022
  • June 30, 2022
• 2021 - 22
  • March 31, 2022
  • December 31, 2021
  • September 30, 2021
  • June 30, 2021
• 2020 - 21
  • March 31, 2021
  • December 31, 2020