Grievance Redressal Mechanism

Chhotaria Securities Private Limited ("the Company" or "Chhotaria") is a Non-Banking Financial Company (NBFC) engaged in the business of providing loans to its borrowers through its mobile application/website, and aims to impart good customer service and enhance the level of customer satisfaction. The Company believes that customer satisfaction is key to business growth as well as to ensuring a long-lasting relationship with the customer.

This Grievance Redressal Mechanism aims at ensuring prompt redressal of Borrower complaints and grievances raised through the Company's app or website, or directly on the e-mail or contact details provided in the Key Fact Statement (KFS). It also deals with issues relating to services provided by any outsourced agency/agencies engaged by the Company.

Chhotaria's Grievance Redressal Mechanism is formulated in line with the Reserve Bank of India's (RBI) guidelines on the Fair Practices Code. This Mechanism outlines the framework for addressing customer grievances.

The Grievance Redressal Mechanism follows the under-noted principles:

• Borrowers shall be treated fairly at all times.
• All complaints, requests and queries received from Borrowers are responded to with courtesy and resolved in a timely manner.
• Borrowers shall be informed of the process to escalate their complaints/grievances within the organisation and their rights to alternative remedy, if they are not fully satisfied with the Company's response to their complaints.
• All complaints are to be dealt with efficiently, expeditiously and fairly, as otherwise they can damage the Company's reputation and business.
• Employees of the Company shall work in good faith and without prejudice to the interests of Borrowers.
• The Company shall comply with all regulatory requirements and guidelines applicable to this function.

This Policy shall apply to all complaints and grievances received from Borrowers relating to the products, services and operations of Chhotaria Securities Private Limited, including those arising from services provided through digital platforms, authorised representatives, collection agencies, recovery agents and Lending Service Providers (LSPs).

The Policy shall also cover complaints relating to:

• Loan processing and disbursement;
• Interest, fees and other charges;
• Borrower service and employee conduct;
• Recovery and collection practices;
• Digital lending services;
• Data privacy and confidentiality;
• Service deficiencies; and
• Non-compliance with applicable RBI directions or the Company's Fair Practices Code.

Borrowers can raise/register complaint(s) containing the nature of the grievance by the Company or any outsourced agency, inter alia, with regard to:

• Non-observance of directions issued by the RBI to NBFCs;
• Non-adherence to any of the provisions of the RBI's guidelines on the Fair Practices Code, issued from time to time;
• Concerns raised over the procedures of the Company.
• Concerns raised over the loan agreement.

Anonymous/incomplete complaints will not be addressed in terms of this Grievance Redressal Mechanism.

4.1 Channels of Raising a Complaint

A Borrower has the right to register a complaint if he/she has a genuine ground for such complaint, as indicated in above. A complaint may be lodged through the following channels:

Once a complaint is lodged using the above channels, the Borrower may also make follow-up calls at the helpline number given above. If the Borrower is not provided a resolution within a period of Seven (7) days, he/she may contact the Grievance Redressal Officer, details of which are provided below:

In case the Borrower's grievance is not resolved by the Grievance Redressal Officer in 21 days or they are not satisfied with the decision of the Grievance Redressal Officer of the Company, they may approach the Nodal Officer of the Company.

In case the borrower's grievance is still not resolved by the Nodal Officer in next Seven (7) days or they are not satisfied with the decision of the Grievance Redressal Officer of the Company, they may lodge a complaint on RBI Complaint.

4.2 Periodic Board Review

A consolidated report on customer complaints, grievance trends, turnaround time and compliance with the Fair Practices Code shall be placed before the Board at periodic intervals for review.

4.3 Information in Complaints shall have the following:

To facilitate prompt resolution, Borrowers are requested to provide the following details while lodging a complaint:

• Full Name;
• Registered Mobile Number;
• Loan/Application ID (where applicable);
• Registered Email Address;
• Brief description of the grievance;
• Relevant supporting documents, if any.

Where any information is incomplete, the Company may seek additional details from the Borrower to facilitate proper investigation of the complaint.

Complaint Lodging/Registration:

A Borrower can lodge a complaint through the channels mentioned in Clauses 4.1 and 4.2 of this Mechanism, which shall be handled as follows:

• Whenever a complaint e-mail is received through the digital channels of the Company, the sender shall receive an acknowledgement of his/her complaint within three working days.
• Whenever a complaint is received in the form of a hardcopy, i.e. through a letter etc., the same shall be recorded in an online tracker. In such cases, the Company's representative shall contact the Borrower at the earliest to ascertain the exact nature of the complaint.
• In case a Borrower raises a complaint in person at the office of the Company, the Borrower shall physically record his/her grievance at the office.
• In case of follow-up of a complaint through the telephonic channel, the Borrower shall contact the Company has an exclusive helpline number where a Borrower can discuss his/her complaint, and may further escalate the concern as per the matrix given in the Annexure - Escalation Grid.

The Customer Support Department shall always inform the Borrower about the following:

• Information pertaining to all issues/concerns raised by the Borrower;
• Explanation of the final solution provided;
• Expected timelines towards closure (where an immediate solution cannot be provided);
• Contact at defined intervals/milestones, to communicate progress on the concern and share reasons for any delay/time taken;
• Requests for further supporting documents/information (where applicable), in a clear manner, along with the reason for such requirement.

Grievances related to attitudinal aspects: Such complaints shall be handled courteously, sympathetically. Misbehaviour/rude behaviour with Borrowers shall be treated at a zero-tolerance level, and immediate action shall be taken. The Company, under no circumstances, tolerates misbehaviour of any degree by its representatives.

Grievances relating to transactions/operations: The Company shall be responsible for ensuring rectification of the entry/transaction if it falls within the Company's purview. If, upon investigation, the Company finds that the issue is due to a third party beyond the Company's control/operations, the customer support executive shall guide the Borrower and provide him/her with avenues to escalate the issue, and the Company shall take such action as may be necessary.

• All complaints/enquiries shall be resolved as soon as possible when raised.
• For complaints that must be verified and may need further investigation/support from other departments, and hence cannot be resolved immediately, the Borrower shall be informed about the expected timeline for closure. For such complaints, tickets shall be raised and assigned to the concerned departments on priority for further investigation, and the Company shall endeavour to provide resolution within 30 days.
• After due investigation, the concerned department shall promptly forward its comments to the customer support executives, and the Customer Support Team shall thereafter provide the resolution to the Borrower.
• The Customer Support Team shall make reasonable attempt(s) to reach the Borrower to provide resolution of his/her complaint.
• After resolution is provided to the Borrower, the concerned department shall update the status of the complaint as closed in the Company's system. Closed complaints remain available for re-examination at any point in time, as and when required.
• If any complaint needs additional time beyond 30 days, the Company shall inform the Borrower of the reasons for the delay in resolution and provide expected timelines for resolution of the complaint.

Note: The above timeframes may vary depending upon the nature and complexity of the complaint.

(Refer to the Annexure - Escalation Grid for Complaints.)

In the event of any complaint regarding Borrower data, the Borrower may, after exhausting the grievance redressal mechanisms provided by the Company, escalate the complaint to the Data Protection Board of India, established by the Central Government. The Borrower may further appeal to the Appellate Tribunal if dissatisfied with the order or direction issued by the Board.

• Complaints are to be seen in the right perspective, as they indirectly lead to continuous improvement in the working of the Company. Complaints received shall be analysed from all possible angles. The Company shall endeavour to send an acknowledgement within three working days of receipt.
• A complaint should be resolved within a maximum of 30 working days from the date of receipt.
• Some complaints may be complex in nature and may need additional time beyond 30 days. In such cases, the Company shall inform the Borrower, in the interim, of the reasons for the delay in resolution and provide expected timelines for resolution of the complaint. However, every effort shall be made to resolve the complaint within the timeframe given.

9.1 Periodical Review of Complaints

The Company shall periodically review the complaints-handling process and suggest changes, if any, required to make the Grievance Redressal Mechanism more effective and robust.

9.2 Review of the Policy

This Policy shall be reviewed, with the approval of the Board, at least once a year, or earlier if required by applicable rules and regulations. However, if the Policy requires amendment due to a change in any statutory/regulatory requirement, requisite modifications shall be carried out and implemented at the earliest, with the approval of the Director of the Company. Such amended Policy shall be placed before the Board at its immediate next meeting for an approval.

9.3 Vernacular Language

The Grievance Redressal Mechanism shall be made available in English and, wherever feasible, in the vernacular language understood by the borrower.

10.1 Public Notice and Display of Grievance Redressal Mechanism

The Company shall prominently display, at all its registered office, corporate office, branches (where business is transacted), customer service locations, digital platforms and other customer interface points, the details of its Grievance Redressal Mechanism. Such display shall include the name, designation, telephone/mobile number and e-mail address of the Grievance Redressal Officer, along with the escalation matrix available to borrowers. The public notice shall also clearly inform borrowers that if their complaint is not resolved by the Company within thirty (30) calendar days from the date of receipt, or if they remain dissatisfied with the resolution provided by the Company, they may escalate the complaint to the Reserve Bank of India through the Complaint Management System (CMS) or any other grievance redressal mechanism prescribed by the RBI from time to time. The Company shall ensure that such information is kept accurate, updated and readily accessible to all borrowers.

10.2 Website Disclosure

In accordance with the Reserve Bank of India's Fair Practices Code and other applicable regulatory directions, the Company shall host this Grievance Redressal Mechanism, the Fair Practices Code, and the contact details of the Grievance Redressal Officer on its official website and digital lending platforms. The Company shall ensure that these documents remain easily accessible to borrowers at all times and are updated promptly whenever there is any change in regulatory requirements, grievance redressal procedures, or the contact details of the concerned officials.

First Level

The borrowers can raise his grievance over the below mentioned mails:

For General: grievance@chhotariasecurities.com

All Digital Platform Apps of Chhotaria Securities Private Limited:

CreditSea
Cash247

Call:

+91 91099 57390

(Monday- Friday [Between 10am to 6pm])

Second Level

If the complaint is not resolved satisfactorily, the borrower can contact the Grievance Redressal Officer:

Third Level

If the complaint is not resolved satisfactorily, the borrower can contact the Nodal Officer: under Ombudsman Scheme for Non-Banking Financial Companies, 2018 - Appointment of the Nodal Officer/Principal Nodal Officer

Fourth Level

If the complaint is not redressed satisfactorily within 30 Calender days days across all levels of escalation mentioned above, the borrower may directly write to the Reserve Bank of India, as detailed below:

• Office-in-Charge, Department of Supervision (NBFC), Reserve Bank of India, regional office having jurisdiction over the Company.
• Complaint Management System (CMS): https://cms.rbi.org.in/
• Centralised Receipt and Processing Centre (CRPC);
  RBI CMS Portal: https://cms.rbi.org.in
  RBI Contact Centre Phone Number: 14448
  RBI Postal Address: Reserve Bank of India Centralised Receipt and Processing Centre, 4th Floor, Sector 17, Chandigarh – 160017
• Consumer Education and Protection Department (CEPD);
• Sachet Portal: https://sachet.rbi.org.in/
• Integrated Ombudsman under the Reserve Bank – Integrated Ombudsman Scheme, 2021.