This Code has been drawn up to:

• Promote good, fair, transparent and trustworthy practices by setting minimum standards in dealings with customers and enable customer to take an informed decision about the financial facilities and services offered by Minerva Capital Private Limited.
• Provide to the customers’ effective overview of practices followed by the Company in respect of financial facilities and services offered by Minerva Capital Private Limited to its Customers.

The FPC will be applicable to the following broad areas:

• Loan applications and processing of Loans
• Loan appraisal and terms and conditions
• Disbursement of loans including changes, if any, in terms and condition.
• Post disbursement supervision/monitoring
• Responsibility of Board of Directors
• Other General Provisions

Loan Application and Processing of Loans

• All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
• Loan application forms shall include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFC’s can be made and informed decision can be taken by the borrower.
• Application forms issued by the Company shall include necessary information which affects the interests of the borrower and shall indicate the documents required to be executed /submitted by the borrower.
• An acknowledgment for receipt of duly completed loan application forms will be given to the customer in all cases. As a matter of policy and customer service, loan applications are sanctioned / rejected immediately. Disbursement of the loan and acceptance of security will be carried out simultaneously.
• The application form will clearly state the information to be provided by the customer to fulfill the KYC norms and to comply with legal and regulatory requirements.
• If any additional documents/information are required from the Customer, same shall be communicated to the Customer immediately.

Loan appraisal and Terms and Conditions:

• The Company shall convey in writing to the borrower in the vernacular language as understood by the borrower by means of a sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record.
• The Company shall disclose all the relevant information regarding the loan/product such as eligible loan amount, Interest rate, charges, penal/overdue interest and method of interest calculation, etc. of the loan to enable the customer to take an informed decision.
• Penal interest if any charged for late repayment shall be mentioned in bold in the loan agreement.
• The Company shall ensure that a Loan Sanction Letter, Loan agreement and other enclosures quoted in the loan agreement are given to the customer containing all the terms and conditions governing the loan facility in the local language or other language understood by the customer. The Loan Sanction Letter will also mention the loan amount, number, interest rate charges, loan processing fee, if any, etc. The Loan Sanction Letter will bear the signature of the authorized official of the Company.

Disbursement of loans including changes if any, in terms and conditions:

• There will be notices served 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, service charges, prepayment charges, etc.
• Changes in interest rates and charges shall be effected only prospectively which shall be mentioned in the loan agreement.
• Decision to recall/ accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
• The Company shall release all the securities, on getting the repayment of its full dues or on realization of the outstanding amount of loan subject to any legitimate right or lien to any other claim the Company may have against its borrowers. It has such rights to set off and if is to be exercised, then the borrower shall be given a notice about the same with full particulars about the remaining claims and conditions under which the Company is entitled to retain the securities till the relevant claim is settled/paid.

Post Disbursement Supervision

• The decision, if any, of the Company to recall/accelerate payment or performance of loan shall be in accordance with the terms and conditions of the Loan Agreement.
• The Company shall give reasonable time to the borrowers before recall the loan or asking for accelerating the payment or performance subject to the terms and conditions contained in the Loan Agreement and other related documents.
• The collaterals lying with the Company may be released on receipt of full and final repayment of loans subject of course to any legitimate right or lien and set off for any other claim that the Company might have against the borrowers. However, in cases where the borrower has availed facility allowing him to borrow/draw monies within the overall amount sanctioned as and when needed by him, the collateral may be retained by the Company for operational convenience and to protect its interest from potential default by the borrowers.

Responsibility of Board of Directors:

• The Board of Directors of the Company shall lay down the appropriate grievance redressal mechanism within the Company which shall ensure that all disputes arising out of the decisions of lending institutions’ functionaries are heard and disposed of at least at the next higher level. The Board of Directors shall also provide for periodical review of the compliance of FPC and the functioning of the grievance redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board at regular intervals. Board shall lay out appropriate internal principles and procedures in determining interest rates and processing and other charges.

Other General Provisions

• The Company will not interfere in the affairs of the customers except for the purposes mentioned in the terms and conditions of the loan agreement.
• In the matter of recovery, the Company will not resort to any type of undue harassment viz; persistently bothering the borrowers at odd hours, use of muscular power for recovery of loans etc. Company shall train all staff to deal with customers in a proper manner.
• The Company shall state the repossession clause in the loan agreement with the borrower which shall contain provisions regarding notice period before taking possession, circumstances under which the notice period can be waived, procedure for taking possession of the security , provision regarding final chance to be given to the borrower for repayment of the loan before auction/sale of security, procedure for giving repossession to the borrower and the procedure for sale/auction of the property.
• The Company shall treat all personal information of its borrowers as private and confidential and will not reveal any information to any other entity other than for regulatory/statutory matters.
• In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise of the Company shall be conveyed within 21 days from the date of receipt of request.
• As a measure of customer protection and also in order to bring in uniformity with regard to prepayment of various loans by borrowers of banks and NBFCs, the Company shall not charge foreclosure charges/ pre-payment penalties on all floating rate terms loans if any sanctioned to individual borrowers.

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

The Board of Directors shall adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.

Unless authorized by the borrower, the Company will treat all his personal information as private and confidential.
The Company may not reveal transaction details of the borrowers to any other persons except under following circumstances:

• If the Company is required to provide the information to any statutory or regulatory body or bodies;
• If arising out of a duty to the public to reveal the information;
• If it is in the interest of the borrowers to provide such information (e.g. fraud prevention);
• If the borrower has authorized the Company to provide such information to its group / associate /entities or companies or any such person/ entity as specifically agreed upon;

The various commitments outlined and made by the Company shall be applicable under the normal operating environment. In the event of any Force Majeure circumstances, the Company may not be able to fulfill the objectives under the FPC to the entire satisfaction of the borrowers, the stakeholders and the public in general.