Our Policies

Fair Practices Code

This Fair Practices Code of the company has been framed with a view to provide all the stakeholders, especially customers, with an effective overview of the practices followed by the Company while offering its services.

"BASNAT INDIA LIMITED" hereby furnishes Fair Practices Code has been prepared by taking into account the “Guidelines on Fair Practices Code for NBFCs” as advised by Reserve Bank of India. The Company shall also make appropriate modifications in the FPC from time to time to confirm the standards that may be prescribed by RBI. The Fair Practices Code, as adopted herein below, is in conformity with the Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circulars.

Objective

This Code has been drawn to

Adopt the best practices in dealing with customers.
Provide the customers an effective overview of the practices followed by the Company.
Enable customers to take informed decisions while dealing with the company and enable customers to have a better understanding of what they can reasonably expect from the services offered by the Company.
Promote fair, transparent and legally tenable practices.
To strive to achieve higher operating standards.
Aiming fair and cordial relationship between the customers and the Company.

The Fair Practices Code adopted by the Company covers the following areas

Application & Appraisal for loans.
Sanctioning with terms & conditions.
Disbursement of loans,
Post disbursement supervision/monitoring
Changes in terms and conditions if any.
Transparency in interest rates and other terms and conditions.
Policy on KYC, Appraisal, insurance, storage of securities, Auction etc.
Confidentiality.
Grievance redressal mechanism.

Application & Appraisal of Loans Along With Kyc Verification:

The Company shall put in place a board approved policy covering the following aspects:
Adequate process to ensure that the KYC guidelines of RBI are complied with that adequate due diligence before extending the loan.
All applications and communications with the borrower shall be either in English or in vernacular language or in a language as understood by the borrower.
Loan application forms issued by the Company shall include necessary information affecting the interests of the borrower, which will enable him to take an informed decision by comparing the terms and conditions with that of other similar NBFCs, and shall also indicate the documents required to be executed/ submitted by the borrower.
All the loan applications shall be disposed of within a period of 90 days from the date of Receipt of duly completed Loan Application Forms together with the requisite documents and subject to receipt of all documents complying with prevailing rules and regulations by the borrower.
The appraisal shall be done internally by the company.
The Company shall consider all the loan applications keeping in mind the risk-based assessment procedures adopted by it and The Company, before sanctioning the loan, would assess the ability of the borrowers to repay the loan and thereby approving the same on merit basis.
Proper appraisal procedure shall be put in place for assessing the value and purity of the jewelry accepted as collateral security.
Declaration shall be obtained from the borrower confirming ownership of gold jewelry, which shall be ascertained with reasonable level of care.
If the Company cannot provide the loan to the customer, it shall communicate in writing the reason (s) for rejection thereof.

Sanctioning & Terms & Conditions

The borrower shall be given a loan sanction letter and copy of the loan document required in English & vernacular language or a language as understood by the borrower which shall include the details of the loan such as amount sanctioned, annualized interest rate, method of application thereof and other terms and conditions stipulated.
The Interest rate fixed and penal interest that will be charged for late payment shall be mentioned clearly in the sanction letter.
Borrower shall acknowledge the sanction letter which will be part of the loan documents.

Disbursement of Loans & Changes in Terms & Conditions

The loan shall be disbursed on executing the necessary documents and completion of documentation and handing over of the security offered by the borrower. Any change in the terms and conditions shall be informed to the borrower in the vernacular or a language known to the borrower.
Changes in interest rates and charges shall be only prospective & never retrospective. A suitable condition in this regard shall be incorporated in the loan document obtained from the borrower.
The decision to recall/ accelerate payment or performance shall be as per the covenants in the loan document.

Post Disbursement Supervision/Monitoring

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 Company shall release all securities on repayment of its full dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against its borrowers. 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 the Company is entitled to retain the securities till the relevant claim is settled/ paid.

Release of Securities

The Company shall release securities on repayment of all dues including interest and charges subject to any legitimate right or General lien for any other claim that Company may have against the 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 the Company is entitled to retain the securities till the relevant claim is settled/ paid.

Rate of Interest

The Company shall frame appropriate internal policies and procedures for determining the interest rates and processing and other charges for various schemes formulated by the company. and It will be ensured that the borrowers are informed in transparent manner.
The Company shall, at all the times ensure that the interest rate and other charges, on loans are in strict adherence to internal policies of the company.
The changes in the Interest Rates and policies shall be published in the website and updated whenever there is change.
The rates of interest and the approach for gradation of risk shall also be made available on the website.
Interest rate slab are meant to encourage timely interest payment, levying of additional interest for discouraging loans from crossing the permitted and agreed period. This shall be mentioned clearly in the loan agreement.
No Pre-payment penalties/ foreclosure charges will be levied on gold loans in the normal course. In case such charges are applicable for any scheme, it will be disclosed in the sanction letter.

Storage of Securities, Insurance etc...

All branches shall have proper storage facility in either Strong Room or Safes conforming to Standards prescribed to store the jewelry in safe custody. The sets of keys to the security room/ safe room & the safe vault shall be held separately by two top management officials and the operations thereof shall be done jointly by the joint custodians. The staff shall be imparted training on a continuous basis to ensure that the guidelines covering security issues are strictly adhered.
The jewelry accepted as collateral security shall be adequately and appropriately insured.
The cost of insurance of security bear by borrower.

Auction Process

In case of non-repayment, process of recovery process shall be initiated that shall be transparent and policy driven.
Prior notice at various stages of demand and default basing on decided terms of repayment will be given/issued to borrower before the auction.
The auction process shall ensure that an arm’s length relationship in all transactions during the auction is maintained including with group companies and related entities.
The details regarding procedure for auction shall be disclosed in the loan document for availing the loan. The auction will be only through auctioneers approved by the Board and the Company shall not participate in the auction.
The auction shall be announced to the public by issuing advertisements in at least two newspapers, one in vernacular language and the other in a national daily Hindi/English newspaper.

Confidentiality

Unless authorized by the borrower, the Company will treat all personal information as private and confidential.
The Company may not reveal transaction details of the borrowers to any other persons except under following circumstances:
1. If the Company is required to provide the information as per regulatory directives to any statutory or regulatory body or bodies.
2. If arising out of a duty to the public to reveal the information.
3. If it is in the interest of the borrowers to provide such information (eg. Fraud prevention).
4. If the borrower has authorized the Company to provide such information to its group/ associates/ entities or Companies or any such person/ entity as specifically agreed upon.

Grievance Redressal Mechanism

Towards ensuring effective redressal of disputes arising out of actions or decisions of the functionaries of the Company, the following mechanism is put in place:
The complaints involving official below the Branch Manager shall be heard and disposed of by the Branch Manager. If required Area Manager shall intervene for better redressal.
Complaints against Branch Managers shall be heard and disposed of by the Area Manager.
If not satisfied with the decision of Area Manager) matter will be heard by GM(O) and if remains un-resolved the matter will be referred to Grievance Redressal officer at HO.
Customer Grievances Redressal Committee at the Company’s Head Office will be headed by CEO.
The contact details of the Grievance Redressal Officer of Reserve Bank of India shall be displayed in all the Branches for the benefit of customers. If the complaint/ dispute is not redressed within a period of one month, the customer will have the option to appeal to the Officer-in-Charge of the Regional Office of DNBS RBI as per the contact details displayed in the branch.
Proper training shall be imparted to staff on an ongoing basis with a view to improving staff behavior and customer service.
The compliance of the fair practices code shall be reviewed by the CEO on a half yearly basis and a consolidated report of such reviews shall be placed before the Board of Directors on half yearly basis.
Fraud in the functioning of the Company shall be enquired into by the appropriate authority and suitable punitive measure and necessary action as required by the law shall be taken by the appropriate disciplinary authority.

General Provisions

The Company shall refrain from interfering in the affairs of the borrower except for the purposes provided in the terms and conditions of the letter of undertaking (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
In the matter of recovery of loans, the Company shall not resort to undue harassment viz. calling the borrowers at odd hours, use of muscle power for recovery of loans etc. The staff of the Company shall be adequately trained in this regard.
The Company will call delinquent customers between 0900 hrs to 1800 hrs unless special circumstances of the borrower’s business require to call them otherwise outside the hours mentioned.
In case of receipt of request from the borrower for transfer of borrower account, the consent or otherwise – i.e., objection of the Company, if any – shall be conveyed to the borrower within 21 days from the date of receipt of any request. Such transfer shall be as per transparent contractual terms in consonance with law.

Interest Rate Policy

The Reserve Bank of India (RBI) had vide its Circular DNBS / PD / CC No. 95/ 03.05.002/ 2006-07dated May 24, 2007 advised that Boards of Non-Banking Finance Companies (NBFC's) lay out appropriate internal principles and procedures in determining interest rates, processing and other charges.

This was reiterated vide RBI's circular DNBS (PD) C.C. No. 133 / 03.10.001/ 2008-09 January 2, 2009, whereby which RBI advised the NBFCs to adopt appropriate interest rate model taking into account relevant factors and to disclose the rate of interest, gradations of risk and rationale for charging different rates of interest to different category of borrowers.

M/S Basant India Limited, hereinafter termed as “non-banking financial company”in this document adopts following policy on Interest Rate to be applied on the loans granted /to be granted during its course of business;

The policies and codes of M/S Basant India Limited should always be read in conjunction with RBI guidelines, directives, circulars and instructions. The company shall apply best industry practices so long as such practice does not conflict with or violate RBI guidelines.

The Company’s board shall fix the interest rates on gold loans based on various factors which are intrinsic and extrinsic to the company. The rates shall be decided and reviewed by the board regularly not later than a month by the board. However, in case of urgency review and changes can be done earlier also.

As per this policy, rate of interest on gold loan schemes shall be fixed taking into account various factors such as cost of funds, overhead costs, matching tenor cost, fair return on capital employed, market liquidity, offerings by competitor, cost of disbursements, market conditions and guidelines of Reserve Bank of India regarding Fair Practices Code. Guidelines of Reserve Bank of India from time to time also shall be strictly followed.

The Board of Directors of the Company or a Committee drawing powers from the Board, while fixing interest rates on Gold Loan Schemes shall be guided by this policy document on Interest Rate Fixation.

In addition to cost factors set out hereunder, the Board or the Committee shall be guided by the market conditions and various rules and regulations, if any, prescribed by the Reserve Bank of India or such other competent authority from time to time.

Interest charged under various Gold Loan Schemes shall have the following components:

Basic Interest Rate
Cost of working capital
Fair return expected on capital
Risk Interest Rate
Panel Interest

The rate of interest of each scheme for each slab period (3 months, 6 months, 12 months) etc. shall be clearly mentioned in the pledge form and shall also be mentioned in the sanction letter issued to the borrower, which will be acknowledged by customer under his/her signatures.

Basic Interest Rate

Basic Interest Rate represents the rate chargeable under every Gold Loan Scheme irrespective of the risk weight attached to the schemes or the type of scheme. Basic Interest shall be arrived at after considering the following aspects:

Cost of Working Capital Funds

This component represents the interest and other incidental charges payable by the Company for servicing the borrowed funds.

Overhead Cost

Overhead costs comprises of employee cost, other operational costs such as charges for rent, electricity, water etc., security charges such as engagement of security guards, setting up of burglar alarms and CCTV cameras, insurance premium for insuring the gold and cash held in the custody of the Company and marketing expenses etc.

Return on Capital Employed

Fair return on capital is arrived as per industry standards and taking into account the interest of stake holders of the Company. The Board shall take into consideration a fair return on capital employed which is to be generated by the management for servicing the owners capital employed in the business.

Risk Interest Employed

Risk Interest shall be determined by taking into account the degree of risk involved in loans under each loan scheme. While the rate shall be the low for the schemes where advance amount vis-à-vis the weight of gold is the lowest, it shall be increased for schemes offering higher advance amount for the same weight. Further, irrespective of the scheme, the risk interest shall also be determined after taking into account the period of the loan as the incidence of risk goes up with the passage of time. Risks in respect of gold loans includes the fall in price of gold, possibility of the gold pledged turning out to be spurious or of low purity, stolen gold being pledged, delays in settling loans of deceased due to legal issues etc.

The interest rate goes up depending upon the periodicity of servicing the interest. Interest servicing within 30 days of disbursal is priced lowest compared to 90 days and so on.

Penal Interest Rate

Penal interest will be charged as penalty for non-servicing of interest & non-repayment of the loan dues as stipulated in sanction letter.

The full details of method of calculation of penal interest has been mentioned in the Fair Practices Code approved by the Board of Directors.

Market Conditions: Market conditions include the rate of interest charged for similar loans by other NBFCs, which will also be factored.

Thus the interest rate for the gold loan schemes shall be determined by considering the cost of working capital, overhead cost and fair return on capital employed and all factors enlisted here above.

Operational Policies

Basant India Limited, hereinafter referred as company shall be bound and governed by the following policy as far as aspects of CUSTOMER ACQUISITION, KYC COMPLIANCE and BUSINESS DEVELOPMENT is concerned.

Customer Acquisition

The company shall conduct business of granting loan against security of Gold ornaments through its Branches initially.
In due course of time company proposes to use Fin-tech model through application to do the business of secured lending against gold ornaments.
The company shall adopt fair market practices and will not resort to any unfair means for acquiring the clients.
The company shall use primarily its employees for acquisition of customers and business and may come out with incentive schemes for promoting business.
The company shall make best use of technology and tools of software to advertise and promote its business and customer acquisition.
The company may engage agencies and use their know-how for advertisement of products in the market / area of operations.

Know Your Customer Policy (KYC)

Broadly KYC policy consists of following four key elements: (i) Customer Acquisition Policy (CAP); (ii) Customer Identification Procedures (CIP); (iii) Monitoring of Transactions; and (iv) Risk Management.

The circulars in vogue as on date and those issued in future will be implemented in the Company in their true letter and spirit and required due diligence in this regard will be done. Company shall obtain copy of at least two Officially Valid Documents (OVD) to identify and for proof of address of the customer.

The company shall be bound by all the rules and regulations of Reserve Bank Of India wrt Know Your Customer Policy is concerned. The companies shall ensure that the details of the customers are updated from time to time. This should, however, not result in unnecessary harassment of customers.

Company shall not do any transaction in Benami names. A latest photograph of the customer shall be obtained at the time of acceptance of customer.

There shall be a designated permanent director responsible for ensuring overall KYC compliance and for reporting KYC compliance to RBI.
Certified copy of any two of the following officially valid document) for Proof of Identity and Address will be obtained:

Proof of Identity
1. Aadhar card
2. Pan Card
3. Govt. employee card with DOB
4. Passport
5. Class X Board Certificate with DOB
6. Birth certificate issued by municipal authority
Proof of Address
1. Aadhar card
2. Passport
3. Voter ID Card issued by Election Commission of India
4. Utilities Bill (Electricity/water/telephone.
5. Copy of registered Sale Deed/Lease Deed

Where ‘simplified measures’ are applied for verifying the identity of customers the following documents shall be deemed to be 'officially valid documents: Identity card with applicant's Photograph issued by Central/State Government Departments, Statutory/Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks, and Public Financial Institutions;

Letter issued by a gazetted officer, with a duly attested photograph of the person. Where ‘simplified measures’ are applied for verifying for the limited purpose of proof of address the following additional documents are deemed to be OVDs.

Utility bill which is not more than two months old of any service provider (electricity, telephone, postpaid mobile phone, piped gas, water bill);

Property or Municipal Tax receipt;

Bank account or Post Office savings bank account statement;

Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address;

Letter of allotment of accommodation from employer issued by State or Central Government departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies. Similarly, leave and license agreements with such employers allotting official accommodation;

1. Lending and Documentation Policy

Basant India Limited having its Head Office at Barakhamba Road Delhi Is an ND-NBFC primarily engaged in lending to customers against security of Gold ornaments and jewellery. The company’s policies are governed by Reserve Bank Of India. The company adopts the following policy with regard to Lending and Documents which are provided to the customers along with the Gold loan sanction letter to secure the loan and financial transactions. It has been ensured that the customer is not put to unnecessary harassment and at the same time the documents are legally strong enough to withstand in court of law in case of disputes or whatsoever.
Following policy will govern lending principles of the company;

1. Eligible customer: Any individual who is the lawful owner of the Gold Jewellery offered as security as per the declaration of ownership submitted by him and fulfilling the KYC norms as per RBI guidelines shall be eligible to avail loan from the company

2. Purposes: The loan can be extended to anyone who is having short term fund requirements like working capital for establishment/ expansion of business activity or meeting personal liquidity requirements or domestic needs including medical expenses etc. Loans shall not be used for any speculative or illegal or unlawful purposes violating the laws of the Country.

3. Quantum of finance: Quantum of finance will be decided on the basis of net weight of gold of 18 to 22 carat ornaments tendered as security, its purity and subject to RBI guidelines regarding loan to value which is 75% of the value of the gold ornaments presented for pledge.

4. Minimum amount per loan: Rs 5000 (Three Thousand only).

5. Quantum and purity of gold ornaments that can be pledged and deductions to be considered: The minimum net weight of gold jewellery that can be considered for pledge is 2 grams. The ornaments shall be of minimum 18 carat purity. The weight of pearl, coral or any other stone or foreign material other than gold contained or forming part of the ornament irrespective of its value shall be deducted from the gross weight of the ornaments to arrive at the net weight for calculating the eligibility for the loan.

6. The interest shall be calculated for the actual number of days the loan remains outstanding, including the date of loan disbursement and the date of closure. However, if the borrower closes the loan within 7 days from the date of disbursement, then a minimum interest for 7 days shall be payable. If the amount of interest so calculated is less than Rs 100/- then a minimum interest of Rs100/- will be charged. A rebate in interest rate may be provided for encouraging timely repayment of interest or closure of the loan on or before the specified tenor as per the scheme. A grace period up to 5 days on due date may be allowed in payment of dues at the discretion of the Company.

For the purpose of calculation of interest, a year will be reckoned as 360 days and a month as 30 days. Interest is calculated on 30 days compounding basis.

7. Penal interest: In the event of failure on the part of the borrower to close the loan along with interest and other charges on the due date or within the grace period permitted, penal interest of 2% over and above the regular agreed interest will be prospectively.

8. Other charges: In addition to interest, the Company may levy other charges as below. The rate at which such charges are to be levied shall be decided by the Board or a Committee empowered by the Board for fixing interest rates and other charges.

Processing charges, Service Charges, Documentation Charges, Insurance charges (0.3%), Notice Charges, SMS Charges, Auction expenses, Cheque re-issue charges & Any other charges as decided by the Board or the Committee empowered by the Board.

2. Standard Operating Process for Granting Gold Loan & Documents to be Obtained

1. Loan Application: The customer shall apply for the loan on the specified format of application, which shall be provided by the company. The application form includes complete details of the customer as follows;

Name & complete Address including telephone number of the borrower along with his father /husband‘s name etc.
Age and gender of the borrower (date of birth)
Occupation of the borrower, business/service etc.
Two photographs.
ID proof may be in form of Aadhaar card/PAN card/ copy of pass port/ voter ID etc.
Bank account details etc.
Referral if any.

2. Consent to obtain Aadhaar details for authentication with UIDAI for “KYC” purpose and Any one or more of the following Documents specified by RBI as address/ ID proof for completing the KYC of the customer:

Identity Proof: Passport/ PAN/ Driving License/ Voter ID card/ Ration Card/ Aadhar Card or any other identity card issued by a government authority, PSU or nationalized bank, containing the photograph of the customer
Address proof: If any of the documents taken as identity proof also contains the address of the borrower, no separate address proof is insisted upon. In other cases, the following documents can be taken towards address proof:
Ration card/ latest electricity/ landline telephone bills/ bank passbook/ bank/ Aadhar Card or any other documents issued by a government authority, PSU or nationalized bank, containing the address of the customer.

3. Field verification of the borrower in order to verify his antecedents etc will be done. The branch staff will verifies the brief facts over the phone and thereafter will conduct personal visit at the given address of the borrower.

4. The complete detail of jewellery proposed to be offered as collateral security and amount of loan required is also to be provided by the customer in application.

5. The company officials shall do their due diligence and Appraisal of the gold will be done in-house by trained employees. Upon appraisal of the gold ornaments and documents provided by the customer, the branch manager shall sanction the loan within policy guidelines of the company. Same shall be discussed and explained to customer in his vernacular language.

6. Loan amount will be decided based on prevailing market price of the gold. Hence it will be fixed on day to day basis. The gold ornaments will be divided in three categories as per the viz;

Solid category: Ornaments having least impurities/stone etc.
Chain form: Ornaments having impurities due to making / design etc.
Others: Ear rings etc. having comparatively more impurities/stone/diamond etc. due to its design & tanka.

As such different per gram rate/value of gold will be decided on these categories.

7. The loan will be sanctioned on net weight, but full details of gross weight & deduction made will be kept on record in order to avoid any dispute at any point of time.
Net weight of Gold = Gross weight of gold – impurities including weight of the stone if any. Eligible amount of loan that can be sanctioned will be 75% (maximum) of Net weight of gold * per gram rate.

Items not to be considered for accepting as security for the loan:

Melted bar/ Primary Gold
Jewellery of a temple/ church or any religious institutions.
Item specified by the Company in the negative list updated from time to time.
Items where the borrower is unable to give a proof or declaration of ownership.
Items which are not permitted to be taken as security by RBI

8. Appraisal note will be drawn specifying details of gross weight, deductions if any, net weight, value of Gold basing on prevailing rate on that day, eligible loan amount.

9. Signature of customer will be obtained on the appraisal format along with signature of appraiser and branch manager.

10. Duly filled and dated Pledge form containing all terms of sanction/details of gold/ interest rate/ repayment terms etc. and Demand Promissory Note and take delivery letter shall be signed by the borrower in presence of at least two officials of the branch. The pronote shall be duly witnessed and agreement shall also be signed by authorized signatory of the company under company’s seal.

11. Proof of ownership of ornaments; Customer shall provide documents/detail/declaration to the satisfaction of the company regarding ownership of the ornaments tendered as security. The best option is receipt of purchase. In absence of receipt any other document to company’s satisfaction and shall sign declaration that the ornaments are owned by him/her. This undertaking will be part of the loan documents.

12. An undertaking will be obtained from the borrower that all the terms of sanction, Rate of Interest and repayment conditions along with penal interest and auction policy in case of default has been fully explained to the borrower in vernacular and that he/ she has understood all the terms and conditions in their letter and spirit.

13. Letter of authority to sell / auction the gold in case of default will also be obtained.

14. The terms and conditions in Hindi or any other language known to customer will also be obtained in addition to English.

15. The sanction letter shall explicitly contain following information in vernacular known to the customer, generally Hindi and English;

Amount of Loan Sanctioned,
Tenure of the loan: All gold loans are sanctioned for a maximum tenor of 12 months unless otherwise specified under a particular scheme.
Repayment and Interest servicing terms,
Applicable Rate of Interest & other service charges and cost etc,
Penal Rate of Interest in case of default in timely servicing of interest etc.
Documents to be submitted by the customer
Mode of Disbursement of loan
Mode of Repayment
Recovery & Auction policy of the company,
Other Terms and conditions applicable to the sanctioned loan

16. Pre-determined Performa of sanction letter will be generated from the system in 3 copies. One copy will be kept along with documents, second copy will be kept in the packet of gold in the security / strong room and third copy will be given to the customer against acknowledgement.

17. The branch Manager shall acknowledge receipt of ornaments received and shall give receipt of gold ornaments to the customer.

18. The agreement and pronote shall be stamped as per regulation of the state. The cost of stamp shall be borne by the customer.

19. The jewellery shall be put in a poly cover along with list and details of the contents.

20. The sealed cover and loan papers will be kept securely by company officials.

21. The loan shall then be disbursed to the customer either by cash or cheque against acknowledgement as per sanction terms and also in strict adherence to Income Tax Act 1961.

22. Generation of periodical reminders for repayment in case there is delay in repayment.

23. Renewal of loan: Although loan will be considered renewed on repayment of interest however fresh pledge form will be obtained on half yearly / yearly renewal as per repayment term of the sanction.

24. The interest will be governed by the Interest rate policy of the company. It will be charged on basis of daily products but will be applied on the day of repayment of interest and or principal. If interest is not paid within stipulated slab period, the ROI will go to next slab. There will also be provision of part payment of interest with a condition that minimum 50 % of amount of interest will have to be paid.

25. Interest will charged from the date of disbursement & so on.

26. The interest in respect of OD limit will be applied on last working day of every month on amount.

27. Procedure of accounting: A system of maintaining daily vouchers will be adopted in branches. There will be a voucher for every transaction and its contra transaction. The voucher will be signed by entering staff & authorized by the manager under full signatures. Daily vouchers will be maintained properly in the branch for audit.

28. Handling of overdue / NPA accounts: The accounts in which interest or principal will not be repaid on due dates and become overdue for more than 180 days will be considered as Non-Performing Assets.

Recovery process will be initiated on first default in repayment of interest or principal by issuance of ordinary notice. If interest /principal is overdue for more than 60 days registered demand notice will be issued to the defaulting borrowers. Failure to repay on registered notice will invoke Legal Notice to auction, wherein 15 days’ time will be granted else security kept in these accounts will be auctioned. This process will be governed by Auction Policy of the company. Provision of one time settlement by providing concession in rate of interest in old defaulting NPA accounts/ disputed cases can be kept with the permission of the competent authority.

29. Release of Jewellery: Jewellery shall be released to the same customer on receipt of full dues including the principal, interest, penal interest and other charges, if any. Release, whether partial or in full can be done only after verification of signature, original KYC documents & customer copy of the original pawn ticket (Token). If the token is lost indemnity in stamp paper of required value to be obtained before release of jewellery. In case the customer is deceased, the ornament will be delivered to the legal heirs as per the procedure stipulated by the Company for settlement of Deceased Loan accounts.

30. Fraud Prevention: All kinds of fraudulent activities or attempt to defraud, whether it is by the employees or outsiders, must be brought to the knowledge of the Management as soon as it is detected for proper action as per company guidelines.

31. Attempt by any suspicious customer trying to pledge stolen/ spurious jewellery should immediately be reported to the Chief Vigilance Officer at Corporate Office and the Vigilance Officer at the Regional Office and to the local police.

32. Jewellery Handling

Gross weight of the jewellery taken on weighing machine will be taken for assessing & appraising the purity. Purity Check shall be conducted as per the various methods prescribed by the Company to make sure that the jewellery offered for pledge is of an acceptable level of purity.
Net weight of the jewellery to be arrived at after deducting the weight of stones embedded in the ornament. Appraiser to sign the appraisal form as proof of having done the appraisal.
Jewellery to be packed securely along with the weight slip in designated sealable plastic pouch and kept in the security room/ safe vault which will be operated jointly by two branch officials. Each plastic pouch will be mentioned number, name of the borrower and date of loan etc clearly.
Separate packets to be prepared for each loan and will be counted and audited regularly.
Ownership of gold: Before disbursement of the loan, branch executives should enquire with the customers about the ownership of the jewellery being pledged for loan and the loan should be granted only after they are convinced about the genuineness of the borrower and his capacity to own that much quantity of gold. In addition to the above, customers are also required to sign a Declaration of ownership of jewellery offered as security for the loan.
In cases where the weight of the gold jewellery pledged by a borrower at any one time or cumulatively on various loans outstanding is more than 20 grams, the declaration should also contain an explanation specifically as to how the ownership was vested with the customer(For eg. Inherited, received as gift, purchased etc.).
Issuance of Certificate of Purity: A certificate of purity of the gold jewellery pledged as security for the loan will be incorporated in the Sanction Letter given to the borrower for the limited purpose of determining the maximum permissible loan and arriving at the reserve price for auction.
Only gold jewellery of 18 carat and above will be accepted as security for the loan. However, in case the purity of the jewellery is found to be less than 22 carat, an option can be exercised by the Company to translate the collateral into 22 carat and state the exact grams of the security accordingly.
Loan to Value: The ceiling rate for granting the loan will conform to the guidelines issued by RBI from time to time (presently 75%) as also the rate per gram under each scheme shall be updated in the CBS and advised to Branches periodically.

Change in rate of gold and schemes will also be updated in the company’s software and intimated to branches periodically from Corporate Office.
Safety Measures: Utmost care is to be taken to ensure the safety of the ornaments pledged by the customer. With this in view the following arrangements shall be in place in all the Branches.
1. 1. Safe rooms or vault / safes operatable jointly by two officials..
2. Armed guard(s)/ watchman at vulnerable Branches as decided by the Company.
3. Burglar alarms, Closed Circuit Cameras and such other devices as deemed necessary shall be installed in vulnerable Branches.
4. Insurance cover against burglary/ fire/ natural calamities or such other risks the Company may decide to insure against.
5. The adequacy of the safety measures put in place as also the insurance cover shall be reviewed on an ongoing basis.

33. Inspection

All Branches will be periodically inspected and audited by internal audit staff at intervals specified by the Company. The audit Department will, at random, verify the quantity and purity of gold ornaments accepted by Branches for pledge. They will also audit various accounting procedures followed at Branches and ensure that the circular instructions issued by the Company from time to time are strictly being adhered to.

34. Delegation of Sanctioning Powers

1. The company shall restrict its lending to secured loans against security of Gold jewellery and ornaments and the branches and officials shall not lend in any other form or scheme.

2. Following shall be the delegation of powers to sanction the loan against Gold ornaments:

Board shall have full powers
CEO: on and above 10 lac.
COO: Up to Rs 10 Lac
Regional Manager Up to Rs 5 Lac
Branch Manager Up to Rs 2 lac

In case of urgency the sanction can be obtained by way of e-mail form the concerned authority. In case of need concession can be considered in rate of interest as a special case. Grace period up to 2 days can be granted if due date for repayment happens to falls on Sunday/holidays.

R. Discretion to grant extra per gram rate of INR 10/-or INR 20/- can be given to BMs/RMs respectively.

35. Business Promotion

The Company shall have an effective Business Promotion Policy.
The Business shall primarily be driven through the employees, particularly the Branch Managers. The Branch Managers shall be the brand ambassadors of the company in driving business of the company. Multiple measures shall be used to motivate employees to contribute in error free lending, business development and Recovery efforts.
In addition to efforts of the branches, company shall adopt various available measures in the market to advertise the company and its products.
Use of Technology and platforms of Google, Facebook etc shall also be explored to their best to popularize the brand of company in its areas.

36. Target Allocation, Review Thereof & Incentives

The company shall have following system of Business Promotion, Target Allocation to Branches and Review mechanism;

The Branches will be allocated Monthly, quarterly, half yearly and yearly target for disbursement of loan.
The branch Manager shall be wholly responsible for achievement of the disbursement targets.
The branch Manager can allocate targets among his team, if he/she desires so.
The remuneration of the Manager particularly shall be linked to performance in achievement of business targets. Which shall mean that there shall be a fixed monthly salary (say 80%) and variable salary (say 20%) basing on the target achievements.
In addition there shall be provision of incentive for higher achievements and error free lending etc. Percentage of which will be announced in beginning of the financial year.
The incentive shall be distributable among all employees of the branch in proportionate to their salaries.
Targets for Recovery shall also be fixed for the branches having Overdues & NPAs in loans. Incentives shall also be announced for recovery in overdue / NPA accounts.

37. Monitoring & Support by Head Office

The branches will be supported by Head office in all aspects of business development, Provision of infrastructure for smooth running of branches, Recovery and streamlining the processes
There will be regular monitoring of branches by HO officials through off-site MIS generation.
There shall be daily on-line teleconference of the branch Manager with GM Operations after business hours. The GM will visit every branch twice a month. The periodicity shall be examined with increase in number of branches
Periodical branch visits will also be done by the CEO /MD of the company
A detailed report of visit shall be placed to next higher authority.

38. Follow-up & Recovery Policy including Auction Policy

The branches shall regularly follow-up with the borrowers for recovery of due interest and principal on due dates.
Due notices will be sent to delinquent borrowers intimating the due dates and effects of delay will also be enumerated therein. Terms of penalty enforced shall also be intimated to the borrowers and every effort will be made to recover dues in time.
Though in its best endeavor company will try to recover its dues by normal means, but in case the interest is not repaid as agreed or loan account is not closed on completion of tenure even after sending reminders through SMS, notices/ registered notices at frequencies stipulated by the Company as per sanction terms, the ornaments will be subjected to auction.
To initiate auction process prior final legal notice of 15 days will be issued to the defaulting borrower. This legal notice will be issued those defaulting borrowers who will not respond to earlier registered notices for recovery of overdues.
The auction will be announced to the public through advertisements published in at least 2 newspapers, one in vernacular language and another in a national daily newspaper.
Basant India Ltd or its Group Companies and its other related entities will not be allowed to take part as a bidder in auction to ensure that there is an arm’s length relationship in all transactions during an auction process. The borrower, if he chooses, can participate in the auction process complying with the conditions stipulated by the Company/ auctioneer. The proceeds of auction, net of auction related expenses and incidental charges shall be appropriated towards the loan outstanding. The Company may decide to recover the shortfall, if any, after such appropriation by various steps including legal action. Excess, if any, shall be refunded to the customer. GST as applicable will be recovered.

Procedure as outlined above is approved by the Board and to be followed in its strict terms.

39. Acquisition of Staff and Training (HRM Policy)

Company shall acquire best experienced employees from the market and shall pay them according to industry’s best policy.
The conduct of employees and their terms of employment will be governed by HRM policy of the BLS Polymers Limited till Basant India Ltd formulates its own HR Policy.
The employees shall undertake to contribute their best during course of employment with the company and shall keep confidentiality of the policies & trade practices of the company. The employees shall also keep customer’s data, detail and financial information secret and will not share with the outsiders under any circumstances.
The employee’s remuneration will be decided and conveyed at the time of recruitment.
The salary of field functionaries will be having two components, fixed and variable. A portion of salary (at least 20%) shall be linked to business secured and target achievements during the month/quarter. The employees shall be transparently intimated about this process when absorbed in the company.
All the employees, as soon as they are inducted into the Company, shall be trained on the systems and processes of handling gold loan business, particularly the methods of assessing the purity of the gold ornaments.
Refresher programs will be conducted to keep them updated on an ongoing basis.

40. Policy on Software, Data Maintenance, Mis & Review

Basant India Limited hereinafter called Company adopts the following policy with regard to Software and Data Maintenance:
The company shall procure software from an established software company who would have supplied software to at least 20 software companies. The supplier company should also have sufficient exposure in gold loan companies.
The software will be tested in our Head office for at least 15 days to check its accuracy in accounting and Data maintenance.
The supplier company shall maintain and preserve data as per requirement of the company. Daily backup of data shall be ensured by the software company and certificate of this shall be given by the software company on monthly basis to the company.
The company shall design its own MIS platform. There shall be a daily, Weekly, Monthly, Quarterly, Half Yearly and yearly MIS sheets. Details of various sheets will be designed by the company. The company shall keep analyzing performance and accuracy of software & MIS on an ongoing basis. Changes will be effected immediately on finding deficiencies. It will be duty of the software provider to expeditiously make changes as required by the company.
Branches will be linked with corporate office for submission of Real Time MIS to corporate office. MIS will be generated in formats having following details;

Daily branch-wise disbursement, Recovery & outstanding & Scheme wise outstanding
Daily branch-wise Interest & other income realized
Interest rate wise breakup of advances
& any other as may be required by the top management /Board.

Balance sheet and Profit and Loss account of the company will be generated quarterly and yearly basis as per company law format adhering to accounting standards.

41. Confidentiality

The company shall always be bound by fair practice of confidentiality in terms of data and information collected from the customers in the course of doing business. However in case the information about customer is sought by the law enforcement agencies under the framework of law of the land the information will be provided to such agencies. The employees of the company shall also be governed by the confidentiality policy in strict manner.