GRIEVANCE REDRESSAL POLICY – PADMALAYA FINSERVE PRIVATE LIMITED

1. Introduction

Padmalaya Finserve Private Limited (herein referred to as "Padmalaya," we," and" Company") is registered with the Reserve Bank of India and holds a Peer to Peer-Non-Banking Financial Company license and is incorporated under the provision of the Companies Act, 2013 and is in the business of facilitating borrowing and lending through its online platform. The Master Directions mandate the Company to formulate and disclose a Board-approved "Grievance Redressal Policy" to protect the rights of the Participants. Additionally, the NBFC Master Directions require the Company to appoint a Nodal Grievance Redressal Officer and institute a mechanism in place for a Participant's concerns.

Padmalaya is fully committed to delivering consistent and exemplary service to all Participants, fostering our continued growth. Our Grievance Redressal Policy is meticulously designed to address any issues that may arise on our platform effectively. The primary objective of minimizing the likelihood of recurrence and establish a well-structured framework for addressing grievances at every level. This policy ensures fair and just treatment of all feedback, requests, queries, complaints, or grievances in strict accordance with our established rules and regulations. Our paramount goal is to provide a secure and transparent platform for all Participants, and the Company will spare no effort to attain this objective. The Company places immense value on our relationships with Participants, irrespective of their tenure, size, volume, or any other parameter, and upholds the utmost significance of maintaining these relationships. Padmalaya acknowledges that certain issues may necessitate escalation beyond the initial level, which is precisely why this policy encompasses a comprehensive redressal mechanism that caters to concerns at all levels.

BASIS

The Grievance Redressal Mechanism Policy has been established in accordance with Clause 13 of the Master Directions - Non-Banking Financial Company - Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 ("Master Directions"), as issued by the Reserve Bank of India (RBI).

OBJECTIVE

This policy aims to outline the policies and procedures governing the receipt, handling, and response to grievances raised by Participants. The following principles apply to the handling of grievances:

  • All Participants (Lenders/Borrowers) are treated fairly and equitably and without prejudice at all times.
  • All Complaints raised by Participants shall be dealt with courtesy and resolved in a timely manner.
  • All Participants shall be informed of avenues to escalate their complaints within the organization and their rights if they are not satisfied with the resolution of their complaints.
  • Compliance with the regulatory guidelines as required for this function.

KEY DEFINITIONS

  • "Participants" person who has entered into an arrangement with Padmalaya to lend on it or to avail of loan facilitation services provided by it.
  • "Nodal Officer" refers to the Officer appointed by the Padmalaya to manage Participants' Grievances/Complaints and ensure their redressal in accordance with the prescribed process, timelines,
  • "Grievance" or "Complaints" or "Query" or "Request" refers to any representation or allegation made in writing or through electronic means containing a grievance alleging deficiency in service. Additionally, Grievances, Complaints, Queries, or Requests can be lodged against inappropriate conduct, acts of omission, or commission; however, any feedback/explanations/requests will not be considered Grievances or Complaints.

GRIEVANCE REDRESSAL POLICY

Padmalaya is committed to addressing any grievances by its Participants with the utmost attention and support. The Company is committed to diligently exploring effective solutions through various communication channels, including in-person, written, or verbal means. To facilitate a quicker and fair resolution process, Participants are required to include their application number, sanction number, or loan account number in all correspondences related to their complaints or requests, along with the registered mobile number.
It is important to note that anonymous complaints will not be considered under the provisions of this Grievance Redressal Mechanism. Mechanism. All Complaints received from the registered mobile number or email or a written letter with the proof of complaint that he/she is a participant will only be considered.

GRIEVANCE MECHANISM SYSTEM & PROCESS

Padmalaya strives to maintain a consistent and high-quality service to valued Participants while diligently striving to minimize the incidence of Grievances. However, it explicitly informs the Participants on the Platform, indicating that they can raise and record any grievances concerning the Platform and the service provided by Padmalaya.
Padmalaya has designed the mechanism to ensure its Participants can seamlessly register their complaints via a multi-channel set-up. Additionally, the mechanism has a 3-step escalation matrix to ensure that a Participant is provided with adequate appeals. Padmalaya has established prescribed timelines at different stages of the mechanism to ensure time-bound redress of complaints.
To register a complaint or grievance, the Participants can avail of any of the following options:

  • A. Phone
    Participants can call the Company's dedicated helpline number, +91 92662 32208 between 10:00 a.m. to 7:00 p.m. from Mondays to Fridays, except public holidays.
  • B. Email
    Participants can write to the Padmalaya at this email Id contact@padmalayafin.com with the subject line "Complaint & Grievance Register with Loan ID"
  • C. Letter
    Participants can write to the Padmalaya at –Padmalaya Finserve Private Limited, B/H Swami Narayan Gurukul, SY No. 43, Gr. Floor Dholakiya Farmhouse, 395004 Surat.

REDRESSAL PROCEDURE

Level -1:
Padmalaya operates as an online peer-to-peer platform, Participants must submit grievances formally via email to contact@padmalayafin.com with the subject line "Complaint and Grievance Registration with Loan ID."
To file a grievance, Participants must provide the following registered account information: Loan ID, Name, and Registered Mobile number. Grievances should be submitted from the registered email address associated with the account or a written letter with proof that the complaint is from the Participant or from the registered mobile number.
Upon receipt, Padmalaya will diligently examine the matter and accordingly communicate, in writing/email/phone, its response to the participants within a maximum period of 05 (Five) Business days from the date of receipt of the formal grievance correspondence. If the resolution requires more time, suitable justification shall be provided, and Participants will be informed of the additional timelines required.

Level -2:
If the Grievance is unresolved post the 05 (Five) working days timeline in Level – 1, it will automatically escalate to Level – 2. Additionally, if the Participant is not satisfied with the resolution provided by the representative or if the Participant does not get a response from the representative within the defined timeline, then the Participant can escalate their Grievance to Level - 2. The Participant must submit grievances or complaints formally via email to contact@padmalayafin.com. Upon receipt, the Representative will then endeavor to resolve the grievance within 10 (Ten) Business days of acknowledging the Complaint; else, the Representative will inform the Participant regarding the delay in complaint resolution. In the event that the Company does not receive any further correspondence from the Participant within 7 (seven) working days after sending the response regarding the complaint or grievance to the Participant, it will be deemed that the complaint or grievance has been satisfactorily resolved to the Participant's contentment.

Level -3:
If the Participant does not receive any response from the Company within fifteen (5+10) Business days, the Participant has the right to escalate their grievance to the designated Grievance Redressal Officer of the Company. The contact details of the Grievance Redressal Officer are as follows: Name: Mr. Sachin Jivanbhai Vadodariya Address: B/H Swami Narayan Gurukul, SY No. 43, Gr. Floor, Dholakiya Farmhouse, Surat, 395004. Email: contact@padmalayafin.com Telephone: +91 92662 32208 Upon receipt of the grievance, the Grievance Redressal Officer shall comprehensively review the matter. The Participant's grievance or complaint shall be addressed and resolved within fifteen (15) working days from the date of receipt of the grievance by the Grievance Redressal Officer. If a grievance remains unresolved or not resolved to the satisfaction of the Participants or is not redressed within a period of 30 (thirty) Business days from the date of registering the grievance without any update from the Company's end, the Participants have the right to approach to the Customer Education and Protection Department of the Reserve Bank of India (RBI) for redressal. The contact details of the designated authority are as follows: The General Manager, CEPD Reserve Bank of India Department of Non-Banking Supervision, Central Office, Centre I, World Trade Centre, Mumbai-400005

FORCE MAJEURE

Padmalaya shall not be liable to compensate Participants for delayed resolutions if some unforeseen event including but not limited to epidemic, pandemic (as declared by the World Health Organization) lockdown, acts of God; fire; explosion; any law, order, or regulation of the Republic of India or other national, state or local government or any civil or military authority; or by national emergencies, wars or strikes, damage to Padmalaya or of its agents, absence of the usual means of communication or all types of transportation, etc., beyond the control of Padmalaya prevents it from performing its obligations.

POLICY REVISION

This Policy is subject to revision in accordance with the guidelines issued periodically by the Reserve Bank of India. Padmalaya will regularly review the Policy and the functioning of the grievances redressal mechanism across different management levels. The Board of Directors of Padmalaya retains the exclusive authority to effectuate any requisite alterations, amendments, or modifications to the Policy at regular intervals as deemed necessary. Such revisions shall be executed in strict adherence to applicable legal and regulatory requirements, ensuring the Policy remains compliant with all pertinent laws and regulations. This provision underscores Padmalaya's commitment to maintaining a robust and effective grievance redressal mechanism in line with the highest standards of Corporate Governance and Customer service.