1 Objective, Purpose and Scope

1.1 Objective

The objective of this Grievance Redressal Policy (hereinafter “Policy”) is to set out the Complaints handling principles and procedures in Emerald Leasing Finance and Investment Company Limited (“Emerald”)

1.2 Purpose

The purpose of this Policy is to stipulate basic principles of Complaints handling management and process in the Company, identify Complaints sources and reduce related risks.

1.3 Scope

This Policy is applicable to the Company.

1.4 Regulatory Context

The Policy takes into account regulatory documents published by regulatory bodies, in particular:

Master Direction – Non-Banking Financial Company – Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 vide RBI/DNBR/2016- 17/45 Master Direction DNBR. PD. 008/03.10.119/2016-17 dated September 01, 2016 as amended from time to time including Fair Practice Code as well as Directions on Managing Risks and Code of Conduct in Outsourcing of Financial Services by NBFCs
Notification issued by RBI bearing number CEPD. PRD. No. S873/13.01.001/2021-22 dated
12.11.2021 Integrated Ombudsman Scheme, 2021

2 Roles and Responsibilities

This clause describes roles and responsibilities related to the Complaints handling management at the Company level:

Company Board of Directors
The BoD, in particular:
approves the implementation of this Policy laying down the appropriate grievance redressal mechanism within the organization, ensuring that all disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level. Such Policy shall be regularly reviewed by BoD, at least annually,

a) is ultimately responsible for the Company’s Complaints handling management,

b) provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances’ redressal mechanism at various levels of management and by its authorized loan service provider. A consolidated report of such reviews shall be submitted to the Board at regular intervals,

c) nominate the head (person in charge) of Customer Care Department as Grievance

Redressal Officer

d) appoint Principal Nodal Officer, or the Nodal Officers, as the case may be, required as per the applicable regulations, to coordinate with the Ombudsman office of RBI and provide requisite information on complaint raised by the Complainant to such office.

e) assigns the Complaints handling function to Customer Care Department

3 Key Complaints Handling Principles and Definitions

As an NBFC, it is the primary responsibility of Emerald Leasing Finance & Investment Company Limited (”Emerald”) to focus on Customer service and satisfaction. This document details the principles and processes of redressal of customer complaints. The key objective of this policy is to ensure the following:

All concerns/complaints raised by Customers are resolved in effective and timely manner, leading to their satisfaction

Through Customers’ feedback, we are able to improve our processes and products
In an event that the Customer is not satisfied with the resolution provided to him, he is provided
with escalation mechanism.

This document aims to describe internal policy for Emerald towards handling Customer complaints. It describes various channels for lodging the complaint, obtaining solutions from the concerned department, and responding to Customers with the solution within the committed time-period.

3.1 Definition of a Complaint

Complaint is an expression of dissatisfaction or resentment either in the form of a representation made in writing or through electronic means or over phone, containing a grievance alleging deficiency in:

• services of Emerald

• services provided by the outsourcing agencies engaged by Emerald for providing service to the customers of Emerald,

• employee’s behavior,

• Maintaining confidentiality/ protection of customer’s personal (including sensitive personal information) and financial information,

• Perceived anomalies in the data as reported to the Credit Bureaus, partner NBFC and other Govt agencies etc. as required by the Regulator
Complaint is not a request for data modification or inquiry about loan products/ schemes, interest
rates or other requests which can be solved by Customer care.

3.2 Definition of a Complainant

Complainant is a customer, who has availed a credit facility of a certain amount from Emerald (or his/ her authorized representative) who addresses a Complaint to the Company either in the form of a representation or allegation made in writing or through electronic means or over phone, containing a grievance alleging deficiency.

3.3 Procedure for raising a complaint

A customer may raise his concern/complaint through the following channels:

1. Call on number: 0172-4603957
Contact hours: weekdays (10:00 AM to 6:00 PM)
Saturday : 10.00 AM to 2:00 PM

2. Email at: info@emeraldfin.com

3. “Contact Us” page on the website (write website URL here)

4. In writing (through letter) to:

Customer Care Department

Emerald Leasing Finance and Investment Company Limited

SCO 7, First Floor,

Industrial Area

Phase 2 Chandigarh – 160002

• Complaint raising by the customer

While raising a complaint, customer should share the following information:

• Customer’s complete name

• Customer’s complete correspondence address

• Loan agreement number

• Mobile number

• e-mail address (if any)

• Details of the complaint

4. Procedure for addressing a complaint

4.1 Complaints Handling Register

Company shall register all received Complaints in its internal system or in another auditable and safe evidence – Complaints Handling Register. Complaints Handling Register shall record information at least on the following:

a) receipt of the Complaint (date, Complainant, channel, source),

b) substance of the Complaint,

c) root cause,

d) High Risk Complaint identification cause,

e) operator responsible for dealing with the Complaint,

f) deadline (regulatory or internal) for closing the Complaint, and

g) date on which the response to the Complaint was sent.

The Complaints Handling Register shall have an alert function (automatic alert function is preferred) notifying the responsible Company Staff, his or her Business Line Manager and, where appropriate, the Company Compliance Department about the pending deadlines for handling a Complaint.

Except for the evidence and register of the Complaints, the Complaints Handling Register shall be the key source for reporting.

4.2 Complaints Handling Management

4.2.1 Identification of a Complaint

The Company shall ensure that processing of any received Customer complaint starts without undue delay after its receipt. The Customer Care Department who starts handling complaint addressed to the Company shall firstly assess the substance of the statement and especially whether it falls within the definition of the Complaint
The Staff who communicates with Customers shall be trained to correctly determine inter alia the substance of the Customer statement and type of claim.

4.2.2 First Contact Resolution of a Complaint

It is recommended that a Complaint is resolved by the Customer Care Department Staff in the first round of communication with the Complainant. The Complaint may be resolved by the Customer Care Department Staff only if:

1. The Complaint is recorded in the Complaints Handling Register (it will enable to identify certain types of failures indicated specifically by Customer input),

2. The issue raised by the Customer is not complex and may be resolved by Customer Care Department Staff dealing with the Complaint without any consultation with the other departments, and

3. The Customer explicitly agrees with the explanation or suggested solution in relation to his or her Complaint and there is no indication of any need to inform other relevant departments (e.g. Compliance Department).

4.2.3 Routing of Complaints & Investigation

• The Complaint, which require specific information or investigation shall be forwarded as soon as possible to the concerned Department and, where appropriate, to the Compliance Department. The speed is crucial, as applicable regulatory deadlines for addressing a Complaint
(if any) usually start at the moment of receipt of Complaint by the Company.

• The Customer Care Department shall seek to gather and investigate all relevant evidence and information regarding the Complaint. The Customer Care Department shall obey all applicable laws and regulations and internal rules of the Company. Customer Care Department shall also obey all special rules applicable to events related to Customers, at least the rules concerning Operational Risk Events, IT Security Events and Incidents, Personal Data Incidents and Breaches and rights of personal data subjects. During the investigation, the Customer Care Department shall, to the extent possible, ascertain the facts of the case and identify the causes and nature of the error, to which the Complaint relates.

• The Company shall ensure that Customer Care Department has powers to seek information, documentation or advice from all relevant units (e.g. Compliance Department) or collaborating third parties.

• The Customer Care Department shall seek advice from the Compliance Department in all cases of High Risk Complaints and in other cases where statement on compliance with the applicable laws and regulations is needed for the appropriate assessment of the Complaint.

4.2.4 Response to Complainant

• The Company shall provide a response to the Complainant without any undue delay or within 30 days of receipt/ escalation of the Complaint. When an answer cannot be provided within the required or expected time limits, the Company should inform the Complainant about the causes of the delay and indicate when the Company’s investigation is likely to be completed.

• The Customer Care Department Staff shall always communicate towards Customers in the plain and understandable language.

• Response to a Complaint should be provided to the Complainant by the Company by means that correspond to a predetermined method of communication between the Company and the Complainant in handling the Complaint, unless the applicable law requires another means of providing a response (e.g. in writing).

• Decision shall always include a clear statement as to whether the Complaint was considered justified or not with an appropriate reasoning. If the Complaint is considered justified, the response shall include information on the remedial measures.

• When providing the final decision that does not fully satisfy the Complainant’s demand (or any final decision, where applicable law requires it), the response shall include a thorough explanation of the Company’s position on the Complaint.

• Where the applicable law provides that the Company is required to inform the Complainant

of the appellate review body (e.g. NBFC Ombudsman), out-of-court settlement of disputes and/or the possibility of lodging a complaint with the supervisory authority, this information should be provided in the response to the Complaint.

Customer care department will inform the customer about the following:

• Information pertaining to all issues/concerns raised by the customer,

• Explanation of final solution provided,

• Expected timelines towards closure (where immediate solution cannot be provided,

• Maintain contact at defined intervals/milestones to communicate progress on his concern
and share reasons for delay/time taken

• Request for supporting documents/information (where applicable) in a clear manner along with the reason for such requirement

The Customer Care Executive shall make limited but reasonable attempts to reach the customer for providing solution to his/ her complaint via Phone, Email, Letter etc

5. Escalation Process

5.1 Escalation Level 1: Grievance Redressal Officer

If the customer is not satisfied with the resolution or has not received any resolution within the committed turnaround time, he/she can raise his/her concern to the “Grievance Redressal Officer” at Emerald, by giving background and history of the issue, in the following form:

In writing (through email addressed to Mr. Ajay Tiwari) to a secure email ID:
info@emeraldfin.com

In writing (through hard copy/letter) to:
Mr. Ajay Tiwari
The Grievance Redressal Officer
Emerald Leasing Finance and Investment Company Limited
SCO 7, First Floor,
Industrial Area
Phase 2 Chandigarh – 160002

Grievance Redressal Officer will respond within 3 working days of receiving the complaint and provide resolution within 21 days.

5.2 Escalation Level 2: Compliance Officer

If the complaint of the customer is not redressed within 21 days from the lodging of complaint
with Emerald, the customer may appeal to the Compliance Officer through email, as below:

Name of the Compliance Officer : Mrs. Amarjeet Kaur

Email Id : cs@emeraldfin.com

Contact Number : +91 78888 98456

Resolution Turnaround Time

All the customer complaints have to be resolved within 30 days of receipt/escalation.

5.3 Escalation level 3:
Escalation of the Complaint to NBFC Ombudsman, Reserve Bank of India

If the Complaint is not redressed within 1 month from the lodging of Complaint with the Company or the Complainant is not satisfied by the response provided, the Complainant may appeal to the Office of Ombudsman, RBI as per detail given below:

The physical address for lodging a complaint	Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh –160017
Link to Complaint Management System of RBI Ombudsman	https://cms.rbi.org.in
Refer to http://www.rbi.org.in for further details of the Scheme

The Company has appointed Principal Nodal Officer and/ or Nodal Officer(s) for representation before and furnishing information to NBFC Ombudsman in respect of complaints filed against the Company. The details of Nodal officer are as below:

Nodal Officer Name: Ms. Sheetal Kapoor
Designation Chief Financial Officer