The objectives of the Fair Practice Code (“the Code”) are:

• To promote good and fair practices by setting minimum standards in dealing with customers
• To increase transparency so that customers can have a better understanding of what they can reasonably expect of the services
• To encourage market forces, through competition, to achieve higher operating standards
• To promote a fair and cordial relationship between customers and Godrej Housing Finance
• To foster confidence in the housing finance system

The Company will act fairly and reasonably in all dealings with customers, by ensuring that:

• It meets the commitments and standards adopted in the Code for the products and services it offers and in the procedures and practices its employees follow
• Its products and services meet relevant laws and regulations in letter and in spirit
• Its dealings with its customers rest on ethical principles of integrity and transparency 

The Company will transparently disclose to the borrower:

• Fees and charges payable for processing a loan application, amount of fees refundable if loan amount is not sanctioned or disbursed
• Pre-payment options and charges, if any
• Penalty for delayed repayment
• Conversion charges for switching a loan from fixed to floating rate or vice-versa
• Information on interest reset clause, if any, and
• Any other matter which affects the interest of the borrower
• ‘All in cost’ inclusive of all charges involved in processing and sanctioning of a loan application in a transparent manner

NON-DISCRIMINATION POLICY

• The Company will not discriminate between its customers based on gender, physical ability, race or religion. The Company will also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from instituting or participating in schemes targeted at different sections of the society.

The Company shall

• Ensure that all advertising & promotional material is clear and not misleading
• In any advertisement, in any media or promotional literature that draws attention to a service or product which includes a reference to interest rates, the Company will also indicate whether other fees or charges will apply and ensure that relevant terms and conditions are made available on request
• Provide information on Interest rates, common fees and charges through any one or more of the following media:
  • Putting up notices at all our branches
  • Through telephone or helplines
  • On the Company’s website, as and when launched
  • Through designated staff or helpdesks
• If the Company avails services of third parties for providing support services, it shall require that such third parties handle customers’ personal information (if any available to such third parties) with the same degree of confidentiality and security as the Company would.
• The Company, from time to time, will communicate to customers, salient features of the products availed by them. Further, the Company may provide information about its other products or promotional offers only if he or she has given his or her consent to receive such information or service either through the application form or the loan agreement or by mail or by registering for the same on the website or on the customer care number.
• Prescribe a Code of Conduct for Direct Selling Agents (DSAs), whose services are availed to market the products of the Company. Such Code of Conduct, amongst other matters, require them to identify themselves when they approach the customer for selling the Company’s products.
• In the event of receipt of any complaint from the customer that the Company’s representative or courier or DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.

APPLICATIONS FOR LOANS AND THEIR PROCESSING

• At the time of sourcing a loan proposal, the Company shall provide information about the applicable interest rates, fees or charges etc. and any other important information which affects the interest of a borrower, so that a meaningful comparison and informed decision can be taken by the borrower
• The Company will issue an acknowledgement receipt for all loan applications. Loan applications shall be disposed of within 21 days or such extended time as may be mutually agreed between the borrower and the Company from the date of receipt of the application form complete in all respects

LOAN APPRAISAL AND TERMS &CONDITIONS

• Normally all details/ documents required for processing the loan application will be collected by the Company at the time of application. If any additional detail/ document is required, the Company will contact the customer again at the earliest possible instance.
• The customer would be informed by means of a written sanction letter of the amount of loan sanctioned or otherwise; all important terms and conditions including Annualized Rate of Interest, method of application of rate of interest, EMI structure, prepayment charges etc. The Company will keep the written acceptance of these terms and conditions by the borrower on its record.
• The Company will furnish a copy of the loan agreement via email or make it available on the secured customer portal, along with a copy each of all enclosures quoted in the loan agreement to every borrower at the time or after disbursement of loans.

COMMUNICATION OF REJECTION OF LOAN APPLICATION

• If the Company is not in a position to provide a loan to a customer, it shall communicate in writing the reason (s) for rejection

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

• The Company will disburse the loans in accordance with the disbursement request made by the customer or disbursement conditions mentioned in the loan Agreement or sanction letter
• The Company will give notice to the borrower of any change in the terms and conditions including changes in terms & conditions relating to disbursement schedule, interest rates, service charges, prepayment charges, other applicable fee or charges etc. The Company will also ensure that revisions in rate of interest and charges are implemented only after notification to the customer. A suitable condition in this regard will be incorporated in the loan agreement
• If such change in terms & conditions is to the disadvantage of the customer, he or she may within 60 days and without notice close his or her account or switch the loan account without having to pay any extra charges or interest
• If such change in terms & conditions is to the disadvantage of the customer, he or she may within 60 days and without notice close his or her account or switch the loan account without having to pay any extra charges or interest
• Decision to recall or accelerate payment or performance under the agreement or seeking additional securities, shall be in consonance with the loan agreement
• The Company will release all securities on repayment of all 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 borrower. If such right of set off is to be exercised, the borrower shall be given a 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.

GUARANTORS

When a person intends to be a guarantor for a loan, he or she shall be informed about:

• His / her liability as guarantor
• The amount of liability he or she will be committing himself or herself to the Company
• Circumstances in which the Company will call on him or her to pay up the liability
• Whether his or her liabilities as a guarantor are limited to a specific quantum or are they unlimited
• Time and circumstances in which his/ her liabilities as a guarantor will be discharged
• The manner in which the Company will notify him or her about the same
• In case the guarantor refuses to comply with the demand made by the creditor or lender, despite having sufficient means to make the payment of the dues, such guarantor may also be treated as Willful Defaulter at sole discretion of the Company; and
• The Company will keep him or her informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor, if it becomes aware of it

SHARING OF INFORMATION

• The Company may provide such information to its group/associate entities or companies for which it has obtained consent/ permission from its customer under loan application/ sanction letter/ loan agreement or through other means
• The Company will treat the personal information of customer even when the customer is no longer a customer as private and confidential. The Company will not reveal the data or information of customer to anyone except as provided above and in the following exceptional cases
  • Putting upRequired by law
  • Duty towards public to reveal information
  • The Company’s interest requires giving information
  • The Company has consent/ permission from the customers
  • The Company’s representatives will inform the customer about his rights/ liabilities under the Laws of India for accessing the personal records that the Company holds about him/her
  • The Company will not use customer’s personal information for marketing purposes unless the customer specifically authorizes us to do so
• If the Company is asked to give a reference about customers by any other bank/ NBFC/ HFC or other entity without any legal/ regulatory obligation, it will obtain his / her written permission before giving it.

CREDIT REFERENCE AGENCIES/ CREDIT INFORMATION COMPANIES

• The Company will share details of the loan and repayment track record of its borrowers to the Credit Information Companies (“CICs”) as per the regulatory directions/ guidelines and the Company’s internal policies.
• The Company will also share information with the Credit Information Companies about the personal debts the customer owes it if:
  • The customer has fallen behind his/ her payments
  • The amount owed is not in dispute
  • The customer has not made proposal following our formal demand for repayment of dues.
• The Company’s representatives will explain to the customers the role of the CICs and the effect the information they provide can have on customer’s ability to get credit.
• The Company will give information about the customer’s account to the CICs in accordance with the statutory/ regulatory requirements.
• The Company will provide relevant information given to the CICs if demanded by the customer.

Any customer with a grievance, complaint or feedback with respect to any of the the products and services offered by Godrej Housing Finance Limited may reach out to the company’s Customer Service Department.

• Call us on 022-68815555 or Email to customercare@godrejhf.com (From Monday to Sunday, 9:00 AM to 6:00 PM)
• Visit the website - www.godrejhf.com
• Write a letter addressed to
  Customer service Team
  Godrej Housing Finance, 3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East,Mumbai, 400079
  Maharashtra, India

HOW SHOULD A COMPLAINT BE MADE?

For accurate and timely resolution, customers are requested to provide all the necessary details like the Customer Relationship Number (CRN), Loan Account Number (LAN), details of the feedback, suggestions, complaint and valid contact Information including phone number & e-mail ID while first contacting with the Company.

HOW SOON SHOULD A CUSTOMER EXPECT A RESPONSE FROM THE COMPANY?

Godrej Housing Finance endeavors to address and respond to all the customers’ requests and complaints within a reasonable time and will keep the customer informed on the status as necessary in the interest of the customer. Since every request and complaint is unique in nature, it may take up to 4 weeks for a thorough resolution, post investigations if any.

WHOM TO APPROACH FOR REDRESSAL?

Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timeline, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:

• Name: Aarti Dhurandhar
  E-mail ID.: nodalofficer@godrejhf.com
  Telephone no.: 8657764527
  Address-
  Aarti Dhurandhar
  Godrej Housing Finance
  3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East
  Mumbai, 400079
  Maharashtra, India

ESCALATION TO NATIONAL HOUSING BANK (“NHB”)

In case the customer does not receive a response from the Company within 4 weeks or is dissatisfied with the response received, the customer may approach the Complaint Redressal Cell of NHB by lodging the complaint in the online mode at https://grids.nhbonline.org.in OR in the offline mode by post, in prescribed format available at http://www.nhb.org.in/%20Grievance-Redressal-System/Lodging-Complaint-Against-HFCs-NHB%E2%80%25%2093Physical-Mode.pdf to NHB at the following address:

The Complaint Redressal Cell
Department of Regulation & Supervision
National Housing Bank
4th Floor, Core 5A, India Habitat Centre
Lodhi Road, New Delhi– 110 003

APPLICATIONS FOR LOANS AND THEIR PROCESSING

• The Company, at its sole discretion, may verify the details mentioned by the customer in the loan application by contacting the customer at his/ her residence and/or business addressees through agencies appointed by it.
• The customer is expected to co-operate if the Company needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if the Company needs to involve them.
• The customer will be responsible for all losses if such customer acts fraudulently or without reasonable care.
• The Company, generally, will give customers information about our products and services in English. However, if requested by the customer, such information will be provided in Hindi or any other appropriate local language.
• The Company will process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.d
• The Company will make available the Code at every branch and on its website.
• The Company will provide existing and new customers with a copy of the Code, if required by the customer.

Background

Godrej Housing Finance Limited (“GHFL” or “the Company”), as a Housing Finance Company with assets size of Rs.50 crores and above, will be required to comply with the ‘Housing Finance Companies- Corporate Governance (NHB) Directions, 2016’ (“NHB CG Directions”) issued by the National Housing Bank (“NHB”) and will be required to disclose the policy on dealing with Related Party Transactions on its website and also in the Annual Report.

Accordingly, it is proposed to adopt Policy on Related Party Transactions (“the Policy”) with the approval of the Board.

Policy Objective

The Policy on Related Party Transactions (“the Policy”) is being adopted by the Company to set forth the procedures under which its transactions with Related Parties shall be reviewed for approval or ratification.

Policy Approval

The Policy therein shall be approved by the Board of Directors, on the recommendation of the Audit Committee.

Effective Date

This Policy shall be effective from the date of approval of the Policy.

Review of Policy

The Audit Committee will review and may amend the policy from time to time.

• “Arm’s length transaction” means a transaction between two related parties that is conducted as if they were unrelated, so that there is no conflict of interest.
• “Audit Committee or Committee” means the Audit Committee of the Board of Directors of the Company constituted under provisions of the NHB CG Directions and the Companies Act, 2013. The Board/ Audit Committee shall review and accordingly may amend this policy, as and when required by the applicable laws, rules and regulations.
• "Board” means the Board of Directors of the Company.
• “Key Managerial Personnel” means Key Managerial Personnel as defined under the Companies Act, 2013.
• “Material Related Party Transaction” means a transaction with a Related Party if the transaction/ transactions to be entered meets the minimum threshold/ limit prescribed in the Companies Act, 2013, OR, applicable Accounting Standards, OR, the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, if applicable.
• “Ordinary course of business” means the usual transactions, customs and practices undertaken by the Company to conduct its business operations and activities and includes all such activities which the Company can undertake as per Memorandum & Articles of Association. The Board or the Audit Committee may apply their discretion, in accordance with statutory requirements and other industry practices and guidelines, for determining ordinary course of business.
• “Relative” would have same meaning as defined under Section 2(77) of the Companies Act, 2013 read with Rule 4 of the Companies (Specification of Definition Details) Rules, 2014.
• “Related Party”: An entity shall be considered as related to the Company if:
  • The entity is a related party under Section 2(76) of the Companies Act, 2013; or
  • Such entity is a related party under the applicable accounting standards; or
  • The entity is a ‘related party’ as defined in the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, if the same is applicable.
• “Related Party Transaction” (“RPT”) means any contract/ arrangements/ transaction directly or indirectly involving any Related Party that involves transfer of resources, services or obligations between a Company and a related party, regardless of whether a price is charged, including but not limited to the following:
  • sale, purchase or supply of any goods or materials;
  • selling or otherwise disposing of, or buying, property of any kind;
  • leasing of property of any kind;
  • availing or rendering of any services;
  • appointment of any agent for purchase or sale of goods, materials, services or property;
  • related party’s appointment to any office or place of profit in the company, its subsidiary company or associate company; and
  • underwriting the subscription of any securities or derivatives thereof, of the company.

• Identification of Related Party and Potential Related Party Transaction
  

  All Directors and Key Managerial Personnel (KMPs) shall be responsible for informing the Company of their interest (including interest of their Relatives) in other companies, firms or concerns at the beginning of every financial year and any change in such interest during the year, immediately on occurrence. Further, Directors and KMPs should disclose to the Board whether they, directly, indirectly, or on behalf of third parties, have material interest in any transaction or matter directly affecting the Company.

  In addition, all Directors and KMPs are responsible for giving notice to the Company Secretary of any potential Related Party Transaction involving them or their Relatives.

  Such notice of any potential Related Party Transaction should be given well in advance so that the Company Secretary (or such other person who may be entrusted for this purpose by the Audit Committee) has adequate time to obtain and review information about the proposed transaction and place the same before the Audit Committee.

  The relevant Director/ KMP will also be required to provide any additional information about the transaction that the Board/Audit Committee may reasonably request. The Board/ Audit Committee will determine whether the transaction does, in fact, constitute a Related Party Transaction requiring compliance with the Policy.

• Review and Approval of a Related Party Transaction (“RPT”) by the Audit Committee
  
  

  The Audit Committee of the Board will review and, if appropriate, approve Related-Party Transactions. Accordingly, at the first meeting of the Audit Committee in every financial year, management shall present to the committee the following information with respect to all Related Party Transactions expected to be entered into during that financial year:

  • the name of the Related Party;
  • the Related Party’s interest in the transactions, including the Related Party’s position or relationship with, or ownership of, any entity that has an interest in the transactions;
  • the estimated rupee value of the transactions;
  • a general description of the transactions, including material terms and conditions;
  • in case of loans, the aggregate amount of loans and the rate of interest payable on such loans;
  • in case of guarantees issued, the aggregate amount of guarantees and commission to be payable on such guarantees;
  • an assessment of whether the transactions are on terms that are comparable to the terms available to unrelated third parties or to employees generally; and
  • any other material information regarding the transaction(s) or the Related Party’s interest in the transaction(s).

  After reviewing such information and being satisfied that there is a need for such Omnibus approval, the members of the Audit Committee (without the participation of the Committee member(s) interested in the transaction, if any) shall approve or disapprove such transactions. Omnibus approval of such transactions shall be given only if it is determined by the Committee that such transactions are:

  • Repetitive in nature and that such approval is in (or not inconsistent with) the best interests of the Company and its shareholders;
  • Compliant with requirement of the Arm’s length transaction;
  • In the ordinary course of the business of the Company.

  Such omnibus approval shall specify:

  • the name/s of the related party;
  • nature of transaction, period of transaction, maximum amount of transaction that can be entered into, and
  • the indicative base price / current contracted price and the formula for variation in the price if any.

  The Audit Committee shall review, on a quarterly basis, the details of Related Party Transactions entered into by the company pursuant to each of the omnibus approval given. Such omnibus approvals shall be valid for a period not exceeding one financial year and shall require fresh approvals after the expiry of one financial year.

  No member of the Audit Committee shall participate in the review, consideration or approval of any Related-Party Transaction with respect to which such member or any of his or her relatives is a Related Party.

  If any material information with respect to such transactions shall change subsequent to the Committee’s review of such transactions, management shall provide the Committee with updated information at a subsequent meeting and will get the changes approved afresh by the Committee.

  If any additional Related-Party Transactions are proposed to be entered into subsequent to the Committee’s first meeting in the financial year, management shall present such transactions to the Committee for approval before entering into such transaction (which can be taken by calling a meeting or by resolution passed through circulation).

  All the directors are required to declare and disclose their concerns or interests in any company or companies or bodies corporate at the first Board meeting in every financial year and subsequently whenever there is any change therein.

  Omnibus approval shall not be made for the transactions in respect of selling or disposing of the undertaking of the Company.

• Approval of the Board of Directors
  

  All Related Party Transactions that are not in the ordinary course of business or not on arm’s length basis shall be referred to the Board of Directors for their approval.

  Any member of the Board who has a potential interest in such Related Party Transaction will recuse himself or herself and abstain from discussion or voting on the approval of such Related Party Transaction.

• Approval of the Shareholders
  

  Any such Related Party Transactions shall also be placed for prior approval of shareholders if it exceeds the thresholds as prescribed under the Companies Act, 2013 or any other regulatory/ statutory requirements.

  All entities falling under the definition of Related Parties shall not vote to approve the said resolution being placed before the shareholders, irrespective of whether the entity is a party to the transaction or not.

• Guiding Principles for approval of a Related Party Transaction by the Board/ Committee
  

  For review of Related Party Transaction, all relevant material information of the Related Party Transaction, including the terms of the transaction, the business purpose of the transaction, the benefits to the Company etc. will be provided to the Board/ Audit Committee. In determining whether to approve or a Related Party Transaction, the Board/ Audit Committee will consider the following factors, among others, to the extent relevant to the Related Party Transaction:

  1. Whether the terms of the Related Party Transaction are fair to the Company and would apply on the same basis if the transaction did not involve a Related Party;
  2. Whether there are any compelling business reasons for the Company to enter into the Related Party Transaction and the nature of alternative transactions, if any;
  3. Whether the Related Party Transaction would impair the independence of an otherwise Independent Director or Nominee of a Director;
  4. Whether the Related Party Transaction would present an improper conflict of interest for any Director, Nominee for Director or KMP of the Company, taking into account the size of the transaction, the overall interest of the Director, Nominee for Director, Executive Officer or other Related Party, the direct or indirect nature of the Director’s Nominee, Executive Officer’s or other Related Party’s interest in the transaction and the ongoing nature of any proposed relationship and any other factors the Board/Committee deems relevant.
• Related Party Transactions that shall not require approval
  

  The following Related Party Transactions shall not require any separate approval under the Policy:

  1. Any transaction that involves the providing of compensation to a Director or Key Managerial Personnel in connection with his or her duties to the Company or any of its subsidiaries or associates, including the reimbursement of reasonable business and travel expenses incurred in the ordinary course of business;
  2. Transactions that have been approved by the Board under specific provisions of the Companies Act, 2013;
  3. Payment of Dividend;
  4. Transactions involving corporate restructuring, such as buy-back of shares, capital reduction, merger, demerger, hive-off etc. which are approved by the Board and carried-out in accordance with the specific provisions of the Companies Act, 2013 or the applicable regulations;
  5. Contribution towards Corporate Social Responsibility (CSR) within the overall limits approved by the Board that require approval of the CSR Committee.
• Disclosures
  

  All Related Party Transactions will be disclosed in Annual Report, Results and other filings made by the Company, to the extent required as per the applicable provisions of the laws and regulations.

  Further, as required in the NHB CG Directions, the Company will disclose the Policy on its website as well as in its Annual Report