Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, is required to comply with the ‘Guidelines on Fair Practices Code’ issued by the Reserve Bank of India (“RBI”) under Chapter XIII of Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 issued on 17th February 2021.
Accordingly, it is proposed to adopt Fair Practice Code with the approval of the Board.
This Code shall apply to all the products and services, whether they are provided by the GHFL, its subsidiaries or Digital Lending Platforms (self-owned and/or under an outsourcing arrangement) across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.
Guidelines for complaint and grievance redressal are contained in Grievance Redressal Policy of the Company.
Language and mode of communicating Fair Practice Code, which shall be in the vernacular language or a language as understood by the borrower, shall be put up on Companies website, for the information of various stakeholders.
Company shall:
When a person is considering being a guarantor to a loan, he/ she is being informed about following:
Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower to whom he/ she stands as a guarantor.
These Terms & Conditions are applicable to all marketing and promotional material (Content) issued by GHF in any form and media, physical or digital or any other platform. This shall be considered a General Disclaimer for all the Content.
Please read the Terms and Conditions (“Terms”) provided below carefully as they will govern conduct, rights, responsibility, and obligations of a User with regard to website of Godrej Housing Finance Limited (“GHF”).
Godrej Housing Finance Limited is a Non-Banking Financial Company - Housing Finance Company (NBFC-HFC) registered with Reserve Bank of India (RBI) engaged in the business of providing finance solutions to the eligible applicants. For acquainting prospective borrowers about its brand, its products, and offerings GHF has issued various types and kinds of material on its website.
“Godrej Housing Finance Limited” is having a valid Certificate of Registration (Without permission to accept Public Deposits) dated 26th October 2020 issued by the Reserve Bank of India under Section 29 A of the National Housing Bank Act, 1987. However, the Reserve Bank of India/National Housing Bank does not accept any responsibility or guarantee about the present position as to the financial soundness of the Company or for the correctness of any statements or representations made or opinions expressed by the Company and for repayment of deposits/discharge of liabilities by GHF.
Content means and includes any material, information, advisory, calculators, FAQs, data or graphs, money market movements, interactive media, marketing material, news items, texts, graphics, links etc., whether belonging to GHF or to its associates, partners and other group entities, which is available either directly or through marketing or Promotional Material of GHF, displayed, hosted on the Website or on any other website or available in print / digital, audio, video or any other media anywhere.
Consumer/User refers to the person (s) who is / are viewing/exposed to the Content through any media form or manner. In the document all reference to “You”, “Us”, “Me”, “We” and “I” shall be to Consumer/User.
Website shall refer to any website on which Content is being displayed/hosted.
The Content belongs to GHF and cannot be used by Consumer in any manner without prior express written permission of GHF. Hosting of Content on a public forum does not dilute the ownership of GHF.
No information sent to any User through the Content shall constitute any representation, warranty by GHF regarding creditworthiness, financial performance or prospects, solvency, of any User or any other legal entity.
GHF may at any time update, remove, replace, edit, alter any information in whole or in part forming part of Content & shall not be held responsible for any matters arising out of said.
In the event, the Website contains links to other Websites of affiliate or group company of GHF, the content, products, services offered on such linked websites, or any quality of the products/services are not endorsed, verified, or monitored by GHF.
In no event shall GHF, its Directors, employees or its affiliates be liable for any direct, indirect punitive, incidental, special, consequential damages of any nature whatsoever arising or connected with use or performance of Website including but not limited to any loss, damage, expense arising from any defect, error, omission, interruption, fault, mistake or inaccuracy.
GHF reserves the right to change the information provided on or via Content, at any time and without notice. GHF shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this Content.
The Website and terms and conditions shall be governed by and construed in accordance with applicable laws of India. All disputes arising out of or in connection with these terms and conditions shall be submitted to exclusive jurisdiction of Courts of Mumbai.
Please read the Terms and Conditions provided below carefully as they will govern the “Instant Sanction” & “Digital Journey” which an User will have with Godrej Housing Finance Limited (“GHF”)
Acceptance is acceptance to any type of terms & conditions will be usage of the Digital Sanction. For application form and sanction letter or offering of any kind which is made to the User by the Company through any of the mode (a) OTP, (b) email acceptance, (c)e-sign or (d) any other mode introduced by company.
Co-Applicant is an applicant whose name comes post Main Applicant in the order of applicants. However, the order of name does not impact either the liability or responsibility of the User. Aco-applicant will act as an agent of main applicant. There may bemultiple co-applicants. Main applicant and co-applicants are together referred to as applicants.
Content means and includes any material, information, advisory, calculators, FAQs, data, or graphs, money market movements, interactive media, marketing material, news items, texts, graphics, links etc, whether or not belonging to GHF, which is available hosted, displayed either directly or through a link or pathway in Website.
Digital Journey is a process hosted on digital media,which may or may not have support of (a) in-person GHF employee /representative, (b) tele-support by GHF employee / representative or (c)co-browsing chat bot, through which GHF allows User to participate inits Risk Qualification Process wherein he may be offered to opt for different loan products / other products by GHF subject to User qualifying to the internal policies of GHF. In the event, User qualifies, a Sanction Letter shall be shared with them, however, acceptance of Sanction Letter is the sole decision of User.
Digital Sanction: Digital Journey together with Instant Sanction is referred to as Digital Sanction.
E-Sign is an IT enabled facility provided with the help of independent Telecom Companies which is one of the facilities used bythe User to give their acceptance to the Company.
Godrej Housing Finance Limited is a Housing Finance Company registered with Reserve Bank of India as a Non-Banking Finance Company – Housing Finance Company (NBFC-HFC). It may be referred to as either GHF or Company interchangeably.
Instant Sanction is a process which may or may not have support of (a) in-person GHF employee / representative, (b) tele-supportby GHF employee / representative or (c) co-browsing chat bot, wherein GHF will convey a to the User sanctioned amount which will be anin-principle non-binding sanction on either party basis the limited information shared by the customer and qualify him to participate further in Digital Journey / normal loan process leading to full appraisal of his credit eligibility.
Main Applicant is the applicant whose name comes first in the order of applicants. However, the order of name does not impact either the liability or responsibility of the User. A main applicant will act as an agent of co-applicant. Main applicant and co-applicants are together referred to as applicants.
OTP or One Time Password is a SMS based confirmation facility provided with the help of independent Telecom Companies whichis one of the facilities used by the User to give their acceptance to the Company.
Risk Qualification Process is the internal credit process of the company which is proprietary to the Company which is to be decided solely by the company.
Sanction Letter is a document containing terms and conditions specific to the grant of loan amount to the User.
User refers to the person (s) who is / are submitting their personal information on own consent with GHF for the purpose of participating in Instant Sanction & Digital Journey and who shall be bound by the Terms and Conditions mentioned herein. The applicants working either individually or together for going through Instant Sanction or Digital Journey will be referred collectively as User. In the document all reference to “You”, “Us”, “Me”, “We” and “I” shall be to User.
This is a binding arrangement between you, the user, and GHF, establishing the terms and conditions under which the Digital Sanction may be undertaken by the User. By accessing, through any means and media this Digital Sanction, you agree to be bound irrevocably by these terms and conditions. In the event of any conflict between the terms and conditions of specific products or services and terms and conditions of Digital Sanction, the conditions specific to such products or services shall prevail.
I declare that I having willingly and with my consent agreed to be part of the “Digital Experience” and that I will share all the particulars and information as is required in this Digital Experience in truthful,accurate and complete manner and understand that they shall form the basis of any decision of the Company to consider me for grant of any loan / credit facility / other offering which GHF may decide to grant me.
I/We expressly authorise GHF or any of its group entities / authorised agents & representatives to carry out the all requisite checks by such processes as may be permissible under law for considering my application for loan including but not limited to
I /we understand that hosting of any Content/residential/non-residential project details/any other product offering or branding on Website is not endorsement of it by GHF and its responsibility of the User to ascertain its details and its selection is on risk and judgement of User.
I / we understand that we may have to use any third party offering during this Digital Sanction process and GHF does not represent them or assures their service or any performance standard and in case of any dispute we would have to approach them with no recourse to GHF.
I / we understand that the financial products / services provided through Digital Sanction on acceptance will lead creation of financial liability towards GHF.
I/We agree and understand that GHF reserves its right to retain the documents / information provided by me/ us even in case I / we do not qualify under the Risk Qualification Process and I/ We shall not dispute this retention.
I/We agree and declare that we shall keep all details, documents and media or any other information related to the Digital Sanction processas confidential and will take prior permission from GHF before sharing it with any third party.
The user acknowledges that in order to fully access the Digital Sanction he would require an active internet connection which can be Wi-Fi or the Local Area Network (LAN) connection. GHF does not assume any responsibility/liability if the User is not able to go through the Digital Sanction due to absence/ insufficiency of the required internet connection.
GHF will not be concerned with any dispute between the user and the Internet Service Provider and/or any third party providing the internet connection or any other services responsible to run the website and will not be a party to same.
The User acknowledges that all rates, charges and fees quoted / stated for various financial products and schemes and interest rates cited as examples of rates which may be in effect from time to time are indicative rates only and are subject to change at any time at the sole discretion of GHF and its group entities as the case may be, and applicable Indian laws. These charges, fees and rates may change depending upon the assessment made by GHF in individual cases upon receiving necessary information and documents.
The user shall be responsible in obtaining and maintaining all computer hardware and other equipment needed for access to and use this Digital Sanction.
I / We agree that the Digital Sanction shall be governed by the rules, guidelines, directives etc. issued by the Reserve Bank of India (RBI) or National Housing Bank (NHB) or any other competent authority.
You are advised to exercise due caution and/or seek independent advice before availing any facility or entering into any financial obligation based on the Content you will come across in Digital Sanction. The Content which you will receive in Digital Sanction or other terms are provided on an “as is”, “as available” basis and are protected by copyright. You cannot distribute the Content to others without the express written consent of GHF. You cannot copy, download, publish, distribute or reproduce any of the Content which you will receive in Digital Sanction in any form without prior permission of GHF.
The Content which you will receive in Digital Sanction should not be regarded as an offer, solicitation, invitation, advice or recommendation to buy or sell investments, securities or any other instrument or financial products / schemes of GHF, or any of its group entities. Use of the products or services described in Digital Sanction may not be permitted in some countries and if in doubt, you should check with your local regulator or authority before requesting further information on such products/ services. Products and Services are available only at the discretion of GHF and its group entities, subject to the individual contractual terms and conditions of products and services on which they are offered and such products and services may be withdrawn or amended at any time without notice. The full range of products or services may not be available in all locations.
The user acknowledges and declares that Third parties assistance, by both User and GHF, may be required for using the Digital Sanction and GHF does not provide any assurance or warranty for the standard or continuance of their service.
No information sent to any user through this Digital Sanction shall constitute any representation or warranty by GHF regarding the credit-worthiness, financial performance or prospects, solvency, or viability of any company or other legal entity or the business carried on by such entity.
All information in this website is being provided under the condition and understanding that the same is not being interpreted or relied on as legal, accounting, tax, financial, investment or other professional advice, or as advice on specific facts or matters. GHF may at any time (without being obliged to do so) update, edit, alter and or remove any information in whole or in part that may be available on this Digital Sanction process and shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability. Nothing contained herein is to be construed as a recommendation to use any product or process, and GHF makes no representation or warranty, express or implied that, the use thereof will not infringe any patent, or otherwise. The User is expected to keep abreast of any changes made in this website and the information available on it on a regular basis and GHF and its group entities undertake no responsibility about advising the user/clients about any such changes.
GHF makes no warranties as to the confidentiality or security of the information or messages whether personal or otherwise received through Digital Sanction unless otherwise specified expressly and bound through applicable law.
Though GHF will endeavour to ensure that information contained on this Digital Sanction Process is obtained from sources which, it considers, are reliable, GHF and its subsidiaries do not warrant such information’s completeness or accuracy.
Though reasonable efforts are maintained by GHF to ensure that Digital Sanction process is free from all viruses no representation is being made that it is free from all defects and User is accessing it at his own risk.
GHF, its directors and employees accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of this Digital Sanction process, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy, its Contents or associated services, or due to any inaccessibility of this Digital Sanction process or any part thereof or any contents or associated services even if the Users are advised of the possibility of such damages, losses or expenses.
As part of Digital Sanction Process the user may be asked to sign the documents such as Application form, Sanction letter etc with the aid of OTP, E-sign facility, email acceptance or any other which will lead to acceptance of the terms and is equal to the acceptance of documents in written form. Users may be asked to input their aadhar number for e-sign and share OTP for e-sign. The company does not store the AADHAR number or OTP. A copy of the signed document will be shared with the User for his record.
All rights relating to this Digital Sanction process as well as its functionalities are the exclusive property of Godrej Housing Finance Limited (particularly including but not limited to copyrights, trademarks, source code, patents as well as any other intellectual property right). All the information provided on or via this Digital Sanction process (including all texts, graphics, design or logos) shall be the intellectual property of GHF and/ or its group entities. You agree not to copy, forward, download or share content without obtaining the necessary rights or permissions to do so. You also agree not to abuse the use of this Digital Sanction Process.
In the event any content on the Digital Sanction process or any intellectual property of GHF are copied / used by the user for any profit or non-profit venture then the User shall be liable to pay for damages as set out by GHF.
This Digital Sanction Process may contain links to other websites of affiliate companies or group entities of GHF. This Digital Sanction Process may also contains links to external websites, having further linked websites, controlled or offered by third parties (Non-Affiliates of GHF), in order to help you find relevant websites, services and/or products which may be of interest to you, quickly and easily. The contents displayed or products / services offered on such linked websites or any quality of the products/ services are not endorsed, verified or monitored by GHF. GHF is also not responsible for the owners or operators of such external links or websites or for any products or services they supply or for the contents of their websites and do not give or enter into any conditions, warranties, express or implied; or other terms or representations in relation to any of these or accept any liability in relation to any of these (including any liability arising out of any claim that the content of any external websites to which this website includes a link infringes the intellectual property rights of any third party).
“Godrej Housing Finance Limited (“GHF”) is having a valid Certificate of Registration (Without Permission to accept Public Deposits) dated …………… issued by the Reserve Bank of India under Section 29A of the National Housing Bank Act, 1987. However, the Reserve Bank of India/ National Housing Bank does not accept any responsibility or guarantee about the present position as to the financial soundness of the company or for the correctness of any of the statements or representations made or opinions expressed by the company and for repayment of deposits / discharge of the liabilities by GHF”.
This website and the terms and conditions shall be governed by and construed in accordance with all applicable laws of India, unless stated otherwise. All disputes arising out of or in connection with these terms and conditions or use of this website shall be submitted to the exclusive jurisdiction of the courts of Mumbai. The Laws of India shall apply.
You confirm that you have/had no insolvency proceedings against you nor have you ever been adjudicated insolvent by any court or other authority.
GHF reserves the right to change the information provided on or via this Digital Sanction Process, including these terms and conditions or to charge for its services, at any time and without notice. It is recommended that you periodically review the information provided on or via this Digital Sanction Process, including these terms and conditions, periodically for changes. GHF shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this website.
GHF can at any time, without the need to give a reason, notice or compensation, suspend your ability to use this Digital Sanction process. The suspension or cancellation of the licence to use this Digital Sanction process will mean that you will no longer have any access to your data, without you having any recourse against GHF or any of its subsidiaries or its affiliates.
You confirm that any information provided by you or any details shared for the Digital Sanction process are correct and you undertake to pass on any modifications to GHF. You shall indemnify and hold GHF harmless against any loss, damage or costs suffered / incurred by GHF as a result erroneous information supplied by you or your authorized Users. Specifically, you are responsible for the confidentiality of any codes and passwords allowing you to use this Digital Sanction process, and access to your information as well as this use and this access by any third party, whether or not they are authorised by you.
You agree that GHF or its group entities or their employees or agents may share all information and details as provided by you in your application in relation to your existing loans and/ or repayment history to any third party including but not limited to its group companies, service providers, banks, financial institutions, credit bureaus, telecommunication companies, statutory bodies etc. for customer verification, personalisation of products and services, credit rating, data enrichment, marketing or promotion of the products or services of Godrej Housing Finance Limited or its group entities or of any other service provider.
You agree that you consent to receiving any other information through telephone / e-mail / SMS / WhatsApp or any other electronic / digital medium for marketing purposes from any GHF / its group entities or other service provider even though your name appears in the National Customer Preference Registry (Do Not Disturb Registry). You expressly agree that any such calls/SMS/e-mails/WhatsApp messages or electronic/ digital messages will not cause any inconvenience to you or your family members.
You expressly and irrevocably consent that for any claim against the service providers, GHF or its group entities shall not be liable and your claim on this account shall be against the service providers and/or tele-callers. You agree to the use of WhatsApp or other electronic/ digital media for communication or sharing of information or documents or for sending notices, agree to abide by the terms and conditions of such applications and agree to the risks associated with such applications or sharing of information or issuance of notices through them. Further, you agree that any acceptance of terms & conditions by you through / e-mail/ SMS/WhatsApp or any other electronic/ digital medium will be binding on you.
The Code is a guide to professional conduct for Independent Directors. Adherence to these standards by Independent Directors and fulfilment of their responsibilities in a professional and faithful manner will promote confidence of the investment community, particularly minority shareholders, regulators and companies in the institution of independent directors. The said Code is aligned pursuant to Section 149 (8) read with Schedule IV of the Companies Act, 2013.
Guidelines of professional conduct:
Role and functions:
Duties :
Manner of appointment:
Re-appointment:
The re-appointment of independent director shall be on the basis of report of performance evaluation.
Resignation or removal:
Separate meetings:
Evaluation mechanism:
Please refer Terms and conditions
Background
The Prevention of Money Laundering Act, 2002 (“PMLA”) and the Rules notified thereunder impose several obligations on Banks, Non-Banking Financial Companies, Housing Finance Companies (“HFCs”), Chit Fund Company and other defined intermediaries to inter alia verify identity of clients, maintain records and furnish requisite information to Financial Intelligence Unit- India (“FIU-IND”).
As per the circular dated 19th May, 2020 issued by the Reserve Bank of India (“RBI”), the Master Direction- Know Your Customer (KYC) Direction, 2016 prescribed by the RBI (“RBI KYC Master Direction”) for various regulated entities has been made applicable to the Housing Finance Companies (“HFCs”) also and HFCs will now be classified as Regulated Entity (RE) under RBI KYC Master Direction
In accordance with the PMLA and the RBI KYC Master Direction, Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, has laid down a ‘Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy’ (“KYC and AML Policy”).
Policy Objective
Key objectives of the KYC and AML Policy are as under:
Approval and Review of the KYC and AML Policy
Effective Date
The KYC and AML Policy shall be effective from the date of commencement of business by the Company as a Housing Finance Company.
Applicability
All the employees of the Company, while dealing with its customers, will have to ensure adherence with the KYC and AML Policy.
“Aadhaar number” means an identification number issued to an individual under subsection (3) of Section 3 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 (18 of 2016), and includes any alternative virtual identity generated under sub-section (4) of that section.
Aadhaar Actmeans Aadhaar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act, 2016.
“Authentication”,in the context of Aadhaar authentication, means the process as defined under sub-section (c) of section 2 of the Aadhaar Act.
Beneficial Owner (BO)
Explanation: Term ‘body of individuals’ includes societies. Where no natural person is identified under (a), (b) or (c) above, the beneficial owner is the relevant natural person who holds the position of senior managing official.
Cash Transaction Report (CTR)- - CTR will include the following:
Certified Copy of Officially Valid Document (OVD) shall mean comparing the copy of OVD with the original and recording the same as per the extant law and guidelines / directions.
Central KYC Records Registry (CKYCR) means an entity defined under Rule 2(1)(aa) of Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, to receive, store, safeguard and retrieve the KYC records in digital form of a customer.
Counterfeit Currency Transaction Cash transactions where forged or counterfeit Indian currency notes have been used as genuine. These transactions should also include transactions where forgery of valuable security or documents has taken place.
Counterfeit Currency Note Report Quarterly Report on status of receipt of counterfeit note received by any HFC to NHB;
Customer means a person who is engaged in a financial transaction or activity with the Company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.
Customer Due Diligence (CDD)means identifying and verifying the customer and the beneficial owner.
Designated Director means the Managing Director or a whole-time Director designated by the Board of Directors of the Company to ensure overall compliance with the obligations prescribed by the PMLA and the Rules.
Digital KYC means the capturing live photo of the customer and officially valid document or the proof of possession of Aadhaar, where offline verification cannot be carried out, along with the latitude and longitude of the location where such live photo is being taken by an authorized officer of the Company as per the provisions contained in the PMLA. The Company will adhere to the applicable requirements in this regard which may be prescribed by the Government/ the Reserve Bank of India (“RBI”) from time to time.
Equivalent E-document means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the client as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.
Know Your Client (KYC) Identifiermeans the unique number or code assigned to a customer by the Central KYC Records Registry
“FATCA” means Foreign Account Tax Compliance Act of the United States of America (USA) which, inter alia, requires foreign financial institutions to report about financial accounts held by U.S. taxpayers or foreign entities in which U.S. taxpayers hold a substantial ownership interest
Non-face-to-face customers-Customers who open accounts without visiting the branch/ offices of the Company or meeting its officials but will not include customers whose account has been opened as per Video Customer Identification Procedure.
Officially valid document (OVD)-Any document defined as OVD under rule 2(l)(d) of the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 and the amendments thereto (“PML Rules”) or any document as may be specifically prescribed by the Reserve Bank of India (“RBI”) as per the applicable regulations. Such OVD will be considered valid for verifying identity and proof of address of individual customer/ beneficial owner/ authorized signatory/ power of attorney holder.
Please refer to Annexure 1 for list of OVDs and other documents which are currently considered valid for verifying identity and proof of address of customers.
Offline Verification means the process of verifying the identity of the Aadhaar number holder without authentication, through such offline modes as may be specified by the Aadhaar regulations.
On-going Due Diligence- Regular monitoring of transactions in accounts to ensure that they are consistent with the customers’ profile and source of funds.
Periodic Updation means steps taken to ensure that documents, data or information collected under the CDD process is kept up-to-date and relevant by undertaking reviews of existing records at periodicity prescribed by the RBI or the PMLA and the Rules thereunder.
Politically Exposed Persons (PEPs) are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States/Governments, senior politicians, senior government/judicial/military officers, senior executives of stateowned corporations, important political party officials, etc.
Principal Officer (PO)- A senior official designated by the Board of Directors of the Company for overseeing and managing the KYC & AML policies and processes. The PO will be responsible for ensuring compliance, monitoring transactions, and sharing and reporting information as required under the law/regulations.
Suspicious transaction means a “transaction”, including an attempted transaction, whether or not made in cash, which, to a person acting in good faith:
Explanation: Transaction involving financing of the activities relating to terrorism includes transaction involving funds suspected to be linked or related to, or to be used for terrorism, terrorist acts or by a terrorist, terrorist organization or those who finance or are attempting to finance terrorism.
Transaction means a purchase, sale, loan, pledge, gift, transfer, delivery or the arrangement thereof and includes:
Video based Customer Identification Process (V-CIP) is an alternate method of customer identification with facial recognition and customer due diligence by an authorized official of the Company by undertaking seamless, secure, live, informed-consent based audio-visual interaction with the customer to obtain identification information required for CDD purpose, and to ascertain the veracity of the information furnished by the customer through independent verification and maintaining audit trail of the process. Such processes complying with prescribed standards and procedures shall be treated on par with face-toface Customer Identification Procedure.
Compliance of KYC policy
The KYC and AML Policy has the following 4 key elements:
CUSTOMER ACCEPTANCE POLICY (CAP) AND CUSTOMER DUE DILIGENCE (CDD)
The Company will adhere to the following criteria for acceptance of customers:
The aspects mentioned in the CAP would be reckoned while evolving the KYC/AML procedures for various types of customers and products. However, while developing the KYC/CDD procedures, the Company will ensure that its procedures do not become too restrictive or pose significant difficulties in availing its services by deserving general public, especially the financially and socially disadvantaged sections of society.
RISK MANAGEMENT
The Company will ensure that it has an effective and appropriate KYC procedures. The overall KYC/ AML program will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibilities will be explicitly allocated within the Company to ensure that the Company’s policies and procedures are implemented effectively.
Risk Categorization
The Company will categorize its customers into low, medium and high-risk category based on the assessment, profiling and perceived money laundering risk. The parameters such as customer’s identity, social/ financial status, nature of business activity, and information about the clients’ business etc. will be considered for the assessment.
Periodic Updation
The Company will conduct periodic updation of KYC documents at least once in every 2 years for high risk customers, once in every 8 years for medium risk customers and once in every 10 years for low risk customers in any of the following manner:
Internal Audit and Assurance
To provide reasonable assurance that its KYC and AML procedures are functioning effectively, audit of its KYC and AML processes will also be covered under the scope of Internal Audit of the Company. The audit findings and compliance thereof will be put up before the Audit Committee of the Board till closure of audit findings.
4 Money Laundering (“ML”) and Terrorist Financing (“TF”) Risk Assessment
It is understood that the ML and TF risks for the Company are likely to be low due to the following reasons:
However, in accordance with the regulatory requirements, the Company will carry out ML and TF Risk Assessment exercise periodically to identify, assess and take effective measures to mitigate money laundering and terrorist financing risk to which the Company may be exposed to. Such internal risk assessment should be commensurate to its size, geographical presence, complexity of activities/ structure, etc.
Such assessment process will consider various relevant risk factors and will take cognizance overall sector-specific vulnerabilities, if any, that the regulator/supervisor may share. Accordingly, it will frame its mitigation plan also. It should involve the relevant functions and have the following stages:
The Company shall conduct the ML and TF Risk Assessment at least once in a year. The outcome of the ML and TF Risk Assessment will be put up to the Audit Committee or to the Transaction Screening Committee.
CUSTOMER IDENTIFICATION
The Company shall undertake identification of customers in the following cases:
Reliance on customer due diligence done by third party
For the purpose of verifying the identity of customers at the time of commencement of an account-based relationship, the Company, may at their option, rely on customer due diligence done by a domestic third party, subject to the following conditions:
CUSTOMER DUE DILIGENCE (CDD) PROCEDURES
The Company will ensure compliance with the regulatory/ statutory requirements with respect to the Customer Identification Procedure to be carried out at different stages, i.e. while establishing a relationship; carrying out a financial transaction or when the Company has a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.
Customer identification means identifying the customer and verifying his/ her identity by using reliable, independent source documents, data or information. The Company will obtain sufficient information necessary to establish, the identity of each new customer, whether regular or occasional and the purpose of the intended nature of relationship.
CDD Procedure in case of Individuals
Documents/ Information to be collected
From an individual (who is prospective customer OR a Beneficial Owner/ Authorised Signatory/ Power of Attorney Holder related to any legal entity) the following documents/ information will be obtained:
Note:
The Company may also carry-out KYC verification under Digital KYC Process defined below (at sub-para 3.5.1.3).
Video based Customer Identification Process (“V-CIP”)
The Company may undertake live V-CIP, to be carried out by an official of the Company, for establishment of an account-based relationship with an individual customer, after obtaining his informed consent. The Company, if implements V-CIP, will adhere to the extant applicablerequirements:
Digital KYC Process
In case Digital KYC Process is adopted by the Company, it will ensure compliance with the following requirements:
Simplified procedure for opening accounts of Individuals
In case a person who desires to open an account is not able to produce any of the OVDs, the Company may at its discretion open accounts subject to the following conditions:
5 On-boarding the Borrowers through Central KYC Registry
Company shall endeavor to provide option to the applicants to be on-boarded through verifying their antecedents through Central KYC Registry
CDD Measures for Legal Entities
For due diligence with respect to legal entities, the Company will obtain the documents as listed in the Annexure 1.
Identification of Beneficial Owner
For opening an account of an entity who is not a natural person, the beneficial owner(s) (as defined above) shall be identified and all reasonable steps to verify his/her identity shall be undertaken. While doing so, the Company will keep the following in view:
ENHANCED DUE DILIGENCE (EDD) PROCEDURES
Accounts of non-face-to-face customers: The Company will ensure the first payment is done through any of the KYC Compliant account through banking channels
Accounts of Politically Exposed Persons (PEPs): If the Company decides to establish a business relationship with PEPs, it will ensure the following:
The above will also be applicable to accounts where a PEP is the beneficial owner.
MONITORING OF TRANSACTIONS/ ON-GOING DUE DILIGENCE
Ongoing monitoring is an essential element of effective KYC procedures. The Company can effectively control and reduce its risk only if it has an understanding of the normal and reasonable activity of the customer so that it can identify transactions that fall outside the regular pattern. The Company will put in place a process to identify and review complex and unusual transactions/ patterns which have no apparent economic or visible lawful purpose, or transactions that involve large amounts of cash or are inconsistent with the normal and expected activity of the customer.
APPOINTMENT OF THE DESIGNATED DIRECTOR AND THE PRINCIPAL OFFICER
The name, designation and address of Designated Director and Principal Officer shall be communicated to FIU-Ind.
REPORTING THE FINANCIAL INTELLIGENCE UNIT-INDIA (FIU-IND)
In accordance with the requirements under the PMLA, the Company will furnish the following reports, as and when required, to the Director, Financial Intelligence Unit-India (FIU-IND):
Additionally, the Company will submit ‘Statement showing the details of Counterfeit Banknotes detected’ to the NHB within 7 days from the last day of the respective quarter. Even in case of ‘Nil’ instance also, the statement is to be submitted to the NHB
The Company will maintain confidentiality in investigating suspicious activities and while reporting CTR/ CCR/ STR to the FIU-IND/ higher authorities. However, the Company may share the information pertaining to the customers with the statutory/ regulatory bodies and other organizations such as banks, credit bureaus, income tax authorities, local govt. authorities etc.
RECORD MANAGEMENT
SELLING THIRD PARTY PRODUCTS
The Company, if acting as agents while selling third party products as per regulations in force from time to time, will comply with the following aspects:
QUOTING OF PAN
Permanent account number (PAN) of customers shall be obtained and verified while undertaking transactions as per the provisions of Income Tax Rule 114B as amended from time to time. Form 60 shall be obtained from persons who do not have PAN
CUSTOMER EDUCATION
Seeking of certain KYC information from customers can sometimes lead to queries from the customer as to the motive and purpose of collecting such information. In this regard, the Company will take appropriate steps to educate customers on the objectives of the KYC measures.
HIRING OF EMPLOYEES AND EMPLOYEE TRAINING
ADHERENCE TO THE KYC AND AML GUIDELINES BY THE COMPANY’S AGENTS
SHARING KYC INFORMATION WITH CENTRAL KYC RECORDS REGISTRY (CKYCR)
The Company will capture the KYC information/ details as the KYC templates and share the same with the CKYCR in the manner as prescribed in the Prevention of Money Laundering (Maintenance of Records) Rules, 2005.
REPORTING REQUIREMENT UNDER FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) AND COMMON REPORTING STANDARDS (CRS)
The Company, if applicable, will adhere to the provisions of Income Tax Rules 114F, 114G and 114H. If the Company becomes a Reporting Financial Institution as defined in Income Tax Rule 114F, it will take requisite steps for complying with the reporting requirements in this regard.
Compliance with Section 51A of Unlawful Activities (Prevention) Act, 1967
The company will ensure compliance with Section 51A of UAPA Act, 1987 by screening the prospective and existing account holders for UN Sanction List or any other list as per UAPA Act, 1987. In event, any account holder resembles the name of as per the list it will be reported to FIU-IND and Ministry of Home Affairs. Further, other requirement including freezing of assets shall be followed by company.
Secrecy Obligations and Sharing of Information
Company shall maintain confidentiality of information as provided in Section 45NB of RBI Act 1934.
List of Documents considered valid for verifying identity and proof of address of prospective customers
S.N. | Type of Customer | Documents |
1 | Individual- Resident Indian (as a Customer/ Beneficial Owner/ Authorized Signatory/ Power of Attorney holder for another individual/ entity) |
OVD shall mean the following:
“Provided that in case the OVD furnished by the customer does not contain updated address, the following documents shall be deemed to be OVDs for the limited purpose of proof of address:
Provided, the customer shall submit OVD with current address within a period of three months of submitting the alternate documents specified above. Explanation: For the purpose of this clause, a document shall be deemed to be an OVD even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name. |
2 | Individual- NonResident Indian (NRI)/ Persons of Indian Origin (PIOs) |
Further, the original certified copy of OVD, certified by any one of the following, may be obtained:
|
3 | Sole Proprietary firms | In addition to OVD, PAN and photograph for the proprietor as an individual, any two of the following documents OR the equivalent e-document thereof, as a proof of business/ activity in the name of the proprietary firm shall also be obtained:
Note: In cases where the Company is satisfied that it is not possible to furnish two such documents as mentioned above, it may accept only one of those documents as proof of business/ activity, subject to contact point verification and collection of such other information and clarification as would be required to establish the existence of such firm. Further, it should be satisfied that the business activity has been verified from the address of the proprietary concern. |
4 | Company | In addition to OVD, PAN and photograph of the director/ manager/ employee (as an individual) holding authority to transact on the applicant company’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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5 | Partnership Firm | In addition to OVD, PAN and photograph of the partner/ manager/ employee (as an individual) holding authority to transact on the applicant firm’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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6 | Trust | In addition to OVD, PAN and photograph of the trustee/ beneficiary/ person (as an individual) holding an attorney to transact on the trust’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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7 | Unincorporated Association or a Body of Individuals | In addition to OVD, PAN and photograph of the person (as an individual) holding an attorney to transact on the entity’s behalf; certified copies of the following documents OR the equivalent edocument thereof:
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8 | Other entities not specifically covered above, such as societies, universities and local bodies like village panchayats | In addition to OVD, PAN and photograph of the person (as an individual) holding an attorney to transact on the entity’s behalf; certified copies of the following documents OR the equivalent edocument thereof:
|
List of Documents considered valid for verifying identity and proof of address of prospective customers
S.N. | Type of customer | Documents |
1 | Individual- Resident Indian (as a Customer/ Beneficial Owner/ Authorized Signatory/ Power of Attorney holder for another individual/ entity) |
OVD shall mean the following:
“Provided that in case the OVD furnished by the customer does not contain updated address, the following documents shall be deemed to be OVDs for the limited purpose of proof of address:
Provided, the customer shall submit OVD with current address within a period of three months of submitting the alternate documents specified above. Explanation: For the purpose of this clause, a document shall be deemed to be an OVD even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name. |
2 | Individual- NonResident Indian (NRI)/ Persons of Indian Origin (PIOs) |
Further, the original certified copy of OVD, certified by any one of the following, may be obtained:
|
3 | Sole Proprietary firms | In addition to OVD, PAN and photograph for the proprietor as an individual, any two of the following documents OR the equivalent edocument thereof, as a proof of business/ activity in the name of the proprietary firm shall also be obtained:
Note: In cases where the Company is satisfied that it is not possible to furnish two such documents as mentioned above, it may accept only one of those documents as proof of business/ activity, subject to contact point verification and collection of such other information and clarification as would be required to establish the existence of such firm. Further, it should be satisfied that the business activity has been verified from the address of the proprietary concern. |
4 | Company | In addition to OVD, PAN and photograph of the director/ manager/ employee (as an individual) holding authority to transact on the applicant company’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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5 | Partnership Firm | In addition to OVD, PAN and photograph of the partner/ manager/ employee (as an individual) holding authority to transact on the applicant firm’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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6 | Trust | In addition to OVD, PAN and photograph of the trustee/ beneficiary/ person (as an individual) holding an attorney to transact on the trust’s behalf; certified copies of the following documents OR the equivalent e-document thereof:
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7 | Unincorporated Association or a Body of Individuals | In addition to OVD, PAN and photograph of the person (as an individual) holding an attorney to transact on the entity’s behalf; certified copies of the following documents OR the equivalent edocument thereof:
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8 | Other entities not specifically covered above, such as societies, universities and local bodies like village panchayats | In addition to OVD, PAN and photograph of the person (as an individual) holding an attorney to transact on the entity’s behalf; certified copies of the following documents OR the equivalent edocument thereof:
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It is hereby declared that there has never been any levy of any penalty on Godrej Housing Finance by National Housing Bank or any by any other regulatory of statutory body.
Background
At Godrej Housing Finance Limited (“GHFL” or “the Company”), is a part of the Godrej Group which has an established reputation of honesty, integrity and sound governance over the years. The Company is, therefore, committed to maintaining the highest standards of Corporate Governance in its conduct towards shareholders, employees, regulators, customers, suppliers, lenders and other stakeholders. The Company’s philosophy of corporate governance is to achieve business excellence by enhancing the long-term welfare and value for its various stakeholders. The Company believes that corporate governance is about creating organisations that succeed in the marketplace with the right approach and values.
The Reserve Bank of India vide Paragraph 55 of Annexure IX of Master Direction – NonBanking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated 17th February 2021 (Directions) has prescribed that Housing Finance Companies (‘HFCs’) should frame their Internal Guidelines on Corporate Governance with the approval of the Board of Directors and host it on website.
Accordingly, the Company has framed its Internal Guidelines on Corporate Governance (“Guidelines”) with the approval of its Board of Directors
Objective
The objective of the Guidelines is to adopt the best standards of Corporate Governance through transparency in business ethics, accountability & required disclosure to its customers, the government/ regulatory authorities and other stakeholders.
Approval and Review of the Policy
The Board of Directors of the Company (“Board”) is the apex body constituted by the Shareholders for overseeing the Company’s overall functioning. The Board provides and evaluates the Company’s strategic directions, management policies and their effectiveness and ensures that Shareholders’ long-term interests are being served.
The Board along with the Committees constituted by it shall provide leadership and guidance for management of the Company.
It will be ensured that each of the Directors of the Company is eligible for appointment on the Board as per the Companies Act, 2013 (“Act”) and meets the Fit & Proper criteria prescribed by the Fit & Proper policy in line with the CG Directions.
The Company recognizes the importance of having a Board comprising of Directors who have a range of experiences, capabilities and diverse points of view. The Board of Directors of the Company are expected to have experience, expertise, capabilities as under:
The Board’s major responsibilities will be as under:
The Directors shall act in accordance with the duties as provided under the Act and prescribed regulations by NHB / RBI. The Independent Directors shall abide by the Code for Independent Directors under the Act. Further, the Board shall periodically review Compliance Reports of all laws applicable to the Company prepared by the Company as well as steps taken by the Company to rectify instances of non-compliance.
The Board’s strength shall be as per the constitutional documents of the Company. The Composition of the Board will be as per the applicable provisions of the Companies Act, 2013 & rules(“Act”) thereunder and the regulatory requirements prescribed by the Reserve Bank of India (“RBI”)/ NHB.
Fit and Proper Policy- The Company will have a Fit and Proper Policy, in accordance with the regulatory requirements, for ascertaining the fit and proper criteria of the Directors at the time of appointment, and on a continuing basis.
Declaration and Undertaking from the Directors-- The Company obtain a declaration and undertaking from all its directors giving information as per the Act and the regulatory requirements prescribed by the RBI/ NHB.
Deed of Covenant- The Company will get the Deed of Covenant signed with each of its Directors, as per the format prescribed by the RBI/ NHB.
Meetings of the Board of Directors- The Board meetings shall be held at least 4 times in a year, such that not more than 120 days shall intervene between 2 consecutive meetings. However, in case of any business requirements the Board meeting can be held at any time within the prescribed guidelines.
Information to be provided to the Board:
Quarterly Statement to the RBI/ NHB- The Company shall furnish a quarterly statement on change of directors, and a certificate from the Managing Director to the RBI/ NHB confirming that fit and proper criteria in selection of the directors has been followed. The statement submitted by the Company for the quarter ending March 31, shall be certified by its Statutory Auditors also.
Chief Risk Officer - Regulation 51 if the Master Directions state that a company is required to appoint a Chief Risk Officer and when it crosses Rs. 5000 crore of asset size.
All regulatory communications, including the letters / advisories received, shall be informed to the Board.
Brief details of various committees to be constituted by the Board are as follows:
Name | Type | Frequency | Constitution | Broad Role |
Audit Committee of Board | Board | Quarterly | 2 Non-Executive Independent Directors & 1 Non – Executive Director |
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Nomination & Remuneration Committee | Board | Quarterly | 2 Independent Directors & 1 Non – Executive Director |
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Risk Management Committee | Board | Quarterly | 1 Non-Executive Directors, 1 Independent Director & Managing Director & CEO |
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Wil-ful Defaulter Review Committee | Board | Need Based | 2 Independent Directors & Managing Director & CEO |
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IT Strategy Committee | Board & Executive | Half-Yearly | 1 Independent Directors, Managing Director & CEO and CTO |
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Executive Committee | Board & Executive | Need Based | 1 Non-Executive Directors, Managing Director & CEO and CFO | To take such operational decisions which have an impact on the operations of the company but are not in strategic in nature though require Board guidance |
Borrowing & Investment Committee | Board & Executive | Quarterly | Managing Director & CEO and CFO | To provide operational flexibility to the Company for its borrowing/ resource raising programmes and investment of surplus funds by it, from time to time |
Asset Liability Committee | Board & Executive | Quarterly | 1 Non-Executive Directors, Managing Director & CEO and CFO |
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Grievance Redressal Committee | Board & Executive | Quarterly | 2 Independent Directors Managing Director & CEO, CFO & CCO | To periodically review types & patterns of customer complaints, response TAT, regulatory escalations, recurring or systemic issues leading to customer complaints |
Customer Strategy Committee | Board & Executive | Quarterly | 1 Independent Director, Managing Director & CEO, CBO and CCO | Review the customer positive steps which are taken by the Company |
Credit Committee | Board & Executive | Need Based | 1 Non-Executive Directors, Managing Director & CRO | To take such credit related decisions which require a presence of larger body of senior officers of the Company including Board guidance |
IT Steering Committee | Board & Executive | Half-Yearly | Managing Director & CEO, CFO & CTO |
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Whistleblower Committee | Board & Executive | Need Based | To be appointed by Managing Director on need basis |
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Wilfful Defaulter Identification Committee | Board & Executive | Need Based | Managing Director & CEO, CFO & CRO |
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Prevention of Sexual Harassment Committee | Executive | Need Based | CHRO, CRO, CTO, CBO & EE |
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Transaction Screening Committee | Executive | Need Based | 1 Independent Director, CFO, | To review transactions and decide whether any needs to be reported in to the FIU-Ind |
Brief details of various committees to be constituted by the Board are as follows:
DISCLOSURE AND TRANSPARENCY
GHF shall put up to the Board of Directors, at regular intervals the following:
The Company shall also disclose the following in their Annual Financial Statements:
The Company shall rotate the partner/s of the Statutory Auditors firm conducting the audit, every 3 years so that same partner shall not conduct audit of the Company continuously for more than a period of 3 years. However, the partner so rotated shall be eligible for conducting the audit of the Company after an interval of 3 years. The Company shall incorporate appropriate terms in the letter of appointment of the firm of auditors to ensure compliance.
Pursuant to Section 178 of the Companies Act, 2013 (the “Act”) and the Rules framed thereunder (as amended from time to time), the Board of Directors of every listed public Company and the following classes of companies are required to constitute a Nomination and Remuneration Committee (Committee) of the Board and is required to formulate a policy ensuring the criteria for evaluation of performance and determination of remuneration based on the performance of Directors, KMPs and Senior Management.
Further, Housing Finance Companies – Corporate Governance (National Housing Bank) Directions, 2016 (NHB Directions) also require an HFC to constitute a Nomination Committee
The Policy is applicable for appointment, terms of appointment and continuation of appointment and review of employment terms of:
The key objectives of the Policy are as follows:
Unless the context otherwise requires, words and expressions used in this policy and not defined herein but defined in the Companies Act, 2013 (as amended from time to time), shall have the meaning respectively assigned to them therein.
Appointment criteria and qualifications:
TERM / TENURE OF MANAGING DIRECTOR/WHOLE-TIME DIRECTOR
The Company shall appoint or re-appoint any person as its Executive Chairman, Managing Director, Executive/ Whole-time Director or Manager for a term not exceeding 5 (five) years at a time. No reappointment shall be made earlier than 1 (one) year before the expiry of term.
Independent Director:
Evaluation
The Committee shall carry out evaluation of performance of Board, its Committees and every Director, KMP and Senior Management on an annual basis or at such regular intervals as may be considered necessary.
The evaluation of independent directors shall be done by the entire board of directors which shall includes
Provided that in the above evaluation, the directors who are subject to evaluation shall not participate.
Removal
Due to reasons for any disqualification mentioned in the Act or under any other applicable law, rules and regulations, thereunder, the Committee may recommend, to the Board with reasons to be recorded in writing, removal of a Director, KMP or Senior Management, subject to the provisions and compliance of the said Act, such other applicable law, rules and regulations.
Retirement
The Directors, KMP and Senior Management shall retire as per the applicable provisions of the Act and the prevailing HR policy of the Company. The Board will have the discretion to retain the Director, KMP, Senior Management in the same position/ remuneration or otherwise even after attaining the retirement age, for the benefit of the Company.
Remuneration to Non- Executive / Independent Director:
The remuneration / commission shall be in accordance with the statutory provisions of the Act and the Rules made thereunder for the time being in force. The Non- Executive / Independent Director may receive remuneration by way of fees for attending meetings of the Board or Committee thereof. Provided that the amount of such fees shall not exceed the maximum amount as provided in the Act, per meeting of the Board or Committee or such amount as may be prescribed by the Central Government from time to time.
Following disclosure of the Policy shall be made:
Board of Directors
Nomination and Remuneration Committee
The Governance framework mentioned herein shall be read along with terms of reference / Charter of Board / Committees approved by the Board of Directors. In case of any conflict, the Terms of Reference / Charter approved by Board to be preferred
The Company has adopted the Code of Ethics & Business Conduct, which lays down the principles and standards that should govern the actions of the Company and its employees.
In order to comply with the provisions of Section 177 of the Companies Act, 2013 and Rule 7 of the Companies (Meetings of the Board and its Powers) Rules, 2014 eligible company needs to have a Vigil Mechanism to enable the employees and the directors to report their genuine concerns or grievance.
Accordingly, this Whistle Blower Policy (“the Policy”) has been formulated with a view to provide a mechanism for employees of the Company to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.
The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees / Directors to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc
“Disciplinary Action” means any actionthat canbe takenonthe completionof /during the investigation proceedings including but not limited to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.
“Employee” means every employee of the Company (whether working in India or abroad)
“Director” means Director on the Board of Directors of the Company.
“Protected Disclosure” means a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity. Protected Disclosures should be factual and not speculative in nature.
“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation under this Policy
“Whistle blower” is someone who makes a Protected Disclosure under this Policy.
“Whistle Officer” means an officer who is nominated/ appointed to conduct detailed investigation of the disclosure received from the whistle blower and recommend disciplinary action. Currently, Mr. V Swaminathan, Head of Corporate Audit & Assurance is nominated as Whistle Officer.
“Whistle Committee” or “Committee” means a Committee of persons who are nominated/appointed to conduct detailed investigation of the disclosure received from the whistle blower and recommend disciplinary action. The Committee, if appointed, should include Senior Level Officers of Personnel & Admin, Internal Audit and a representative of the Company / Division/ Department where the alleged malpractice has occurred.
“Company” means, “Godrej Housing Finance Limited.”
“Good Faith”: An employee shall be deemed to be communicating in ‘good faith’ if there is a reasonable basis for communication of unethical and improper practices or any other alleged wrongful conduct. Good Faith shall be deemed lacking when the employee does not have personal knowledge on a factual basis for the communication or where the employee knew or reasonably should have known that the communication about the unethical and improper practices or alleged wrongful conduct is malicious, false or frivolous.
“Policy or This Policy” means, “Whistle Blower Policy.”
Various stakeholders of the Company are eligible to make Protected Disclosures under the Policy. These stakeholders may fall into any of the following broad categories:
A person belonging to any of the above-mentioned categories can avail of the channel provided by this Policy for raising an issue covered under this Policy.
The Policy covers malpractices and events which have taken place/ suspected to take place involving:
The Policy should not be used in place of the Company grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.
The responsibility for overall implementation and upkeep of this policy rests with the Whistle Blower committee.
Compliance with this policy is mandatory and the task of implementation of the policy is with the Human Resource team. Chief Human Resource Officer may delegate specific responsibilities of this policy to a specific employee of the company on the recommendation of leaders.
The policy is communicated by the CHRO to the entire organization as deemed necessary.
In this section, specific policies are defined which form the foundation of the Fair Practice Code for GHF. This policy is supported by other policies, additional templates, configuration documents and standard operating procedures where required.
MD & CEO can setup a Whistle Blower committee to whom Directors and employees shall address their serious concerns arising from irregularities, malpractices and other misdemeanors committed by the Company’s personnel.
The Whistle blower Committee of the Company will be approved by the Board of Directors.
Role of Whistle Blower Officer
Any employee who has a genuine complaint or concern about any fraud or violation of any law, rule or regulation or unacceptable/improper practice and/or any unethical practice may complain about this to his superior or to the designated person to attend to Whistle officer as mentioned below, or to the Audit Committee.
Mr. V. Swaminathan, has been appointed as the “Whistle Officer”, for Godrej Group with effect from May 1, 2010, and can be contacted in writing at Pirojshanagar, Eastern Express Highway, Vikhroli-East, Mumbai 400 079 or on telephone at +91 22 25194403 or on email at ve.swaminathan@godrejinds.com.
To keep consistency with the group policy and to have an external assured person to manage the sensitive function the company also appoints him as a “Whistle Officer” for GHF.
He shall be responsible for the following functions:
Role of the Whistle blower Committee
The Committee will decide on carrying out further investigation upon the receipt of the report of the official undertaking the preliminary investigation
Suitable disciplinary action (including termination of service) may be taken against the Subject in case he is found guilty of misconduct against the Whistle blower, in retaliation of a complaint submitted.
Head - HR shall assist Directors or employees who have witnessed offences and are in need of counselling about their roles and responsibilities in seeking a redressal of the wrongdoings. Interested concerns can reach out on ruhie.pande@godrejhf.com
WHISTLE BLOWER REPORTING
If an investigation leads the Designated Authority to conclude that an improper, unethical, fraudulent act or misconduct has been committed, the Designated Authority shall recommend to the management of the Company to take such disciplinary or corrective action against the erring officials (Subjects) as the disciplinary authority may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject(s) as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or Staff Conduct and Disciplinary Procedures.
A quarterly report on the findings under the Whistle blower Policy will be submitted to the ACB for information. The Human Resource department will be the convener of the Whistle blower Committee and will monitor and will submit the quarterly reports to the ACB.
The Whistle blower Policy shall be displayed on the Company’s intranet, and a paper copy of this will be made available to any person on demand from any of the offices of the Company. New employees in the Company will be informed about the Policy as part of their joining formalities.
Charge Description | CHARGE AMOUNT EXCLUSIVE OF GST IN INR | ||
Processing Fees | Mortgage loan up to 2% of the loan amount, Flexible loan up to 3% of the loan amount |
||
1st Presentation EMI Bounce every month | 1000 | ||
2nd Presentation EMI Bounce every month | 1000 | ||
Late Payment Penalty per Month | 2% of the total EMI outstanding (principal + interest) | ||
Repayment Mode (Cheque / NACH) Swap | 500 | ||
Foreclosure and Part Pre-payment charges | |||
Type of Borrower | Type of Loan | Type of ROI | Applicability |
Individual | (a) Housing Loans, (b) Personal Loans, (c) LAP other than Business purpose |
Floating, Semi-fixed (during the period ROI is floating) |
NIL |
Fixed rate of Interest | Nil – If paid through own source of funds 4% on prepaid amount in case of Balance takeover by any other financial institution |
||
(a) LAP Business (b) Non–Residential Purchase Loans
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Floating, Fixed & Semi-fixed | Balance Takeover from a bank/ HFC/ NBFC/ any other Financial Institution – 4% for foreclosure on Principal pre-paid | |
Self-source – 4% on Principal pre-paid in case amounts prepaid in a financial year is over 20% of the o/s loan amount. | |||
Non-Individual | Housing Loans | Floating, Semi-fixed (during the period ROI is floating) |
NIL |
Fixed rate of Interest | Nil – If paid through own source of funds 4% on prepaid amount in case of Balance takeover by any other financial institution |
||
Any other | Any | 4% on principal pre-paid | |
Loan cancellation charges | Nil up to 30 calendar days or the 1st EMI due date, whichever is earlier. Post that 1% of principal outstanding. | ||
Physical Statement of Account | 500 | ||
Physical Duplicate NOC | 500 | ||
Physical Repayment Schedule | 500 | ||
List of Documents | 1000 | ||
EMI Pick Up | 500 | ||
Physical copy of Property Documents | 2000 | ||
Charges to issue Loan Foreclosure Letter | 500 | ||
Conversion or Switch Charges (Floating to Fixed or Fixed to Floating) | Up to 1.5% of the principal outstanding | ||
Repricing Fee | 1% of the Principal Outstanding | ||
Document Retreival (Per Retreival) | 500 | ||
Stamping or Franking | On Actuals | ||
Bank charges on cheque / ECS / NACH bounce | On Actuals as charged by customer’s bank | ||
Charges towards Legal/ SARFAESI/ Recovery action | On Actuals | ||
Charges to be paid to CERSAI/ CKYCR | As applicable and prescribed by CERSAI/ CKYCR | ||
Demand draft or pay order re-issuance or cancellation | 750 | ||
Other Documents | 500 | ||
Property Documents Holding Fee (Charged per month post 60 days from date of loan closure) | 750 | ||
Miscellaneous Charges | On Actuals | ||
Technical Fees (For additional Property) | On Actuals | ||
Valuation Fees (In Construction Linked Loans) | On Actuals | ||
Charges towards Stamp Duty / Registration / Intimation of Mortgage / Creation of Mortgage | As Applicable & Prescribed by the relevant Government Authority |
1. For Semi-fixed pre-payment charges to be levied as per prevailing rate at time of closing
2. Refund of Fee: No refund of fee shall be allowed in any case at any point of time
3. Please note: In addition to the above fee and charges, GST, any cess & other taxes, levies etc.
prescribed by the Government of India or respective state will also be charged. Further the above fee and charges are subject to change and will be at the sole discretion of GHF.
4. The Company has adopted an interest rate model based on cost of funds, cost of operations, various risks associated with the loan & security etc. An additional spread, based on the overall risk perceived, is factored in the pricing, which is function of income, credit history, credit information, profile of the borrower, internal assessment of the Company etc. Accordingly, the applicable rate of interest may be different for different customers’ loan exposures.
Pradhan Mantri Awas Yojana (Urban) Mission launched on 25th June 2015 which intends to provide housing for all in urban areas by year 2022. One of the key components of this mission is the Credit Linked Subsidy scheme that focusses on providing loans in subsidised manner to the under privileged sections of the society. The beneficiary segments are divided into 4 groups viz. – Economically Weaker Sections (EWS), Lower Income Group (LIG) and Middle-Income Group (MIG – I & II). The scheme will be valid till Mar’2022 for EWS and LIG; and for MIG segments the validity was recently increased to March’2021.
Scheme Snapshot – The calculation parameters used for calculating subsidy
Particulars | EWS | LIG | MIG I | MIG II |
Annual Household Income (Rs.) | Upto 3,00,000 | 3,00,001 - 6,00,000 | 6,00,001 - 12,00,000 | 12,00,001 - 18,00,000 |
Interest Subsidy (% p.a.) | 6.50% | 6.50% | 4.00% | 3.00% |
Maximum loan tenure (in years) | 20 | 20 | 20 | 20 |
Eligible Housing Loan Amount for Interest Subsidy (Rs.) | 6,00,000 | 6,00,000 | 9,00,000 | 12,00,000 |
Dwelling Unit Carpet Area | 30 Sq. m. | 60 Sq. m. | 160 Sq. m. | 200 Sq. m. |
Discount Rate for Net Present Value (NPV) calculation of interest subsidy (%) | 9.00% | 9.00% | 9.00% | 9.00% |
Maximum subsidy amount | Rs. 2.67 lakh | Rs. 2.67 lakh | Rs. 2.35 lakh | Rs. 2.30 lakh |
Scheme FAQ’s
Category | Question | Answer |
Scheme Related | What is Pradhan Mantri Awas Yojana (Urban) and its objectives and scope? | Pradhan Mantri Awas Yojana (Urban) was launched on 25th June 2015 for providing pucca houses to all eligible beneficiaries by 2022. The Mission provides Central Assistance to implementing agencies through States/Union Territories (UTs) and Central Nodal Agencies (CNAs) for providing houses to all eligible families/ beneficiaries against the validated demand for houses There are multiple options under which the benefits can be availed by the beneficiaries depending on their income, finance and availability of land,
For more details you can visit https://pmay-urban.gov.in/ |
GHF offering | IS GHF offering all the PMAY schemes ? | No , Godrej Housing Finance is the Primary Lending Institution only for Credit Linked Subsidy Schemes(CLSS) |
Scheme Related | What is Credit Linked Subsidy Scheme (CLSS)? | PMAY – CLSS provides for subsidised Loans by way of credit into the Loan accounts of borrowers eligible under this scheme. Interest Subsidy up to 2.67 lakh per house is available for Beneficiaries of Economically Weaker Section (EWS)/Low Income Group (LIG). Middle Income Group (MIG)-I and Middle Income Group (MIG)-II seeking housing loans from Banks, Housing Finance Companies and other such institutions for acquiring/constructing houses can avail a maximum of Rs. 2.35 Lac subsidy under this scheme. |
Scheme Related | Who can avail of PMAY CLSS? How are beneficiaries defined under PMAY? |
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Scheme Related | What are the documents to be uploaded by the beneficiary? | Beneficiary to mandatorily upload the house photograph for which subsidy has been availed through PMAY (U) application. |
Scheme Eligibility | What are the category definitions for PMAY subsidy? |
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Scheme Eligibility | What are the Property related conditions for PMAY CLSS? |
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Scheme Eligibility | Can an under-construction property be eligible for PMAY subsidy or only fully constructed properties are only considered? | Yes, under construction properties are eligible for PMAY subsidy provided it meets all the mandatory criteria. However, the property needs to be completed in 36 months from the date of the first disbursement, otherwise the subsidy would be recalled by the PLI and credited to the Central Nodal Agency Account |
Scheme Eligibility | What happens if the construction of the property is stalled? | In such cases, the loan becomes ineligible for PMAY interest subsidy. |
Scheme Eligibility | I am buying the house in my company’s name. Can I still be eligible for PMAY subsidy? | No, the PMAY scheme can be availed by individual borrowers only. |
Scheme Eligibility | Is this applicable for properties in rural areas? | No, the properties should be in urban areas basis 2011 census. |
Scheme Eligibility | Does land purchase come under Pradhan Mantri Awas Yojana? | No, land cannot be purchased under PMAY. The scheme is applicable to provide affordable homes at subsidised rates to every household in India. |
Scheme Eligibility | Is Woman Ownership Mandatory To Be Eligible For This Subsidy? | We recommend and counsel that women ownership for houses across categories be promoted. |
Scheme Eligibility | Will I be eligible for the CLSS scheme if I am a co-applicant of my father's home loan for a property owned by him? | No. If you are a co-applicant of a home loan, you are not eligible for CLSS benefits under PMAY. If an individual or any of their family members already own a pucca house, he or she cannot get interest subsidy for a home loan under the scheme. |
Scheme Eligibility | Can we get 30 year home loan for EWS beneficiary? | Yes, beneficiaries can apply for sanction of home loan for tenure of 30 years, which would depend on the due diligence norms of the PLIs concerned. The subsidy however, the interest subsidy would be restricted on home loans upto Rs. 6 lakhs/9 Lakhs /12 Lakhs for tenure not more than 20 years as per the category in which the beneficiaries are eligible. |
Scheme Eligibility | Is there a limit on the home loan amount under PMAY? | There is no cap on the loan amount under PMAY it is dependent on the credit worthiness of applicant and internal policy of GHF. |
Subsidy Release | How the subsidy is to be released to beneficiaries? | The subsidy would be released by the Central Nodal Agency (CNA) based on the disbursements made by Primary Lending Institutions (PLI) to the beneficiaries. Subsidy, so disbursed by the CNA to the PLI, will be credited by the PLI to the borrower’s account by deducting it from the principal loan amount and reduce his EMI. The borrower will pay EMI on the remainder of the principal loan amount thus lowering the overall EMI E.g., the borrower avails a loan for Rs. 48.00 lakhs and subsidy works out to Rs. 2.67 lakhs, the amount (Rs. 2.67 lakhs) would be reduced upfront from the loan (i.e., the loan would reduce to Rs. 45.33 lakhs) and the borrower would pay EMIs on the reduced amount of Rs. 45.33 lakhs |
Subsidy Release | How will I know that the PMAY subsidy is approved / credited? | On credit of the PMAY subsidy amount in loan account, GHF will inform the details of the same to the customers. |
Subsidy Release | Why is the PMAY subsidy adjusted against my EMI amount only? I want the EMI to remain the same and tenure to be reduced? | As per PMAY guidelines, the subsidy amount has to be adjusted against the total Principal amount and the reduction is to be given in EMI amount, hence it is adjusted accordingly. |
PMAY – Balance Transfer | What will happen if I transfer my current loan which is under PMAY scheme from GHF to other financial institution (before PMAY subsidy credit)? | In case the loan is eligible for PMAY subsidy, GHF will initiate the claim to the Central Nodal Agencies (CNAs) and if the loan is transferred from GHF before receiving the subsidy amount, this amount will not be credited to the customer loan account. Also, when the new financial institution will apply for PMAY claim, it may be rejected by CNAs on account of duplicity. |
PMAY – Loan Closure | What happens when beneficiary after getting CLSS benefit, sells the property and pre-closes the loan. Is subsidy to be refunded to CNAs? | No, the subsidy amount will not be required to be refunded in such scenario. |
PMAY Charges | Is there a processing fee for availing loan under PMAY? | There is no charge for the borrower. However, the lender is paid a sum of Rs 3,000 by the Central Government as processing fees. However, fee can be charged on loan amount above subsidy eligible loan amount. |
PMAY Delinquency | What happens when the PMAY subsidised loan becomes delinquent? | In case any account which has received PMAY subsidy becomes delinquent, the customer will have to return the credit subsidy amount to the CNAs via GHF. |
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.
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:
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 https://nhb.org.in/Grievance-Redressal-System/Lodging-Complaint-Against%20HFCs-NHB%20%83yr%20Physical-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
Most important terms and conditions of the loan agreed between __________________________________________________ (hereinafter referred to as “the Borrower”) and Godrej Housing Finance Limited (“the Company” or “GHF”) having registered office at Godrej One, Pirojshanagar, Eastern Express Highway,Vikhroli (East), Mumbai, Maharashtra- 400079 are as under:
Loan Account No. | |
Sanctioned Loan Amount | |
Type of Loan | |
Purpose of Loan |
Type of Rate of Interest (”ROI”) | |
Fixed Rate of Interest (”ROI”) | _________________ % per annum interest shall be payable by the Borrower at monthly rests or as per the terms & conditions mentioned in the Loan Agreement |
Floating / Varibale Rate of Interest (”ROI”) | _________________ % per annum Godrej Housing Finance Prime Lending Rate (“GHFPLR”) (as on date) + / - ________________ % per annum Spread _________________ % per annum Applicable Rate of interest |
Semi Fixed Rate of Interest (“ROI”) | _________________ % per annum interest shall be payable by the Borrower at monthly rests or as per the terms & conditions mentioned in the Loan Agreement for_______________ months. + / - ________________ % per annum Spread ____________ % per annum applicable “ROI” from ___________ month onwards. |
Subsidy (if applicable) | Eligibility to any subsidy program shall be as per its prescribed eligibility criteria. The application shall be forwarded to competent authority only in case it meets the criteria. Company cannot assure receipt of subsidy as decision rests with competent authority. |
Moratorium (if applicable) | Borrower may be offered moratorium on the loan subject to its qualification to company’s internal policy & under specific product terms. Under moratorium, borrower will not be making any payment for moratorium tenure and interest will not be due but shall be capitalized and added to principal. Post expiry of moratorium borrower shall make payment as per the repayment schedule. |
Date of reset of Rate of Interest | The applicable rate of interest on the loan will be revised/ reset with the change in the GHFPLR. Any change in GHFPLR will be notified to the Borrower in the mode and manner as mentioned below in section Notice / Communication relating to Rate of Interest, Fee & Charges. |
Loan Tenor (Total Number of EMIs to be paid) | ______________ Months subject to change in case of Floating/ Semi-Fixed Rate of interest |
Instalment Type | Monthly |
EMI/ PEMII (as on date) | Rs. _____________________ (subject to change in case of Floating Rate of interest or Type of Repayment Plan). |
Repayment Plan - Moratorium Period | __________________ months |
EMI Break Months (If applicable) | EMI break, subject to qualification to specific credit norms and satisfactory repayment performance by the borrower in sole opinion of lender, for specific pre-agreed months wherein there will be an increase in EMI for all tenure but the customer need not pay EMI for specified months. For more details refer the amortization schedule |
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Borrower
____________
Co-Borrower 1
____________
Co-Borrower 2
____________
Co-Borrower 3
Date of Commencement of PEMII | Basis final disbursement date Before 15th of the month – starts next month onwards Post 15th of the month – starts second month onwardss |
Date of Commencement of EMI | EMI start date depends on the projection completion date, loan structure and product features. For more details refer the amortization schedule. |
Due Date for payment of EMI/ PEMII | 3rd of the month 6th of the month |
In case of any change/revision in applicable Rate of Interest, the Company, at its sole discretion, may revise the EMIs or tenor of the loan or both and inform the customer through prescribed mode. Accordingly fresh ECS /NACH mandate, if required, will have to be provided by the Borrower for revised EMIs. In case of partially disbursed cases, Pre Equated Monthly Instalment Interest (PEMII) may be required to be paid on monthly basis on the due date. PEMII will be charged from the date of the first disbursements to the date of commencement of EMI. In case of delayed payment, overdue interest for the delayed period will be charged at rates mentioned by the Company from time to time. The above terms are subject to change as per market movement or company policy which are explained in detail in loan agreement |
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Annual Outstanding Balance Statement | To be issued within 30 Days of closure of financial year |
Obtaining insurance is not mandatory and neither linked to the Loan. However in order to safeguard the interests of the dependents in the event of untimely death of borrower or in event of damage to the property, the company facilitates obtaining of a life insurance policy for securing loan amount & property insurance for the collateral. Brief details of it are as below:
Company facilitates insurance from an IRDA registered insurance company with whom it has a Master Policy. Policy will be issued as subject to the terms and conditions set out by the Insurer.In the event of death / damage to property the proceeds will be first used for extinguishing loan liability post which the sum, if any, shall be transferred to heirs / borrowers.
Company makes no warranty or representation about the insurance company or product & all guidelines issued by the Insurere on claims, policy, surrender among others will be applicable.
Any grievance related to insurance is to be taken up with insurance company
Taking insurance policy is not linked with obtaining loan.
Procedure for intimation of the changes in Rate of Interest/ EMI or applicable charges | Any revision in rate of interest or fee/ charges by the Company shall be notified through any one or more of the following media and shall be construed as full notice to the customer:
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Mortgage of below mentioned property in favour of the Company |
Details of the Property Mortgaged:_________ |
Other Security:_____________ |
Detail of Guarantor(s) :________ |
Any other security as per Sanction Letter : |
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Borrower
____________
Co-Borrower 1
____________
Co-Borrower 2
____________
Co-Borrower 3
Charge Description | CHARGE AMOUNT EXCLUSIVE OF GST IN INR | ||
Processing Fees | Mortgage loan up to 2% of the loan amount, Flexible loan up to 3% of the loan amount |
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1st Presentation EMI Bounce every month | 1000 | ||
2nd Presentation EMI Bounce every month | 1000 | ||
Late Payment Penalty per Month | 2% of the total EMI outstanding (principal + interest) | ||
Repayment Mode (Cheque / NACH) Swap | 500 | ||
Foreclosure and Part Pre-payment charges | |||
Type of Borrower | Type of Loan | Type of ROI | Applicability |
Individual | (a) Housing Loans, (b) Personal Loans, (c) LAP other than Business purpose |
Floating, Semi-fixed (during the period ROI is floating) |
NIL |
Fixed rate of Interest | Nil – If paid through own source of funds 4% on prepaid amount in case of Balance takeover by any other financial institution |
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(a) LAP Business (b) Non–Residential Purchase Loans
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Floating, Fixed & Semi-fixed | Balance Takeover from a bank/ HFC/ NBFC/ any other Financial Institution – 4% for foreclosure on Principal pre-paid | |
Self-source – 4% on Principal pre-paid in case amounts prepaid in a financial year is over 20% of the o/s loan amount. | |||
Non-Individual | Housing Loans | Floating, Semi-fixed (during the period ROI is floating) |
NIL |
Fixed rate of Interest | Nil – If paid through own source of funds 4% on prepaid amount in case of Balance takeover by any other financial institution |
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Any other | Any | 4% on principal pre-paid | |
Loan cancellation charges | Nil up to 30 calendar days or the 1st EMI due date, whichever is earlier. Post that 1% of principal outstanding. | ||
Physical Statement of Account | 500 | ||
Physical Duplicate NOC | 500 | ||
Physical Repayment Schedule | 500 | ||
List of Documents | 1000 | ||
EMI Pick Up | 500 | ||
Physical copy of Property Documents | 2000 | ||
Charges to issue Loan Foreclosure Letter | 500 | ||
Conversion or Switch Charges (Floating to Fixed or Fixed to Floating) | Up to 1.5% of the principal outstanding | ||
Repricing Fee | 1% of the Principal Outstanding | ||
Document Retreival (Per Retreival) | 500 | ||
Stamping or Franking | On Actuals | ||
Bank charges on cheque / ECS / NACH bounce | On Actuals as charged by customer’s bank | ||
Charges towards Legal/ SARFAESI/ Recovery action | On Actuals | ||
Charges to be paid to CERSAI/ CKYCR | As applicable and prescribed by CERSAI/ CKYCR | ||
Demand draft or pay order re-issuance or cancellation | 750 | ||
Other Documents | 500 | ||
Property Documents Holding Fee (Charged per month post 60 days from date of loan closure) | 750 | ||
Miscellaneous Charges | On Actuals | ||
Technical Fees (For additional Property) | On Actuals | ||
Valuation Fees (In Construction Linked Loans) | On Actuals | ||
Charges towards Stamp Duty / Registration / Intimation of Mortgage / Creation of Mortgage | As Applicable & Prescribed by the relevant Government Authority |
1. For Semi-fixed pre-payment charges to be levied as per prevailing rate at time of closing
2. Refund of Fee: No refund of fee shall be allowed in any case at any point of time
3. Please note: In addition to the above fee and charges, GST, any cess & other taxes, levies etc.
prescribed by the Government of India or respective state will also be charged. Further the above fee and charges are subject to change and will be at the sole discretion of GHF.
4. The Company has adopted an interest rate model based on cost of funds, cost of operations, various risks associated with the loan & security etc. An additional spread, based on the overall risk perceived, is factored in the pricing, which is function of income, credit history, credit information, profile of the borrower, internal assessment of the Company etc. Accordingly, the applicable rate of interest may be different for different customers’ loan exposures.
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Any Special Condition: As per the Sanction Letter/ Loan Agreement, if any |
The Borrower is expected to pay the EMI or PEMI regularly on due date without any notice, reminder or intimation. If the amount due is not paid within the agreed timelines, the Company will follow-up with/ send reminders to the Borrower/ Guarantor for payment of dues by Post, Telephone, E-mail, SMS , any other electronic means and/or through third parties appointed for collection purpose. Any third party so appointed by the Company will be required to adhere to the code of conduct of the Company for recovery of dues. Further, the Company is required to provide Credit information relating to its borrowers to Credit Information Companies (CICs) periodically. Hence, to avoid any adverse impact on the credit history with CICs like CIBIL, it is advised that the Borrower should ensure timely payment of the amount due on the loan amount. In the event of default, all outstanding amounts owned by the Borrower to the Company shall become due as per the terms of the Loan Documents and the Company may undertake such necessary processes/ measures to enforce rights available to it under the Loan Documents including but not limited to charging Overdue/ Legal Charges, Charges for recovery of dues by enforcing the Security in accordance with the remedy available under the Law. |
For any assistance and further information, you may connect the Customer Service team of the Company through below modes between 9 AM to 6 PM on working days: | |
1. Contact the branch manager / branch in charge of the branch nearby you. | |
2. Call our Customer care No.: 022-68815555 | |
You can also write an email to us at the E-Mail Id: customercare@godrejhf.com | |
For further details, you please visit the Company’s website: www.godrejhf.com | |
You can collect the following documents by visiting our branch as per the mentioned timelines: | |
Loan Account Statement | Within 1 working days |
Photocopy of the title documents | Within 7 working days |
Return of Original document on closure of the loan | Within 45 working days |
Complaint Point | 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 |
First Escalation | Grievance Redressal Officer: Aarti Dhurandhar E-mail ID.: nodalofficer@godrejhf.com Telephone no.: 8657764527 Address :Godrej Housing Finance, 3rd Floor, Godrej One Pirojshanagar, Vikhroli East, Mumbai, 400079, Maharashtra, India |
NHB (In case delayed or no response) | Complaint Redressal Cell of NHB Online mode: https://grids.nhbonline.org.in OR Offline mode: By post, in prescribed format available at https://nhb.org.in/Grievance-Redressal-System/Lodging-Complaint-Against%20HFCs-NHB%20%83yr%20Physical-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 |
Important Points to Note:
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.
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Borrower
____________
Co-Borrower 1
____________
Co-Borrower 2
____________
Co-Borrower 3
GHF endeavours 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.
The above mentioned Most Important Terms and Conditions (MITC) are not exhaustive and are to be read in conjunction with the terms contained in Sanction letter and the Loan Agreement and the other documents which the borrower has executed with Godrej Housing Finance Limited. In case of any conflict in the terms, the terms as provided in the Loan Agreement shall prevail.
With Warm Regards
For Godrej Housing Finance Limited
Authorised Signatory
I have received a copy of the document containing Most Important Terms and Conditions in my preferred language pertaining to the loan availed by me. The above terms and conditions have been read by the Borrower(s) / read over to the borrower by Shri/Smt. ________of the Company. I confirm that I have understood the above Most Important Terms and Conditions and I accept them. |
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Applicant | ___ | Co-Borrower 1 | ___ |
Signature | ___ | Signature | ___ |
Co-Borrower 2 | ___ | Co-Borrower 3 | ___ |
Godrej Housing Finance Limited (“Godrej” or “GHF” or “Company”) conducts itself with highest standard of integrity and has always followed both letter and spirit of the law.
Related party transactions can present a potential or actual conflict of interest which may be against the best interest of GHF and / or its shareholders. GHF does not promote any transaction which may be at variance with the established principles of Corporate Governance or which does not meet the highest standard of ethics or integrity.
This policy shall regulate transactions between the Company and its Related Parties based on the laws and regulations applicable to the Company.
In terms of the provisions of Section 188 of the Companies Act, 2013, the Company is required to follow the procedure as prescribed for the Related Party Transactions for which inter alia it is required to draft a Related Party Transaction Policy (Policy) as per the extant law and adhere to it for operations.
The Reserve Bank of India vide Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated 17th February 2021 prescribed that Housing Finance Companies (HFCs) with asset size of Rs. 50 crore and above should evolve a Related Party Transaction Policy (Policy) and share the same in public domain.
This Policy is intended to ensure due and timely identification, approval, disclosure and reporting of transactions between GHF and any of its Related Parties in compliance with the applicable laws and regulations as may be amended from time to time.
The provisions of this Policy are designed to govern the approval process and disclosure requirements to ensure transparency while conducting Related Party Transactions and to comply with the statutory provisions in this regard.
“Act” means Companies Act, 2013 and rules made thereunder, as amended 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
“Associate” means an enterprise in which the Company has a significant influence, but which is not a subsidiary company of the Company having such influence and includes a joint venture company and the term “Associate Company” shall be interpreted accordingly. For the purpose of this definition, “Significant Influence” means control of at least twenty percent of total share capital, or of business decisions under an agreement.
“Board” means the Board of Directors of the Company.
“Committee” means Audit Committee of the Company as constituted or reconstituted by the Board of Directors of the Company in accordance with the Section 177 of the Companies Act, 2013 read with the rules framed thereunder (“Act”).
“Company” means Godrej Housing Finance Corporation Limited.
“Company Secretary” means a person who is appointed by the Company to perform the functions of the Company Secretary under provisions of the Companies Act, 2013;
“Directors” means Directors appointed by the Board including executive, non-executive and independent directors.
“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 and Audit Committee may lay down the principles for determining ordinary course of business in accordance with the statutory requirements and other industry practices and guidelines.
“Independent Director” means a director referred to in Section 149(6) of the Companies Act, 2013.
“KMP” or “KMPs” means the following key managerial personnel:
“Member” means a Director of the Company appointed as member of the Committee.
“Material Related Party Transaction” means a transaction with a Related Party in relation to –
“NHB Guidelines” means and includes NHB Act, 1987, NHB Directions, 2010, NHB Notifications, Circulars and others such communications thereto.
“Relative” with reference to a Director or KMP means persons as defined under Section 2(77) of the Companies Act, 2013 and rules prescribed thereunder.
“Related Party” have the meaning as defined in Section 2(76) of Companies Act, 2013Regulation 2(1)(zb) of the Securities and Exchange Board of India (Listing Obligations And Disclosure Requirements) Regulations, 2015.
"Related Party Transaction" means the transaction under Section 188 of the Companies Act, 2013 encompasses all contracts or arrangements with a Related Party and have
have the meaning as defined under Regulation 2(1)(zc) of the Securities and Exchange Board Of India (Listing Obligations And Disclosure Requirements) Regulations, 2015 as means transfer of resources, services or obligations between a listed entity and a related party, regardless of whether price is charged and a transaction with a related party shall be construed to include a single transaction or a group of transactions in a contract, including but not limited to the following –
A transaction shall be construed to include a single transaction or a group of transactions in a contract.
“Senior Management Personnel / Senior Management” means personnel of the company who are members of its core management team excluding Board of Directors comprising all members of management one level below the executive directors, including the functional and departmental heads.
Unless the context otherwise requires, words and expressions used in this policy and not defined herein but defined in the Companies Act, 2013 or NHB Act, 1987, NHB Directions, Notifications, Circulars or guidelines as may be amended from time to time shall have the meaning respectively assigned to them therein.
Identification of Related Parties
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 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.
Also, every officer of the Company entrusted with the authority to enter into any transaction shall be responsible for providing notice to the Board or Audit Committee, through the Company Secretary of the Company of any Related Party Transaction involving the Company. The Board / Audit Committee, through the Company Secretary will determine whether the Transaction does, in fact, constitute a Related Party Transaction requiring compliance with this Policy.
Such notice of any Related Party Transaction should be given at least 1 week 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.
Ordinary Course of Business
The phrase Ordinary Course of Business is not defined under the Act or Rules made thereunder. The Company shall adopt a reasonable approach / methodology to demonstrate ‘Ordinary Course of Business’ which shall, inter alia, include the Nature of the transaction, the frequency / regularity / length of time the company is engaged in such transaction, such transaction / action is consistent with the past practices and was taken in the ordinary course of the normal day-today operations of such company, common commercial practice i.e. customarily taken, in the ordinary course of the normal day-to-day operations of other companies that are in the same / similar line of business.
Arms-Length Transaction
For transactions between two related parties to be considered to be at Arm’s Length Pricing, the transaction should be conducted between the two parties as if the parties were unrelated, so that there is no conflict of interest i.e. Arm’s Length Pricing is the condition or the fact that the two related parties transact as independent (un-related) parties and on an equal footing from one or more of the following aspects viz. nature of goods / services, risk assumed, assets / resources employed, key terms / covenants.
In the absence of any guidelines on Arm’s Length Pricing in the Act, the Company shall adopt reasonable approach / methodology to demonstrate Arm’s Length Pricing for the specified Related Party Transactions identified, which shall, inter alia, include, the nature of the transaction, description of functions to be performed, risks to be assumed and assets to be employed, key terms / special terms in the arrangement forming part of a composite transaction;
The Company shall adopt an appropriate framework to assess whether transactions with related parties are done at an Arm’s Length and Company adopts generally accepted practices and principles in determining whether the transaction is at “Arm’s Length”.
Materiality Threshold for Related Party Transaction
The Company follows Materiality Thresholds for Related Party Transactions as defined under Definition section of this Policy, which are not in the ordinary course of business and/or not at arm’s length basis.
Guiding Principles for Approval of Related Party Transactions
For seeking approval of Audit Committee and the Board of Directors, as the case may be, for Related Party Transaction(s), all relevant material information of the Related Party Transaction(s), 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 reject a Related Party Transaction, the Board/ Audit Committee will consider the following factors, among others, to the extent relevant to the Related Party Transaction:
Related Party Transaction not approved under the policy
In the event the Company becomes aware of a Related Party Transaction with a Related Party that has not been approved under this Policy prior to its consummation, the matter shall be reviewed by the Committee / Board.
The Committee / Board shall consider all the relevant facts and circumstances regarding the Related Party Transaction, and shall evaluate all options available to the Company, including ratification, revision or termination of the Related Party Transaction.
The Committee / Board shall also examine the facts and circumstances pertaining to the failure of reporting such Related Party Transaction to the Committee under this Policy and shall take any such action it deems appropriate.
In any case, where the Committee / Board determines not to ratify a Related Party Transaction that has been commenced without approval, the Committee / Board, as appropriate, may direct additional actions including, but not limited to, immediate discontinuation or rescission of the transaction.
In connection with any review of a Related Party Transaction, the Committee / Board has authority to modify or waive any procedural requirements of this Policy.
Approval of the Audit Committee
Every related party transaction shall be approved by the Audit Committee (“Committee”) as required in terms of the provisions of the Companies Act, 2013 and the Directions. The Audit Committee of the Board will review and, if appropriate, approve Related-Party Transactions. Accordingly, 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:
After reviewing such information and being satisfied that there is a need for such 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 to transactions
The Committee may consider to grant Omnibus approval of such transactions only if it is determined by the Committee that such transactions are:
Such omnibus approval shall specify:
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.
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 Shareholders
Any such Related Party Transactions shall also be placed for prior approval of shareholders by way of resolution, if it exceeds the thresholds as defined under the definition of Material Related Party Transactions under this Policy.
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.
Related Party Transaction not requiring Approval
The following Related Party Transactions shall not require any separate approval under the Policy:
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 Directions, the Company will disclose the Policy on its website as well as in its Annual Report
Godrej Housing Finance Limited has the following Prime Lending Rates:
Prime Lending Rate |
Rate |
Date of Application |
GHF PLR |
17.26% |
10th September 2022 |
GHFPLRCR |
17.46% |
10th September 2022 |
DISCLOSURES
CAPITAL MARKET DISCLOSURES
S. No. | Transactions Type | TAT in Working Days |
1 | EMI issue | 5 |
2 | Foreclosure Enquiry / SOA Request | 15 |
3 | Refunds | 15 |
4 | Property Papers | 15 |
5 | SMS Request post closure | 15 |
6 | Sanction Pending Disbursement | 15 |
* TAT to be calculated from the date when complete information with respect to service respect has been provided
Godrej Housing Finance Limited (hereinafter referred to as “GHF)/Pyxis, a company incorporated under the provisions of Companies Act, 2013, having our registered office at 3 rd Floor, Godrej One, Pirojshanagar, Vikhroli (East), Mumbai – 400079 and having corporate identity number U65100MH2018PLC315359, we value your trust and respect your right to privacy.
General
This Privacy Policy provides you with details about the manner in which your data is collected, stored and used by us. You are advised to read this Privacy Policy carefully. If you do not agree to the terms of this Privacy Policy, please do not further use or access GHFL website, GHF applications or its digital assets (Website/Journeys/ Applications/Mobile, tablet apps/Digital and SMS Communication)
For the purpose of this Privacy Policy, the term "You" or "User" shall mean any natural or legal person including online and offline clients visiting this website and the term "We", "Us", "Our" shall mean GHF Limited along with its Subsidiaries.
Use of this Website/digital asset/communication signifies your acknowledgement and consent to this Privacy Policy. If, however, you object to Your Information being used, processed and transferred by GHFL in any way, please do not share your information on the Website. If you would like to make a complaint about a possible breach of local privacy laws, please do so by calling us on 8657764527 or email at the following address: nodalofficer@godrejhf.com.
This privacy statement is applicable to website and applications (mobile and hybrid, hereinafter referred to “applications”) of GHFL. This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, or television or any other media or computer resource to access our Services. It also applies to those who register on our website/applications in connection with use of our services, or whose data GHFL otherwise receives in connection with its services. It is important that you read the Privacy Policy carefully because whenever you use our website/applications, your personal data will be processed (if at all) in accordance with this policy.
Personal Data and its collection
Personal Data, means and includes, any data relating to identified or identifiable living person (‘data subject’ here in referred as you/your’) including but not limited to, name, address, mailing address, telephone number, email ID, bank account details including bank statements, linked to credit/debit payment instruments, information about your mobile phone, any personal details that may have been voluntarily provided by the customer, whether to Unique Identification Authority of India (UIDAI), Credit Information Bureau of India Limited (CIBIL) or any other agency including any other Credit Information Companies (CIC)
1. Information Collected when you use our Website
We collect data about you or your usage for the purpose of providing loan / other financial services to all of our users and such information is kept protected at all times. We collect data in the following ways. Many of our services require you to register/sign up for an account on GHFL. When you do, we will ask for Personal Data, such as, but not limited to your name, email address, contact number, country, address to create/ update your account
When you use the GHFL website to request a call back or more information or more assistance or to apply for new loans, we will ask for Personal Data including but not limited to Name, Email ID and Contact number. We may collect your personal data such as but not limited to financial details-bank statement, salary statement, family details-father, mother, spouse name location / log details for compliance / company requirement purposes
When you use the GHFL website to provide feedback, we collect your Personal Data including but not limited to name, title, Email ID, contact number, address and country. We collect data about the services that you use and how you use them. This data includes log data and location data. We may collect your data through marketing campaigns and publicly available sources.
When you communicate with GHFL or use the GHFL platform to communicate with other members, we collect data about your communication and any data you choose to provide. If you choose to sign in with your social media account to access GHFL, or otherwise connect your social media account with the services of GHFL, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the data that you make available to us through the social media interface.
ii. Information Collected when you use our Applications
When you download our mobile application or use our hybrid application (related to our various services) we collect the below information, but not limited to –
GHFL does not collect Personal Data about individuals except when such individuals specifically provide such data on a voluntary basis. Upon such voluntary disclosure of Personal Data, we may further verify, collate or receive data about you from publicly and commercially available sources (as permitted by law), which we may combine with other data we receive from you. We may also receive data about you from third-party social networking services, wherein you have provided such consent to those third party platforms, if you are already connected with those services.
GHFL has adopted the ‘Fair Practice Code’ and has grievance redressal mechanism which can be accessed at www.godrejhf.com.
Lawful Basis of Processing
The information is collected for a lawful purpose connected with a function or activity of GHFL or any person on its behalf; and the collection of the sensitive personal data or information is considered necessary for that purpose.
Use of Personal Data
We use Personal Data to provide you with any service you explicitly requested for, to resolve disputes, troubleshoot concerns, help promote safe services, assess your interest in our services, inform you about offers, products, services, updates, customize your experience, detect and protect us against errors, fraud and other criminal activity, enforce our terms and conditions, etc.
We may also use your Personal Data to send you offers regarding various services/facilities which GHFL or its group companies may, from time to time, launch. Your consent will be taken before we send you any such communication.
Cookies and Other Tracking Technologies
Some of our Web pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect data about Web site activity. Some cookies and other technologies may serve to recall Personal Data previously indicated by a Web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Web site.
Tracking technologies may record data such as Internet domain and host names; Internet protocol (IP) addresses; browser software, co-browsing services, and operating system types; clickstream patterns; and dates and times that our site/application is accessed. Our use of cookies and other tracking technologies allows us to improve our website/applications and your Web experience. We may also analyse information that does not contain Personal Data for trends and statistics.
Information Sharing and Disclosure
We restrict access to your Personal Data to employees who we believe reasonably need to know that data in order to fulfil their jobs to provide, operate, develop, or improve our products or services.
GHFL does not rent, sell, or share Personal Data about you with other people or non-affiliated companies except:
Sharing of Data with Third Parties
We provide the data to trusted partners who work on behalf of or with GHFL under confidentiality agreements. These companies may use your Personal Data to help GHFL communicate with you about offers from GHFL and our marketing partners. However, these companies do not have any independent right to share this data
We may disclose your personal data to agents or contractors of GHFL and/or its group companies/affiliates to enable processing of transactions or communications with you “on need” basis. Your aforesaid data may be further used for assessment and analysis of our market, customers, products, and services and to understand the way people use our Services so that we can improve them and develop new products and services. However, it shall be on the basis that the agents are required to keep the data confidential and will not use the data for any other purpose other than to carry out the services they are performing for GHFL and/or its group companies/affiliates
With your permission we may share your personal data with Godrej group and/or its affiliates for providing details on latest offers from our other entities
Third-Party Links and Content on Services
Our Services may link to third-party websites/applications and services that are outside our control. Further, GHFL, its group companies, its affiliates, and their directors and employees (“Godrej Group”) accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of any application or any site or inability to use by any party, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy with any online application, its Contents (material, data, money market movements, news items, etc.) or associated services, or due to unavailability of any application or any part thereof or any Contents or associated services even if GHFL Group are advised of the possibility of such damages, losses or expenses.
Minors
To use the Site/Application you agree that you must be the minimum age (described in this paragraph below) or older. The minimum age for these purposes shall be 18, however if local laws require that you must be older in order for GHFL to lawfully provide the services in the Site/Application to you then that older age shall apply as the applicable minimum age.
Data Retention
Your personal data processed by GHFL are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed in line with legal, regulatory, contractual or statutory obligations as applicable.
At the expiry of such periods, your personal data will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.
Security and Confidentiality
GHFL makes sure at all times to implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection and safeguarding of your personal data as the same is of vital importance to GHFL. At GHFL, we are strongly committed to protecting the personal and financial data that you submit to us.
GHFL shall ensure to safeguard the security and confidentiality of any data you share with us. Any of your personally identifiable data obtained by us shall not be used or shared other than for the purposes to which you consent. However, despite our utmost efforts to protect your Personal Data, GHFL cannot warrant the security of any data you transmit to us through our online services/ applications. By accepting this Privacy Policy, you accept that such transmission of your Personal Data is done at your own risk.
Lastly, you are requested to help us protect your data privacy by maintaining the secrecy of the username and password you use for any of our Services.
Social media
GHFL operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. GHFL monitors and records comments and posts made on these channels about GHFL in order to improve its products and services.
Please note that you must not communicate to GHFL through such social media sites the following information:
GHFL is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. GHFL is only responsible for its own use of the personal data received through such sites
Disclaimer
GHFL shall not be liable for any loss or damage sustained by reason of disclosure (inadvertent or otherwise) of any data concerning the user's account and / or data relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any data so disclosed and used whether or not in pursuance of a legal process or otherwise. GHFL does not store any Credit / Debit card details. Any other personal and sensitive Personal Data shared by you which is not asked by GHFL during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and GHFL will not be liable for breach of such data.
No contractual obligation
Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.
Intellectual Property Rights
Please note that GHFL retains all rights (including copyrights, trademarks, patents as well as any other intellectual property right) in relation to all information provided on or via this web site/applications (including all texts, graphics and logos).
Changes to this Privacy Policy
GHFL reserves the right to change or update this Privacy Policy or any other of our policies/practices at any time without giving any prior notification; hence, you are requested to review the Privacy Policy periodically, to make sure that you are aware of any such changes. This Privacy Policy shall apply uniformly to GHFL website and GHFL applications or any other media used by GHFL for its Services. Any changes or updates will be effective immediately upon posting the same on our web site at www.godrejhf.com. If you have any questions or concerns or require any clarifications with respect to this Privacy Policy, please do so by calling us on 8657764527 or email at the following address: nodalofficer@godrejhf.com.
Annual Percentage Rate (APR):
Annual Percentage Rate (APR):
Particulars |
Insurance Funded |
Insurance Self Funded |
Unsecured |
||
HL |
LAP |
HL |
LAP |
||
Annual Percentage Rate |
6.85% |
8.06% |
6.95% |
8.16% |
7.01% |
For details – kindly refer APR Terms & Conditions