Code of Conduct

Saggraha code of Conduct explains the overall business philosophy and lays down the guidelines to be followed by the company and its field staff. Saggraha as a Business Correspondent to Banks, would follow the guidelines and fair practices as set out by the Bank. This document aims at communicating the code of conduct of the company as a Self – Disciplinary and Self – Regulatory mechanism.

  1. INTEGRITY AND ETHICALBEHAVIOUR
    1. Saggraha has defined the policies and operating guidelines to treat clients and fellow employees with dignity.
    2. Saggraha employees are trained to ensure transparent and professional conduct of business activities and are oriented as per the defined codes and practices.
  2. TRANSPARENCY
    1. Saggraha discloses all the terms and conditions of the products to clients in their regional language both by personal communication and by Audio-visual mode for a uniform and better understanding.
      • Standardizing the communication by the field staff in explaining about the company and its role as Business Correspondent on behalf of the Bank.
      • The standard 10 point communication schedule is communicated during Projection Meeting, Group Formation and Saggraha Video Training (SVT).
      • SVT will include the terms and conditions, loan process, meeting process, Do’s and Don’ts for the clients, loan size, rate of interest, processing fee, repayment terms and other conditions and are explained with examples.
    2. The disclosure is made prior to disbursement as per the regulatory fair practice code. Along with the Sanction letter, Loan schedule and the Group kit, Individual schedules are also issued to the clients. All the communication will be provided in detail, including the rate of interest is on the reducing balance basis.
    3. Saggraha will ensure to follow the guidelines set out by the banks and also ensure keeping all formal records of the transactions as prescribed and defined by Bank.
  3. CLIENT PROTECTION
    1. Fair Practices
      1. Saggraha will ensure provision of financial services as per the bank and comply with regulatory guidelines.
      2. Saggraha will obtain copies of relevant documents from clients, as per standard KYC norms. Additional documents sought must be reasonable and necessary for completing the transaction.
      3. Saggraha will ensure that additional measures are initiated to ensure that financial services are delivered to the client in accordance to the guidelines.
    2. Avoiding Over-indebtedness
      1. Saggraha will conduct proper due diligence as per credit policy to assess the need and repayment capacity of client before recommending a loan and must only recommend loan amounts commensurate with the client’s ability to repay.
      2. If a client has loans from Two 2 separate/other lenders, then irrespective of the source of the loans and irrespective of the loan outstanding amount, Saggraha will not encourage enrollments.
      3. Saggraha will not breach the total indebtedness limit for any client, as prescribed by the bank.
    3. Appropriate interaction and collection practices:
      1. Saggraha has clearly defined guidelines for employee interactions with clients.
      2. The employees of Saggraha have been instructed to follow the below points religiously:
        1. Use courteous language, maintain decorum and a respectful disposition and be sensitive to cultural aspects, during all interaction with clients.
        2. DO NOT indulge in any behavior that in any manner would suggest any kind of threat or violence with clients.
        3. DO NOT contact clients at odd hours (late nights), as per the RBI guidelines for loan recovery.
        4. DO NOT visit clients at inappropriate occasions such as bereavement, sickness, etc., to collect dues.
      3. Saggraha during the group training of clients, also clearly explains the Do’s and Don’ts to be followed and among the points.
      4. Saggraha will provide a valid receipt as advised and confirmed by Bank for each and every payment received from the client/Group.
      5. Saggraha will follow the process defined by the bank to deal with clients, at each stage of repayment default.
      6. Saggraha will not collect repayment shortfalls in collections from employees except in case of employee fraud.
    4. Privacy of client information
  4. Saggraha will keep personal client information strictly confidential. Client information may be disclosed to a third party subject to the following conditions:

    1. Client has been informed about such disclosure and permission has been obtained in writing to check the credit bureau and on authorization of the Bank.
    2. In cases where it is legally required to do so.
    3. This practice is customary amongst financial institutions and available for a close group on reciprocal basis(such as a credit bureau).
  5. GOVERNANCE
  6. Saggraha will incorporate a formal governance system that is transparent and professional, and adopts the following best practices of corporate governance:

    1. Saggraha will ensure compliance to the Company law and other applicable laws of the land.
    2. Saggraha will observe high standards of governance by inducting persons with good and sound reputation as members of Board of Directors/Governing body.
    3. Saggraha will appoint an audit committee of the Board.
    4. Saggraha will ensure transparency in the maintenance of, books of accounts and reporting/presentation and disclosure of financial statements by qualified auditor/s and ensure statutory compliance without any compromise.
    5. Saggraha will follow the Audit and Assurance Standards issued by the Institute of Chartered Accountants of India (ICAI).
    6. Saggraha will place before the Board of Directors, a compliance report indicating the extent of compliance with this Code of Conduct, specifically indicating any deviations and reasons therefore, at the end of every financial year.
  7. STAFF GOVERNANCE
  8. The code covers all staff.

    1. As a matter of free and fair recruitment practice, recruitment will be by legitimate means in the public domain like general recruitment, advertisements in local newspapers, web advertisements, walk-in interviews, employee reference etc.
    2. Any employee recruited, it will be mandatory to seek a reference check from the previous employer. The reference check will be sought from current employer only after an offer is made and an offer letter is issued to the prospective employee.
    3. Saggraha will respond to the reference check request from another institution within two weeks from the date of receipt of the request.
  9. CLIENT EDUCATION
    1. Saggraha will have a dedicated process to raise clients’ awareness of the options, choices and responsibilities vis-à-vis financial products and services available.
    2. New clients must be informed about the organization’s policies and procedures to help them understand their rights as borrowers. The education is done in different means including audio visual training and other means in which the client understands using simple local language.
    3. Saggraha will ensure regular checks on client awareness and understanding of the key terms and conditions of the products / services offered / availed. (As part of internal audit systems or through some other regular monitoring mechanism)
  10. FEEDBACK/GRIEVANCE REDRESSAL MECHANISM
    1. Saggraha has established dedicated feedback and grievance redressal mechanisms for its clients to correct any error and handle/receive complaints speedily and resolve efficiently.
    2. Saggraha will inform clients about the existence and purpose of these mechanisms and how to access them.
    3. Saggraha has designated a grievance redressal official to handle complaints and/or note any suggestions from the clients and make his/her contact numbers easily accessible to clients.
    4. Where complainants are not satisfied with the outcome of the investigation conducted by Saggraha into their complaint, they shall be notified of their right to refer the matter to the grievance redressal mechanism established by the respective bank.