Aadhar Housing Finance Limited

AADHAR HOUSING FINANCE LIMITED

FAIR PRACTICES CODE

(Revision Effective from 25th July,2025)

Version - XII

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CONTENTS

Sl. Topic Page No.

No.
1. Introduction 3
2. Objective 3
3 Application of the code 4
4. Commitments 4
5 Loans 5
5.1.1 Applications for loans and their processing 5
5.1.2 Loan appraisal and terms/conditions and communication of 5
rejection of loan application
5.1.3 Disbursement of loans including changes in terms and 6
conditions; and Release of Movable/ Immovable Property
Documents on Repayment/ Settlement of Personal Loans
(including Housing Loans)
6 Loans sourced over Digital Lending Platforms and Guidelines 8
on Digital Lending
7 Responsibility of Board of Directors 8
8 Complaints and Grievance Redressal - Internal Procedures 8
9 Language and mode of communicating Fair Practice Code 11
10 Regulation of excessive interest charged by the Company 11
11 Excessive interest charged by Company 12
12 Penal Charges in Loan Accounts 12
13 Reset of Floating Interest Rate on Equated Monthly 13
Instalments (EMI) based Personal Loans (including housing
loans)
14 Advertising, Marketing and Sales : 14
15 Guarantors 15
16 Privacy And Confidentiality 15
17 Post disbursement supervision 16
18 Collection of Dues 17
19 Disclosure and Transparency 19
20 Credit reference agencies / Credit Information Companies 19
21 Know Your Customer (KYC) Policy 20
22 Deposit Accounts 20
23 Branch Closure / Shifting / Relocation/ Merger 21
24 General- The Company shall 21

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Aadhar Housing Finance Limited

FAIR PRACTICES CODE

(As amended and approved by the Board of Directors of the Company)

1. Introduction

National Housing Bank had issued their Fair Practices Code guidelines vide
notifications/Circular No. NHB (ND)/DRS/Pol-No.16/2006 dated 5 th September, 2006,
and the same had been subsequently amended in the guidelines issued by them vide
Circular No. NHB/ND/DRS/Pol. No. 34/2010 -11 dated 11 th October, 2010, NHB
(ND)/DRS/REG/MC-03/2017 dated 1st July, 2017, NHB (ND)/DRS/REG/MC-03/2018
dated 2nd July, 2018 and further amendments notified from time to time. Aadhar
Housing Finance Limited (AHFL), (previously known as DHFL Vysya Housing
Finance Ltd.) with a view to ensure the best Corporate Practices and transparency in
dealing with its clients, has adopted the guidelines in its Fair Practice Code (Code) was
originally approved by the Board of Directors of the Company in its Meeting 24 th April,
2018 and also reviewed and modified at the Board meeting held on 30 th April, 2019.

Further, the Board of Directors at their meeting held on 28th May, 2021, reviewed and
modified this policy as per Master Direction- Non-Banking Financial Company –
Housing Finance Company (Reserve Bank) Directions, 2021 (herein after referred as
“RBI Directions”) issued by Reserve Bank of India vide Circular No. RBI/2020-21/73
[Link].120/03.10.136/`2020-21 dated 17 th February, 2021. The said
policy was reviewed by the Board of Directors at their meeting held on 12 th August,
2022, 9th August, 2023 and 7th November, 2023. Further the modifications are duly
approved by the Board of Directors by circulation on 26th March, 2024 and at their
meeting held on 7th August 2024. Further the present modifications are approved by the
Board of Directors on 25th July 2025.

This code deals with promotion of good and fair practices, increased transparency,
encouraging market forces, ensuring a fair and cordial relationship between borrower /
Customer and the Company and to foster confidence of the customer in the housing
finance system of the Company. The Code has the following key elements.

2 Objectives :

 To promote good and fair practices by setting minimum standards in dealing

with customers;
 To increase transparency so that the customer can have a better understanding
of what they can reasonably expect of the services;
 To encourage market forces, through competition, to achieve higher operating
standards;
 To promote a fair and cordial relationship between customer and AHFL; and
 To foster confidence in the housing finance system.

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3 Application of the Code

 This Code shall apply to all the products and services, whether they are provided
by AHFL, 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.

 The code shall be applicable across all aspects of operations including

marketing, loan origination processing and servicing and collection activities
and various service providers, engaged by AHFL. Our commitment to Fair
Practice Code would be demonstrated in terms of employee responsibility,
efficiency, monitoring and auditing programmes, training and technology.

 Through regular training programs, meetings, seminars, circulars and other

modes of the communication employees would be made aware of the code so
that there is a strong commitment for fair and quality lending and efficient and
fair services.

4 Commitments

AHFL shall adhere to this code to act fairly and reasonably in all dealings, on the ethical
principle of integrity and transparency, to meet the standard practices prevalent in the
housing finance industry.

AHFL shall meet the commitments and standards in this Code for the products and
services it offers and in the procedures and practices its staff follows.

AHFL shall ensure that their products and services comply with relevant laws and
regulations in letter and spirit.

AHFL shall deal with their customers on ethical principles of integrity and
transparency.

AHFL would provide clear information, without any ambiguity, to the customer in
understanding:
Products and services together with its terms and conditions including interest and
service charges.

Benefits available to customer

AHFL will deal quickly and sympathetically in correcting mistakes if any and attend to
customer's complaints in light of the objectives of this code.

AHFL shall treat all personal information of customers as private and confidential and
shall not divulge any information to third person unless required by any law or
Government authorities including Regulators or Credit agency or where the sharing of
information is permitted by the customer.

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AHFL would provide, on request, copy of the Code to the existing borrowers and new
customer prior to commencement of business transaction.

AHFL shall not discriminate its customers on the basis of age, race, caste, gender,
marital status, religion or disability. However, the restrictions if any, as mentioned in
the loan products, shall continue to apply.
5. Loans
5.1.1 Applications for loans and their processing.

All communications to the borrower shall be in the vernacular language or a language

as understood by the borrower.

Standard schedule of fee/ charges relating to the loan application / ‘all in cost’ inclusive
of all charges involved in processing/ sanctioning of loan application depending on the
segment to which the accounts belong will be made available to all the prospective
borrowers in a transparent manner, along with the loan application, irrespective of the
loan amount. Likewise, amount of fee refundable or not in the event of non-acceptance
of the application, prepayment options and any other matter which affects the interest
of the borrower will also be made known to the borrower at the time of application. The
loan application form may also indicate the list of documents required to be submitted
with the application form. Receipt of completed application forms will be duly
acknowledged by call/sms/mail.

The acknowledgement would also include the approximate date by which the applicant
should call on the Company for preliminary discussions, if deemed necessary.

All loan applications will be disposed of within a period of 4 weeks from the date of
receipt of duly completed loan applications i.e. with all the requisite information/papers.

In case of rejection of loan application, irrespective of category of loans or threshold

limits, the same would be conveyed in writing along with the main reason(s), which led
to rejection of the loan application.

5.1.2 Loan appraisal and terms/conditions and communication of rejection of loan

application.

In accordance with AHFL’s prescribed risk based assessment procedures, each loan
application will be assessed and suitable margin/securities will be stipulated based on
such risk assessment and AHFL’s extant guidelines, however without compromising
on due diligence.

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a) Normally all particulars required for processing the loan application shall be
collected by the AHFL at the time of application. In case it needs any additional
information, the customer should be told that he would be contacted immediately again.
b) AHFL should convey in writing to the borrower, in the vernacular language or a
language as understood by the borrower by means of sanction letter or otherwise, the
amount of loan sanctioned along with all terms and conditions including annualized
rate of interest, method of application, EMI Structure, prepayment charges, penal
charges plus applicable GST (if any) and keep the written acceptance of these terms
and conditions by the borrower on its record.

c) AHFL shall mention the penal charges for late repayment in bold in the loan
agreement.

d) AHFL shall invariably furnish a copy of the loan agreement along with a copy each
of all enclosures quoted in the loan agreement to every borrower at the time of sanction
/ disbursement of loans, against acknowledgement.

e) Communication of rejection of Loan Application to be given by sms/email/letter.

5.1.3 Disbursement of loans including changes in terms and conditions; and Release of
Movable/ Immovable Property Documents on Repayment/ Settlement of Personal
Loans (including Housing Loans)

Disbursement of loans sanctioned is to be made immediately on total compliance of

terms and conditions including execution of loan documents governing such sanction.

Any change in terms and conditions, including interest rate and service charges, will be
informed individually to the borrowers in case of account specific changes and in case
of others by display on Notice Board at the branches/on the AHFL’s website/through
Print and or other Media from time to time.

Changes in interest rates and service charges will be effected prospectively.

Consequent upon such changes any supplemental deeds documents or writings are
required to be executed, the same shall also be advised. Further, availability of facility
will be subject to execution of such deeds documents or writings.

Interest on loans disbursed to customer will be charged from the date of Cheque
Handover with effect from RBI circular dated 29.04.2024.

I. Disbursement of loans including changes in terms and conditions

a) Disbursement should be made in accordance with the disbursement schedule given

in the Loan Agreement/ Sanction Letter.

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b) The AHFL should give notice to the borrower in the vernacular language or a
language as understood by the borrower of any change in the terms and conditions
including disbursement schedule, interest rates, penal charges (if any) service charges,
prepayment charges, other applicable fee/ charges etc. AHFLs should also ensure that
changes in interest rates and charges are effected only prospectively. A suitable
condition in this regard should be incorporated in the loan agreement.
c) If such change is to the disadvantage of the customer, he/she may within 60 days and
without notice close his / her account or switch it without having to pay any extra
charges or interest.
d) Decision to recall / accelerate payment or performance under the agreement or
seeking additional securities, should be in consonance with the loan agreement.
e) AHFLs should release securities on repayment of all dues or on realization of the
outstanding amount of loan subject to any legitimate right or lien for any other claim
AHFLs may have against borrower. If such right of set off is to be exercised, the
borrower shall be given notice about the same with full particulars about the remaining
claims and the conditions under which AHFLs are entitled to retain the securities till
the relevant claim is settled /paid.

f) The Company is required to release all movable/ immovable property documents

upon receiving full repayment and closure of loan account. The following process shall
be followed by the Company in this regard:

II. Release of Movable/ Immovable Property Documents:

a. The Company shall release all the original movable/ immovable property documents
and remove charges registered with any registry within a period of 30 days after full
repayment/ settlement of the loan account.

b. The borrower shall be given the option of collecting the original movable/ immovable
property documents either from the branch where the loan account was serviced or any
other office of the Company where the documents are available, as per her/ his
preference.

c. The timeline and place of return of original movable/ immovable property documents
shall be mentioned in the loan sanction letters issued on or after the effective date.
d. In order to address the contingent event of demise of the sole borrower or joint
borrowers, the Company shall have a well laid out procedure for return of original
movable/ immovable property documents to the legal heirs. Such procedure shall be
displayed on the website of the Company along with other similar policies and
procedures for customer information.

III. Compensation for delay in release of Movable/ Immovable Property Documents:

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a. In case of delay in releasing of original movable/ immovable property documents or

failing to file charge satisfaction form with relevant registry beyond 30 days after full
repayment/ settlement of loan, the Company shall communicate to the borrower reasons
for such delay. In case where the delay is attributable to the Company, it shall
compensate the borrower at the rate of ₹5,000/- for each day of delay.
b. In case of loss/ damage to original movable/ immovable property documents, either
in part or in full, the Company shall assist the borrower in obtaining duplicate/ certified
copies of the movable/ immovable property documents and shall bear the associated
costs, in addition to paying compensation as indicated at sub-paragraph (i) above.
However, in such cases, an additional time of 30 days will be available to the Company
to complete this procedure and the delayed period penalty will be calculated thereafter
(i.e., after a total period of 60 days).
c. The compensation provided under these directions shall be without prejudice to the
rights of a borrower to get any other compensation as per any applicable law.

The Directions under Paragraph 76.6 shall be applicable to all cases where release of
original movable/ immovable property documents falls due on or after December 01,
2023 (as notified by Reserve Bank of India).

6 Loans sourced over Digital Lending Platforms and Guidelines on Digital

Lending

The Para No. 76A and 76B of Chapter XIII- Fair Practice Code of RBI Master 2021,
shall be applicable to the Company as and when the Digital lending will be started by
the Company.

7 Responsibility of Board of Directors

1. The Board of Directors of the Company has laid down the appropriate grievance
redressal mechanism within the organization to resolve complaints and
grievances. Such a mechanism shall ensure that all disputes arising out of the
decisions of lending institution’s functionaries are heard and disposed of at least
at the next higher level.

2. The Board of Directors of AHFL should provide for periodical review of the
compliance of the Fair Practices Code and the functioning of the grievances
redressal mechanism at various levels of management. A consolidated report of
such reviews may be submitted to the Board at regular intervals, as may be
prescribed by it.

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8 Complaints and Grievance Redressal - Internal Procedures

 The Company would endeavor to deal quickly and sympathetically to correct

any mistake committed by its staff/system/process and would cancel any
charges wrongly accrued due to such mistakes.
 The Company would provide suitable alternative avenues to alleviate problems
arising out of technological failures.
 To redress customer grievances, he/she may write or call the Manager of the
concerned Branch clearly stating the nature of Customer’s grievance along with
necessary documents, if any, and the customer will be provided a Complaint
Reference Number.
 The Company would request customer to complain against
representative/courier or Direct Selling Agent (DSA) or broker for servicing
deposits or any other agencies employed by The Company if they are engaged
in any improper conduct or action in violation of the code. The company would
ensure that the complaint is properly investigated and proper action and
redressal takes place.

i. Complaints-

The Board of Directors of AHFL should lay down the appropriate grievance redressal
mechanism, as per the Board approved policy within the organization to resolve
complaints and grievances. Such a mechanism should ensure that all disputes arising
out of the decisions of lending institution’s functionaries are heard and disposed of at
least at the next higher level.

a) AHFL shall have a system and a procedure for receiving, registering and disposing
of complaints and grievances in each of its offices, including those received on-line.

b) Customer should be told where to find details of AHFL’s procedure for handling
complaints fairly and quickly. AHFL shall make available facilities at each of its offices
for the customers to lodge and/or submit their complaints or grievances, if any.
c) If the customer wants to make a complaint, he/she should be told:
I. How to do this
II. Where a complaint can be made
III. How a complaint should be made
IV. When to expect a reply
V. Whom to approach for redressal
VI. What to do if the customer is not happy about the outcome.
VII. AHFL’s staff shall help the customer with any questions the customer has.

d) If a complaint has been received in writing from a customer, an AHFL shall

endeavour to send him/her an acknowledgement / response within a week.
The acknowledgement should contain the name & designation of the official who will
deal with the grievance. If the complaint is relayed over phone at AHFL’s designated
telephone helpdesk no. 180030042020 or customer service number, the customer shall

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be provided with a complaint reference number and be kept informed of the progress
within a reasonable period of time.
e) After examining the matter, AHFL shall send the customer its final response or
explain why it needs more time to respond and shall endeavour to do so within six
weeks of receipt of a complaint and he/she should be informed how to take his/her
complaint further if he/she is still not satisfied.
f) AHFL shall publicize its grievance redressal procedure (e-mail id and other contact
details at which the complaints can be lodged, turnaround time for resolving the issue,
matrix for escalation, etc.) for lodging the complaints by the aggrieved borrower and
ensure that it is specifically made available on its website. AHFL shall clearly display
in all its offices / branches and on the website that in case the complainant does not
receive response from the company within a period of one month or is dissatisfied with
the response received, the complainant may approach the Grievance Redressal
Department of National Housing Bank by lodging its complaints in Online mode at the
link [Link] OR in offline mode by post, in prescribed format
available at link [Link] Grievance-Redressal-System/Lodging-
Complaint-Against-HFCs-NHB%E2%80% [Link], to National Housing
Bank, Grievance Redressal Department, 4th Floor, Core 5A, India Habitat Centre,
Lodhi Road, New Delhi – 110 003.

In case the response is unsatisfactory or no response is received, the complaint should

be escalated to the following: The Grievance Redressal Officer, email id-
[Link]@[Link]
[Link]@[Link]
ii. Grievance Redressal Mechanism
The Company strives to provide quality services & make the customer satisfied within
the framework of the Regulatory norms, Board/Top Management approved policies,
processes & procedures, as per the Grievance Redressal Mechanism. AHFL operates in
a decentralized manner where in each branch is under the control of Branch
Manager/Branch In-charge, who will report to Cluster Manager & then to Regional
Business Head, who in turn reports to Corporate Office respective functional heads.
Hence, customers may normally approach branches for their grievances/complaint
redressal or to the Corporate Office, Mumbai.
In case of any grievance or a complaint relating to any services/charges of AHFL, the
customer can lodge a complaint & approach the Branch Manager/In-charge of the
Branch at the respective location, where he/she has availed his/her housing loan &
account is maintained and register the complaint either by way of a Letter addressed to
the Branch Manager at the address given in the loan sanction letter or visit the branch
office personally and make an entry of the complaint/ grievance in the Complaint
Register maintained by the Branch. The customer shall be responded within a week
from the date of receipt of complaint by the Branch, to resolve the issues.
In case, the response given by Branch is unsatisfactory, dissatisfied or did not receive
any response from the Branch within the above time-limit, the customer can escalate
his/her complaint/grievance to the Registered office, Bengaluru, either by way of a

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Letter addressed to the Customer Care Officer/ Grievance Redressal Officer or

Principal Officer of AHFL at the address or by e-mail send to the address given below:-
The Customer Care Officer/ Grievance Redressal Officer, Aadhar Housing Finance
Ltd.,
2nd Floor, No.3, JVT Towers, 8th A Main, Road, Sampangi Rama Nagar, Hudson Circle,
Bengaluru, Karnataka- 560027.
Email ID: [Link]@[Link]
Email ID: customercare@[Link]
After examining the complaint/grievance received, we shall send to the customer a final
response or explain why it needs more time to respond and shall endeavour to send a
detailed reply or intimation within six weeks of receipt of complaint at the Registered
Office of the company.
In case the response is unsatisfactory or dissatisfied with the response received or did
not receive any response from the company within a period of one month, the customer
may approach the Grievance Redressal Department, National Housing Bank (NHB) for
HFCs, by lodging the customer complaints in online mode at the link:
[Link] OR in offline mode by post, in prescribed format
available at NHB website link: [Link]
System/Lodging-Complaint-Against-HFCs-NHB%E2% 80% 93 [Link],
send to the following address:-

National Housing Bank (NHB),

Grievance Redressal Department
4th Floor, Core 5-A, India Habitat Centre,
Lodhi Road, New Delhi - 110003.

The company holds the Registration of a Corporate Agent (composite) with IRDAI for
solicitation of insurance business. It will ensure adherence to the IRDAI Regulations,
with respect to redressal of grievances relating to insurance. The offices of the company
where complaints related to insurance products sold by the company are received will
acknowledge the complaint and facilitate redressal of the same within 14 days of the
receipt of such complaint through the respective Insurance Company(ies).
If the compliant is not resolved or the customer is unsatisfied with the resolution
provided, then he/she can lodge the compliant online through Bima Bharosa System by
logging into: [Link]

9 Language and mode of communicating Fair Practice Code

Fair Practices Code (which shall preferably be in the vernacular language or a language
as understood by the borrower) based on the directions outlined hereinabove shall be
put in place by the Company with the approval of the Board. The Company has the
freedom of drafting the Fair Practices Code, enhancing the scope of the directions but
in no way sacrificing the spirit underlying the above directions. The same shall be put
up on the website, for the information of various stakeholders.

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10 Regulation of excessive interest charged by the Company

a) The Board of AHFL shall adopt an interest rate policy taking into account relevant
factors such as cost of funds, margin and risk premium and determine the rate of interest
to be charged for loans and advances. The rate of interest and the approach for gradation
of risk and rationale for charging different rate of interest to different categories of
borrowers shall be disclosed to the borrower or customer in the application form and
communicated explicitly in the sanction letter. The Board of the Company also has
clearly laid down policy for penal charges (if any).

b) The rates of interest and the approach for gradation of risks, and penal charges plus
applicable GST (if any) shall also be made available on the website of the companies
or published in the relevant newspapers. The information published in the website or
otherwise published shall be updated whenever there is a change in the rates of interest.

c) The rate of interest plus applicable GST (if any) must be annualised rate so that the
borrower is aware of the exact rates that would be charged to the account.

d) Instalments collected from borrowers should clearly indicate the bifurcation between
interest and principal.

11 Excessive interest charged by Company

Though interest rates are not regulated by the Bank, rates of interest beyond a certain
level may be seen to be excessive and can neither be sustainable nor be conforming to
normal financial practice. The Company shall lay out appropriate internal principles
and procedures in determining interest rates and processing and other charges
(including penal charges, if any). In this regard the directions in this Code about
transparency in respect of terms and conditions of the loans are to be kept in view. The
Company shall to put in place an internal mechanism to monitor the process and the
operations so as to ensure adequate transparency in communications with the
borrowers.

12 Penal Charges in Loan Accounts

Penalty, if charged, for non-compliance of material terms and conditions of loan

contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in
the form of ‘penal interest’ that is added to the rate of interest charged on the advances.
There shall be no capitalisation of penal charges i.e., no further interest computed on
such charges. However, this will not affect the normal procedures for compounding of
interest in the loan account.
The Company shall not introduce any additional component to the rate of interest and
ensure compliance to these guidelines in both letter and spirit.

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The Company shall formulate a Board approved policy on penal charges or similar
charges on loans, by whatever name called.
The quantum of penal charges shall be reasonable and commensurate with the non-
compliance of material terms and conditions of loan contract without being
discriminatory within a particular loan / product category.
The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes
other than business’, shall not be higher than the penal charges applicable to non-
individual borrowers for similar non-compliance of material terms and conditions.
The quantum and reason for penal charges shall be clearly disclosed by the Company
to the customers in the loan agreement and most important terms & conditions / Key
Fact Statement (KFS) as applicable, in addition to being displayed on REs website
under Interest rates and Service Charges.
Whenever reminders for non-compliance of material terms and conditions of loan are
sent to borrowers, the applicable penal charges shall be communicated. Further, any
instance of levy of penal charges and the reason therefor shall also be communicated.
These instructions shall be implemented in respect of all the fresh loans availed from
April 01, 2024 onwards. The Company may carry out appropriate revisions in their
policy framework and ensure implementation of the instructions in respect of all the
fresh loans availed/ renewed from the effective date. In the case of existing loans, the
switchover to new penal charges regime shall be ensured on next review or renewal
date falling on or after April 01, 2024, but not later than June 30, 2024.

13 Reset of Floating Interest Rate on Equated Monthly Instalments (EMI) based

Personal Loans (including housing loans)

I. At the time of sanction of EMI based floating rate personal loans, the Company is
required to take into account the repayment capacity of borrowers to ensure that
adequate headroom/ margin is available for elongation of tenor and/ or increase in
EMI, in the scenario of possible increase in the external benchmark rate/ interest
rates during the tenor of the loan. However, in respect of EMI based floating rate
personal loans, in the wake of rising interest rates, several consumer grievances
related to elongation of loan tenor and/or increase in EMI amount, without proper
communication with and/or consent of the borrowers have been received. In order
to address these concerns, the Company is advised to put in place an appropriate
policy framework meeting the following requirements for implementation and
compliance:

A) At the time of sanction, the Company shall clearly communicate to the

borrowers about the possible impact of change in interest rate on the loan
leading to changes in EMI and/or tenor or both. Subsequently, any increase in
the EMI/ tenor or both on account of the above shall be communicated to the
borrower immediately through appropriate channels.

B) At the time of reset of interest rates, the Company shall provide the option to
the borrowers to switch over to a fixed rate as per their Board approved policy.

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The policy, inter alia, may also specify the number of times a borrower will be
allowed to switch during the tenor of the loan.
C) The borrowers shall also be given the choice to opt for (i) enhancement in EMI
or elongation of tenor or for a combination of both options; and, (ii) to prepay,
either in part or in full, at any point during the tenor of the loan. Levy of
foreclosure charges/ pre-payment penalty shall be subject to extant instructions.
D) All applicable charges for switching of loans from floating to fixed rate and any
other service charges/ administrative costs incidental to the exercise of the
above options shall be transparently disclosed in the sanction letter and also at
the time of revision of such charges/ costs by the Company from time to time.
E) The Company shall ensure that the elongation of tenor in case of floating rate
loan does not result in negative amortisation.
F) The Company shall share / make accessible to the borrowers, through
appropriate channels, a statement at the end of each quarter which shall at the
minimum, enumerate the principal and interest recovered till date, EMI amount,
number of EMIs left and annualized rate of interest / Annual Percentage Rate
(APR) for the entire tenor of the loan. The Company shall ensure that the
statements are simple and easily understood by the borrower.

II. Apart from the equated monthly instalment loans, these instructions would also
apply, mutatis mutandis, to all equated instalment based loans of different
periodicities.

The above instructions are extended to the existing as well as new loans suitably by
December 31, 2023. All existing borrowers shall be sent a communication, through
appropriate channels, intimating the options available to them.

14 Advertising, Marketing and Sales :

AHFL :
(a) Shall ensure that all advertising and promotional material is clear & factual, and
not misleading.
(b) in any of its advertisement in any media and promotional literature that draws
attention to a service or product and includes a reference to an interest rate shall
also indicate whether other fees and charges will apply and that full details of the
relevant terms and conditions are available on request or on the website.
(c) shall provide information on interest rates, common fees and charges (including
penal charges, if any) through putting up notices in their branches; through
telephone or help-lines; on the company’s website; through designated staff/ help
desk; or providing service guide/ tariff schedule.
(d) if it avails of the services of third parties for providing support services shall require
that such third parties handle customer's personal information (if any available to
such third parties) with same degree of confidentiality and security as the Company
would.

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(e) may from time to time, communicate to customers various features of their
products availed by them. Information about their other products or promotional
offers in respect of products / services may be conveyed to customers only if he/
she has given his / her consent to receive such information/service either by mail
or by registering for the same on AHFL’s website or in customer service number.
(f) shall prescribe a code of conduct for the Direct Selling Agencies (DSAs) whose
services are availed to market products / services which amongst other matters
require them to identify themselves when they approach the customer for selling
products personally or through phone.
(g) in the event of receipt of any complaint from the customer that the Company's
representative / courier agency or DSA has engaged in any improper conduct or
acted in violation of this Code, appropriate steps shall be initiated to investigate
and to handle the complaint and to make good the loss.

15 Guarantors:

When a person is considered to be a guarantor to a loan, AHFL shall inform him/her

the following under acknowledgement-
(a) Letter/ Deed of Guarantee stating the terms of liability as guarantor;

(b) AHFL shall keep him/her informed of any default in servicing of the loan
by the borrower to whom he/she stands as a guarantor ;

(c) his/her liability as guarantor;

(d) the amount of liability he/she will be committing him/herself to the

company;

(e) circumstances in which AHFL will call on him/her to pay up his/her

liability;
(f) whether AHFL has recourse to his/her other monies in the company if he/she
fail to pay up as a guarantor;
(g) whether his/her liabilities as a guarantor are limited to a specific quantum or
are they unlimited; and
(h) time and circumstances in which his/her liabilities as a guarantor will be
discharged as also the manner in which AHFL will notify him/her about this.

(i) In case the guarantor refuses to comply with the demand made by the
creditor/lender, despite having sufficient means to make payment of the
dues, such guarantor would also be treated as a wilful defaulter.

AHFL 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.

16 Privacy And Confidentiality

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All the customer/borrower’s personal information both present and past, shall be treated
as private and confidential (even when he/she is no longer our customer) and shall be
guided by the following principles and policies. The Company shall not reveal
information or data relating to Customer accounts whether provided by the customers
or otherwise to anyone, including other companies in the group, other than in the
following exceptional cases :

a) If the information is to be given by law or any competent Court / authorities so direct.

b) If there is a duty towards the public to reveal the information.

c) If the AHFL’s interests require them to give the information (for example, to prevent
fraud) but it should not be used as a reason for giving information about customer or
customer accounts (including customer name and address) to anyone else, including
other companies in the group, for marketing purposes after taking customers’
permission/ consent.
d) If the customer ask the Company to reveal the information, or with customers’
permission/ consent.
e) If AHFL is asked to give a reference about customers, they shall obtain his / her
written permission before giving it.
f) The customer shall be informed the extent of his / her rights under the existing legal
framework for accessing the personal records that an AHFL holds about him /her.
g) AHFL shall not use customer’s personal information for marketing purposes by
anyone including AHFLs unless the customer specifically authorizes them to do so.

In light of the above conditions, if the customer provides express consent for sharing
of such information, the company may provide such information or share such
information to AHFL’s Group /associates companies for the purpose of offering any
other financial products and services for the benefit of the customer(s).
17 Post disbursement supervision

Post disbursement supervision, particularly in respect of loans, would be constructive

with a view to taking care of any genuine difficulties that the borrower may face.

a) Other general provisions.

AHFL would refrain from interference in the affairs of the borrower except for what is
provided in the terms and conditions of loan sanction documents (unless new
information, not earlier disclosed by the borrower, has come to the notice of the AHFL
as lender). However this does not imply that AHFL’s right of recovery and enforcement
of security under Law.

AHFL will not discriminate on the grounds of gender, caste or religion in its lending
policy and activity. Further, AHFL shall also not discriminate visually impaired or

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physically challenged applicants on the ground of disability in extending products,

services, facilities, etc. However, this does not preclude HFCs from instituting or
participating in schemes framed for different sections of the society.
In the case of recovery, AHFL would resort to the usual measures as per laid down
guidelines and extant provisions and would operate within the legal framework. AHFL
is already having a Model Policy on Code for Collection of Dues and Repossession of
Security.

In case of request for transfer of borrowers accounts, either from the borrower or from
a Bank/Financial Institution, the AHFL’s consent or otherwise shall be conveyed within
21 days from the date of receipt of request. Such transfer shall be as per transparent
contractual terms in consonance with law.

AHFL shall not charge pre-payment levy or penalty on pre-closure of housing loans
under the following situations:

a. Where the housing loan is on floating interest rate basis and pre-closed from any
source.

b. Where the housing loan is on fixed interest rate basis and the loan is pre-closed by
the borrower out of their own sources.

The expression “own sources” for the purpose means any source other than by
borrowing from a bank/ HFC/ NBFC and/or a financial institution.

All dual/ special rate (combination of fixed and floating) housing loans will attract the
pre-closure norms applicable to fixed/ floating rate depending on whether at the time of
pre-closure, the loan is on fixed or floating rate. In case of a dual/ special rate housing
loans, the pre-closure norm for floating rate will apply once the loan has been converted
into floating rate loan, after the expiry of the fixed interest rate period. This applied to
all such dual/ special rate housing loans being foreclosed hereafter. It is also clarified
that a fixed rate loan is one where the rate is fixed for entire duration of the loan.

AHFL shall not impose foreclosure charges/ pre-payment penalties on any floating rate
term loan sanctioned for purposes other than business to individual borrowers, with or
without co-obligant(s).

AHFL shall display of various key aspect such as service charges, interest rates, penal
charges plus applicable GST (if any), services offered, product information, time norms
for various transactions and grievance redressal mechanism, etc. is required to promote
transparency in the operations of AHFL. AHFL shall follow the instructions on “Notice
Board”, “Booklets/ Brochures”, “Website”, “Other Modes of Display” and on “Other
Issues” as per the format prescribed by RBI Directions.

AHFL shall display about their products and services in any one or more of the
following languages: Hindi, English or the appropriate local language.

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18 Collection of Dues

Whenever loans are given, AHFL would explain to the customer the repayment process
by way of amount, tenure and periodicity of repayment. However if the customer does
not adhere to repayment schedule, a defined process in accordance with the laws of the
land shall be followed for recovery of dues. The process will involve reminding the
customer by sending him/her notice or by making personal visits and / or repossession
of security, if any as per Collection and Recovery Policy. The provisions of RBI/NHB
Directions, applicable for the Company’s activities, relating to the customers, shall be
complied, as far as applicable.

In the matter of recovery of loans, the Company shall not resort to harassment viz.
persistently bothering the borrowers at odd hours, use muscle power for recovery of
loans etc. As complaints from customers also include rude behavior from the staff of
the companies, The Company shall ensure that the staff is adequately trained to deal
with the customers in an appropriate manner.

All assistance shall be given to resolve disputes or differences regarding dues in a

mutually acceptable and in an orderly manner.
i. Whenever loans are given, AHFLs should explain to the customer the
repayment process by way of amount, tenure and periodicity of repayment.
However if the customer does not adhere to repayment schedule, a defined
process in accordance with the laws of the land shall be followed for
recovery of dues. The process will involve reminding the customer by
sending him / her notice or by making personal visits and / or repossession
of security if any.

ii. The AHFL’s collection policy should be built on courtesy, fair treatment
and persuasion. AHFLs should believe in fostering customer confidence and
long-term relationship. AHFL’s staff or any person authorized to represent
them in collection of dues or / and security repossession shall identify
himself / herself and display the authority letter issued by the AHFL and
upon request, display his / her identity card issued by the AHFL or under
authority of the company. AHFL’s shall provide customers with all the
information regarding dues and shall endeavor to give sufficient notice for
payment of dues.

iii. All the members of the staff or any person authorised to represent the AHFL
in collection or / and security repossession should follow the guidelines set
out below:

a) Customer would be contacted ordinarily at the place of his / her choice and in the
absence of any specified place at the place of his / her residence and if unavailable at
his / her residence, at the place of business / occupation.
b) Identity and authority to represent the AHFL should be made known to the customer
at the first instance.

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c) Customer’s privacy should be respected.

d) Interaction with the customer shall be in a civil manner.
e) AHFLs’ representatives shall contact the customers between 8.00 a.m. and 7.00 p.m.,
unless the special circumstances of the customer’s business or occupation require
otherwise.
f) Customer’s request to avoid calls at a particular time or at a particular place shall be
honoured as far as possible.
g) Time and number of calls and contents of conversation would be documented.
h) All assistance should be given to resolve disputes or differences regarding dues in a
mutually acceptable and in an orderly manner.

i) During visits to customer’s place for dues collection, decency and decorum should
be maintained.

j) Only employees of the Company or Recovery Agency shall visit the borrower’s
premises for the recovery/ collection activity and no other person shall accompany such
Recovery Agent.

k) Inappropriate occasions such as bereavement in the family or such other calamitous

occasions or marriage functions, festivals etc. should be avoided for making calls/visits
to collect dues.

l) The written communication sent by the collection agent to the borrower should have
the approval of the Company.
m. the Company shall interact only with the customer/ borrower or the guarantor (only
if so required) and shall not approach any other relatives/ contacts of the borrower.

19 Disclosure and Transparency

AHFL would provide information on interest rates, common fees and charges through:

(a) MITC format duly signed by customer.

(b) Putting up notice in branches.
(c) Providing service guide/ tariff schedule.
(d) Telephone or help-lines.
(e) AHFL’s website; and
(f) Designated staff/ help desk.

AHFL would transparently disclose to the borrower all information about fees/charges
payable for processing the loan application, the amount of fees refundable if loan
amount is not sanctioned /disbursed, pre-payment options and charges, if any, penal
charges for delayed repayment if any, conversion charges for switching loan from fixed
to floating rates or vice-versa, existence of any interest re-set clause and any other

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matter which affects the interest of the borrower. In other words, AHFL shall disclose
‘all in cost’ inclusive of all charges involved in processing/sanction of loan application
in a transparent manner. It would also be ensured that such charges/fees are non-
discriminatory.

20 Credit reference agencies / Credit Information Companies

a) When a customer opens an account, AHFL shall inform him / her when they may
pass his / her account details to Credit Reference Agencies/ Credit Information
Companies and the checks AHFL may make with them.
b) AHFL may give information to credit reference agencies about the personal debts
the customer owes them if:
i. The customer has fallen behind with his / her payments;
ii. The amount owed is not in dispute; and
iii. The customer has not made proposals that the AHFL are satisfied with, for repaying
his / her debt, following AHFL formal demand.

c) In these cases, the Company shall intimate customer in writing its plan to give
information about the debts he/she owe it to credit reference agencies. At the same
time, the Company shall explain to the customer the role of the credit reference
agencies and the effect the information they provide can have on Customer’s ability
to get credit.

d) AHFLs may give credit reference agencies other information about the customer’s
account if the customer has given them his / her permission to do so.

e) A copy of the information given to the credit reference agencies shall be provided
by the AHFL to a customer, if so demanded.

f) Requests / complaints received from customer / CIC will be processed and updated
to customers as per RBI circular effective from 26.04.2024.

21 Know Your Customer (KYC) Policy:

The Company shall carry out due diligence as required under "Know Your Customer"
(KYC) policy of our Company before opening and operating customer’s account and
in furtherance of the policy. The customer will be asked to submit or provide necessary
documents or proofs for the same. The Company shall ensure obtaining only such
information so as to meet Company's KYC, Anti Money Laundering or any other
statutory requirements.

The Company shall provide the Loan application form / account opening forms and
other material to the Customer and the same shall contain all details of essential

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information required to be furnished and documents to be produced for verification

and/or for record for meeting the KYC requirements.

The Company shall explain the procedural formalities and provide necessary
classifications sought by the customer while opening a loan account.

22 Deposit Accounts :

AHFL shall provide all information regarding its various deposit schemes, if and when
the same are permitted by NHB / launched, including rate of interest, method of interest
application, terms of the deposits, premature withdrawal, loan against deposits,
nomination facilities etc.

23 Branch Closure / Shifting / Relocation/ Merger

AHFL shall give notice to the customer in the event of closure/shifting of its branch
office by display on notice board and public notice to be issued in two newspapers at
least 90 days prior to the relocation/ shifting/ merger or closure and intimate to NHB.
24 General- The Company shall :

 Explain the key features of its loan products including applicable fees and
charges while communicating the sanction of the loan. AHFL shall give
customers full information about the benefits which would accrue to them, how
they could avail such benefits, their financial implications and whom he could
contact in the event of any doubt for addressing their queries.

 Advise the information/documentation required from customer to enable him /

her to apply. Customer would also be advised regarding what documentation is
needed from him / her with respect to customer’s identity, address, employment,
etc. and any other document that may be stipulated by statutory authorities (e.g.
PAN details) in order to comply with legal and regulatory requirements.

 Verify the details mentioned by Customer in the loan application by contacting

him/ her at their residence and / or on business telephone numbers and / or
physically visiting his/her residence and/or business addresses through agencies
appointed for this purpose, if deemed necessary by the Company.

 Customer would be informed to co-operate if the Company needs to investigate

a transaction on his/her account and with the police/ other investigative
agencies, if the Company needs to involve them.

 The Company would advise the customer that if her / she act fraudulently,
he/she will be responsible for all losses on his/her account and that if he/she act
without reasonable care and this causes losses, he/she may be responsible for
the same. Not to discriminate on the basis of race, caste, gender, marital status,
religion or disability.

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1. AHFL shall verify the details mentioned by him/her in the loan application by
contacting him/her at his/her residence and / or on business telephone numbers and / or
physically visiting his/her residence and/or business addresses through agencies
appointed for this purpose, if deemed necessary by the AHFL.

2. The customer should be informed to co-operate if the AHFL needs to investigate a

transaction on the customer’s account and with the police/ other investigative agencies,
if the AHFL needs to involve them.

3. AHFL should advise the customer that if the customer acts fraudulently, he / she will
be responsible for all losses on his/her account and that if the customer acts without
reasonable care and this causes losses, the customer may be responsible for the same.

4. AHFL shall not discriminate on grounds of sex, caste and religion in the matter of
lending. Further, HFCs shall also not discriminate visually impaired or physically
challenged applicants on the ground of disability in extending products, services,
facilities, etc. However, this does not preclude AHFLs from instituting or participating
in schemes framed for different sections of the society.
5. AHFL shall process requests for transfer of a loan account, either from the borrower
or from a bank/financial institution, in the normal course.

6. To publicise the code, AHFL shall:

a) Exhibit a copy of this Code on the Web site & Notice Board at Branches.

b) make this Code available on request either over the counter or by electronic
communication or mail to customers;
c) ensure that their staff are trained to provide relevant information about the Code and
to put the Code into practice;
d) provide existing and new customers with a copy of this Code.

Note: The requirements regarding Digital Lending Platforms are not applicable to the
Company.

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