The debt collection policy (hereinafter referred to as the “Policy”) of Yuvaraj Finance Private Limited (hereinafter referred to as the “YUVARAJ”) is built around dignity and respect to customers. YUVARAJ will not follow policies that are unduly coercive in collection of dues.

The policy is built on courtesy, fair treatment. YUVARAJ believes in following fair practices with regard to collection of dues and thereby fostering customer confidence and long-term relationship.

All the practices adopted by YUVARAJ for follow up and recovery of dues will be in consonance with the law.

Collections is an important service that helps to both maintain clients and free up money for lending again. It is a strategic process that is key to generating good habits and a payment culture among clients.
Because lending cannot exist without repayment, and repayment requires collections, debt collection practices are integral to our scope of work. We understand that our collectors must not only effect repayment but must also conduct their work in an open, honest and legal manner.

This Policy is covering three key dimensions that impact how strong controls are on customer treatment.

First, it is a strong correlation between the legal infrastructure available for enforcement of claims and the sophistication of the controls employed by YUVARAJ. For example, field collections tends to be the dominant mode of customer contact, while in some specific cases YUVARAJ can tend to rely more heavily on voice contact, where oversight options are stronger.

Second, an independent governance and oversight framework is one of the main instruments of the collection activity. We understand that setting and ensuring adherence to ethical standards is one of the core responsibilities of YUVARAJ.
Our collection methods should always balance between achieving the highest possible recoveries and achievement of the best ethical treatment of customers.
All customer complaints tend to be handled and monitored using procedures that are adopted by YUVARAJ.

As 3rd important part of the scope for regulation of our collection activity we see the trainings offered to our employees to ensure that we are fully compliant with current legislation and rules established by this Policy.
This Policy together with other policies of YUVARAJ establish regulation that provides a legal recourse framework, a consumer protection framework, protection from creditors through all legal possible options and recourse mechanisms for ill‑treated borrowers (e.g. ombudsman offices). Our policies also promotes strong credit information infrastructures, customer education and collection trainings.

Collection Process (Standard Operating Procedure)
By this Policy we set up disciplined collections processes that assist us to achieve better control over the customer experience, but also deliver superior collections performance.

If the customer does not adhere to repayment schedule, a defined process in accordance with the laws of the land will be followed for recovery of dues. The process will involve reminding the customer by sending the notice or by making personal visits. In case of default / anticipated default, while YUVARAJ reserves the right to take recourse to all available legal and contractual remedies, it may also use the services of specialized recovery agencies / legal advisors.

Reducing conflicts with customer
1. We take responsibility to make analysis of applying best collection practices and strategies
2. Strong measuring and reporting of collections activities;
3. System of identification and responding to weaknesses in controls;
4. Financial education of our customers by well-informing about products and processes that are implemented on our side. We think that is our “financial literacy”, where we openly put all information to the customer in all front-end solutions within additional explanations by our team.

Principles of collections conduct
1. Investing in a transparent relationship with the borrower:
a. Borrower awareness of the consequences of default;
b. Terms and conditions clearly communicated;
c. Education about avoiding delinquency;
d. Avoidance of predatory lending practices;
e. Etc.

2. Interacting with the customer in a fair and respectful manner:
a. Non-discrimination;
b. Contact at reasonable hours and frequency;
c. Polite, respectful, non-threatening language;
d. Respect of privacy;
e. Good faith participation in negotiations, mediation and other processes for consensual resolution of debts;
f. Etc.

3. Develop relationships and systems to support ethical practices
a. No outsourcing of unethical practices to other collectors;
b. No manipulation of legal or political institutions to condone irresponsible/unethical practices;
c. Internal systems to regularly audit practices and operational performance to ensure compliance with ethical guidelines;
d. Loan restructuring and other solutions for hardship cases;
e. Training and incentives for ethical practices;
f. Etc.

Our Collection Strategy
1. Early identification of the borrower’s situation, ideally pre-delinquency or after the first missed payment, assessing likely capacity and willingness to repay.

2. Triage of borrowers to align contact strategy to customer situation, balancing costs with expected recoveries. Reassessment of tactics as new information is received.

3. Access to a variety of “exit options” including restructuring, modifications and concessions.

4. Failure to voluntarily repay, including civil recourse for unsecured exposures, criminal liability in fraud cases and credit bureau reporting.

To implement this strategy our collection institutions is applying to the following activities:
a) Using of behavioral and other customer data as well as contact feedback to assess the customers’ situation and identify fraud and skip cases early on. Our analytical tools include scoring and other predictive segmentation methods. We ensuring a smooth flow of customer information between parties interfacing with the customer to provide continuity in dialog.

b) Customer intelligence is used to segment borrowers into alternative collections processes: (e.g., gentle reminders for first time delinquents likely to repay, immediate legal proceedings for suspected fraud cases, and everything in between).

c) We ensure that management have confidence that the agent-customer interface is well understood by conducting trainings.

Field Collection Control Mechanisms
1. Close supervision:
Our field agents are generally managed in small teams. Agents typically report daily to our team leaders who closely manage their caseflow, accompany agents on selected visits and bring in more senior collectors for more difficult cases or those requesting modifications or settlements.
2. Technology:
We use mobile and other technologies by collectors to help manage workflow, record customer trail information, track collectors’ whereabouts and issue receipts to borrowers. Such systems reducing fraud and cash defalcation.
3. Team visits:
For special cases or where we think that it will be reasonable we send staff in pairs or teams, or send staff to accompany third parties engaged for repossessions. This ensures that a second pair of eyes keeps a check on the customer interaction and discourages fraud. We understand that it is costly, but this is the price for our responsible collection activity.
4. Visit follow-ups:
We established a system of random follow-up calls to customers visited by field agents. These confirm that a visit was made, verify the outcome of the visit (i.e., whether a payment or promise to pay was given) and seek feedback on the collector’s conduct.

Call Collection Activity
Phone contact is usually used for soliciting repayment for early stage delinquencies, but we are not limited to apply call collection activity for later stages of delinquency.
Our collection institutions fully centralized for phone contacts at a call center. This makes impossible for anyone to make any call to our customer from their own mobile devices.
All our calls are heavily scripted, recorded and highly monitored by special audit terms. As a result, there is a low risk of misconduct.

Legal Resource
YUVARAJ has the right in accordance with legislation to timely, equitable and enforced civil proceedings against defaulting borrowers, whether the debt is secured or unsecured.
In parallel with legal proceedings against the defaulted borrower telephonic reminders or visits by the YUVARAJ representatives to the borrowers place or residence may be used as loan follow up measure.
Respective Legal Demand Notice sent by YUVARAJ or by legal representative on behalf of YUVARAJ is the part of collection activity that is stipulated by Indian legislation.

Other Channels for Collection Activity
YUVARAJ is not limited to use any other channels for collection activity which are fully compliant with current legislation. It covers (but not limited) SMS, e-mail, post mail, social network messages, etc.

These channels could be used for the following activity:
a) Text payment notifications. Payment reminders can help debtor to reduce collection costs and encourage customers to pay their debts.
b) Inform clients of debt collection laws to help them understand the legal repercussions of overdue payments.
c) Follow up on payment confirmations. This improves your relationship and increase customer loyalty.
d) Schedule payment reminders.
e) Send SMS messages with account details. Full transparency and constant updates makes it easier to collect the entire debt.
f) Generate auto-responders for common inquiries. We can send automated texts, such as payment plans, debt amounts, interest rates, etc via text. Simply we do assign keywords to common questions and the customer receives respective automatic replies.
g) Monitor communication efficiency. Bulk messaging provides intuitive dashboards with metrics such as delivery time, delivery status, response rate, costs, etc. This help us to determine the effectiveness of our strategy.
h) Etc.

Outsourcing to 3rd party agencies
Engaging third-party agencies at some stage in collections occurs periodically and depends on our strategy of working with each case.
Usually, third parties participate in all stages of collections. Sometimes they are contracted for specific skills which YUVARAJ is not able to provide, but volume capacity can be the reason also.
Ensuring responsible practices by these agencies is the one of our core responsibility.
There is our not exhaustive list of principles for choosing 3rd party agencies:
a) Years in business;
b) Local expertise;
c) Specialized skills;
d) Reputation;
e) Background check;
f) Collection efficiency;
g) Hiring policy;
h) Customer complaints;
i) Etc.

Monitoring of collection activity
Active monitoring and complaint handling mechanisms established by YUVARAJ at ad hoc level. This is our investment for responsible collection activity.
Monitoring of activities in our call center is strong, with tight management spans (typically 1 supervisor to small group of callers) and call recording in place.
We have different tools to achieve the best quality of call-center activity like detection of foul language or aggressive tones, etc.
Second part of monitoring landscape is complaints management policy that establish different mechanism to protect rights of our customers like:
a) Dedicated complaints hotlines
b) Alternative complaint channels – SMS, email, mail
c) Advertising hotlines to customers through documents, receipts

Our Ethical Collections Standards
1. Transparent relationship with the borrower: borrowers should be made aware of the consequences of defaulting on a payment. All terms and conditions should be clearly communicated to the borrowers, and they should be educated about ways to avoid delinquency. In the event that a borrower defaults on his loan due to some hardship, loan restructuring options or other solutions should be offered to him in such a way as to avoid over-indebtedness and help him out of his situation.

2. Interacting with the customer in a fair and respectful manner. The following policies are adopted and followed strictly:
a. No discrimination on the basis of race, religion, gender etc.
b. Borrowers should not be contacted at unreasonable hours or frequency
c. Language and behavior used should be polite, respectful, and non-threatening. On no account should collectors resort to physical violence or verbal abuse.
d. The customer’s privacy should be respected. His state of indebtedness should not be unduly revealed to third parties.
e. Do not outsource unethical practices to other collectors
f. Do not manipulate legal or political institutions to condone unethical practices

Other regulations of Fair Practice Code
YUVARAJ would strive to provide valuable inputs to the stakeholders and facilitate effective interaction with YUVARAJ and ensure utmost transparency.

This Code shall apply across all aspects of YUVARAJ’s operations including marketing, processing, servicing, collection and other activities.

YUVARAJ’s Board of Directors and the management are responsible for establishing practices designed to ensure that its operations reflect a strong commitment to fair relations and that all employees are aware of that commitment.

Activities of YUVARAJ are conducted in line with RBI / Company Law and prevailing local regulations/rules/laws/Acts. In the event this Policy is at variance with regulations/rules/laws/Acts at any stage due to omissions or changes in regulations/rules /laws/Acts, the regulations/rules/laws/Acts would prevail. If any clarifications are needed on these regulations/rules /laws/Acts, the same must be referred to respective officer at YUVARAJ for its final opinion on the issue.

This FPC applies to all categories of products and services offered/to be offered by YUVARAJ.

Key Aspects of FPC
The essence of the FPC lies in the following aspects that YUVARAJ shall strive to follow in spirit and in letter:
a) To provide professional, efficient, courteous, diligent and speedy services;
b) Not to discriminate on the basis of religion, caste, gender, descent in any manner;
c) To be fair and honest in any advertisement and marketing of products;
d) To provide customers with accurate and timely disclosure of terms, costs, rights and liabilities as regards transaction;
e) To attempt in good faith to resolve any disputes or differences with customers by setting up Complaints Management Policy within the organization;
f) To comply with all the regulatory requirements in good faith;
g) Seek to use governance structures that provide appropriate levels of oversight in the areas of potential conflicts of interest;
YUVARAJ believes in following fair practices with regard to collection of dues and thereby fostering customer confidence and longterm relationship.

Scope of FPC
All debt recovery in India is to be performed in compliance with Fair Practices Code of RBI:
 Recovery should normally be made only at a central designated place.
 Field staff shall be allowed to make recovery at the place of residence or work of the borrower only if borrower fails to appear at central designated place on two or more successive occasions.
 All collection staff is regularly trained with systems in place for their recruitment, training and supervision.
 All staff shall perform appropriate behavior towards borrowers without adopting any abusive or coercive debt collection / recovery practices.
 Compensation methods for staff should have more emphasis on areas of service and borrower satisfaction than merely the number of loans mobilized and the rate of recovery.
 Penalties may also be imposed in cases of non-compliance by field staff with the Code of conduct.
 Generally only employees and not outsourced recovery agents be used for recovery in sensitive areas.
× No violation of any law
× No abusive or inappropriate or foul language should be used
× Not calling or visiting at night hours shall be done
× No unauthorized interaction with debtors
× No use of unauthorized templates, scripts, etc.
× No disclosure of personal or financial information to third unrelated parties
× Not pretending to be state authorities or any other authorities
× Not misleading of the debtor regarding the amount or terms of its debt

Aforementioned scope adjusted with the following requirements for all the members of the staff or any person authorized to represent YUVARAJ in collection:

1. The 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.

2. Identity and authority of persons authorized to represent YUVARAJ for follow up and recovery of dues would be made known to the customers at the first instance. YUVARAJ staff or any person authorised to represent the YUVARAJ in collection of dues will identity himself / herself and display the respective letter issued by YUVARAJ and upon request.

3. YUVARAJ would respect privacy of its borrowers. It shall however be noted that contacting the borrower on phone or personal visits for recovery of dues (in line with this model policy) will not be construed as an intrusion of the privacy of the borrower.

4. YUVARAJ is committed to ensure that all written and verbal communication with its borrowers will be in simple business language and YUVARAJ will adopt civil manners for interaction with borrowers.

5. Normally YUVARAJ representatives will contact the borrower within hours that are allowed by the law and/or agreement with the borrower, unless the special circumstances of his/her business or occupation requires YUVARAJ to contact at a different time.

6. Borrower’s requests to avoid calls at a particular time or at a particular place would be honoured as far as possible.

7. YUVARAJ will document the efforts made for the recovery of dues and gist of interactions with the borrowers.

8. All assistance will be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.

9. Inappropriate occasions such as bereavement in the family or such other calamitous occasions will be avoided for making calls/visits to collect dues.