Grievance Redressal Policy

CUSTOMER GRIEVANCE REDRESSAL MECHANISM POLICY

Policy Overview

Document Revision History

Table Of Contents

1. Preamble

DJT Microfinance Private Limited is committed to providing its customers fair, transparent, and dignified financial services. A cornerstone of this commitment is a robust, accessible, and time-bound Customer Grievance Redressal Mechanism (CGRM) that ensures every customer concern is heard, acknowledged, and resolved fairly.

This policy is mandated by and fully aligned with:

• RBI Master Direction — Non-Banking Financial Company — Micro Finance Institutions (NBFC-MFI) Directions, 2025
• MFIN Code of Conduct for Microfinance Institutions
• Sa-Dhan Code of Conduct for Microfinance Institutions

This policy supersedes all previous versions and applies to all customers of DJT Microfinance Pvt. Limited irrespective of the product or service availed.

2. Policy Objectives

The CGRM policy is designed to achieve the following objectives:

• Provide DJT MICROFINACE PVT. LIMITED customers with convenient, multiple, and accessible channels to raise complaints, service requests, and queries.
• Ensure all grievances are acknowledged, recorded, investigated, and resolved within defined turnaround times in a fair and transparent manner.
• Protect customers from fraud, mis-selling, deceptive practices, and coercive recovery behaviour.
• Maintain a comprehensive complaints database to generate actionable insights for continuous improvement of products and services.
• Ensure timely and accurate reporting of complaints data to the Board, SROs (MFIN and Sa-Dhan), and RBI as required.
• Uphold customer dignity and the right to complain without fear of retribution or adverse impact on loan relationships.
• Enable disciplinary accountability for staff found responsible for customer grievances.

3. Scope and Applicability

This policy applies to:

• All existing and past customers of DJT MICROFINACE PVT. LIMITED, including borrowers of group loans, individual loans, and holders of insurance products such as credit life insurance and hospital cash insurance.
• Any family member or legal representative acting on behalf of a customer.
• Complaints received through any channel — including those forwarded by MFIN, Sa-Dhan, RBI, or any other external authority.
• All employees, agents, and third-party service providers who interact with DJT MICROFINACE PVT. LIMITED's customers.

4. Definitions

5. Categorisation of Complaints and Calls

All calls, written complaints, and digital communications received by DJT MICROFINACE PVT. LIMITED shall be classified into one of the following three primary categories upon receipt:

5.1 Complaint Sub-Categories

All complaints / grievances shall be further classified into sub-categories in alignment with MFIN's Code of Conduct (4th Edition):

5.2 Severity Tagging

• Severe Complaints: Fraud by staff, coercive/abusive recovery practices, excessive undisclosed charges, staff misconduct, or fraud by external agencies. Severe complaints must be escalated immediately to the GRO and the IIC for priority investigation.
• Non-Severe Complaints: All other complaints shall be resolved through the standard redressal process within the defined TAT.

6. Complaint Channels

DJT MICROFINACE PVT. LIMITED provides four channels for customers to register complaints, service requests, or queries:

Channel 1 — Physical Receipt at Branch

Customers may approach any DJT MICROFINACE PVT. LIMITED branch during working hours and register their complaint in the Feedback cum Complaint Register maintained at the branch. Every branch shall mandatorily display and maintain: the Feedback cum Complaint Register; name, designation, and contact number of the Branch Manager; DJT MICROFINACE PVT. LIMITED Toll-Free Number: 1800-309-2493; MFIN Toll-Free Number: 1800 102 1080; and RBI / DNBS Contact: +91-011-23714456 / 0538 | dnbsnewdelhi@rbi.org.in. Branch-level complaints not resolved within 7 working days must be escalated by the Branch Manager to the Head Office Customer Grievance Cell.

Channel 2 — DJT MICROFINACE PVT. LIMITED Head Office Toll-Free Helpline

Toll-Free Number: 1800-309-2493 | Hours: 9:00 AM – 6:00 PM, Monday to Saturday | Email: grievance@djtmpl.com | GRO: Mr. Anuj Kumar Gupta, Manager — Plot No. A2B, 8th Floor, Sector 125, NOIDA – 201303, Uttar Pradesh.

Customers or their representatives may call this number to register complaints, submit service requests, or raise queries. The Customer Care Executive (CCE) will record the complaint and provide a reference number. Details logged in the complaint sheet are listed in Section 8 below.

All categories of complaints received on this channel will be resolved within 30 working days. For insurance-related cases, the TAT is 60 days, subject to correct documentation and verification by the insurer.

Channel 3 — MFIN Toll-Free Number

MFIN Toll-Free: 1800 102 1080 | Hours: 9:00 AM – 6:00 PM, Monday to Friday.

If a complaint is not resolved to the customer's satisfaction at DJT MICROFINACE PVT. LIMITED's level, the customer may escalate to the MFIN grievance redressal helpline. DJT MICROFINACE PVT. LIMITED will resolve such complaints within 15 working days of receipt from MFIN.

Channel 4 — RBI / DNBS

Contact: Dy. General Manager, Department of Non-Banking Supervision (DNBS), Reserve Bank of India, 6, Parliament Street, New Delhi – 110001 | Tel: +91-011-23714456 / 0538 | Email: dnbsnewdelhi@rbi.org.in.

If a complaint remains unresolved through all the above channels, the customer may approach the Regional Office of DNBS (Department of Non-Banking Supervision of the Reserve Bank of India) under whose jurisdiction DJT MICROFINACE PVT. LIMITED's registered office falls.

7. Escalation Matrix

The following escalation matrix defines the structured path for complaint resolution:

8. Complaint Recording and Log Management

DJT MICROFINACE PVT. LIMITED maintains a centralised, electronic Complaint Log / Control Sheet in MS Excel for all complaints received across all channels. The log is updated in real-time and serves as the primary record for escalation, reporting, and audit purposes.

8.1 Mandatory Data Fields

8.2 Complaint Status Definitions

• Open: Complaint registered and under active investigation or pending action by the relevant department.
• Under Investigation: Complaint referred to regional operations, IIC, or third-party provider for resolution.
• Escalated: Complaint escalated to next level (MFIN / RBI) due to non-resolution within TAT.
• Closed: Complaint resolved to the satisfaction of the customer, or resolution communicated and TAT expired with no further appeal.

9. Grievance Resolution Process

The following end-to-end process governs the receipt, investigation, and closure of all complaints:

• Receipt & Acknowledgement: Upon receipt through any channel, a unique complaint reference number is generated and communicated to the customer within 24 hours. For written/email complaints, an acknowledgement is sent within 3 working days.
• Classification: The CCE or Branch Manager classifies the complaint into primary category, sub-category, and severity as defined in Section 5.
• Validation & Routing: The CCE validates the complaint against DJT MICROFINACE PVT. LIMITED's records and routes it to the relevant department. For third-party (insurance) complaints, the customer is provided the third-party provider's contact details and follow-up is conducted.
• Investigation: The assigned department investigates the complaint. For Severe complaints, the IIC is convened immediately.
• Resolution & Communication: Once resolved, the decision is communicated to the customer via phone call. The case status is updated to Closed in the Complaint Log.
• TAT Exceptions: In cases where the TAT may be exceeded due to circumstances beyond DJT MICROFINACE PVT. LIMITED's control (e.g., complex investigations, third-party delays), an interim reply must be provided to the complainant within the standard TAT period.
• Post-Resolution Satisfaction Check: The Operations team conducts a weekly sampling of recently closed complaints to verify customer satisfaction. Results are recorded in the Complaint Log.
• Interim Replies: Where a complaint cannot be resolved within the standard TAT, an interim reply must be provided acknowledging receipt and providing a revised expected resolution date.

10. Nodal Officer Appointment and Role

In compliance with the RBI Ombudsman Scheme for Non-Banking Financial Companies, 2018, DJT MICROFINACE PVT. LIMITED has appointed a Principal Nodal Officer (PNO) at the Head Office and Nodal Officers at Regional / Zonal levels.

10.1 Principal Nodal Officer (Head Office)

10.2 Role and Responsibilities of the Nodal Officer

• Represent DJT MICROFINACE PVT. LIMITED before the RBI Ombudsman and the Appellate Authority under the RBI Ombudsman Scheme for NBFCs, 2018.
• Coordinate and liaise with the Consumer Education and Protection Department (CEPD), RBI Central Office, Mumbai.
• Furnish information and documentation to the Ombudsman in respect of all complaints filed against DJT MICROFINACE PVT. LIMITED.
• Forward names and contact details of Zonal / Regional Nodal Officers to the relevant RBI Ombudsman offices.
• Oversee the overall functioning of the CGRM and report to the Board.

11. Governance, Reporting, and Oversight

11.1 Monthly CGRM Report

The CGRM team shall prepare a Monthly CGRM Report covering:

• Total number of complaints, service requests, and queries received — channel-wise and category-wise
• Number and percentage of complaints resolved within TAT
• Number of complaints escalated to MFIN / RBI
• Number of complaints pending beyond TAT with reasons
• Top 3 branches by complaint volume
• Severe complaints — details and resolution status
• Customer satisfaction scores from post-resolution calls

The Monthly CGRM Report shall be reviewed by Senior Management and shared with the Board.

11.2 Quarterly Board Reporting

A comprehensive CGRM summary shall be presented at every quarterly Board meeting, covering:

• Trend analysis of complaints by type, sub-category, and severity
• KPI performance against benchmarks (see Section 11.4)
• Root cause analysis of systemic issues and corrective actions taken
• Status of all open / escalated complaints
• MFIN quarterly CGRM report filed

11.3 Internal Audit

During the quarterly Internal Audit cycle, the Internal Audit team shall review:

• Complaint registers at all branches for completeness and timely closure
• Adherence to TAT for all categories of complaints
• Adequacy of branch-level display of grievance contact information
• Staff compliance with CGRM training and protocols

Audit findings shall be reported to the Audit Committee of the Board, and corrective actions shall be tracked to closure.

11.4 KPI Monitoring Framework

12. Staff Training and Communication

12.1 New Staff Induction

All new DJT MICROFINACE PVT. LIMITED staff shall receive mandatory training on the CGRM as part of their induction programme, covering: customer rights and the importance of grievance redressal; complaint categorisation, recording, and escalation procedures; soft skills for empathetic complaint handling; and consequences of non-compliance with CGRM norms.

12.2 Refresher Training

All existing staff shall receive refresher training on CGRM at least once per year, and additionally whenever material amendments are made to this policy, new RBI / MFIN / Sa-Dhan guidelines are issued, or significant patterns of complaints are identified at any branch or region.

12.3 Communication to Customers

DJT MICROFINACE PVT. LIMITED shall ensure that customers are made aware of their right to complain and the channels available through the following touchpoints:

• At origination / loan application stage
• At the training meeting (Centre Leader / Group orientation)
• At disbursement — the helpline number shall be printed on the loan sanction letter, acknowledgement receipt, and loan card
• At every subsequent interaction with field staff

All branch premises shall prominently display the Grievance Notice Board with DJT MICROFINACE PVT. LIMITED's toll-free number, GRO details, MFIN helpline number, and RBI DNBS contact details in the local language.

13. Disciplinary Action Against Staff

Where a complaint is found, after investigation, to have been caused by the conduct, negligence, or misconduct of a DJT MICROFINACE PVT. LIMITED employee, appropriate disciplinary action shall be taken. The nature of action shall be commensurate with the frequency and severity of the complaint and may include: verbal or written warning; mandatory re-training; performance improvement plan; suspension pending investigation; or termination of employment for severe or repeat misconduct. All disciplinary actions shall be initiated by the supervisor / State Head in coordination with the HR team, following a formal investigation process.

14. Compliance with Industry Code of Conduct

This policy is fully aligned with the MFIN Code of Conduct (4th Edition, October 2022) and the Sa-Dhan Code of Conduct, which require all member MFIs to:

• Maintain a robust Customer Grievance Redressal System that addresses complaints effectively and within defined timelines.
• Clearly communicate the details of the CGRM at branches, in loan documents, and through all customer communication materials.
• Record all complaints — including those received through external channels (MFIN, Sa-Dhan, RBI) — and report quarterly to SROs.
• Ensure customers can exercise their right to complain without fear of adverse consequences to their loan relationship.

DJT MICROFINACE PVT. LIMITED submits the MFIN CGRM quarterly report within the prescribed deadline, as requested by MFIN by email each quarter.

15. Policy Review and Amendment

This policy shall be reviewed periodically, and at a minimum annually, by the Compliance team in consultation with Operations and Senior Management. It shall be revised when: changes are introduced to RBI NBFC-MFI Directions or Master Circulars; amendments are made to MFIN or Sa-Dhan Codes of Conduct; new grievance channels are introduced; or significant systemic issues are identified through KPI monitoring or Internal Audit.

All amendments shall be approved by the Board of Directors before coming into effect.