Ombudsman Policy

RBI INTEGRATED OMBUDSMAN SCHEME

Policy Overview

Document Revision History

Table Of Content

DJT Microfinance Private Limited is a Non-Banking Financial Company - Microfinance Institution (NBFC-MFI) registered with and regulated by the Reserve Bank of India. The Company is committed to providing high-quality financial services to its customers and ensuring that customer grievances are addressed in a fair, transparent, and expeditious manner.

This policy document outlines DJT Microfinance Private Limited approach to compliance with the Reserve Bank - Integrated Ombudsman Scheme, 2021 ("the Scheme"), which came into effect on November 12, 2021.

1. Introduction

1.1 Purpose

The purpose of this policy is to:

• Establish a comprehensive framework for handling customer complaints in accordance with the RBI Integrated Ombudsman Scheme, 2021
• Define roles, responsibilities, and processes for effective grievance redressal
• Ensure customers are fully informed about their rights under the Scheme
• Facilitate seamless coordination with the RBI Ombudsman mechanism
• Promote a customer-centric culture within the organization
• Maintain full regulatory compliance and minimize operational risks

1.2 Scope

This policy applies to:

• All customers of DJT Microfinance Private Limited who have availed or are availing financial services
• All employees, officers, and representatives of the Company involved in customer service delivery
• All branches, offices, and business locations of the Company across India
• All products and services offered by the Company that fall within the regulatory purview of the Reserve Bank of India

1.3 Regulatory Framework

This policy is formulated in accordance with:

• Reserve Bank - Integrated Ombudsman Scheme, 2021 (RBI Notification Ref. CEPD.PRD.No.S873/13.01.001/2021-22 dated November 12, 2021)
• Section 45L of the Reserve Bank of India Act, 1934
• Section 35A of the Banking Regulation Act, 1949
• Section 18 of the Payment and Settlement Systems Act, 2007
• RBI Master Direction - Non-Banking Financial Company - Microfinance Institutions (Reserve Bank) Directions, 2016
• Fair Practices Code for NBFCs as prescribed by RBI

2. Definitions

For the purposes of this policy, the following terms shall have the meanings assigned to them below:

2.1 Appellate Authority

Means the Executive Director in-charge of the Department of the Reserve Bank administering the Scheme.

2.2 Authorised Representative

Means a person, other than an advocate, duly appointed and authorised in writing to represent the complainant in proceedings before the Ombudsman.

2.3 Award

Means an award passed by the Ombudsman in accordance with the Scheme.

2.4 Complaint

Means a representation in writing or through other modes alleging deficiency in service on the part of the Company.

2.5 Deficiency in Service

Means a shortcoming or an inadequacy in any financial service which the Company is required to provide statutorily or otherwise, which may or may not result in financial loss or damage to the customer.

2.6 Ombudsman

Means an officer of the Reserve Bank appointed to consider customer complaints relating to deficiency in service.

2.7 Appellate Authority Secretariat

Means the Department in the Reserve Bank which is administering the Scheme.

2.8 Bank

Means a 'banking company', a 'corresponding new bank', a 'Regional Rural Bank', 'State Bank of India' as defined in the Banking Regulation Act, 1949, a 'co-operative bank' as defined in Section 56(c) of the Banking Regulation Act, 1949 to the extent not excluded under the Scheme, but does not include a bank in resolution or winding up or under directions or any other bank as specified by the Reserve Bank.

2.9 Non-Banking Financial Company (NBFC)

Means an NBFC as defined in Section 45-I(f) of the Reserve Bank of India Act, 1934 and registered with the Reserve Bank, to the extent not excluded under the Scheme, but does not include a Core Investment Company (CIC), an Infrastructure Debt Fund-Non-Banking Financial Company (IDF-NBFC), a Non-Banking Financial Company - Infrastructure Finance Company (NBFC-IFC), a company in resolution or winding up/liquidation, or any other NBFC specified by the Reserve Bank. Explanation: The terms CIC and IDF-NBFC shall have the same meaning assigned to them under the RBI Directions.

2.10 Regulated Entity

Means a bank or a Non-Banking Financial Company or a System Participant as defined in the Scheme, or any other entity as may be specified by the Reserve Bank from time to time, to the extent not excluded under the Scheme.

2.11 Settlement

Means an agreement reached by the parties to the complaint by facilitation or conciliation or mediation, as per the provisions of this Scheme.

2.12 System Participant

Means a person other than the Reserve Bank and a System Provider, participating in a payment system as defined in the Payment and Settlement Systems Act, 2007.

2.13 System Provider

Means and includes a person who operates an authorised payment system as defined in Section 2 of the Payment and Settlement Systems Act, 2007.

3. Applicability and Coverage

3.1 Entities Covered

• All Commercial Banks, Regional Rural Banks, Scheduled Primary (Urban) Co-operative Banks and Non-Scheduled Primary (Urban) Co-operative Banks with deposits size of Rupees 50 crore and above as on the date of the audited balance sheet of the previous financial year.
• All Non-Banking Financial Companies (excluding Housing Finance Companies) which (a) are authorised to accept deposits; or (b) have customer interface, with an assets size of Rupees 100 crore and above as on the date of the audited balance sheet of the previous financial year.
• All System Participants as defined under the Scheme.

4. Grounds of Complaint

Any customer aggrieved by an act or omission of a Regulated Entity resulting in deficiency in service may file a complaint under the Scheme personally or through an authorised representative as defined under clause 2(2.2).

5. Grounds for Non-Maintainability

5.1 Matters Not Covered

No complaint for deficiency in service shall lie under the Scheme in matters involving:

• Commercial judgment or commercial decision of the Company
• A dispute between a vendor and the Company relating to an outsourcing contract
• General grievances against management or executives
• A dispute involving employee-employer relationship
• A grievance not addressed to the Ombudsman directly
• A dispute in which action is initiated by a Regulated Entity in compliance with the orders of a statutory or law enforcing authority
• A service not within the regulatory purview of the Reserve Bank
• A dispute between Regulated Entities

5.2 Procedural Requirements

A complaint under the Scheme shall not lie unless:

• the complainant had, before making a complaint under the Scheme, made a written complaint to the Regulated Entity concerned and —
  1. the complaint was rejected wholly or partly by the Regulated Entity, and the complainant is not satisfied with the reply; or the complainant had not received any reply within 30 days after the Regulated Entity received the complaint; and
  2. the complaint is made to the Ombudsman within one year after the complainant has received the reply from the Regulated Entity to the complaint or, where no reply is received, within one year and 30 days from the date of the complaint.

• the complaint is not in respect of the same cause of action which is already —
  1. pending before an Ombudsman or settled or dealt with on merits, by an Ombudsman, whether or not received from the same complainant or along with one or more complainants, or one or more of the parties concerned;
  2. pending before any Court, Tribunal or Arbitrator or any other Forum or Authority; or, settled or dealt with on merits, by any Court, Tribunal or Arbitrator or any other Forum or Authority, whether or not received from the same complainant or along with one or more of the complainants/parties concerned;

• the complaint is not abusive or frivolous or vexatious in nature;
• the complaint to the Regulated Entity was made before the expiry of the period of limitation prescribed under the Limitation Act, 1963, for such claims;
• the complainant provides complete information as specified in clause 11 of the Scheme;
• the complaint is lodged by the complainant personally or through an authorised representative other than an advocate unless the advocate is the aggrieved person.

6. Procedure for Filing Complaint with RBI Ombudsman

6.1 When to Approach the Ombudsman

A customer may file a complaint with the RBI Ombudsman when:

• The Company has rejected the complaint wholly or partly
• The Company has not responded within 30 days
• The complaint must be filed within one year from receiving Company's reply (or one year and 30 days if no reply)

6.2 Procedure for Filing Complaint

6.2.1 Online Portal (Recommended)

Website: https://cms.rbi.org.in

6.2.2 Email

Email: CRPC@rbi.org.in

6.2.3 Physical / Postal Mail

Centralised Receipt and Processing Centre

Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160017

6.2.4 Toll-Free Helpline

• Toll-Free Number: 14448
• Timing: 9:30 AM to 5:15 PM (Monday to Friday)
• Languages: Hindi, English, and regional languages

The Principal Nodal Officer (PNO) represents the Regulated Entity in complaint matters and provides required information; contact details are available on the company website.

The Regulated Entity must submit a written response with all relevant documents to the Ombudsman within 15 days, with the possibility of an extension if approved by the Ombudsman.

The Ombudsman/Deputy Ombudsman may reject a complaint at any stage if it is not maintainable under the Scheme.

A complainant can appeal to the Appellate Authority (Executive Director, CEPD, RBI) within 30 days of the Award or rejection, with a maximum additional 30 days allowed for valid delay reasons.

7. Ombudsman Process and Proceedings

7.1 Initial Scrutiny

1. Complaints which are in the nature of offering suggestions or seeking guidance or explanation shall not be treated as valid complaints under the Scheme and shall be closed accordingly with a suitable communication to the complainant.

2. Complaints which are non-maintainable under clause 10 shall be separated to issue a suitable communication to the complainant.

3. The remaining complaints shall be assigned to the offices of the Ombudsman for further examination under intimation to the complainant. A copy of the complaint shall also be forwarded to the Regulated Entity against whom the complaint is filed with a direction to submit its written version.

7.2 Company's Response Obligations

7.3 Timeline

• Submit written response within 15 days from receipt
• Extension may be granted by Ombudsman if justified
• Failure to respond may result in ex-parte Award with no right of appeal

7.3.2 Content of Response

• Detailed point-by-point reply to all allegations
• All relevant facts and timeline of events
• Copies of all relevant documents
• Signature of authorized officer (PNO or designated representative)

7.4 Resolution Methods

The Ombudsman may resolve complaints through:

• Facilitation – informal process for quick resolution
• Conciliation/Mediation – formal mediation process
• Adjudication (Award) – if settlement not possible

8. Awards and Compensation

8.1 No Monetary Limit on Dispute Amount

There is NO upper limit on the amount of dispute that can be brought before the Ombudsman. Customers can file complaints irrespective of the value involved.

8.2 Compensation Powers

8.2.1 Consequential Loss

For actual financial loss:

• Maximum compensation: Lower of actual loss OR Rs. 20 lakhs.
• This is EXCLUSIVE of (i.e., in addition to) the principal amount in dispute

8.2.2 Harassment and Mental Anguish

For non-monetary loss:

• Maximum compensation: Rs. 1 lakh
• Covers: Loss of time, expenses incurred, harassment, mental anguish
• This is IN ADDITION to compensation for consequential loss

8.3 Award Acceptance and Implementation

8.3.1 Complainant's Acceptance

• Award is sent to both parties
• Award lapses if complainant does not accept within 30 days
• Acceptance must be in writing stating 'full and final settlement'

8.3.2 Company's Compliance

Upon receipt of complainant's acceptance letter, DJT Microfinance Private Limited must:

• Comply with the Award within 30 days
• Intimate compliance to the Ombudsman
• Award is binding on the Company (unless appeal is filed and allowed)

9. Rejection of Complaints

The Ombudsman may reject a complaint if:

1. The Deputy Ombudsman or the Ombudsman may reject a complaint at any stage if it appears that the complaint made:

(a) is non-maintainable under clause 10; or

(b) is in the nature of offering suggestions or seeking guidance or explanation.

2. The Ombudsman may reject a complaint at any stage if:

(a) in his opinion there is no deficiency in service; or

(b) the compensation sought for the consequential loss is beyond the power of the Ombudsman to award the compensation as indicated in clause 8(2); or

(c) the complaint is not pursued by the complainant with reasonable diligence; or

(d) the complaint is without any sufficient cause; or

(e) the complaint requires consideration of elaborate documentary and oral evidence and the proceedings before the Ombudsman are not appropriate for adjudication of such complaint; or

(f) in the opinion of the Ombudsman there is no financial loss or damage, or inconvenience caused to the complainant.

10. Appeal Process

10.1 Appellate Authority

The Appellate Authority is the Executive Director in-charge of the Consumer Education and Protection Department (CEPD) of RBI.

10.2 Who Can Appeal

10.2.1 Appeal by DJT Microfinance Private Limited

The Company may file an appeal if aggrieved by:

• An Award passed after adjudication on merits
• Closure of complaint under specific rejection grounds

IMPORTANT: Company CANNOT appeal against Award passed due to non-furnishing of information/documents.

APPROVAL: Appeal requires prior sanction of Chairman, MD/CEO, or in their absence, Director.

10.2.2 Appeal by Complainant

The complainant may file an appeal if aggrieved by Award or rejection of complaint.

10.3 Timeline for Filing Appeal

Both parties must file appeal within:

• 30 days from date of receipt of Award/rejection order
• Extension up to additional 30 days may be granted if sufficient cause shown
• Total maximum period: 60 days

10.4 Powers of Appellate Authority

The Appellate Authority may:

• Dismiss the appeal
• Allow the appeal and set aside the Award/order
• Remand the matter for fresh disposal
• Modify the Award/order
• Pass any other order as deemed fit

11. Customer Awareness and Information Dissemination

11.1 Display at Branches

All branches must display prominently:

• Name and contact details of Principal Nodal Officer
• RBI CMS portal: https://cms.rbi.org.in
• RBI toll-free helpline: 14448
• Email: CRPC@rbi.org.in
• Salient features of the Ombudsman Scheme
• Display in English, Hindi, and regional language

11.2 Company Website

DJT Microfinance Private Limited website must have:

• Dedicated 'Customer Grievance' section on homepage
• Salient features and full text of the Scheme
• Contact details of Principal Nodal Officer
• Links to RBI CMS portal
• Downloadable complaint form
• Online complaint lodging facility

Annex

FORM OF COMPLAINT (TO BE LODGED) WITH THE OMBUDSMAN

[Clause 11(2) of the Scheme]

(TO BE FILLED UP BY THE COMPLAINANT)

All the fields are mandatory except wherever indicated otherwise

To

The Ombudsman Madam/Sir,

Sub: Complaint against …………………… (place of Regulated Entity’s branch or office) of (name

of the Regulated Entity)

Details of the complaint:

• Name of the complainant …………………………………………………………….
• Age (years)………….
• Gender……..………..
• Full address of the complainant ………………………………………………………

……………………………………………………………………………………………….

………………………………………………………………………………………………. Pin Code ………………..

Phone No. (if available) ……………. Mobile Number.……………………

E-mail (if available) …………………….

• Complaint against (Name and full address of the branch or office of the Regulated Entity) ………………………….……………………………………………………………...

…………………………………………………………………………………………………. Pin Code …………………….

• Nature of relationship/account number (if any) with the Regulated Entity

……………………………………………………………….………………………

• Transaction date and details, if available

……………………………………………………………….…………………………………

• 1. Date of complaint already made by the complainant to the Regulated Entity (Please enclose a copy of the complaint)

……………………………………………………………….…………………………………

• 1. Whether any reminder was sent by the complainant? Yes/No (Please enclose a copy of the reminder)

……………………………………………………………….…………………………………

• Please tick the relevant box (Yes/No)

Whether your complaint:

• Subject matter of the complaint

………………………………………………………………………………………………….

• Details of the complaint:

(If space is not sufficient, please enclose a separate sheet)

…………………………………………………………………………………………………

…………………………………………………………………………………………………

1 Complaint is sub-judice/under arbitration if the complaint in respect of the same cause of action is already pending/dealt with on merits by any Court, Tribunal or Arbitrator or any other Authority, whether individually or jointly.

• Whether any reply has been received from the Regulated Entity within a period of 30 days of receipt of the complaint by it? Yes/No

(if yes, please enclose a copy of the reply)

• Relief sought from the Ombudsman

…………………………………………………………………………………………………

………………………………………………………………………………………………… (Please enclose a copy of documentary proof, if any, in support of your claim)

• Nature and extent of monetary loss, if any, claimed by the complainant by way of compensation (please refer to clauses 15 (4) & 15 (5) of the Scheme)

Rs.………………………………………………………………………………………………

…………………………………………………………………………………….…………….

• List of documents enclosed:

Declaration

• I/We, the complainant/s herein declare that:
  1. the information furnished above is true and correct; and
  2. I/We have not concealed or misrepresented any fact stated above, and in the documents submitted herewith.

• The complaint is filed before the expiry of a period of one year reckoned in accordance with the provisions of clause 10 (2) of the Scheme.

Yours faithfully

(Signature of the Complainant/Authorised Representative)

AUTHORISATION

If the complainant wants to authorise a representative to appear and make submission on her/his behalf before the Ombudsman, the following declaration should be submitted:

I/We …………….. hereby nominate Shri/Smt ……………………….as

my/our authorised representative whose contact details are as below:

Full Address …………………………………………………………………………………..

Pin Code ……………..……………..

Phone No ………………….

Mobile Number ……………….

Email …………………

(Signature of the Complainant)