OBJECTIVE AND SCOPE OF THE POLICY

AVA Finance Private Limited (“Company”), being a Non-Banking Financial Company (NBFC), is committed to ensuring fair treatment to customers and providing prompt and effective redressal of customer grievances in compliance with applicable Reserve Bank of India (RBI) guidelines, including but not limited to:

• RBI Master Direction – Non-Banking Financial Company – Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (as amended).
• RBI Guidelines on Digital Lending (2022 and subsequent updates).
• RBI Integrated Ombudsman Scheme, 2021.
• Fair Practices Code for NBFCs.

This Policy aims to:

• Ensure timely and effective resolution of customer complaints.
• Provide a structured grievance redressal mechanism.
• Enhance customer satisfaction and trust.
• Ensure transparency in complaint handling.
• Comply with regulatory requirements.

This Policy applies to all products, services, digital platforms, and customer interactions of the Company, including those offered through outsourcing partners, Lending Service Providers (LSPs), and fintech platforms.

DEFINITION OF COMPLAINT AND CUSTOMER

A “Complaint”shall mean any expression of dissatisfaction made by a customer or on behalf of a customer, in writing, electronically, or verbally, alleging deficiency in:

• Lending services, loan processing, or servicing
• Terms and conditions, interest rates, or charges
• Digital lending processes or platform-related issues
• Conduct of employees, agents, or third-party service providers
• Data privacy, unauthorized use or breach of customer information
• Incorrect reporting to Credit Information Companies (CICs)
• Recovery practices or harassment-related issues.

The following shall not be treated as complaints:

• General inquiries or requests for information
• Requests for product features or loan applications
• Routine service requests without dissatisfaction.

CUSTOMER
“Customer” means any person who has availed or intends to avail financial products/services from AVA Finance Private Limited, including borrowers, co-borrowers, guarantors, and applicants.

CHANNELS FOR LODGING COMPLAINTS

Customers may lodge complaints through the following channels:

a) Phone (Customer Care):
The customer can call us at Customer Care Helpline at +91-8860199288 between 09:00 AM to 6:00 PM from Monday to Saturday.

b) Email:
Please write to us at info@kamakshimoney.com

c) Postal (through letter):
Customer Care Department,
AVA Finance Private Limited,
3rd Floor, 8/17, Plot No. 17, Block No. 8, W.E.A Karol Bagh, New Delhi – 110005

d) Complaint in Person:
AVA Finance Private Limited,
3rd Floor, 8/17, Plot No. 17, Block No. 8, W.E.A Karol Bagh, New Delhi – 110005

INFORMATION REQUIRED FOR COMPLAINT REGISTRATION

Customers are encouraged to provide the following details while raising a complaint:

i. Customer’s complete name.
ii. Customer’s complete correspondence address.
iii. Loan ID.
iv. Registered mobile number/Phone number.
v. E-mail address, if any.
vi. Nature and details of the complaint.
vii. Documentary Proof, if required.

COMPLAINT HANDLING PROCESS

The Company shall follow a structured, transparent, and RBI-compliant mechanism for handling customer complaints across all channels, including physical, digital, and third-party (LSP) platforms.

Receipt and Logging of Complaints

a) All complaints received through phone, email, website, physical branch(es), or through Lending Service Providers (LSPs) shall be mandatorily recorded in a centralized Complaint Management System (CMS).
b) Each complaint shall be assigned a Unique Complaint Reference Number (CRN).
c) Date and time stamping of receipt shall be ensured.
d) Complaints received by LSPs/outsourcing partners must be forwarded to the Company within T+1 working day, in line with RBI Digital Lending Guidelines.
e) The Company shall ensure that customers are able to directly lodge complaints with AVA Finance Private Limited irrespective of whether the loan is sourced through digital platforms or Lending Service Providers.

5.2 Acknowledgment

The Company shall acknowledge the complaint within 48 hours of receipt.

The acknowledgment shall include:

• CRN
• Date of receipt
• Expected resolution timeline
• Escalation matrix details

5.3 Categorization of Complaints

For effective monitoring and regulatory reporting, complaints shall be categorized as follows:

• Loan origination / disbursement
• Interest rates, fees, and charges
• EMI / repayment / foreclosure
• Digital lending / app-related issues
• Data privacy / data breach / unauthorized access
• Credit Information Company (CIC) reporting issues
• Recovery and collection practices (including harassment complaints)
• Fraud / unauthorized transactions
• Employee / agent misconduct

5.4 Assignment and Responsibility

Complaints shall be assigned to the relevant department based on category and a Complaint Owner shall be designated for each complaint.

For complex or sensitive complaints, a Single Point of Contact (SPOC) shall be assigned.

The Company shall retain full responsibility for complaints even if they arise through LSPs or outsourced entities.

5.5 Assessment and Risk-Based Prioritization

Complaints shall be prioritized based on severity and regulatory impact:

• High Priority: Fraud, data breach, coercive recovery practices, regulatory violations
• Medium Priority: Financial impact to customer
• Low Priority: Service quality issues

High-priority complaints shall be escalated immediately to Compliance and Senior Management.

5.6 Investigation and Resolution Process

The investigation process shall include:

a) Review of internal systems, loan records, and transaction history;

b) Examination of call recordings, chat logs, and digital footprints;

c) Coordination with internal departments and third-party service providers;

d) Customer interaction where clarification is required;

e) Verification of documents and supporting evidence.

For complaints involving LSPs:

f) The Company shall obtain all necessary information from the LSP;

g) Ensure compliance with RBI outsourcing and digital lending norms;

h) Ensure that customer communication is issued in the name of AVA Finance Private Limited.

5.7 Interim Updates

If a complaint cannot be resolved within 7 working days, interim updates shall be provided.

The update shall include:

• Current status
• Reason for delay
• Revised timeline for resolution

5.8 Resolution and Customer Communication

A final response shall be provided to the customer upon completion of investigation.

The response shall contain:

• Summary of complaint
• Findings and rationale
• Resolution provided or corrective action taken
• Reasons in case of rejection

All communications shall be clear, courteous, and non-technical, and shall be provided in English or in a vernacular language as appropriate.

5.9 Turnaround Time (TAT)

• First Call Resolution: Immediate / same day
• Standard complaints: Within 7 working days
• Complex complaints: Within 30 days from receipt
• Fraud / unauthorized electronic transactions: As per RBI circulars on customer liability

If a complaint is not resolved within 30 days, the customer shall be informed of their right to approach the RBI Ombudsman.

5.10 Closure of Complaints

A complaint shall be treated as closed only when:

i. Resolution is communicated to the customer; and

ii. Customer acceptance is received, or reasonable efforts to contact the customer have been made.

iii. Closure remarks shall be recorded in the system.

5.11 Reopening of Complaints

A complaint may be reopened if the customer provides additional information, or if the resolution is found to be inadequate, or as required by audit/regulatory directions.

5.12 Monitoring, Quality Control and Audit

Compliance function shall periodically review complaint handling, including sample checks of closed complaints, adherence to TAT, and quality of resolution.

Any deviations shall be reported to senior management and corrective actions shall be implemented.

5.13 Root Cause Analysis and Preventive Action

Recurring complaints shall be analyzed to identify root causes.

Corrective and preventive actions (CAPA) shall include:

• Process improvements
• System enhancements
• Staff training
• Strengthening of LSP oversight

5.14 Record Maintenance

Complete audit trail of complaints shall be maintained, including Complaint details, Investigation notes, Communication records and Final resolution.

Records shall be preserved as per RBI guidelines and internal record retention policy.

6. ESCALATION MATRIX

LEVEL 1: Customer Relationship Manager

Customers may contact Customer Support through the channels mentioned above.

Timings: 09:00 AM to 06:00 PM on weekdays

LEVEL 2: Customer Service Help Desk

If you are not satisfied with the response received from the branch or if you don't receive a response in 3 working days, please call our Help Desk Representatives.

Helpline No: +91-8860199288
Email id: info@kamakshimoney.com
Timings: 9 am to 6 pm on weekdays

LEVEL 3: Grievance Redressal Officer

If the complaint is not resolved within 7 working days or the customer is dissatisfied:

Grievance Redressal Officer (GRO) / Nodal Officer

Name: Ankit Verma

Address:
3rd Floor, 8/17, Plot No. 17, Block No. 8,
W.E.A Karol Bagh, New Delhi – 110005

Contact No.: 9599197388

Email: nodalofficer@kamakshimoney.com

Response Timeline: Within 7 working days

LEVEL 4: RBI OMBUDSMAN / CMS ESCALATION

If the complaint is not resolved within 30 days or the customer is not satisfied with the resolution, the customer may approach the Reserve Bank of India under the Integrated Ombudsman Scheme, 2021 through:

CMS Portal: https://cms.rbi.org.in

Sachet Portal: https://sachet.rbi.org.in

The details of the Ombudsman Scheme are available on the RBI website www.rbi.org.in

7. DISCLOSURE REQUIREMENTS

The following shall be displayed prominently on the Company’s website, branches, and digital platforms:

• Grievance Redressal Policy
• Contact details of Grievance Redressal Officer
• Escalation matrix
• RBI Ombudsman details

8. SUPERVISION AND REPORTING

The Company shall maintain a robust system for recording, monitoring, and reporting of customer complaints in line with RBI requirements.

All complaints received through any channel, including branch, call center, email, website, mobile application, or through Lending Service Providers (LSPs), shall be mandatorily recorded in a centralized Complaint Management System (CMS).

The Summary of the customer grievance report along with its Status Report indicating the actions taken for resolution of the complaints, shall be placed before the Board of Directors for their review on a semi-annual basis.

The report shall contain information like, the total number of complaints received, disposed of and pending, with reasons thereof, which will be placed before the Board for information / guidance.

9. REVIEW OF THE POLICY

This Policy shall be reviewed at least annually or earlier, if required, due to changes in regulatory guidelines, business requirements, or audit observations.

Any amendments to this Policy shall be approved by the Board of Directors.

In case of any inconsistency between this Policy and applicable RBI regulations, the provisions of such regulations shall prevail.

10. EFFECTIVE DATE

This Policy shall be effective from the date of approval by the Board of Directors and shall supersede all earlier versions, if any.