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Indian School Finance Company Private Limited

Policies

Fair practices Code

Indian School Finance Company Private Limited (hereinafter written as Company) is a Non-Banking Finance Company registered with Reserve Bank of India (“RBI”) and is in the business of lending to the Private schools for their infrastructural requirements.

  • To ensure that the company follows and practices fair and transparent dealings with the customers.
  • Ensuring that the company’s products are compliant with relevant laws and regulations.
  • To strengthen the grievance redressal mechanism of the company.
  • All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
  • The Loan application forms of the Company will include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower.
  • The loan application form will indicate the documents required to be submitted with the application form.
  • If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.
  • The Company will have a system of giving acknowledgement for receipt of all loan applications. The time frame within which loan applications will be disposed of will be indicated in the acknowledgement.
  • The Company will 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 the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record.
  • The Company will mention the penal interest charged for late repayment in bold in the loan agreement.
  • The Company will furnish a copy of the loan agreement preferably in the vernacular language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.
  • The Company will 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, service charges, prepayment charges etc. The Company 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.
  • Decision to recall / accelerate payment or performance under the agreement will be in consonance with the loan agreement.
  • The Company will release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/paid.
  • The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
  • In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of the Company, if any, will 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.
  • In the matter of recovery of loans, the Company will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. To avoid rude behavior from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.

Repossession of vehicles The Company has a built in re-possession clause in the contract/loan agreement with the borrower which is legally enforceable. To ensure transparency, the terms and conditions of the contract/loan agreement contains provisions regarding: (a) notice period before taking possession; (b) circumstances under which the notice period can be waived; (c) the procedure for taking possession of the security; (d) a provision regarding final chance to be given to the borrower for repayment of loan before the sale / auction of the property; (e) the procedure for giving repossession to the borrower and (f) the procedure for sale / auction of the property.

  • The Board of Directors will adopt an interest rate model for determining the rate of interest to be charged on loans and advances, processing and other charges taking into account relevant factors such as, cost of funds, margin and risk premium, etc. The rate of interest and the approach for gradations 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 rates of interest and the approach for gradation of risks shall also be made available on the web-site of the Company. The information published in the website or otherwise published should be updated whenever there is a change in the rates of interest.
  • The rate of interest should be annualised rates so that the borrower is aware of the exact rates that would be charged to the account.

The company aims to provide best customer service and is consistently striving on creating a robust and efficient customer service platform. If the customers have any issues or wish to register a complaint, they can reach us at any of the following:

STEP 1: The customer can call us and log his grievances at: +91 040 6650 5000.

STEP 2: Customers can also write their grievances at e mail ID: grievance@isfc.in

STEP 3: Customers can also write to:Mr AnandKrishnam.M.R,

Chief Operating Officer,

Indian School Finance Company Pvt Ltd,

8-2-269/2/52, 1st Floor, Plot No 52, Sagar Society, Road No 2, Banjara Hills, Hyderabad -500034

Escalation: If the complaint of the customer is not redressed within 1 month from the lodging of complaint with company, the customer may appeal to the Regional office of Reserve Bank of India at following address Office In charge, Department of Non Banking Supervision, 6-1-56, Secretariat Road, Saifabad, Hyderabad-500004, Phone: 040-23241270, Email:-dnbshyderabad@rbi.org.in

A periodical review of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management would be undertaken by the Company. The Company shall abide by this Fair Practices Code following the spirit of the Code and in the manner it may be applicable to its business.

The Company shall put the above Fair Practices Code outlined hereinabove on its web site, for the information of various stakeholders. The Company would also review and refine the Code, as may be required periodically –based on its own experience and fresh guidelines, if any, to be issued by the Reserve Bank of India in this regard.

WHISTLE BLOWER POLICY

  • Objective
      ‘Whistleblowing’ policy empowers employees to inform suspected misconduct, illegal acts or failure to act within or with third party dealing with the organization without threat of designation and position. The aim of this Policy is to encourage employees and others who have serious concerns about any aspect of the Colleagues/Manager at work to come forward and voice those concerns to the designated Compliance Officer. Employees are often the first to realize that there may be something seriously wrong within or with third party dealing with the organization. ‘Whistleblowing’ is viewed as a positive act that can make a valuable contribution.
  • Scope
      The Policy is applicable:
    • Employees of all branches/Zone/State at all levels
    • Employees of contractual nature, agency staff, Temporary workers, Management Trainees, Probation employees and directors
    • Voluntary workers, Trainees, interns working with ISFC
    • Employees of suppliers and those providing services under a contract or other agreement with ISFC.
    • ISFC customer.
  • Policy
      No adverse personnel action shall be taken or recommended against an employee in retaliation to his disclosure in good faith of any unethical and improper practices or alleged wrongful conduct in the organization or amongst its employees. This policy protects such employees from unfair termination and unfair prejudicial employment practices. However, this policy does not protect an employee from an adverse action which occurs independent of his disclosure of unethical and improper practice or alleged wrongful conduct, poor job performance, any other disciplinary action, etc. unrelated to a disclosure made pursuant to this policy. The Whistle Blowing Policy aims to:
    • Encourage employee to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about Unethical and Improper practice
    • Provide avenues for employees to raise those concerns and receive feedback on any action taken and in case of disagreement the process of escalation.
    • Reassure employee that they will be protected from possible reprisals or victimisation if they have made any disclosure in good faith.
      Unethical and Improper Practices
      Unethical and improper practices shall mean –
    1. An act which does not conform to approved standard of social and professional behaviour;
    2. An act which leads to unethical business practices;
    3. Improper or unethical conduct;
    4. Breach of etiquette or morally offensive behavior;
    5. An act against the accepted business practices or values of the organization, etc.
    6. Fall below established standards of practice; or
    7. Conduct which is an offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation)
  • Interpretation
      Terms that have not been defined in this Policy shall have the same meaning assigned to them in the Companies Act, 1956 and/or SEBI Act and/or any other SEBI Regulation(s) as amended from time to time.
  • Guidelines
    • Disclosure & Maintenance of Confidentiality
        An employee / vendor who observe or notices any unethical & improper practices or alleged wrongful conduct in the Company may report the same to the Head of Department or Head HR or in case it involves Managerial Personnel to the Managing Director. Confidentiality of whistle blower shall be maintained to the largest extent possible.
    • Compliance Officer
        Compliance officer is Chief Operations Officer, of the company.
    • Procedures
        Any employee / vendor who observes any unethical & improper practices or alleged wrongful conduct shall make a disclosure to the Head of Department or Compliance Officer or Head HR or in case it involves Managerial Personnel to the Managing Director. Employee can write an e-mail to sayit@isfc.in or call the Compliance Officer at 7829906637 as soon as possible but not later than 45 consecutive calendar days after becoming aware of the same. The following process shall be followed:
      • The Departmental Head shall immediately forward the Whistle Blower Report Compliance Officer.
      • The Compliance Officer may cause such enquiry to be conducted as deemed appropriate given the nature of the complaint lodged.
      • An Anonymous Complaint will be taken up only if it has substance and full details are given.
      • If the complaint is against the Compliance Officer, it can then be directed to MD of the company and shall be directed by MD.
      • The Compliance Officer, after due enquiries, pass orders for remedies as per the disciplinary policy.
      • For every legitimate complaint received from the employees, the employee shall be awarded with the maximum bonus slab applicable for the year as per PMS process.
  • False Allegation & Legitimate Employment Action
      An employee / vendor who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct to the Audit Committee shall be subject to disciplinary action, up to and including termination of employment, in accordance with Company rules, policies and procedures. Further, this policy may not be used as a defence by an employee against whom an adverse personnel action has been taken independent of any disclosure of information by him and for legitimate reasons or cause under Company rules and policies.
  • Notification
      All departmental heads are required to notify & communicate the existence and contents of this policy to the employees of their department. The new employees shall be informed about the policy by the HR department. This policy as amended from time to time shall be made available at the internet site of the Company which is accessible to its employees/vendors.

Pricing Policy

Indian School Finance Company Private Limited will follow the following internal guiding principles and interest rate model for determining Interest rate, processing fees and other charges to our customers, as laid out by the board the Indian School Finance Company. ISFC will apply best industry practices so long as such practice does not conflict with or violate RBI guidelines.The policy of ISFC for determining Interest Rates, Processing and Other Charges is as follows:

  • The rate of interest shall be determined based on the cost of borrowed funds, matching tenor cost, market liquidity, refinance avenues, offerings by competition, tenure of customer relationship, cost of disbursements( Cost of Fund). In addition to the cost of fund, the rate of interest shall further be determined based on inherent credit and default risk in the products and customer per se arising from customer segment, profile of the customers, professional qualifications, stability in earning and employment and repayment ability, overall customer yield, risk premium, nature and value of primary and collateral securities, past repayment track record of the customers, external ratings of the customers , industry trends, etc.
  • ISFC may adopt an interest rate model whereby the rate of interest for same product and tenor availed during same period by customers would be different from customer to customer depending upon consideration of any or combination of a few or all factors listed out in point (b) above . Hence, the interest rate applied would be different from customer to customer and his/ her loans.
  • The annualized rate of interest would be intimated to the customer. The interest rates would be offered on fixed, floating, variable basis. The prime lending rate for the floating rates would be reviewed on quarterly intervals. In case of floating rate of interest, the interest rate would be reviewed and reset on quarterly basis. The interest rate would be computed on daily balances basis and charged on monthly rest or such other rest as the empowered committee decide in accordance with applicable rules and regulations.
  • Interest rates shall be intimated to the customers at the time of sanction/ availing of the loan and the equated installments apportionment towards interest and principal dues shall be made available to the customer.
  • Interest changes would be prospective in effect and intimation of change of interest, if any, or other charges would be communicated to customers.
  • In case deemed fit, ISFC may consider necessary moratorium for interest payment and repayment of principal with proper built in pricing.
  • In case of staggered disbursements, the rate of interest would be subjected to review and the same may vary according to the prevailing rate at the time of disbursement or as may be decided by ISFC.
  • The interest rate, benchmark prime lending rate and other charges applicable from time would be hosted on website and updated from time to time.
  • Besides normal interest, ISFC may collect penal interest / late payment charges for any delay or default in making payments of any dues. These penal interest / late payment charges for different products or facilities would be decided by ISFC from time to time.
  • No claims for refund or waiver of such charges/ penal interest / additional interest would normally be entertained by ISFC and it is the sole discretion of ISFC to deal with such requests if any.
  • All processing / documentation and other charges recovered are expressly stated in the Loan documents. They vary based on the loan product, exposure limit, customer segment, geographical location and generally represent the cost incurred in rendering the services to the customers. The practices followed by other competitors in the market would also be taken into consideration while deciding the charges.

The interest rate models, benchmark prime lending rate (BPLR) and other charges applicable shall be reviewed by the board periodically.

Corporate Social Responsibility Policy

    The main objective of ISFC’s CSR policy is:

    1. To lay down guidelines to make CSR a key business process for sustainable development of the society.

    2. To directly/indirectly undertake projects/programs, this will enhance the quality of life and economic well-being of the communities in and around our plant and society at large.

    3. To generate goodwill and recognition among all stake holders of the company.

    Further we recognize that we must integrate our business values and operations to meet the expectations of our stakeholders. They include customers, employees, investors, suppliers, the community and the environment.
  • We recognize that our social, economic and environmental responsibilities to these stakeholders are integral to our business. We aim to demonstrate these responsibilities through our actions and within our corporate policies.
  • We take seriously all feedback that we receive from our stakeholders and, where possible, maintain open dialogue to ensure that we fulfill the requirements outlined within this policy.
  • We shall be open and honest in communicating our strategies, targets, performance and governance to our stakeholders in our continual commitment to sustainable development.
  • The committee members are responsible for the implementation of this policy and will make the necessary resources available to realize our corporate responsibilities. The responsibility for our performance on this policy rests with all employees throughout the company.
  • We shall encourage suppliers and contractors to adopt responsible business policies and practices

    1. INTRODUCTION

    With the applicability of section 135 of Companies Act, 2013, the board has examined the applicability on the Company and has found that since the company falls under the criteria of applicability of section 135, it is hereby decided to form a CSR policy for spending 2% of average net profit of preceding three financial years on the activities as mentioned in Schedule VII of the Companies Act, 2013. We believe that Company’s CSR initiative would play a pivotal role in improving the lives of the communities and society at large. This would also enable us to fulfill our commitment to be socially responsible corporate citizen.


    2. COMMITTEE COMPOSITION

    The CSR Committee shall consist of the following directors:

    a. Mr. Rakesh Rewari
    b. Mr. Hari Krishnier Padmanabhan
    c. Ms. Erika Norwood
    Members of the CSR Committee may be replaced by Board with any other member of the Board.


    3. COMMITTEE MEETINGS

    The CSR Committee shall meet as often as its members deem necessary to perform the duties and responsibilities.


    4. DUTIES AND RESPONSIBILITIES OF CSR COMMITTEE

  • (i) Formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the company as specified in Schedule VII. Any amendments/ inclusions made to Schedule VII of the Companies Act, 2013 shall be taken into consideration.
  • (ii) Recommend the CSR Expenditure to be incurred on the CSR activities/ programs.
  • (iii) Institute a transparent mechanism for implementation of the CSR projects and activities. Effectively monitor the execution of the CSR activities.

  • 5. RESPONSIBILITY OF THE BOARD

  • (i) Approve the CSR Policy and the CSR Expenditure after taking into consideration the recommendations made by CSR Committee.
  • (ii) Ensure the CSR spending every financial year of at least 2% of the average net profits made during immediately preceding 3 financial years, in pursuance with the Policy.
  • (iii) Ensure that the CSR activities included in the CSR Policy are undertaken by Indian School Finance Company Private Limited and that such activities are related to the activities specified in Schedule VII of the Companies Act, 2013.
  • (iv) Director’s Report for FY 2017-18 onwards to include: (a) Contents of the CSR Policy and Composition of the CSR committee; (b) A report on the CSR in the prescribed format as under Companies Act, 2013; (c) Reasons for failure (if any) to spend required amount on CSR activities.

  • 6. CSR EXPENDITURE

  • (i) In every financial year, ISFC shall spend a minimum of 2% of its average Net Profits in the immediately preceding three (3) financial years. Average Net Profits shall be calculated in accordance with the provisions of section 198 of Companies Act, 2013.
  • (ii) CSR Expenditure shall mean all expenditure incurred in respect of specific projects/ programs relating to the approved CSR activities.
  • (iii) CSR Expenditure shall not include expenditure on an item not in conformity or not in line with activities which fall within the purview of the CSR activities listed in Schedule VII.
  • (iv) CSR Expenditure shall not include Projects or programs or activities undertaken outside India.
  • (v) The surplus arising out of the CSR activities or projects shall not form part of the business profit of ISFC.
  • (vi) Contributions by other ISFC affiliates or employees may also be received and utilized in respect of the CSR activities undertaken.

  • 7. OUR RESPONSIBILITIES

  • A) Towards our communities We will involve communities surrounding our operations to bring about a positive change in their lives through holistic, sustainable and integrated development.
  • B) Towards our Customers We will build gainful partnerships with the customers to understand their needs and provide right product and service solutions. We will adopt and actively encourage the best and fair business practices and shall endeavor to build solid bonds with them.
  • C) As a Corporate Citizen We reaffirm our commitment to conduct our business with environmental accountability. We will endeavor to adopt environment-friendly technologies and energy efficiency in our operations while continuously monitoring and reducing emissions.
  • D) Responsibilities toward our Employees We will foster a work culture with high ethical principles and standards and encourage our employees to perform with total integrity, commitment and ownership. We will do all we can to support their professional growth and recognize high achievers. We will continue to raise the bar of our standards and guidelines. We recognize that our employees and contractors deserve to work in safe and healthy work environment and will make it our responsibility to ensure zero harm to people.

  • 8. CSR mainstay

    CSR activities at ISFC shall be carried out through Contribution / donation made to such other Organization / Institutions as may be permitted under the applicable laws from time to time or directly by the Company for fulfilling its responsibilities towards various stakeholders.


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