I.            Introduction

Tycoon Credit & Portfolios Limited. (hereinafter referred to as the “Company”), operating under the brand name True Rupee, is registered with the Reserve Bank of India (RBI) as a Non-Banking Financial Company (NBFC), and is engaged in extending loan facilities through the True Rupee digital lending platform. Customer service and satisfaction are of the highest priority for the Company. As part of its commitment to fair and responsive customer engagement, the Company has put in place this Grievance Redressal Policy (“Policy”) to offer a structured, accessible, and time-bound mechanism through which customers can raise complaints, seek redressal, and share feedback regarding their dealings with the Company.

This Policy has been formulated in compliance with the following regulatory frameworks:

• Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit Taking Company (Reserve Bank) Directions, 2016 dated September 1, 2016.
• Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023.
• Guidelines on Fair Practices Code for Non-Banking Financial Companies issued by the Reserve Bank of India.

Any amendment, clarification, or direction issued by the RBI from time to time will be deemed incorporated into this Policy to the extent applicable.

     II.            OBJECTIVE OF THE POLICY

The Company recognizes that quick and effective grievance redressal is key to building and maintaining customer trust. This Policy has been formulated with the following objectives:

1. To ensure that every customer is treated fairly, equally, and with dignity at all times.
2. To address complaints promptly, courteously, and without unreasonable delay.
3. To accord priority handling to grievances raised by senior citizens, pensioners, and persons with physical disabilities.
4. To keep customers informed of all available escalation channels within the organization and their rights to seek alternative remedies where dissatisfied.
5. To handle complaints in a fair and efficient manner so as to protect the Company’s reputation and the interests of its customers.
6. To ensure that all employees discharge their responsibilities in good faith, without bias, and in the best interest of customers.

Any customer who is dissatisfied with the services of the Company or any entity acting on its behalf will be entitled to register a complaint under this Policy.

  III.            SCOPE OF THE POLICY

The provisions of this Policy apply to:

1. All offices and branches of True Rupee
2. All employees of the Company, whether permanent or on contractual engagement.
3. All customer-facing activities undertaken by the Company through the True Rupee platform or otherwise.

For the purposes of this Policy, the following definitions apply:

“Customer” means any individual or entity that has availed a loan facility from the Company through the True Rupee platform or any other channel operated by the Company.

“Complaint” means any written or electronic expression of dissatisfaction, grievance, or allegation raised by a customer alleging deficiency in respect of:

• The services, products, policies, or procedures of the Company.
• The conduct or behavior of the Company’s employees in dealings with customers.
• The confidentiality, protection, or security of a customer’s personal information, sensitive personal information, or financial information.

   IV.            CORE COMMITMENTS

The Company is committed to the highest standards of customer satisfaction and operates in line with the following principles:

A.     Fair and Transparent Dealings

• All products and services offered through True Rupee comply with applicable laws and regulatory requirements.
• All customer interactions are conducted with honesty, transparency, and integrity.
• The Company’s systems, procedures, and processes are designed and implemented in the best interests of its customers.

B.     Customer Assistance and Information

• Customers are provided relevant product and service information in English and/or in a local language of their choice.
• The financial implications of any product or service are clearly explained before the customer commits.
• Customers are supported in identifying and selecting the product or service most appropriate to their needs.

C.      Error Rectification

In the event of any error, omission, or oversight on the part of the Company, the following steps will be taken on a priority basis:

• Prompt correction of the error.
• Redressal of the customer’s complaint.
• Guidance to the customer on escalation options, where dissatisfaction persists.
• Reversal of any charges, including interest, wrongly applied to the customer’s account due to an error or lapse by the Company.

     V.            GROUNDS FOR FILING COMPLAINTS

Customers may file a complaint in writing, setting out clearly the nature of grievance or deficiency. Grounds for filing a complaint include, but are not limited to, those specified under Clause 8 of the Ombudsman Scheme for NBFCs, 2018:

1. Failure to communicate in writing the sanctioned loan amount, along with the applicable terms and conditions including the annualized rate of interest and its method of application.
2. Failure or refusal to provide a sanction letter or terms and conditions

• Failure or inordinate delay in releasing security documents to the borrower upon repayment of all dues; levying of charges without adequate prior notice; or failure to include a legally enforceable repossession clause in the loan agreement.

1. Non-compliance with directions issued by the Reserve Bank of India applicable to non-banking financial companies.
2. Non-adherence to any other provision of the RBI’s Fair Practices Code guidelines for Non-Banking Financial Companies.

   VI.            COMPLAINT FILING CHANNELS

The Company has set up a Grievance Redressal Mechanism (“GRM”), approved by its Board of Directors. The GRM ensures that all disputes arising from the decisions of the Company’s functionaries are heard and disposed of at the next higher level.

Level 1: In case of any service request / complaints, the customer may contact the customer engagement team at E Mail: care@truerupee.com

On receipt of service request / complaint, an acknowledgement will be given within 3 (Three) working days by the company to the customer via e-mail/ letter by post/ SMS/any other form of legally valid electronic communication including WhatsApp. The Company will endeavor to resolve to the same within a period of 7 (Seven) working days. However, in case where a complaint warrants extensive investigation and/or support of the customer to identify the perpetrator, root cause analysis, or under litigation (incl. pending with local Police authorities), the TAT for responding and resolving such complaints may be more than 7 (seven) working days.

In case the customer is not satisfied with the resolution/response provided by the customer engagement team/s as above, then customer will escalate to Level 2 as given below.

Level 2 : It may be noted that the customers will approach for resolution of their service request/complaint at the first instance to the customer engagement team as mentioned in Level 1 hereinabove, and if their request / complaint remains unresolved for a period of 7 days or they are dissatisfied with the resolution given, they are required to contact, he may approach the Grievance Redressal Officer (GRO) of the Company at : gro@truerupee.com

We will make every effort to resolve customer complaints at this level within the next 7 working days. If the customer is aggrieved by the GRO or rejection of complaint by GRO Office, customer can file an appeal within 30 days of receipt of Award or rejection of complaint to:

Consumer Education & Protection Department Reserve Bank of India

The customer may also lodge a complaint through the RBI Complaint Management System (CMS) portal or the Sachet portal at https://sachet.rbi.org.in, particularly for reporting frauds or unregulated entities.

The Company will ensure full compliance with the Reserve Bank – Integrated Ombudsman Scheme, 2021 (“Scheme”), as amended from time to time. The salient features of the Scheme are set out below for the benefit of the Company’s borrowers.

Complaints under the Scheme may be filed through the following channels:

• Online through the Integrated Ombudsman portal at https://cms.rbi.org.in.
• By email to CRPC@rbi.org.in.
• In physical form at the Centralized Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160 017.
• Through the toll-free Contact Centre at 14448 (available from 9:30 a.m. to 5:15 p.m.), which provides assistance in Hindi, English, and regional languages.

VII.            REVIEW OF THE POLICY

This Policy will be reviewed and, if necessary, revised by the Board of Directors. The Company reserves the right to amend this Policy at any time in line with changes in applicable law, regulatory directions, or internal governance requirements. In the event of any conflict between this Policy and applicable law or RBI directions, the latter will prevail.