1. Introduction

Ruptok Capital is committed to fair and effective grievance redressal.

The Board of Directors of Ruptok Capital ("the Company") has designed and implemented an appropriate grievance redressal mechanism within the organisation to ensure that disputes arising from the decisions or actions of the Company's functionaries are heard and disposed of at the appropriate higher level.

The mechanism is intended to provide customers with a structured and transparent process for raising concerns and seeking resolution.

The Company shall maintain a grievance redressal mechanism to ensure that customer concerns and complaints relating to its products and services are properly registered, reviewed and resolved in a fair and timely manner.

This mechanism shall cover the Company's website, digital platforms, mobile applications, where applicable, and other customer-facing channels through which its products and services are offered.

The Board of Directors shall periodically review compliance with the Fair Practices Code and the effectiveness of the grievance redressal mechanism across different levels of management.

2. Purpose of the Policy

Every customer concern deserves a clear channel and a fair response.

This policy sets out a clear process for customers to raise complaints or concerns about Ruptok Capital's products and services.

It also explains how such complaints will be recorded, reviewed, resolved and escalated, with the aim of ensuring timely and fair grievance handling in line with applicable regulations and internal procedures.

The policy further provides a defined escalation mechanism so that, where a complaint is not resolved at one level or the customer remains dissatisfied with the response received, the matter may be taken to the next appropriate level of grievance redressal.

3. Grievance Redressal Officer

A designated Grievance Redressal Officer shall oversee the mechanism.

The Board of Directors shall appoint a Grievance Redressal Officer (GRO) to oversee the Company's grievance redressal mechanism.

The GRO shall handle escalated grievances and ensure that complaints are addressed promptly and efficiently.

4. Grievance Redressal Mechanism and Complaint Channels

Customers can raise a complaint through the designated channels.

Any customer having a grievance, complaint or feedback with respect to the products or services offered by Ruptok Capital may approach the Company through the available customer grievance channels.

Filing a Complaint

• Email: Customers may submit their grievance through the designated grievance email address: grievance@ruptokcapital.com
• Letter: Customers may submit a written complaint to:
  Ruptok Capital
  DSM-501, 5th Floor, DLF Tower 15, Shivaji Marg, Moti Nagar, New Delhi - 110015
• Customer Care: 9289968389
• Customer Support Email: customer.support@ruptokcapital.com
• Working Hours: 10:00 am to 6:00 pm Monday to Saturday

Anonymous complaints shall not be addressed.

5. Complaint Resolution Process

Every complaint shall be recorded, acknowledged and taken through the appropriate resolution process.

Upon receiving a complaint, the CGRM team shall acknowledge and record it promptly. The Customer Service Officer shall ensure timely resolution and update the complaint status until closure.

The Customer Service Officer shall monitor the status of complaints to ensure that they are resolved within the applicable timelines.

Where additional time is required for resolution, the CGRM team shall inform the customer of the reasons for the delay within the specified timelines and provide the expected timeline for resolution.

Complaints registered through the prescribed channels shall be addressed within 5 (five) business days.

6. Turnaround Time (TAT) for Resolution of Complaints

Timelines matter, particularly when a customer is waiting for an answer.

The above escalation framework shall be followed for the resolution of complaints, with matters moving to the appropriate higher level where they remain unresolved or where the customer is not satisfied with the response received.

7. Level 1 Escalation

Level 1 is the first formal point of grievance escalation.

Customers may submit their complaints or grievances through the following channels:

The Company shall acknowledge and address complaints within the applicable timelines.

8. Level 2 Escalation

If the first response does not resolve the concern, the customer can move to the next level.

If a complaint is not resolved within 15 days, or if the customer is not satisfied with the response received at Level 1, the customer may escalate the matter to the Grievance Redressal Officer / Principal Nodal Officer.

9. Level 3 Escalation

Unresolved grievances move upward for further examination.

If the complaint addressed to the Grievance Redressal Officer is not taken up or resolved within 21 days, or if the customer remains dissatisfied with the response received, the matter may be escalated to the Internal Ombudsman, where applicable.

10. Level 4 Escalation

The final external escalation route is available through the RBI Ombudsman mechanism.

If the complaint, grievance or dispute remains unresolved within one month from the date of representation or complaint to the Company, the borrower/customer may approach the Ombudsman of the Reserve Bank of India, subject to the applicable requirements and timelines.

11. RBI Ombudsman

Customers retain the right to seek further redressal through the applicable RBI mechanism.

A customer may approach the RBI Ombudsman within one year from the date of the reply received from the Company, where applicable.

Details of the RBI Ombudsman mechanism shall be made available through the official RBI website.

12. Role and Responsibilities of Internal Ombudsman

The Internal Ombudsman provides an independent layer of review within the prescribed framework.

The Internal Ombudsman shall not ordinarily handle complaints received directly from complainants or members of the public, but shall deal with complaints that have already been examined by the Company and have been partly or wholly rejected, in accordance with the applicable regulatory framework.

The Internal Ombudsman will not deal with complaints concerning corporate fraud or misappropriation, unless the matter involves a deficiency in service by the Company.

Complaints relating to suggestions or commercial decisions will also remain outside the Internal Ombudsman's scope, except where they involve a service deficiency.

Matters concerning the Company's internal administration, human resources, staff salaries or other employee-related matters are also excluded.

The Internal Ombudsman shall examine complaints using available records, documents and relevant clarifications, and may seek additional information through the Company where required.

The Internal Ombudsman shall also analyse complaint patterns and identify recurring issues that may require corrective measures or policy-level intervention.

13. Amendment and Review of the Policy

A policy must keep pace with the framework it operates within.

This Policy shall be reviewed by the Board of Directors / Applicable Board Committee at annual intervals.

It shall also be amended whenever required due to changes in applicable regulatory guidelines or for any other relevant reason.

The Policy shall be made available on the Company's website and at its branches, where applicable, upon request.

14. Annexure A: Standard Operating Procedure

The SOP forms the operating backbone of this grievance mechanism.

The Standard Operating Procedure (SOP) for Customer Grievance Redressal Mechanism / Escalation Process shall be maintained as Annexure A to this Policy.

The SOP shall cover the applicable complaint categories, service requests, escalation process, resolution timelines and reporting requirements.

15. Complaint Categories

Complaints can emerge from lending, servicing, collections or customer interactions.

The grievance mechanism shall cover, as applicable, complaints concerning fraudulent conduct by staff, improper charges, misuse of customer KYC or personal information, repayment and collection issues, rude or unprofessional behaviour, coercive recovery practices, unauthorised visits, mis-selling or forced selling of third-party products, interest-rate discrepancies, digital transaction issues, loan documentation, repayment records and credit information reporting.

Specific complaints may include commission demands for loan sanctioning, excess charges collected from customers, incorrect interest calculations, loan amounts credited to incorrect accounts, duplicate deductions, non-receipt of loan documents, non-updation of loan closure or NOC records, and incorrect or delayed reporting to credit information companies.

16. Service Requests

Not every customer interaction is a complaint.

The Company may also receive service requests relating to updating or providing KYC and loan-related documents, loan application status, delayed-payment requests arising from exigencies, refund of excess amounts paid, foreclosure, cancellation of loan applications, settlement-related matters, loan status, outstanding balances and instalment information.

17. General Queries

Customers may also seek information without raising a formal grievance.

General queries may include enquiries relating to the settlement process or foreclosure, staff information including name and contact details, loan status, remaining balance and applicable instalment amount, or other information connected with the Company's products and services.

18. Reporting to the Committee and RBI

Complaint data should reveal patterns, not disappear into records.

The Internal Ombudsman shall submit reports on cases referred to him/her and analysis of the overall complaints received by the Company to the appropriate Committee of the Board, preferably on a quarterly basis and not less than half-yearly intervals.

The Internal Ombudsman shall also submit reports to the Reserve Bank of India, wherever applicable, in the prescribed format and within the intervals defined by the RBI.

19. TAT and Escalation Summary

A grievance should move forward, not remain suspended between desks.

If a complaint is not resolved within 15 days, or the customer is dissatisfied with the response, the customer may escalate the matter to the Grievance Redressal Officer / Principal Nodal Officer.

If the complaint is not taken up or resolved within 21 days, or the customer remains dissatisfied with the response from the Grievance Redressal Officer, the matter may be escalated to the Internal Ombudsman, where applicable.

Where a complaint, grievance or dispute remains unresolved within one month from the date of representation or complaint to the Company, the borrower/customer may approach the RBI Ombudsman, subject to the applicable requirements and prescribed timelines.

The customer may approach the RBI Ombudsman within one year from the date of the reply received from the Company, where applicable.