Scope

The following document serves to provide the details of grievance redressal mechanisms for customers and the procedure the employees at Light need to follow when such a complaint arises.

Mode of Complaints

Considering customer profile, their literacy level and vulnerability, LIGHT has identified various channels of sourcing customer complaints proactively.

Customer Enquiries / Complaints received at field

Customers can submit their written or verbal enquiries / complaints to any LIGHT staff who meets them at any forum such as center meetings, MGTs, GRTs and exit interviews, dedicated CGR phone number etc. These enquiries / complaints shall be forwarded to Branch Helpdesk for further follow up and resolution. If any complaints are received during center meeting visit then visitor should update the same in Center Meeting Checklist, in the Branch Helpdesk, which will investigate the issue with the assistance from CM’s/AM’s and provide resolution to customer.

Customer walk-ins at branches

Verbal Complaints – Nodal officers or contact persons at Branch will record the complaints and provides the solutions

Written Complaints – Customer can obtain Complaint Form (enclose format) and fill her complaint details (branch staff will assist if customer is not literate), deposit the same in the complaint box, provided in each Branch. All written complaint forms shall be sent to Complaint Resolution Officer thru post/courier, every week. Branches should keep copies of customer complaint forms for assisting the customer.

Customer Call-ins

Customer calls to CGR phone number – who will record the complaint, does follow ups and provides the resolution

Customer calls to Complaint Resolution Officer dedicated for collating the customer grievances– Customers can call or write to Grievance Redressal Officer to escalate their unresolved grievances

Whistle Blower

A Whistle blower is an LIGHT employee who gives complaint against a colleague who allegedly involved in prohibited activities and breaches code of conduct such as fraud, misappropriation of funds, unethical behavior, mistreatment of customers etc. A whistle blower would also be a customer who gives complaint against an employee or/and customer of LIGHT who allegedly involved in prohibited activities, mentioned above. In this regard, internal staff or customer of LIGHT can call Regional office or Dedicated Whistle blower in charge and submit their complaint. Investigations will occur and appropriate actions will be taken. (Caller name will be kept confidential if requested)

However, the caller should have enough evidence on correctness of the customer grievance and should avoid raising unrealistic complaints. A whistle blower reporting unrealistic complaints shall not be punished if the complaint was raised with good intention and if there enough grounds to suspect a colleague. A staff reporting unrealistic complaints with a bad intention/motivation is liable to receive a disciplinary action i.e. oral warning on first instance and a written warning in case of repetition.

External Complaints

Complaints received from (on behalf of customer or on the basis of public interest) general public & other stake holders such as Govt agencies, RBI, police, lawyers, industry ombudsman (MFIN & SAADHAN etc) & social activists will also be recorded at branch level and provided with appropriate solutions. Hence, any staffs who receive complaints from such agencies should escalate them to Complaint Resolution Officer immediately.

Policy Objective

The objective of this policy document is to provide necessary safeguard for protection of all associated stakeholders from reprisals or victimization, for raising concern and reporting malfunctioning, frauds and unethical practices followed within the company. This policy document outlines framework of company’s safe and secure vigil mechanism and encourages its stakeholders to report concerns which will help company to fulfill its commitment to adhere to the highest standards of ethical, moral and legal conduct of business operations.

Definition

‘Audit Committee’ means the Audit Committee of the Company as constituted by the Board of Directors of the Company as per the guidelines of Reserve Bank of India and the Companies Act, 2013.

‘Business Associates’ means vendors associated with the Company and who have dealt with the Company or have been associated with the Company successfully or unsuccessfully in the past.

‘Complainant/Whistle Blower’ means a person who exposes misconduct, alleged dishonest or illegal activity occurring in the Company.

‘Disciplinary Action’ means any action that can be taken on the completion of / during the investigation proceedings including but not limiting to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.

‘Employee’ means an employee of the Company including outsourced, contract personnel, probationer, trainee, ex‐employee, the Directors in the employment of the Company.

‘Ethics Committee’ means the Ethics committee of the company as constituted by Board of Directors of the Company

‘Investigator/Investigators’ mean those persons authorized, appointed, consulted or approached by the Ethics Committee and includes the person authorized by the Company.

‘Light/Company’ means Light microfinance Pvt. Ltd.

‘Protected Disclosure’ means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

‘Subject’ means a person against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.

Scope & Eligibility

This Policy document is applicable to all employees, Directors, Business Associates and Partners of Light.

This policy covers malpractices and events which have taken place / suspected to have taken place, misuse or abuse of authority, frauds or suspected frauds, violation of company rules, manipulations, negligence causing danger to public health and safety, misappropriation of monies, and other matters or activity on account of which the interest of the Company is affected and formally reported by Whistle Blowers concerning its employees.

Whistle Blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Ethics/Audit Committee or the Investigators.

Policy

Light has secure vigil mechanism as applicable under section 177 subsection (9) and (10) of The Companies Act, 2013.

Light ensures a protected reporting channel for its stakeholders, which enables them to raise concern and report any unehical practices, frauds and breach of its code of conduct.

Light ensures that genuine Whistle Blower will be provided protection from reprisal or victimization.

Disqualification

Light provides protection to all genuine Whistle Blower against unfair treatment/victimization. However, any abuse of this protection will warrant disciplinary action.

Light may take strong penal or disciplinary action against Whistle Blowers, who make any Protected Disclosure which have been found to be bogus or false and done intentionally with malafide intent.

Whistle Blowers, who make 2(two) or more Protected Disclosures, which have been subsequently found to be mala fide or malicious, frivolous, baseless or reported otherwise than in good faith, will be disqualified from reporting further Protected Disclosures under this Policy.

Procedure

Whistle Blower can make the Protected Disclosure to Chairperson of Ethics Committee or Chairperson of Audit Committee, as the case may be through any of the mentioned channel as soon he become aware of the ongoing mal practice.

Whistle Blower can report through any of the following channel:

a)In the form of Letter with subject “Protected Disclosure under Vigil Mechanism” to be given personally or through postal mail to-

The Chairperson

Ethics Committee

Light Microfinance Pvt. Ltd.

310, Pinnacle Business Park

Corporate Road, Prahladnagar

Ahmedabad - 380015

b)In the form of E-mail to address whistleblower@lightmicrofinance.com with subject “Protected Disclosure under Vigil Mechanism”.

c)Through Phone to Ethics Committee which will be documented and recorded, on following number: +91-7575002324

d)Whistle Blower can also report orally to any of the member of ethics committee which will be documented and recorded.

In case Protected Disclosure is received by any of the employee other than member of Ethics Committee, it should immediately be forwarded to Ethics Committee and concerned employee should maintain confidentiality of the matter.

Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised.

For all Protected Disclosures which contains names of member/s of Ethics Committee shall be directly reported to Chairperson, Audit Committee in sealed envelope or through email. The Contact information is as follow:

Light microfinance Pvt. Ltd.

310, Pinnacle Business Park

Corporate Road, Prahladnagar

Ahmedabad – 380015

Email: Compliance@lightmicrofinance.com

The Company encourages and strongly recommends that the Protected Disclosure should contains necessary and relevant details of the fraud or misconduct or suspected fraud or misconduct or any other unfair practice including the name of the employees or any other person who have engaged or who may have engaged, in the opinion of the Whistle Blower, in the misconduct or fraud or any other unfair practice.

Investigation

All Protected Disclosures reported under this Policy are thoroughly investigated by the Ethics/ Audit Committee of the Company.

The Chairperson of the Ethics/Audit Committee may at his discretion, consider involving any Investigators for the purpose of investigation.

The decision to conduct an investigation taken by the Ethics/Audit Committee is by itself not an accusation and is to be treated as a neutral fact‐finding process. The outcome of the investigation may not support the conclusion of the Whistle Blower that an improper or unethical act was committed.

The Whistle Blower is expected to co‐operate with the Investigation Officer, when the matter is under inquiry and is expected to disclose such information or provide documents as may be required for the purpose of the investigation.

Subject will normally be informed of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation. Identity of the subject is kept confidential unless required legally to disclose.

Subject have the right to consult any person of his choice other than those involved in the investigation process and can engage counsel at their own cost to represent them during investigation proceedings.

Ethics/Audit committee documents and maintains all proofs, reports of the proceedings and ensures they are secured.

Investigation Officer should submit the report within 45 days of complaints. Extension may be provided in some special cases by Audit Committee Chairperson.

Decision

Light ensures that no unfair treatment is meted out to a Whistleblower by virtue of his/her having reported a Protected Disclosure under this Policy.

If an investigation leads the Chairperson of Ethics/Audit Committee to conclude that an improper or unethical act has been committed, he/she shall recommend to the management of the Company to take such disciplinary or corrective action as he/she may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.

If the report of investigation is not to the satisfaction of the complainant, the complainant has the right to report the event to the appropriate legal or investigating agency. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the Subject will be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

Protection

Light ensures that no unfair treatment is meted out to a Whistleblower by virtue of his/her having reported a Protected Disclosure under this Policy.

The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistleblowers.

Complete protection is given to Whistleblower/s against any unfair practice like retaliation, threat or intimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistleblower’s right to continue to perform his/her duties/functions including making further Protected Disclosure.

The Company takes steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus if the Whistleblower is required to give evidence in criminal or disciplinary proceedings, the Company arranges for the Whistleblower to receive advice about the procedure, etc.

Light ensures that the Whistle Blower, if a Business Associate, is protected from any adverse action which may include but is not limited to unfair termination of the contract, unfair withholding the payments due, non-acceptance of the goods or any other unfair act which may arise solely out of the concerned Business Associate.

The identity of the Whistle Blower is kept confidential. Any other Employee assisting in the said investigation or furnishing evidence is also protected to the same extent as the Whistle Blower.

The Whistle Blower has the right to directly approach the chairperson of audit committee in case of violation of above protection guidelines or occurrence of any adverse action against him/her.

Confidentiality

Light maintains confidentiality/secrecy of all complaints registered and only share the details with the specific persons involved in the process unless legally bound to disclose.

The Whistle Blower, the Ethics Committee, the Investigator, the Subject and all other persons involved in the process are required to maintain complete confidentiality/secrecy of the matter.

The identity of the Whistle Blower is kept confidential. In some special case where it is necessary to disclose complainant’s identity, it will be disclosed only after prior approval from the complainant.

Light keeps all documents and records related to case confidential unless legally required to be produced.

Retention of documents

All Protected disclosures in writing or documented along with the results of Investigation relating thereto, are retained by the Light for a minimum period of 7 (seven) years.

Amendment

The company reserves the right to modify or amend the part or whole of the policy as and when required. However all amendment will be in compliance with the regulatory guidelines and will be applicable when communicated in writing whether physically or electronically.

Policy Objective

This Policy document on Fair Practice Code is in accordance with the RBI guidelines. The objective of this document is to ensure fair treatment for all stakeholders and to maintain transparency and ethics in all its operations.

Download Fair Practice Code