Customer Grievance Redressal Policy
DSG Investments Private Limited
Documents Details
“Customer Grievance Redressal Policy”
TABLE OF CONTENTS:
OBJECTIVE AND SCOPE OF THE POLICY:
As a service organization, it is our primary responsibility to focus on Customer service and satisfaction. This document details the policy of redressal of customer complaints. The key objective of this policy is to ensure the following:
- All concerns/complaints raised by Customers are resolved in effective and timely manner, leading to their satisfaction;
- Through Customers’ feedback, we are able to improve our processes and products;
- In an event that the Customer is not satisfied with the resolution provided to him, he can escalate the issue to a higher level in the organization.
This document aims to describe internal policy for handling Customer complaints. It describes various channels for lodging the complaint, obtaining solutions from the concerned department and responding Customers with the solution within the committed time period.
Complaint: Complaint is an expression of dissatisfaction or resentment either in the form of a representation or allegation made in writing or through electronic means or over phone, containing a grievance alleging deficiency in:
- services, products, policies of DSG Investments Private Limited,
- services provided by the outsourcing agencies engaged by DSG Investments Private Limited for providing service to its customers,
- employee’s behavior,
- to deal with FinTech/ digital lending related complaints/ issues raised by the borrowers,
- maintaining confidentiality/ protection of customer’s personal (including sensitive personal information) and financial information.
Complaint is not a request for data modification or inquiry about loan products/ schemes, interest rates or other requests which can be solved by Customer care.
Customer: Customer means the person who has obtained the loan or finance facility from DSG Investments Private Limited.
RAISING A COMPLAINT
Modes of raising Complaint:
- Voice Support: The customer can call us at Customer Care Helpline at +91-9871772080 between 10:00 AM to 6:00 PM from Monday to Saturday.
- Email Support: Please write to us at support@dsginvesments.com
- Postal (through letter): Customer Care Department, DSG Investments Private Limited, Office Number 604 Plot No 8, 6th Floor Sachdeva Corporate Tower Rohini Sector 8, Naharpur, Northwest Delhi, Delhi, Delhi, India, 110085.
- Complaint in Person: DSG Investments Private Limited, Office Number 604 Plot No 8, 6th Floor Sachdeva Corporate Tower Rohini Sector 8, Naharpur, Northwest Delhi, Delhi, Delhi, India, 110085.
Content / information in Complaints
While raising a complaint, each complaint should have the following information:
- Customer’s complete name;
- Customer’s complete correspondence address;
- Loan ID;
- Registered mobile number/Phone number;
- E-mail address, if any;
- Details of the complaint;
- Documentary Proof, if required
COMPLAINTS TREATMENT
Procedure for addressing the complaint:
- First call resolution: All the complaints which can be resolved immediately when raised, the response shall be provided on the same call and close the same.
- Resolution post verification: For the complaints which must be verified and may need further investigation/support from other departments and hence cannot be resolved immediately, customers shall be informed about the expected timelines of the closure. For these complaints, tickets shall be raised and assigned to the concerned departments on priority.
We are committed towards resolving all customer’s complaints within 1 (One) month from the date of receipt of complaint with complete details.
Mechanism to handle customer complaints/ grievances:
While handling the customer complaints, the customer shall be informed about the following:
- Information pertaining to all issues/concerns raised by the customer;
- Explanation of final solution provided;
- Expected timelines towards closure (where immediate solution cannot be provided);
- Maintain contact at defined intervals/milestones to communicate progress on his concern and share reasons for delay/time taken; and
- Request for supporting documents/information (if applicable) in a clear manner along with the reason for such requirement.
Concerned team members handling the complaint should make reasonable attempts to reach the customer for providing a solution to his/ her complaint, preferably in the form the complaint was received.
Complaints Archiving
After the resolution is provided to the customer, the concerned department shall update the status of these complaints as closed in the system. These complaints reflect in a closed complaints bucket which can be re-examined at any point of time, as and when required.
Grievance Redressal Mechanism
Customers who wish to send in complaint/feedback over any issue can use the following channels.
LEVEL 1: Customer Relationship Manager
Please contact Customer Relationship Manager.
- Timings: 10 am to 6 pm on week days
- Helpline No: +91-9871772080
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 available on the phone to register your complaints.
- Helpline No: +91-9871772080
- Email id: support@dsginvestments.com
- Timings: 9 am to 6 pm on week days
LEVEL 3: Grievance Redressal Officer
If you are not satisfied with the response from customer service helpdesk or if you don't receive a response within 3 working days, please call or write to Grievance Redressal Officer. You will receive a response within 5 working days of Grievance Redressal Officer receiving the complaint.
Grievance Redressal Officer (Nodal Officer)
- Name: Mr. Mahesh Chaudhary
- Address: Ground Floor, House NO-227, Block-A Pocket-4, Sector-4 Rohini, North West Delhi, Delhi, 110085
- Contact No.: +91-9315206327
- Email: Nodal@dsginvestments.com
Also, if the complaint / dispute are not redressed within a period of one month, the customer may appeal to the RBI on the following addresses:
The General Manager
Deptt. Of Non-Banking Supervision (DNBS)
Reserve Bank of India
6, Sansad Marg, New Delhi- 110001
Email: dnbsnewdelhi@rbi.org.in, dosnewdelhi@rbi.org.in
Complaint Portal: https://cims.rbi.org.in/#/login
RESOLUTION TURNAROUND TIME
Overall customer complaints shall be resolved within 1 (One) month from the date of receipt of complaint with complete details.
SUPERVISION AND REPORTING
Reporting:
There are complaints about MIS and reporting in place. This reporting serves as an input for other analysis, for periodical review.
Supervision:
- 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 no. of complaints received, disposed off and pending, with reasons thereof, which will be placed before the Board for information / guidance.
Code of Conduct
DSG INVESTMENTS PRIVATE LIMITED
(This Code of Conduct was approved by the Board of Directors in the Board Meeting held on ____________.)
Documents Details
Code of conduct
General Responsibilities
You are required to perform all duties and responsibilities assigned to you by DSG Investments Private Limited with diligence and integrity. Your performance should comply with established policies and procedures, aiming to protect and promote the Company’s interests.
Conflict of Interest
You must not engage in any business, occupation, or activity that could be detrimental to Company’s interests, either directly or indirectly, without written permission from the Company. This includes roles or responsibilities that might create a conflict of interest.
Confidentiality
You are required to keep details of your salary and employment benefits confidential. This confidentiality extends to all confidential information related to Company’s business and its clients that you may come into possession of during your employment. Such information should only be disclosed as necessary for the execution of your duties.
Protection of Confidential Information
You shall not disclose or divulge any confidential or sensitive information about Company’s business operations or clients unless required by your role. This includes not making copies or duplicates of any confidential materials or proprietary information without authorization.
Adherence to Company Policies
You will adhere to Company’s Code of Conduct and all other rules, regulations, policies, and directives issued by the Company. These encompass conduct, discipline, and service conditions, including but not limited to leave, medical, and retirement policies, as if they were part of your appointment contract.
Interaction with Customers
- Honesty and Courtesy: Always engage with customers in an honest, courteous, and straightforward manner.
- Respectful Communication: Use respectful language and uphold cultural sensitivities in all communications with customers.
- Professional Boundaries: Avoid contacting customers at inappropriate times or during sensitive occasions such as bereavement or illness.
- Confidentiality: Maintain strict confidentiality of all customers and company information.
Integrity and Conduct
- Ethical Standards: Act with integrity and trustworthiness, adhering to the highest ethical principles. Ensure that no policies, procedures, or positions are exploited for personal gain.
- Collection Procedures: Do not seek to recover shortfalls from employees unless in cases of proven fraud.
- Personal Appearance: Maintain a clean and professional appearance in the office, during client visits, and at all times while representing the Company.
- Care of Company Property: Ensure the cleanliness, maintenance, and security of all Company property, including office equipment, records, vehicles, and buildings.
- Work Efficiency: Perform your duties diligently and efficiently. Avoid using Company time or resources for personal business.
Professionalism
Creative Problem-Solving: Approach each situation with creativity, confidence, and courage. Strive to find positive solutions and outcomes for all involved parties in your interactions.
9. Accountability
- Take responsibility for your actions and decisions during the recovery process.
- Report any observed unethical behavior or violations of this code.
10. Continuous Improvement
- Pursue ongoing training and development to enhance skills and knowledge in recovery practices.
- Encourage a culture of feedback and collaboration among team members to improve processes.
Acknowledgment
I have read and understood the Code of Conduct and agree to adhere to its principles and guidelines.
CREDIT POLICY
DSG INVESTMENTS PRIVATE LIMITED
TABLE OF CONTENTS:
OBJECTIVE AND SCOPE OF THE POLICY:
DSG Investments Private Limited (Company) is registered with Reserve Bank of India (RBI) as a non-deposit accepting NBFC. Being an NBFC, it has to comply with Guidelines / Directions issued by RBI from time to time. The Company’s Credit Policy is the framework, which defines the principles for its lending business. The Company shall duly implement and keep the Credit Policy including the Appendices and any amendments thereto up to date, in accordance with any regulatory, corporate or other legal requirements.
The objectives of this Policy are as below:
- To create a set of standardized policies and procedures for the lending activities of DSG Investments Private Limited.
- To institute due diligence for mitigating level of credit risks and improve credit quality.
- To define overall risk appetite.
- To establish underwriting framework- including maximum credit limits, risk limits, etc.
- To ensure thorough Credit appraisal and proper monitoring of all outstanding Credits. This includes both; supervision of outstanding Credits as well as recovery of overdue Credits.
- This Credit policy provides an overall description of all stages of the lending process.
In pursuing its business, DSG Investments Private Limited will operate according to the highest ethical and compliance standards and constantly seek to follow best practices in the industry. Under no circumstances will contravention of laws and relevant regulations would be tolerated.
BUSINESS STRATEGY AND BUSINESS OPERATIONS:
DSG Investments Private Limited business operations need to be financially sustainable i.e.; all expenses shall have to be met from income essentially from interest earned on credit extended in addition to income from investments and fees collected from services extended to customers. The Company may give credit to any Body Corporate(s), firm(s), Individuals, etc.
Business Segments
Retail Lending: DSG Investments Private Limited aims to extend Credits, to the public for personal credits including consumer durables, travel, marriage and such. The Credit Policy enumerates on the customer segments, purpose of Credit, process of Credit approval and disbursal, interest rate determination of the Credit disbursal and charges to be borne by an individual customer.
Corporate Lending: The Company can further extend Credits to any Body Corporate(s), firm(s), non-individual entities.
Other Segments / Credit Products: The Committee can further determine product parameters for retail lending and set limits on total book size for each product. The Credit policy has been framed in line with the Fair Practices Code prescribed by RBI.
Sanctioning Authority
Board of Directors (herein after referred to as ‘Authority’ or ‘the Board’) shall be the sanctioning authority. The board have been authorized to sanction the loan on case- to-case basis covering the entire spectrum of aspects viz. Purposes, size, interest rate, term, repayment terms, and security required and any other conditions will be as decided by the Board.
The Board may directly approve any particular Credit or any other feature of the Policy.
PURPOSE OF CREDIT:
In the long term, it is envisaged that the lending business will reach out to both existing customers as well as open market customers and fulfil their financing needs for purposes as wide ranging as Credits for purchasing consumer durables, cash credits, and the gamut of curated lending products.
The Company can further extend the credits to corporate (non-individual entities) for their business needs within the risk appetite and regulatory framework.
CUSTOMER SELECTION:
In case of individuals, Credits shall be provided to:
- Salaried Employees of Public Sector Institutions/Companies/Undertakings
- Salaried Employees of Private Sector Companies
- Self-Employed Individuals
- Students
CREDIT UNDERWRITING:
The process from the receipt of customers' request and communication of the final approval of facility will be as under:
Credit Approval process:-
The process will start from the receipt of customers' request through mobile app or web portal of the Company or through our fintech platform Myflot.com and the processing of same, including approval of the credit facility. The process ends with the communication of an approval of facility to the customer through a term sheet/sanction letter.
- Credit Application: The customer shall submit an online application to inform the Company regarding the interest in a certain Credit product.
- KYC Document Verification: The documents submitted by the customer will be required to be analyzed either using competent technological or human resources.
- Credit Appraisal: This step involves arriving at a decision to provide the Credit or not, DSG Investments Private Limited shall require additional documents such as income statement, PAN, Form16 or other considered necessary from the customer.
- Final decision on Sanction: The final decision to provide the Credit or not will remain with DSG Investments Private Limited after all the previous steps.
Since the major focus in retail Credits shall be unsecured Credits, the underwriting shall be strengthened such that Credits shall only be granted after the ability and intention to pay of the individual is assessed to an extent as much as possible. Unconventional sources such as alternative data modelling to arrive at the credit worthiness of the individual can also be used.
Unsecured Credits shall not be granted to those who do not have a verifiable regular income, other than students. In case of students, the personal Credit shall require the guarantee of another person who shall pay in case of default.
Processing Fee:–
DSG Investments Private Limited has decided to charge a processing fee at applicable rates from time to time. Any revision in these charges would be implemented on prospective basis with due communication to customers. These charges would be decided upon by the respective business / Function heads in consultation with Operations, Finance, Compliance and Legal Heads.
Other Charges:-
The below charges shall be as applicable for each product line.
- Platform/Tech Fee
- Prepayment Charges/Credit Foreclosure
- Additional Interest on late payment
- PDC/ECS swap charges
- Credit cancellation charges
- Legal charges
TENOR:
The retails Credits shall be granted for a tenor of not more than 12 months.
DETERMINATION OF INTEREST RATES:
The base interest rate comprises of the cost of funds, operational costs, risk and the minimum rate of return desired. The further spread will take into account the factors in the creditworthiness of the customer in the form of risk premium.
Other relevant factors have been enumerated below:
Interest shall be accrued and charged periodically but not less than monthly rests. Fees/ charges may be levied upfront or at other specific intervals as per the agreed terms and conditions.
Some fees or commissions may have to be paid before the commencement of a facility; the customer shall be required to make advance payment of such funds to DSG Investments Private Limited.
In all cases, the effective interest rate/ Annualized Percentage Rate (APR) shall be clearly communicated to the customers, all fees, commissions, interest rates and their calculations shall be transparent and explained in a manner that could be understood by the customers, in compliance with the Fair Practice Code (FPC), Key Fact Sheet (KFS) and Digital Lending Guidelines, and the sanction letter and the term sheet duly signed shall be obtained from the borrowers in token of acceptance of the terms and conditions of the facility.
Interest Rate policy will be reviewed periodically to take into account market forces, inflation and risk factors.
Interest rate structure may vary among borrowers depending upon the risk factors & need for achieving operational & financial sustainability. The Credit Authority will go through the rate recommended and give approval in all such cases.
The sanctioning authority shall record specific reasons in writing at the time of sanctioning Credits, in case no interest is stipulated or a moratorium for principal or interest is granted for any period.
The rate of interest shall majorly depend on three overarching major factors:
Company factors:
- The cost of funds: Currently, both equity and debt funding are provided by the DSG Investments Private Limited, at an internally decided rate. Going forward, DSG Investments Private Limited shall opt for bank borrowings, debentures and commercial papers.
- Operational costs: This would include the cost of using manpower for applicant’s checks and document processing/verification, and if any face-to-face interaction is required.
- Marketing Cost: This would include cost incurred to acquire a customer and cost incurred for the promotion of the business.
- Technology costs: This includes cost incurred for the development, maintenance, data storage and other cost involved relating to successfully running the technology.
- Forecasting and planning objectives: DSG Investments Private Limited shall have an Annual Operating Plan with certain Return on equity/Return on Assets targets. Thus, the interest rate would have a margin for fulfilment.
Customer Factors based on the risk categorization (low, medium, high) of the customer:
- Credit Bureau Rating: All customers with existing trade lines shall be partly evaluated on the basis of their credit score. A cut-off score shall be defined with risk categorization and associated interest rates.
- Customer History: If a customer already has a Credit account with DSG Investments Private Limited, the performance of the individual on the existing repayments shall be evaluated. This is also a subset of the credit score.
- Customer Alternate data results: Going forward, DSG Investments Private Limited shall heavily invest in developing strong technological capabilities to analyze social media content via partnerships, Information sourced from electronic devices via mobile-based application permissions to understand the linkages between the declarations made by the customer and the reality reflected by his/her financial transactions and actions.
- Applied Amount and Tenor of the Credit: The interest rate shall also factor in the amount of Credit and the number of months that the Credit shall be repaid in.
External Factors:
- Possibility of linkage of Credit rates with benchmarked rates.
- Competition Credit Rates: DSG Investments Private Limited shall be mindful of the interest rates charged by its peer group companies for the benefit of the customer as well as for being ahead of the curve in terms of sound business sense.
Other Important factors:
- The rate of interest shall be annualized percentage rate so that the borrower is aware of the exact rates that would be charged to the account.
- 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 companies or published in the relevant newspapers. The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.
Repayment:
The Credit may be repayable in one or more instalments as per the terms agreed upon. However, the cut-off date for repayment may be extended by the sanctioning authority for any particular case. Where such cut-off date for repayment is extended beyond the due date, the sanctioning authority shall record specific reasons in writing for such extension.
Security:
For secured Credits, the borrower shall, in consideration of the Credit given, create such security in favour of the Company as stipulated by it, including a demand promissory note, wherever applicable.
Collaterals:
In case it is felt necessary to strengthen the credit worthiness of the borrower, a co- borrower / guarantor may be considered.
CUSTOMER JOURNEY:
DSG Investments Private Limited shall have two ways in which the customer can reach out for the services.
- Independent through Web: This shall be either through the mobile application or the online website (web-app).
- Assisted through web/offline: This shall be in both online and offline modes (in affiliated stores) and branches, if any, opened in future.
PRE-APPROVED CUSTOMERS:
In this case, DSG Investments Private Limited may approach the customer based on the determined credit worthiness from alternative sources of data obtained via application permissions, credit bureau and enabling the decision engine to identify customers.
This would then simply be a consent to the offer made by DSG Investments Private Limited from acceptance of the offer to actual disbursement, it could be independent or assisted.
GENERAL INFORMATION:
- All customers shall be informed in detail regarding the features, terms and conditions including all charges of the Credit before the sourcing of the application. In case of credit facility availed over online or telephonic mode, no Credit application shall be processed without a written consent from the customer.
- DSG Investments Private Limited shall not discriminate the sanctioning of Credits based on gender, caste or religion. However, it may choose to develop lending schemes for specific sections of the society.
- After the sanction of the Credit, the Credit terms and conditions, sanctioning letter, repayment schedule and all other such relevant documents shall be sent in any chosen mode and explained to the customer.
- Endeavour shall be made to inform the customer regarding status of the account prior to it turning into an NPA.
REPORTING TO CICS:
DSG Investments Private Limited shall ensure submission and updation of credit information for its borrowers regularly to all the Credit Information Companies (CICs) on a monthly basis or at shorter interval.
PERIODIC UPDATION:
The Credit Policy shall be reviewed annually or as and when required necessary.
Fair Practice Code
DSG INVESTMENTS PRIVATE LIMITED
(This fair practice code was reviewed and approved by the Board of Directors in the Board Meeting held on …………)
Documents Details
INTRODUCTION
RBI has drafted the guidelines on Fair Practices Code for Non-Banking Finance Companies which sets the fair practices standards when dealing with individual customers and to serve as a part of best corporate practice.
It is, and shall be, our policy to make loan products available to all qualified applicants without discrimination on the basis of race, caste, colour, religion, sex, marital status or handicap. Our policy is to treat all the customers consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. We will also communicate our Fair Practices Code to our customers by placing it on the company's website.
We shall ensure that charges / fees are appropriately informed to the borrower. Terms and conditions pertaining to the facility will be conveyed to the prospective borrowers. We commit that disputes arising out of the lending decisions will be appropriately resolved by a grievance redressal mechanism set up by us.
The Company's Fair lending practices shall apply across all aspects of our operations including marketing, loan origination, processing, servicing and collection activities. Our commitment to Fair Practice Code would be demonstrated in terms of employee accountability, monitoring and auditing programs, training and technology.
The Company's Board of Directors and the management Team is responsible for establishing practices designed to ensure that our operations reflect our strong commitment to fair lending and that all employees are aware of that commitment. DSG Investments Private Limited is committed to providing service of the highest quality to its clients.
This Fair Practices Code applies to all categories of products and services offered by us (currently offered or which may be introduced at a future date.
The Fair Practices Code is applicable to the above irrespective of whether the same is provided at the Branch, over the phone, on the Internet or by any other method we may be currently using or may introduce at a future date.
OBJECTIVE
The primary objectives of this FPC are following:
- To promote fair, ethical, and transparent dealings with customers.
- To establish a fair relationship between the customer and Company;
- To ensure compliance with legal norms in matters relating to recovery of advances;
- To strengthen mechanisms for redressal of customer grievances effectively and efficiently.
KEY COMMITMENTS
The Company's key commitments to customers:
Act fairly and reasonably in all their dealings with customers by:
- Meeting the commitments and standards specified in the Code, for the products and services which the Company offers and, in the procedures, and practices its staff follows;
- Making sure that Company's products and services meet relevant laws and regulations applicable to it;
- Company's dealings with customers will rest on ethical principles of integrity and transparency.
Help customers understand how company's product works by explaining their financial implications.
Deal quickly and sympathetically with things that go wrong by:
- Correcting mistakes;
- Handling customer's complaints;
- Telling customers how to take their complaint forward if they are still not satisfied
Publicize the Code, display it on Company's website and have copies available for customer on request.
Applications for loans and their processing
- All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
- Loan application forms 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.
- The company will devise a system of giving acknowledgement for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of will also be indicated in the acknowledgement.
Loan appraisal and terms/ conditions; and Key Facts Statement for Loans and Advances
The Company shall make proper and prompt assessment of all Loan applications. The Company shall conduct a due diligence on the credit worthiness of the applicants. Mere offering of Hypothecation on Asset will not be the sole consideration for sanctioning loans.
When sanctioned, the company shall convey to the applicant the details of Loan amount, interest rates, penal interest for late payment, repayment schedule, terms & conditions for loan and other charges in Loan Agreement in writing to the borrower in the vernacular language or any other language as understood by the borrower by means of sanction letter or otherwise and keep the acceptance of these terms and conditions by the borrower on Company's record. The Company will also mention the penal charge which will be charged for late repayment and / or any other default on the part of the customer, in bold in the loan agreement.
The company shall furnish a copy of the loan agreement 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 shall comply with the instructions contained in the circular on ‘Key Facts Statement (KFS) for Loans & Advances’ dated April 15, 2024, as amended from time to time. RBI Circular for Key Facts Statement (KFS) for Loans & Advances.
Penal charges in loan accounts
- Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.
- The company will not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit.
- The company will formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called.
- The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan/product category.
- The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges to non-individual borrowers for similar non-compliance of material terms and conditions.
- The quantum and reason for penal charges shall be clearly disclosed by the company to the customers in the loan agreement and most important terms & conditions/Key Fact Statement (KFS) as, in addition to being displayed on websites of the company under Interest rates and Service Charges.
- Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.
- The Company shall implement the revised penal charges framework for all fresh loans sanctioned or renewed on or after April 01, 2026, and ensure migration of existing loans to the new regime at the time of their next review or renewal, but not later than June 30, 2026, with necessary revisions made in the internal policy and processes to ensure full compliance.
Disbursement of loans including changes in terms and conditions
- The company will give notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. We will also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard will 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 realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim 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 company is entitled to retain the securities till the relevant claim is settled/paid.
Responsible Lending Conduct – Release of movable/immovable property documents on repayment/ settlement of personal loans
To address the issues faced by the borrowers and towards promoting responsible lending conduct, the following instructions shall be followed:
Release of movable/immovable property documents
- The company will release all the original movable / immovable property documents and remove charges registered with any registry within a period of 30 days after full repayment/settlement of the loan account.
- The borrower shall be given the option of collecting the original movable/ immovable property documents either from the banking outlet/branch where the loan account was serviced or any other office of the company where the documents are available, as per her/his preference.
- The timeline and place of return of original movable/immovable property documents shall be mentioned in the loan sanction letters issued on or after the effective date.
- In order to address the contingent event of demise of the sole borrower or joint borrowers, company will have a well laid out procedure for return of original movable/immovable property documents to the legal heirs. Such procedure shall be displayed on the website of company along with other similar policies and procedures for customer information.
Compensation for delay in release of movable/immovable property documents
- In case of delay in releasing of original movable/immovable property documents or failing to file charge satisfaction form with relevant registry beyond 30 days after full repayment/ settlement of loan, company will communicate to the borrower reasons for such delay. In case where the delay is attributable to the NBFC, it shall compensate the borrower at the rate of ₹5,000 for each day of delay.
- In case of loss/damage to original movable/immovable property documents, either in part or in full, company will assist the borrower in obtaining duplicate/certified copies of the movable/immovable property documents and shall bear the associated costs. However, in such cases, an additional time of 30 days will be available to the company to complete this procedure and the delayed period penalty will be calculated thereafter (i.e., after a total period of 60 days).
- The compensation provided under these directions shall be without prejudice to the rights of a borrower to get any other compensation as per any applicable law
Reset of floating interest rate on Equated Monthly Instalments (EMI) based personal loans
- At the time of sanctioning EMI-based floating rate personal loans, the Company shall assess the borrower’s repayment capacity with adequate margin for possible increases in external benchmark rates, and shall put in place a policy framework to ensure that any change in loan tenor or EMI amount due to rising interest rates is implemented only with proper communication to and, where applicable, consent of the borrower, thereby ensuring transparency and borrower protection in line with RBI directions.
- At the time of sanction, company will clearly communicate to the borrowers about the possible impact of change in benchmark interest rate on the loan leading to changes in EMI and/or tenor or both. Subsequently, any increase in the EMI/ tenor or both on account of the above shall be communicated to the borrower immediately through appropriate channels.
- At the time of reset of interest rates, company will provide the option to the borrowers to switch over to a fixed rate as per their Board approved policy. The policy, inter alia, may also specify the number of times a borrower will be allowed to switch during the tenor of the loan.
- The borrowers shall also be given the choice to opt for (a) enhancement in EMI or elongation of tenor or for a combination of both options; and, (b) to prepay, either in part or in full, at any point during the tenor of the loan. Levy of foreclosure charges/ prepayment penalty shall be subject to extant instructions.
- All applicable charges for switching of loans from floating to fixed rate and any other service charges/ administrative costs incidental to the exercise of the above options shall be transparently disclosed in the sanction letter and also at the time of revision of such charges/ costs by the company from time to time.
- Company will ensure that the elongation of tenor in case of floating rate loan does not result in negative amortisation.
- Company will share/ make accessible to the borrowers, through appropriate channels, a statement at the end of each quarter which shall at the minimum, enumerate the principal and interest recovered till date, EMI amount, number of EMIs left and annualized rate of interest/Annual Percentage Rate (APR) for the entire tenor of the loan. Company will ensure that the statements are simple and easily understood by the borrower.
- Apart from the equated monthly instalment loans, these instructions would also apply, mutatis mutandis, to all equated instalment based loans of different periodicities.
- All existing borrowers shall be sent a communication, through appropriate channels, intimating the options available to them
General
- 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 lender).
- In case of receipt of request from the borrower for transfer of borrower 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, As complaints from customers also include rude behaviour from the staff of the companies, NBFCs shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
- As a measure of customer protection and also in order to bring in uniformity with regard to prepayment of various loans by borrowers of banks and NBFCs, company will not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).
Responsibility of Board of Directors
The Board of Directors of company will also lay down the appropriate grievance redressal mechanism within the organization. Such a mechanism shall ensure that all disputes arising out of the decisions of lending institution’s functionaries are heard and disposed of at least at the next higher level.
The Board of Directors shall also provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board at regular intervals, as may be prescribed by it.
Further Assistance
Complaints:
In case of any complaint/grievance, the applicant/borrowers will have to inform in writing the concerned branch. The Branch Officials shall immediately take up the matter for redressal.
Grievances Redressal Mechanism
All disputes in relation to the products and services shall be heard and disposed off within 30 days from the date of receipt of the complete details in respect of the grievance.
Grievance Redressal – Contact Details
In case of grievances you may contact the Grievance Redressal Officer, please contact us in any of the following ways:
- Name of Grievance Redressal Officer: Mr. Mahesh Chaudhary
- Email: Nodal@dsginvestments.com
- Contact No.: +91- 9315206327
In case the borrower is not satisfied with the decision of the Grievance Redressal Officer of the Company, he may approach the Officer in Charge of the Regional Office of Department of Non-Banking Supervision of RBI at the address given below:
Department of Non-Banking Supervision
The General Manager
Department of Supervision (DoS)
Reserve Bank of India
6, Sansad Marg, New Delhi- 110001
Email: dnbsnewdelhi@rbi.org.in
Online: https://cms.rbi.org.in
Email: crpc@rbi.org.in
Toll-Free Number: 14448
A consolidated report of periodical review of compliance of fair practice code and functioning of the grievances redressal mechanism at various levels of management may be submitted to the Board/Committee of Directors at regular intervals as may be prescribed by it.
Feedback and Suggestions
We request our customers to provide feedback on our service to help us to improve our services.
Monitoring
We have a Grievance Redressal Officer to ensure compliance of the Code.
Regulation of excessive interest charged by company
- The Board of company shall adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances. 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 website of the companies or published in the relevant newspapers. The information published on the website or otherwise published shall be updated whenever there is a change in the rates of interest.
- The rate of interest must be annualised rate so that the borrower is aware of the exact rates that would be charged to the account.
Complaints about excessive interest charged by NBFCs
Company recognize that charging fair and reasonable interest is essential to building long-term trust with our customers. While interest rates are determined by the company, we are committed to ensuring that they remain justifiable, sustainable, and in line with normal financial practices. We will not levy interest or charges at levels that could be considered excessive or unfair.
To achieve this, our Board has laid down clear internal principles and procedures for determining interest rates, processing fees, and other applicable charges. These principles are guided by transparency, fairness, and accountability. Customers will always be informed in a clear and transparent manner about the applicable terms and conditions of their loans, in line with our Fair Practices Code.
Loan facilities to the physically/visually challenged by Company Complaints:
Company will not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability.
REVIEW
The Board of Director reserves the right to review the Fair Practice Code from time to time and to carryout necessary changes, accordingly as and when required.
The code will be available on the website of the Company and copies will be made available on request.
Gradation of Risk Policy
DSG INVESTMENTS PRIVATE LIMITED
This policy was updated and approved by the Board of Directors in its meeting held on 19th March, 2026.
Documents Details
Introduction
DSG Investments Private Limited (hereinafter referred to as "the Company") is committed to managing risk in a prudent and transparent manner. The Company's Gradation of Risk Policy outlines the process for assessing the risk associated with each loan offered, the factors influencing loan approval, and the applicable interest rates for various loan products. This policy ensures that the Company operates in accordance with industry standards, and that risks are effectively assessed and mitigated in the loan decision-making process.
Purpose
The purpose of this policy is to establish a consistent framework for evaluating and assigning risk grades to loan applications, and determining the interest rate applicable to each loan. The Company intends to ensure that borrowers are offered fair and transparent loan terms, while also safeguarding the financial health of the Company.
Loan Risk Assessment Criteria
The decision to approve a loan and the interest rate applicable to each loan account shall be assessed on a case-by-case basis using multiple parameters that help in determining the overall risk level. The primary risk factors include, but are not limited to:
- Asset Type: The nature and type of the asset being financed (e.g., vehicle, equipment, or property).
- Borrower Profile: The financial stability, creditworthiness, and repayment history of the borrower.
- Repayment Capacity: The borrower’s ability to repay the loan, assessed based on their income, expenses, and existing financial obligations.
- Financial Commitments: The borrower's other existing financial obligations, including loans, credit facilities, and other commitments that could affect their repayment ability.
- Past Repayment Track Record: The borrower’s previous repayment history (if any), including their punctuality and reliability in repaying loans.
- Security for the Loan: The value of the collateral or security provided against the loan, which may include the underlying asset financed or other guarantees.
- Loan-to-Value (LTV) Ratio: The ratio of the loan amount to the value of the underlying asset, which impacts the level of risk assumed by the Company.
- Mode of Payment: The agreed method of repayment, including whether payments are monthly, quarterly, or annual, and whether the payment structure aligns with the borrower’s cash flow.
- Tenure of the Loan: The duration of the loan, with longer tenures generally presenting higher risk.
- Geography (Location) of the Borrower: The location of the borrower may influence the risk profile, taking into account local economic conditions, legal framework, and market stability.
- End Use of the Asset: The intended use of the financed asset (e.g., personal, business, or investment) and the potential for the asset to generate returns or enhance the borrower’s financial position.
Gradation of Risk Levels
The Company shall classify loans into different risk categories based on the parameters outlined above. The risk categories are designed to ensure a balanced and fair approach to loan approvals and interest rate assignments.
- Low Risk (Grade A): Borrowers with a strong financial background, excellent creditworthiness, stable income, a low LTV ratio, and a secure loan repayment structure. Loans in this category are generally offered lower interest rates.
- Moderate Risk (Grade B): Borrowers with a satisfactory financial profile but with some minor risks such as moderate LTV ratios or occasional late payments in the past. These borrowers may be offered interest rates slightly higher than those in the Low Risk category.
- High Risk (Grade C): Borrowers with weaker credit histories, unstable financial profiles, high LTV ratios, or other significant risks. These loans are associated with higher interest rates to compensate for the increased risk.
- Very High Risk (Grade D): Borrowers with significant financial challenges, high default probabilities, or lack of sufficient collateral. These loans carry the highest interest rates and may require stricter terms and conditions.
Interest Rate Structure
The interest rate listed above are indicative and will be determined after evaluating the borrower's risk profile on a case-by-case basis. The final interest rate offered will be annualized, ensuring transparency in the amount charged to the loan account.
Review and Amendment of Risk Gradation Policy
The Board of Directors or the designated Risk Committee of DSG Investments Private Ltd shall be responsible for the administration, interpretation, and application of this policy. The Committee will review this policy regularly and make amendments as necessary to reflect changes in market conditions, regulatory requirements, or the Company’s strategic goals.
Policy Amendments: The Risk Committee has the authority to make changes to this policy at any stage, with or without prior notice, in accordance with the Company’s requirements.
Policy Disclosure: The Company shall disclose the interest rates and risk gradation structure on its website to ensure that borrowers are fully informed of the terms and conditions applicable to their loan.
Periodic Updation:
The Board of Director shall reviewed and update Gradation of risk policy annually or as and when required necessary.
INTEREST RATE AND PENAL CHARGES POLICY
DSG INVESTMENTS PRIVATE LIMITED
(This policy was reviewed and approved by the Board of Directors in the Board Meeting held on …………….)
Documents Details
Index
Introduction
The Reserve Bank of India ("RBI”) vide Master Direction – Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 has stipulated at Chapter III - Fair Practices Code for all applicable Non-Banking Financial Companies (“NBFCs”) and has directed all NBFCs to lay down appropriate internal policies and procedures in determining rates of interest, processing fees, other charges and display the rates of interest and the approach for gradation of risks on their website.
The objective of adopting and implementing this policy is to institute fair and transparent dealings in the lending business in accordance with the aforesaid regulatory requirements and the Fair Practices Code adopted by the DSG Investments Private Limited (hereinafter referred to as the “Company”).
The said Interest Rate and Penal Charges Policy broadly outline the Interest Rate Model, Applicable penal charges in case of delay in repayment of loan and the Company’s approach of risk gradation in this regard.
This Policy also aligns with RBI instructions on Key Fact Statement (KFS), transparency in digital lending, and customer protection measures as applicable from time to time.
Objective
The main objectives of this Policy are to:
- Ensure that interest rates are determined in a manner as to ensure long term sustainability of business by taking into account the interests of all stakeholders,
- Develop and adopt a suitable model for calculation of a interest rate;
- Enable fixation of interest rates which are reasonable: both actual and perceived;
- Ensure that computation of interest is accurate, fair and transparent in line with regulatory guidelines and market practices;
- Charge differential rates of interest linked to the risk factors as applicable;
- Decide on the principles, methodology and approach of charging spreads to arrive at final rates charged from customers.
Review and approval of the policy
This policy is approved by the Board of Directors of the Company and the Company has adopted the Policy on Interest Rate and Penal Charges taking into account relevant factors such as cost of funds, margin and risk premium and determining the rate of interest to be charged for loans and advances. Any revision in the Policy shall be reviewed by the relevant internal units and approved by the Board of Directors.
This Policy shall always be read in conjunction with extant RBI guidelines, directives, circulars and instructions.
Disclosures
As per extant regulations and in terms of this Policy, the following disclosures shall be made:
- The rate of interest and the approach for gradation of risks and the rationale for charging different rates of interest to different categories of borrowers shall be disclosed by the Company to the borrower or customer and will be communicated explicitly in the sanction letter.
- The rate of interest and the approach for gradation of risks shall also be made available on the website of the Company. The information published on the website shall be updated whenever there is a change in the rate of interest.
- The annualized rate of interest shall be disclosed so that the borrower is aware of the exact rates that would be charged in relation to the loan amount.
- Any change in the rate of interest or other charges, as applicable, shall, be made prospectively and the same shall be adequately disclosed in the loan agreement, sanction letter and Key Fact Statement (“KFS”).
- The quantum and reason for Penal charges shall be clearly disclosed to the customers in the loan agreement, Key Fact Statement, in addition to rate of interest and other charges being displayed on the Company’s website.
Principles for Determining of Interest Rates
The interest rate of each product is decided from time to time, giving due consideration to the following factors:
- Cost of Capital: To run the business, the Company has been infused with equity share capital in huge proportions, and accordingly the cost of such equity share capital being infused shall be taken into consideration.
- Weighted Average cost of Borrowing: Since the Company borrows funds from various banks, financial institutions and other external lender(s), the weighted average borrowing cost, as well as costs incidental to those borrowings like brokerage, consultancy fees, processing fees shall be taken into consideration. The cost of borrowings varies according to market conditions thus pricing of interest rates shall be consequently impacted and decided accordingly.
- Risk: Risk related to loss of credit due to short tenure of loan, nature of facility, ticket size of loan, geographical condition, customer segment, sourcing channels, stability in earnings and employment, financial position, past repayment track record with us or other lenders, external ratings of customers, credit reports, customer relationship, other existing indebtedness, results from digital verifications etc. Therefore, risk of recovery of loan shall be taken into consideration and accordingly the risk premium would be reckoned.
- Opex Cost: It includes employee expenses, office and infrastructure related fixed and variable costs, operations costs, sales and marketing expenses, etc.
- Profit Margin: Fair profit margin is added to arrive at the lending rate. The company may at its discretion fix different margins for different customers, considering the risk of default. All customers will however be notified of the interest payable for the loan to be availed from the company.
Apart from the aforesaid factors, following points also impact the interest rate determination:
- Risk profile of the borrower
- Tenor of the Loan
- Credit score of the borrower
- Credit and default risk in the related business segment
- Historical performance of similar kind of customers
- Prevailing Interest rate trends in the money market
- Treasury bill rates and the sovereign yield curve
- Market scenario relating to credit risk premia/default premia including CDS spreads
- Internal Cost of doing business
- Interest rates offered by other NBFCs in the industry
- Loan documentation and maintenance fees/ costs
- Cost for portfolio monitoring
- Customer communication costs
- Recovery costs
- Other factors that may be relevant in each case.
Rate of Interest
Rate of Interest shall be offered based on the parameters as explained above.
Our loans range from INR 1,000/- to INR 1,00,000/- with repayment periods starting from 15 days to 47 days for Unsecured Pay day loans.
The Board of Directors, in its meeting held on ___________, reviewed and approved the Interest Rate and Penal Charges Policy. The Board further resolved to update the interest rate structure, which shall now be applicable as follows:
1. Pay Day Loan: 0.10% to 1.00% per day
The Company shall ensure that interest rates, including for short-tenure or high-risk products, are reasonable, transparent, and commensurate with the risk profile and cost structure, and do not result in unfair or excessive burden on borrowers.
Interest rate can be of two types:
- Fixed interest rate: In fixed rate loans, lenders charge a constant personal loan rate throughout the tenure. Here the total interest payable remains fixed.
- Floating Interest Rate: Floating or variable personal loan interest rates in India are susceptible to fluctuating economic conditions. Here, the customers may get the benefits of low interest personal loans initially, but there is a possibility of the lender revising the rates as per the repo rate which may result in varying rates of interest throughout the tenure of the loan.
Currently, all loans offered by Company to its customers are at Fixed Interest rates.
The interest re-set period for variable rate loans would be decided by the Company from time to time. The interest could be charged on monthly or on such rest as communicated in the loan sanction terms, however, no such loans have been issued.
Interest rates would be intimated to the customers at the time of sanction / availing of the loan.
The interest shall be deemed payable immediately on the due date as communicated and no grace period for payment of interest is allowed. Besides this rate of interest, the Company may levy additional/penal charges for delay or default in making payments of any dues.
The changes in the interest rates and related charges would be prospective in nature and intimation of change of rate of interest or other related charges would be given to customers in a mode and manner deemed fit in accordance with applicable laws and regulations.
Penal charges in loan accounts
The Company shall ensure that Penalty, if charged, shall be for non-compliance of material terms and conditions of the loan agreements by customers. It shall not be levied in the form of ‘Penal Interest’ that is added to the rate of interest being levied on the loans and advances.
There shall be no capitalization of Penal Charges (i.e. no further interest computed on such charges). However, this will not affect the normal procedures for compounding of interest in the loan account.
The Company shall ensure that the quantum of Penal Charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan agreement without being discriminatory with a particular loan / loan product. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions.
Event of default which will attract Penal Charges:
- When the repayment of loan amount becomes overdue.
- Breaches to any other important or material terms and conditions of the loan contract. However, materiality would be determined by the Company as to what constitutes material breach.
Penal Charges:
- The Penal Charges will be levied at the rate of 0.50% per day of outstanding principal loan amount in addition to the normal rate of interest applicable on the loan.
- The Company shall display the quantum and reason for penal charges to the customers in the loan agreement and / Key Fact Statement (KFS) as applicable.
- The applicable penal charges, as updated from time to time, shall be displayed on the Company's website.
- The Company shall ensure that the applicable penal charges are clearly communicated to the borrowers, whenever reminders for non-compliance of loan terms are sent to borrowers.
- Any instance of levy of penal charges and the reason therefore shall also be appropriately communicated to the borrowers.
Other fees and charges
Besides interest, other financial charges like processing fees, origination fees, prepayment, foreclosure charges, recovery/collection charges, re-scheduling charges, penal charges on late repayment of a loan, payment gateway charges, cheque swap charges, security swap charges, charges for issue of statement account, customer care, credit assessment, ECS/ Direct Debit/ NACH mandate registration/ lodgment/ handling or for any other service provided by the Company or cost incurred by the Company for the provision of services related to the loan granted to the customers or as per schedule of charges communicated by the company from time to time or cost towards an expense incurred by the Company for the recovery of the loan. Besides these charges, service tax and other cesses, if any, would be collected at applicable rates from time to time. Any revision in these charges would be prospective in effect with due communication to customers.
These fees and charges may vary based on the loan type, exposure limit, expenses incurred, and customer segment and generally represent the costs incurred in rendering the services to the customer. All such fees and charges shall be clearly communicated to the customer by way of a sanction letter, KFS, financing documents and the schedule of charges notified by the Company from time to time.
The Company may also levy and collect charges and penal charges, for delay or late payment of loan instalment and other dues to the Company and bouncing of ECS/ Direct Debit/ NACH.
The Company may also levy and collect charges for loan documentation, portfolio monitoring, recovery of loan or for other facilities and services provided based on market standards. The details of the charges will be as per the schedule of charges.
Loan Cancellation
If a borrower wishes to exit the loan after it has been sanctioned, he/she can do so within 3 days of loan disbursement which shall be the free look up period. The principal amount and other applicable charges will have to be paid. However, no penalty shall be charged during such period.
Wavier/Refund
No claims for refund or waiver of charges / penal charges / additional charges for loan documentation, portfolio monitoring, recovery of loan or for other shall normally be entertained by DIPL and it is at the sole discretion of the Company to deal with such requests, if any.
Foreclosure and Part Prepayment
- Foreclosure of the facility shall not attract any charges; however, the borrower shall be liable to pay interest at the contracted rate up to the date of final repayment.
- Part pre-payment of the facility is strictly not permitted.
Communication To Customer
The Company shall communicate the effective rate of interest - to customers at the time of sanction / availing of the loan through the acceptable mode of communication. Interest Rate Policy would be uploaded on the website of the company and any change therein would be uploaded on the web site of the Company.
Changes in the rates and charges for existing customers, if any, would be communicated to them through various modes of communication such as on the website, digital platform and/or via email, letters, SMS, etc. However, the company would ensure that there is no change during the tenure of the loan for such loans which had already been contracted with customers
Amendments To This Policy
The Board of directors is authorized to make appropriate changes to this Policy taking into account changes in the money market scenario in the Country which includes the upward / downward revision in interest rates applicable to various loan products and the relevant charges applicable for such loan products.
KYC/AML POLICY
DSG INVESTMENTS PRIVATE LIMITED
The Policy was approved by the Board of Directors in its meeting held on 19th March 2026
Documents Details
1. Preamble
In line with the Reserve Bank of India's (RBI) guidelines on Know Your Customer (KYC) and Anti-Money Laundering (AML) measures, DSG Investments Private Ltd ("Company") is committed to preventing its services from being misused for money laundering or financing terrorism activities. This policy outlines the comprehensive framework for customer identification and transaction monitoring, as required by the RBI and relevant regulations.
2. Objectives, Scope, and Application of the Policy
The primary objectives of this Policy are:
- To prevent the Company from being used for illegal money laundering or financing terrorism.
- To establish clear criteria for the acceptance of MSME B2B merchant customers.
- To define procedures for verifying customer identities and monitoring transactions.
- To outline measures for due diligence and reporting suspicious transactions.
3. Definition of Customer
For the purposes of this policy, a ‘Customer’ refers to any individual or entity engaged in business with the Company, as defined by the RBI's KYC norms and AML guidelines.
4. Customer Acceptance Policy (“CAP”)
The Customer Acceptance Policy mandates that all potential and existing customers must complete the DSG Investments Application Form, providing necessary information and supporting documents. This process is essential for customer identification and compliance with KYC requirements.
5. Customer Identification Procedures (“CIP”)
Customer identification involves verifying the identity of customers through reliable, independent sources. DSG Investments will gather sufficient information to verify the identity of each new customer, including details about the business’s owners and management. This process will be adapted based on the perceived risk level.
6. KYC Document Requirements
Customers must submit the following documents:
- Identity Proof: Aadhar Card (mandatory), Voter ID (mandatory)
- Address Proof: Electricity Bill (not older than 3 months), Water Bill, Aadhar Card, Passport, Bank Passbook, Ration Card, Sarpanch Letter, or any other government-issued proof of identity.
- Banking Details: Bank account details of the applicant or co-applicant, which should be active and show at least one financial transaction (deposit or withdrawal) in the past 3 months.
7. Monitoring and Reporting of Transactions
Transaction monitoring will be conducted based on the risk profile of each account. DSG Investments will review customer transactions to identify unusual patterns, especially large or complex transactions without apparent economic or lawful purpose. The risk categorization of loan assets will be reviewed at least every 6 months. Customer identification data, including photographs, will be updated regularly, with a minimum review period of five years for low-risk customers and two years for high-risk customers.
To comply with the Prevention of Money Laundering Act, 2002, Mr. Anil Gupta, Director, is designated as the Company’s "Designated Director" for KYC/AML. Mr. Deepak Samuel, Director of the company will serve as the Principal Officer responsible for monitoring and reporting KYC/AML activities.
8. Principal Officers for KYC/AML/CFT
The Principal Officer(s) will operate independently and report directly to the Designated Director. Their responsibilities include overseeing compliance with KYC/AML/CFT regulations and ensuring adherence to the Prevention of Money Laundering Act, 2002.
9. Risk Management
All customers are subject to this policy, with exceptions only for statutory bodies such as RBI-registered banks or government entities. Customers will be categorized based on risk levels into:
- Category A: Low Risk
- Category B: Medium Risk
- Category C: High Risk
No exemptions will be made from DSG Investments’’ KYC procedures regardless of the customer’s status or relationship with the Company. Risk categorization will be adjusted based on risk assessments.
10. Periodic Reporting
The Principal Officer may present periodic reports to the Board of Directors for high-risk cases requiring further assessment. An independent consultant with relevant expertise may be consulted if necessary. All risk-related discussions will be confidential and not disclosed to third parties.
11. KYC for Existing Accounts
KYC guidelines apply to new customers and are also enforced for existing customers based on materiality and risk. Continuous monitoring of existing accounts will detect any unusual activity. Information collected from customers will be securely retained and treated as confidential, with no use for cross-selling or other unauthorized purposes.
12. Employee Training
DSG Investments will maintain an ongoing training program to ensure employees are well-versed in KYC/AML/CFT procedures. Training will be tailored for frontline staff, compliance staff, and those handling new customers, emphasizing the importance of understanding and implementing KYC policies.
13. Policy Updates
The Board of Directors is authorized to amend or modify this KYC/AML/CFT Policy as needed to align with RBI regulations and other statutory requirements.
PRIVACY POLICY
DSG INVESTMENTS PRIVATE LIMITED
Other Particulars
PRIVACY POLICY
DSG Investments Private Limited (hereinafter referred to as the “Company”) is committed to protecting the privacy and confidentiality of personal information and sensitive personal data or information of its customers, borrowers, users, and other stakeholders. The Company recognises the importance of safeguarding personal data and adopts appropriate measures to ensure its security, confidentiality, and lawful use.
This Privacy Policy has been framed in accordance with the provisions of the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, applicable provisions of the Digital Personal Data Protection Act, 2023 (to the extent applicable), and the guidelines, directions, and circulars issued by the Reserve Bank of India (“RBI”) from time to time, including the Fair Practices Code and RBI Digital Lending Guidelines.
1. DEFINITIONS
For the purpose of this Policy:
- “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying such person.
- “Sensitive Personal Data or Information” shall have the meaning assigned to it under applicable law and shall form part of Personal Information for the purposes of this Policy.
- “Third Party” means any service provider, lending service provider (LSP), consultant, contractor, or agent engaged by the Company for providing operational, technological, or other support services.
2. PURPOSE OF COLLECTION OF PERSONAL INFORMATION
The Company may collect, store, process, and use personal information strictly for legitimate business and regulatory purposes, including but not limited to:
- Verification of identity and completion of Know Your Customer (KYC) requirements;
- Processing, sanctioning, servicing, and recovery of loans;
- Responding to customer requests, queries, and grievances;
- Credit appraisal, underwriting, and risk assessment;
- Fraud detection, prevention, and regulatory compliance;
- Improvement of products, services, and customer experience; and
- Compliance with applicable laws, RBI guidelines, and directions issued by statutory or regulatory authorities.
The Company shall collect only such data that is necessary, relevant, and proportionate to the stated purpose and shall not collect or retain data beyond such purpose.
3. COLLECTION OF PERSONAL INFORMATION
The Company and its authorised Third Parties may collect personal information directly from customers or through digital platforms, applications, websites, or other lawful means during the course of providing financial services.
Personal information collected may include, inter alia, name, date of birth, contact details, address, occupation, income details, bank account details, identity and address proof documents, and such other information as may be required for regulatory, credit, or operational purposes.
The Policy represents the minimum standards that Company has set with respect to data privacy. It aligns with (and in some cases exceeds) the requirements of applicable laws and regulations (i.e. Indian IT Act of 2000, IT Amendment Act of 2008, IT Rules of 2011 and Aadhaar Act 2016).
Sensitive Personal Data or Information may include passwords, financial information, biometric or authentication-related information, as may be required under applicable law.
4. DIGITAL APPLICATION AND DEVICE PERMISSIONS
Where the Company offers digital lending or related services through mobile or web-based applications, access to device resources such as camera, location, storage, SMS, or contacts shall be obtained only with the explicit, informed, granular, and revocable consent of the user.
- Camera and storage permissions may be used solely for uploading KYC and other required documents.
- Location data may be collected for address verification, fraud prevention, and regulatory compliance.
- Access to financial transactional SMS, if permitted, shall be limited strictly to credit assessment, cash-flow analysis, and fraud prevention.
The Company does not access or store personal, non-financial SMS, media files, or unrelated personal content. Denial or withdrawal of optional permissions shall not result in automatic rejection of loan applications, unless such data is essential for regulatory or credit assessment purposes, which shall be clearly disclosed to the customer.
5. USE OF COOKIES AND WEB TECHNOLOGIES
The Company’s websites and digital platforms may use cookies and similar technologies to enhance user experience, analyse usage patterns, and improve services. Users may manage cookie preferences through browser settings. Disabling cookies may affect certain website functionalities.
6. DISCLOSURE AND SHARING OF PERSONAL INFORMATION
6.1 Internal Use
Personal information may be accessed by authorised employees of the Company strictly on a need-to-know basis for legitimate business purposes.
6.2 Third Parties and Lending Service Providers
The Company may share personal information with Third Parties, including Lending Service Providers, strictly for purposes necessary to provide services to customers. The Company remains fully responsible for the actions of such Third Parties and ensures that appropriate contractual safeguards, confidentiality obligations, and security standards are in place in accordance with RBI guidelines.
6.3 Regulatory and Legal Disclosures
Personal information may be disclosed to government authorities, regulators, or law enforcement agencies as required under applicable law or RBI directions.
The Company does not sell or disclose personal information to unauthorised third parties.
7. DATA STORAGE AND RETENTION
All personal and financial data of customers shall be stored on servers located within India, unless otherwise permitted under applicable law or RBI directions.
Personal information shall be retained only for such period as is necessary to fulfil the stated purpose or as required under applicable laws and regulatory guidelines, after which it shall be securely deleted or anonymised.
8. SECURITY PRACTICES
The Company adopts reasonable security practices and procedures, including administrative, technical, and physical safeguards, aligned with recognised information security standards, to protect personal information against unauthorised access, disclosure, alteration, or destruction.
9. CUSTOMER RIGHTS AND CHOICE
Customers may access, review, and request correction of their personal information by contacting the Company. Customers may also withdraw consent for the use of personal information, subject to applicable legal and regulatory requirements.
Customers have the option to opt out of non-essential promotional communications without affecting the core financial services provided by the Company.
10. GRIEVANCE REDRESSAL
Any grievance or concern relating to privacy or protection of personal information may be addressed to the Grievance Officer:
- Name: Mr. Mahesh Chaudhary
- Contact Number: 9315206327
- Email: Nodal@dsginvestments.com
- Working Days: Monday to Saturday
- Working Hours: 9 a.m. to 6 p.m.
The Company shall endeavour to resolve grievances within 30 days from the date of receipt. If a customer is not satisfied with the resolution, the grievance may be escalated in accordance with the RBI Ombudsman framework, as applicable.
11. REVIEW AND AMENDMENT
This Privacy Policy shall be reviewed periodically and updated as necessary to reflect changes in laws, regulations, or business practices. Any material changes shall be appropriately communicated.
This Policy is approved by the Board of Directors or an authorised committee thereof and shall be available on the Company’s website and digital platforms.
RECOVERY AND COLLECTION POLICY
DSG INVESTMENTS PRIVATE LIMITED
(This policy was reviewed and approved by the Board of Directors in the Board Meeting held on …………….)
RECOVERY AND COLLECTION POLICY
1. PREAMBLE
DSG Investments Private Limited ("the Company"), a Non-Banking Financial Company (NBFC – Base Layer) registered with the Reserve Bank of India (RBI), is committed to adopting fair, transparent, ethical, and legally compliant recovery and collection practices. This Recovery and Collection Policy ("Policy") is framed in alignment with:
- RBI Act, 1934 and applicable RBI Master Directions for NBFCs
- RBI Fair Practices Code Guidelines
- RBI Digital Lending Guidelines and outsourcing norms
This Policy governs all recovery and collection activities of the Company and forms an integral part of the overall credit governance framework, ensuring consistency across loan origination, servicing, recovery, settlement, and write-off stages.
2. OBJECTIVES OF THE POLICY
The objectives of this Policy are to:
- Establish a structured, transparent, and RBI-compliant recovery framework
- Ensure dignified, non-coercive, and borrower-friendly recovery practices
- Protect borrower rights, privacy, and confidentiality
- Minimize delinquencies and credit losses through timely intervention
- Clearly define escalation, settlement, and write-off processes
- Ensure accountability of employees and outsourced recovery agents
3. APPLICABILITY
This Policy shall apply to:
- loan products offered by the Company
- All recovery actions undertaken by in-house teams or outsourced agencies
- All employees, officers, representatives, and third-party service providers engaged in recovery and collection
4. GUIDING PRINCIPLES
The Company shall adhere to the following principles:
- Fairness and Respect: Borrowers shall be treated with dignity and respect at all times
- Transparency: Clear communication of dues, charges, consequences, and options
- Non-Coercion: No harassment, intimidation, abuse, or force
- Confidentiality: Borrower data shall be protected and used strictly for recovery purposes
- Legal Compliance: All actions shall be within the framework of applicable laws and RBI directions
5. RECOVERY GOVERNANCE STRUCTURE
- Overall oversight shall vest with the Board of Directors
- Day-to-day recovery operations shall be managed by the Collections Department
- Legal actions shall be routed through the Legal Department
- Settlement and write-off decisions shall be governed by the Settlement & Write-off Policy
6. RECOVERY MECHANISM
6.1 Product-Specific Alignment with Credit Policy
The recovery and collection framework for payday loans shall be strictly governed by the Company’s approved Credit Policy, particularly:
- Section 6: Collection Risk Strategy
- Section 6.1: Delinquency Management Framework
- Section 6.2: Escalation & Write-Off Protocols
Given that Payday Loans are short-tenure, bullet repayment loans with relatively higher risk pricing, the recovery strategy emphasizes early intervention, structured escalation, and time-bound resolution, while ensuring full compliance with RBI Fair Practices Code and borrower protection norms.
6.2 Delinquency Identification and Account Classification
- An account shall be treated as overdue if the full repayment amount (principal, interest, and applicable charges) is not received on the due date.
- Days Past Due (DPD) shall be computed from the day immediately following the due date.
- All recovery actions shall be mapped to DPD buckets as defined below.
6.3 DPD-Based Recovery and Escalation Framework
6.4 Telephonic and Digital Recovery Process
- Telephonic recovery shall be conducted only by trained personnel using approved scripts.
- Contacts shall be made only between 8:00 AM and 7:00 PM
- Digital communication shall comply with RBI Digital Lending Guidelines
- No access shall be taken to borrower contacts, gallery, or personal data.
- Frequency of communication shall be reasonable and proportionate to the DPD status.
6.5 Legal Recovery Actions
- Legal action shall be considered only after reasonable opportunities for repayment have been provided.
- Legal measures may include issuance of demand notices, arbitration, civil proceedings, or other remedies as permitted by law.
- All legal actions shall be approved by the designated authority as per the internal approval matrix.
6.6 Settlement, Restructuring, and Compromise
- Settlement or restructuring may be considered on a case-to-case basis, based on borrower profile, repayment intent, and recovery potential.
- Any compromise or waiver shall require prior internal approvals.
- Settlement terms shall be documented in writing and communicated transparently to the borrower.
6.7 Write-Off Policy
- Accounts exceeding 30 DPD and assessed as uncollectible may be considered for write-off for accounting purposes.
- Write-off shall not extinguish the borrower’s liability.
- Post write-off recovery efforts may continue through legal means or empaneled recovery agencies.
6.8 Recovery Agency Management
- Recovery agencies shall be appointed after due diligence and RBI-compliant agreements.
- Agencies shall follow this Policy, Fair Practices Code, and RBI Code of Conduct.
- The Company shall remain fully responsible for the acts of its recovery agents.
6.9 Monitoring, MIS and Governance
Recovery performance shall be monitored through MIS aligned with the Credit Policy, including:
- DPD bucket movement
- Bounce trends
- Risk-grade-wise delinquency
- City-wise and device-wise delinquency trends
Deviations from approved recovery strategy shall be escalated to senior management.
7. CONDUCT OF RECOVERY STAFF AND AGENTS
Recovery staff and agents shall:
- Carry valid authorization and identity proof
- Clearly identify themselves and the Company
- Be courteous, professional, and non-threatening
- Not use abusive language or make false representations
- Not threaten arrest, imprisonment, or legal action without basis
- Not contact borrowers’ relatives, friends, or employers except as legally permitted
8. FIELD VISITS
- Field visits shall be conducted only when necessary
- Visits shall respect borrower privacy and social standing
- No public humiliation or display of borrower information
- Female borrowers shall not be visited by male agents alone
9. DIGITAL AND TELEPHONIC COLLECTION
- Digital communication shall comply with RBI Digital Lending Guidelines
- No unauthorized access to borrower’s contacts, gallery, or personal data
- All digital communications shall be auditable and traceable
10. LEGAL RECOVERY ACTIONS
- Legal recovery actions shall be initiated strictly as a measure of last resort, after exhaustion of amicable and operational recovery efforts.
- All legal actions shall be consistent with the loan agreement, Fair Practices Code, and applicable laws.
- Borrowers shall be given reasonable notice and opportunity before initiation of legal proceedings.
- Legal recovery shall be approved as per the internal authority matrix and documented appropriately.
11. SETTLEMENT, RESTRUCTURING AND WAIVER
- Settlement, compromise, or restructuring shall be governed by the Company’s Comprehensive Policy on Settlements & Write-offs.
- Settlements may be considered for accounts with DPD > 30 days, NPAs, written-off accounts, or cases involving genuine borrower hardship.
- No settlement or waiver shall be granted arbitrarily or as a recovery shortcut.
- Settlement approvals shall be strictly as per the Delegation of Authority defined in the Settlement & Write-off Policy and shall be one level higher than the loan sanctioning authority.
- Borrowers shall be informed about the credit bureau impact of settlement or write-off prior to acceptance.
- All settlement terms shall be communicated in writing, including payable amount, waived amount, timelines, and consequences of non-compliance.
11A. WRITE-OFF
- Write-offs shall be technical write-offs only and shall not extinguish the borrower’s liability.
- Written-off accounts shall continue to be pursued for recovery, settlement, or legal action.
- Re-aging of accounts is strictly prohibited.
- Accounting treatment and provisioning shall be in accordance with RBI norms and the Settlement & Write-off Policy.
- The Company may consider restructuring, rescheduling, or settlement on a case-to-case basis
- Any waiver or compromise shall follow internal approval
12. CONFIDENTIALITY AND DATA PRIVACY
- All borrower information, records, call recordings, field visit notes, and recovery-related communications shall be treated as strictly confidential.
- Access to borrower data shall be restricted to authorised personnel strictly on a need-to-know basis for recovery and compliance purposes.
- The Company shall comply with RBI Digital Lending Guidelines, Information Technology Act, 2000, and applicable data protection and privacy laws while handling borrower data.
- Recovery agents shall not copy, store, misuse, or share borrower data in any physical or electronic form.
- Any data breach, misuse, or unauthorised disclosure shall attract strict disciplinary action, termination of contracts, and legal proceedings, as applicable.
13. BORROWER COMMUNICATION AND DISCLOSURES
All recovery-related communications shall be factual, transparent, non-misleading, and respectful.
Borrowers shall be clearly informed of:
- Total outstanding amount with breakup of principal, interest, penal charges, and other dues
- Consequences of continued default
- Available repayment, restructuring, or settlement options, where applicable
Any levy of penal charges or overdue charges shall be communicated along with the specific reason for such levy.
Communications shall be made, as far as practicable, in a language understood by the borrower.
14. GRIEVANCE REDRESSAL MECHANISM
- The Company shall maintain a robust grievance redressal mechanism for complaints relating to recovery and collection practices.
- Borrowers may lodge complaints through the channels specified in the Fair Practices Code, including email, written communication, or customer support channels.
- Complaints alleging harassment, coercion, misrepresentation, or misconduct by employees or recovery agents shall be investigated on priority.
- All grievances shall be resolved within the timelines prescribed by RBI.
- Where the borrower is not satisfied with the resolution, escalation to the RBI Ombudsman / Department of Supervision shall be facilitated in accordance with applicable guidelines.
15. TRAINING, SUPERVISION AND AUDIT
- The Company shall conduct regular training programmes for employees and recovery agents covering RBI recovery guidelines, Fair Practices Code, borrower rights, and ethical conduct.
- Telephonic calls, digital communications, and field visits may be recorded, monitored, and audited for quality, compliance, and behavioural standards.
- Internal audit and compliance teams shall periodically review recovery operations, outsourced agencies, documentation, and adherence to this Policy.
- Observations and non-compliances identified during audits shall be promptly addressed and reported to senior management.
16. DISCIPLINARY ACTION AND ZERO-TOLERANCE POLICY
- The Company follows a zero-tolerance approach towards harassment, coercion, intimidation, abuse, or any unethical recovery practice.
- Employees violating this Policy may face disciplinary action including warning, suspension, recovery-linked penalties, or termination.
- Recovery agencies found in violation shall be immediately suspended or terminated and may be permanently blacklisted.
- Serious violations may be reported to regulatory authorities or law enforcement agencies, wherever required.
17. REVIEW AND AMENDMENT
- This Policy shall be reviewed at least annually by the Board of Directors or earlier if required due to regulatory changes, RBI circulars, or business needs.
- Any amendment to this Policy shall require prior approval of the Board of Directors.
18. BOARD APPROVAL AND EFFECTIVE DATE
This Recovery and Collection Policy has been approved by the Board of Directors of DSG Investments Private Limited at its meeting held on _________ and shall be effective from the same day.
RISK MANAGEMENT POLICY
DSG INVESTMENTS PRIVATE LIMITED
This policy was updated and approved by the Board of Directors in its meeting held on 19th March, 2026.
Documents Details
“RISK MANAGEMENT POLICY”
TABLE OF CONTENTS:
Definition
This Risk Management Policy outlines the framework for managing risks arising from the mismatch between assets and liabilities of “DSG Investments Private Limited” and its balance sheet. It is designed to support sustained growth, profitability, and solvency by encompassing strategic goals, liquidity risk, interest rate risk, and market risk management. This policy includes a set of actions and procedures to control financial risks and ensure the safety and soundness of “DSG Investments Private Limited”, balancing the need for consistent earnings with growth and service objectives.
Purpose
The purpose of this policy is to:
- Define the Scope and Responsibilities of the Risk Management Committee and Asset/Liability Management Committee (ALCO), which is formally overseen by the Finance & Audit Sub-Committee.
- Measure and manage various risks consistently.
- Establish guidelines to comply with applicable regulatory rules and statutes.
- Align with other policies (investments, lending, operations, etc.) to form a cohesive risk management approach.
Responsibility
The Board of Directors holds the ultimate responsibility for effective risk and asset/liability management. Authority for formulation, revision, and administration of this policy is delegated to the Risk Management Committee. Responsibilities of the Risk Management Committee include:
- Overseeing balance sheet planning from a risk-return perspective, including interest rate and liquidity risks.
- Developing and implementing asset/liability management processes and procedures.
- Establishing and maintaining monitoring and reporting systems.
- Developing asset/liability strategies and tactics.
- Submitting quarterly written reports to the Board.
- Ensuring the management information system provides timely and relevant data for effective asset/liability management.
Implementation
Successful implementation requires strong commitment from senior management to integrate operations and strategic decision-making with risk management. The Board is responsible for establishing, reviewing, and ensuring compliance with this policy, while the Risk Management Committee will:
- Review the policy annually with management.
- Review funds management activities quarterly, including:
- Rate sensitivity analysis summary.
- Liquidity position analysis.
- Financial results comparison with budget and previous periods.
- Adherence to risk parameters and tolerance limits.
Primary Objectives
The primary objectives of this policy are to:
- Achieve consistent earnings and maintain a Net Capital to Assets ratio within acceptable levels.
- Manage four main risks:
- Interest Rate Risk (IRR): Risk that changes in prevailing interest rates will adversely affect the company's earnings, including interest income and expenses.
- Price Risk (Market Risk): Risk that changes in interest rates and market factors will impact the value of assets, liabilities, and capital.
- Liquidity Risk: Risk of insufficient cash flow to meet obligations or capitalize on opportunities.
- Credit Risk: Risk of loan defaults or investment losses affecting capital and asset quality.
Scope
The Risk Management Function will cover:
- Liquidity Risk Management
- Currency Risk Management (if applicable)
- Interest Rate Risk Management
- Funding and Capital Planning
- Profit Planning and Growth Projection
Liquidity Risk Management
7.1 Effective liquidity management is crucial to ensure “DSG Investments Private Limited” can meet its obligations as they arise. Liquidity needs are assessed using a maturity ladder and cumulative surplus/deficit calculations based on the RBI's prescribed format.
7.2 The Maturity Profile will be categorized into time buckets as follows:
- 1 day to 30/31 days
- Over 1 month and up to 2 months
- Over 2 months and up to 3 months
- Over 3 months and up to 6 months
- Over 6 months and up to 1 year
- Over 1 year and up to 3 years
- Over 3 years and up to 5 years
- Over 5 years
7.3 The investment portfolio policy, recorded and approved by the Board, will be communicated to the RBI's Regional Office as required.
7.4 The Statement of Structural Liquidity will account for all cash inflows and outflows in the maturity ladder, considering assumptions based on asset-liability profiles and future strategies.
7.5 Short-term liquidity profiles will be monitored dynamically from 1 day to 6 months, using business projections and commitments.
8. Currency Risk
Currently, “DSG Investments” does not have currency risk due to the absence of currency-related transactions. Should such transactions occur in the future, this policy will be updated to incorporate measures for managing currency risk.
Interest Rate Risk
Interest rate risk affects “DSG Investments” financial condition through changes in market interest rates. This risk impacts earnings (Net Interest Income) and long-term equity value (Market Value of Equity).
Earnings Perspective: Measured through Net Interest Income (NII) or Net Interest Margin (NIM). Techniques such as Gap Analysis, Duration Gap Analysis, Simulation, and Value at Risk will be used for measurement and management.
Economic Value Perspective: Assesses changes in the economic value of assets, liabilities, and off-balance sheet positions due to interest rate fluctuations.
This policy aims to address interest rate risk through both traditional and modern techniques, ensuring effective management as “DSG Investments” develops its expertise and systems.
Note: This policy should be reviewed annually and updated as needed to reflect changes in the regulatory environment or “DSG Investments” business model.
