POLICIES
One Capital Policy Page
One Capital Limited believes in the conduct of the affairs of its constituents in a fair and
transparent manner by adopting highest standards of professionalism, honesty, integrity and
ethical behaviour. T owards this end, One Capital has formulated the One Capital Code of
Conduct ("the Code"), which lays down the principles and standards that should govern the
actions of One Capital and their employees. Any actual or potential violation of the Code,
whosoever insignificant or perceived as such, would be a matter of serious concern for the
Company. The role of the employees in pointing out such violations of the Code cannot be
undermined.
Clause 49 of the Listing Agreement inter alia, provides for a non-mandatory requirement for all
listed companies to establish a mechanism called Whistle Blower Policy for employees to report
to the management instances of unethical behaviour, actual or suspected, fraud or violation of
the Company’s code of conduct or ethics policy.
Accordingly, this Whistle Blower Policy ("the Policy") has been formulated with a view to provide
a mechanism for employees of the Company to approach the Audit Committee of the Company.
Definitions:
The definitions of some of the key terms used in this Policy are given below. Capitalised terms
not defined herein shall have the meaning assigned to them under the Code.
"Audit Committee" means the Audit Committee constituted by the Board of Directors of the
Company in accordance with Section 177 of the Companies Act, 2013 and read with Clause 49
of the Listing Agreement with the Stock Exchanges.
"Employee" means every employee of the Company (whether working in India or abroad),
including the Directors in the employment of the Company.
"Code" means the One Capital Code of Conduct.
"Investigators" or “the Investigator” mean those person(s) authorised, appointed, consulted or
approached by the Audit Committee and includes the auditors of the Company and the police.
"Protected Disclosure" means any communication made in good faith that discloses or
demonstrates information that may evidence unethical or improper activity.
"One Capital" or “the Company” means One Capital.
"Subject" means a person against or in relation to whom a Protected Disclosure has been made
or evidence gathered during the course of an investigation.
"Whistle Blower" means an Employee making a Protected Disclosure under this Policy.Scope:
This Policy is an extension of the One Capital Code of Conduct. The Whistle Blower’s role is
that of a reporting party with reliable information. They are not required or expected to act as
investigators or finders of facts, nor would they determine the appropriate corrective or remedial
action that may be warranted in a given case.
Whistle Blowers should not act on their own in conducting any investigative activities, nor do
they have a right to participate in any investigative activities other than as requested by the
Investigator or the Audit Committee or the Investigators.
Protected Disclosure will be appropriately dealt with by the Audit Committee.
Disqualifications:
While it will be ensured that genuine Whistle Blowers are accorded complete protection from
any kind of unfair treatment as herein set out, any abuse of this protection will warrant
disciplinary action.
Protection under this Policy would not mean protection from disciplinary action arising out of
false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a
mala fide intention.
Whistle Blowers, who make three or more Protected Disclosures, which have been
subsequently found to be mala fide, frivolous, baseless, malicious, or reported otherwise than in
good faith, will be disqualified from reporting further Protected Disclosures under this Policy. In
respect of such Whistle Blowers, the Company/ Audit Committee would reserve its right to take/
recommend appropriate disciplinary action.
Protection:
No unfair treatment will be meted out to a Whistle Blower by virtue of his/ her having reported a
Protected Disclosure under this Policy. The Company, as a policy, condemns any kind of
discrimination, harassment, victimization or any other unfair employment practice being adopted
against Whistle Blowers. Complete protection will, therefore, be given to Whistle Blowers
against any unfair practice like retaliation, threat or intimidation of termination/ suspension of
service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any
direct or indirect use of authority to obstruct the Whistle Blowers right to continue to perform his
duties/functions including making further Protected Disclosure. The Company will take steps to
minimize difficulties, which the Whistle Blower may experience as a result of making the
Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or
disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice
about the procedure, etc.
Vigil Mechanism Bullets The identity of the Whistle Blower shall be kept confidential to the
extent possible and permitted under law. Whistle Blowers are cautioned that their identity maybecome known for reasons outside the control of the Investigator/ Audit Committee (e.g. during
investigations carried out by Investigators).
Vigil Mechanism Bullets Any other Employee assisting in the said investigation shall also be
protected to the same extent as the Whistle Blower.
Amendment:
The Company reserves its right to amend or modify this Policy in whole or in part, at any time
without assigning any reason whatsoever. However, no such amendment or modification will be
binding on the Employees unless the same is notified to the Employees in writing.
Fair Practices:
This Fair Practices Code has been framed with a view to providing to all its stake holders,
especially customers an effective overview of the practices followed by the Company while
offering its products and services. This Fair Practices Code has been prepared taking into
account the “Guidelines on Fair Practices Code for NBFCs” issued by the Reserve Bank of India
and is updated from time to time and aims to enable customers to take informed decisions in
respect of the facilities and services offered by the Company.
This Code has been drawn aiming to:
● Adopt the best practices followed by entities in the financial and similar service sector
while dealing with customers.
● Provide to the customers effective overview of practices followed by the Company in
respect of financial facilities and services offered by the Company to its Customers
● Enable customers to take informed decision about the financial facilities and services
offered by the Company.
● Promote good, fair, transparent and legally tenable practices by setting minimum
standards in dealings with customers.
● Enable customers to have better understanding of what they can reasonably expect of
the services offered by the Company.
● Reckon with market forces, through competition and strive to achieve higher operating
standards.
● Foster fair and cordial relationship between the customers and the Company.
The Fair Practices Code adopted by the Company covers the following areas.
● Applications for loans and their processing.
● Loan appraisal and terms/conditions.
● Disbursement of loans, including changes in terms and conditions.
● Disclosures about interest rates and approach for gradation of risk.
● Policy on KYC, Appraisal, insurance, storage of securities, Auction etc.
● Confidentiality
● Grievance redressal mechanism
● General Provisions
Decelerations & Commitments:
● The Company undertakes to abide by all applicable laws, regulations and guidelines
passed/issued by the Regulators(Reserve Bank of India, SEBI, IRDA etc) and other
competent authorities such as Government, Local Authority etc.
● The Company commits itself to full customer satisfaction through efficient, professional
and courteous services across all its offices.
● The Company shall consistently strive to meet with and improve upon the internally set
benchmarks and practices and be ahead of the standards prevalent in the industry.
● The Company undertakes not discriminate customers on grounds of religion, caste,
gender or language.
● The Company will provide clear and full information about its products and services to its
customers/prospective customers and will not resort to any misleading or potentially
misguiding advertisement or publicity.
● The Company undertakes to desist from introducing any products/services having
elements of hidden charges or lack of transparency.
● The Company undertakes not to take advantage of any unintentional or clerical error
made by the customer while transacting business.
● The Company shall display the FPC on its website and also make available to the
Customer on request, a copy of the FPC on demand.
Applications for loans and their processing:
● All communications to the borrower shall be either in English or in vernacular language
or in a language as understood by the borrower
● Loan application forms issued by the Company shall include necessary information
affecting the interests of the borrower, which will enable him to take an informed decision
by comparing the terms and conditions with that of other similar NBFCs, and shall also
indicate the documents required to be executed/submitted by the borrower.
● If any additional documents/informations are required from the Customer, the same shall
be communicated to the Customer immediately.
● In case of all loans, other than gold loans which are sanctioned on the same day of
receipt of the application, an acknowledgement will be given to the applicant, also
indicating the probable date by which a decision regarding sanction of the loan will be
intimated to him. The acknowledgement can also be given in the form of a tear off from
the application form or through an SMS message.
Policy on KYC, Appraisal, Insurance, storage of securities, auction etc
The Company shall put in place a policy duly approved by the Board covering the following
aspects:
● Adequate steps to ensure that the KYC guidelines stipulated by RBI are complied with
and to ensure that adequate due diligence is carried out on the customer before
extending any loan.
● Proper appraisal procedure for assessing the value and purity of the jewellery accepted
as collateral security.
● Declaration shall be obtained from the borrower confirming ownership of gold jewellery.
● All branches shall have proper storage facility of either Strong Rooms or Safes
conforming to BIS Standards of reputed make to store the jewellery in safe custody. The
sets of keys to the strong room/safe shall be held separately by two officials and the
operations thereof shall be done jointly. The staff shall be imparted training on a
continuous basis to ensure that the guidelines covering security issues are strictly
adhered to. The gold items shall be periodically inspected by the internal auditors to
ensure quality, quantity and proper storage
● The jewellery accepted as collateral security shall be adequately and appropriately
insured.
● The auction procedure in case of non – repayment shall be transparent. Prior notice to
the borrower shall be given before the auction and there shall not be any conflict of
interest. The auction process shall ensure that an arm’s length relationship in all
transactions during the auction is maintained including with group companies and
related entities. The details regarding procedure for auction shall be disclosed in the loan
document for availing the loan. The auction will be only through auctioneers approved by
the Board and the Company shall not participate in the auction. The auction shall be
announced to the public by issuing advertisements in at least two newspapers, one in
vernacular language and the other in a national daily newspaper.
● Any fraud in the functioning of the Company shall be enquired into by the appropriate
authority and suitable punitive measure shall be taken by the appropriate disciplinary
authority. Any review of the decision of the disciplinary authority shall be carried out by
the Managing Director
INTEREST RATE POLICY
This document prescribes the guiding principles of fixing interest rates on gold loans and other
loan schemes of One Capital, as enumerated below.
The rate of interest on gold loan schemes is fixed by taking into account various factors such as
the cost of funds, overhead costs, fair return on capital employed, market conditions, and
guidelines of the Reserve Bank of India regarding the Fair Practices Code.
The Board of Directors of the Company or a Committee drawing authority from the Board, while
fixing interest rates on Gold Loan Schemes, shall be guided by this policy document for Interest
Rate Fixation.
In addition to the cost factors set out hereunder, the Board or the Committee shall be guided by
market conditions and any relevant rules and regulations prescribed by the Reserve Bank of
India or such other competent authority from time to time.Interest charged under various Gold Loan Schemes shall have the following components:
• Basic Interest Rate
• Risk Interest Rate
• Penal Interest Rate
APP DISCLAIMER:
The Mobile App for location mapping is developed by One Capital Systems and T echnologies
Pvt Ltd for the exclusive use of staff working at the various branches of One Capital, using the
username and password provided to them by the Company. Nobody other than the branch staff
of One Capital can log in to this application unless the username and password are provided to
them by the Company. The IMEI number of the mobile phones on which this application is
downloaded will be tracked by One Capital for its internal use.
Product:
T o provide loans to customers against the pledge of gold jewelry as collateral security.
Nomenclature and T enure of the Loan:
• Nomenclature: The loan is given as a demand loan.
• T enure of the Loan: All gold loans are sanctioned for a maximum tenor of 12
months unless otherwise specified under a particular scheme.
Eligible Customer:
Any individual who is the lawful owner of the gold jewelry offered as security, as per the
declaration of ownership submitted by them and fulfilling the KYC norms as per RBI guidelines.
Purposes:
The loan can be extended to anyone with short-term fund requirements, such as working capital
for establishment/expansion of a business, personal liquidity needs, or domestic requirements,
including medical expenses. Loans shall not be used for speculative, illegal, or unlawful
purposes violating the laws of the country.
Quantum of Finance:
The quantum of finance will be determined based on the net weight of 22-carat gold ornaments
tendered as security, its purity, and subject to RBI guidelines on loan-to-value. Minimum loan
amount per pledge: Rs.1500/-
, provided that (a) the minimum weight of gold offered is 1 gram
(net weight), and (b) at least 25% of the eligible loan amount is availed.Quantum and Purity of Gold that can be Pledged and
Deductions:
The minimum net weight of gold jewelry that can be pledged is one gram, with a minimum purity
of 22 carats. The weight of any non-gold materials (e.g., pearl, diamond, coral) in the ornament
will be deducted from the gross weight to calculate the net weight for the loan amount.
Interest and Charges:
Interest and other charges shall be governed by the interest rate policy adopted by the Board.
The Board or an empowered committee shall periodically review and approve necessary
revisions. Any revision in interest shall be prospective. Interest rates shall be decided based on
factors such as the cost of funds and risk grading, where higher risk entails higher interest,
within the ceiling rate set by the Company. No loan shall be granted below the average cost of
funds without Board approval.
Interest is calculated based on the loan’s actual outstanding days. If the borrower closes the
loan within 7 days of disbursement, a minimum 7-day interest will apply if the minimum effective
interest rate exceeds 11%. For schemes with a rate of 11% or lower, a minimum 15-day interest
applies if closed within 15 days. Minimum interest charged will be Rs.50/-
. Interest rebates may
be offered for timely repayment or closure.
Interest is compounded monthly based on a 365-day year. If an interest payment due date falls
on a holiday, the Company may permit payment on the next working day without penalty,
considering the intervening period as a grace period.
Penal Interest:
In case of failure to repay the loan with interest and charges by the due date, penal interest as
decided by the Company will apply over the regular interest for the outstanding period.
Other Charges:
In addition to interest, other charges as set by the Board or its Committee may apply, including:
1. Security Charges
2. Processing Charges
3. Service Charges
4. Documentation Charge
5. Notice Charges
6. Lost T oken Charges
7. SMS Charges8. Auction Expenses
9. Cheque Re-issue Charges
10. Dormancy Charges
11. Partial Release Charges
12. Transaction Charges (under specific schemes)
13. Other charges, as set by the Board or Committee, will be disclosed upfront.
14. Stamp duty as per state laws.
Documentation:
• Loan Application
• Demand Promissory Note and T ake Delivery Letter
• T erms and Conditions Letter (including declarations and undertakings)
• Consent for Aadhaar authentication with UIDAI for “eKYC” purposes
• KYC Documents (OVDs) for identity and address proof per RBI norms, such as
Passport, PAN, Driving License, Voter ID, Ration Card, Aadhaar Card, or other
government-issued identity cards.
Jewelry Handling:
• Jewelry’s gross weight and purity are appraised by Company-prescribed methods.
• Stones and non-gold materials are deducted from gross weight to determine net weight.
• Jewelry is securely packed with a weight slip and stored in a strong room/safe.
• Each loan has a separate packet.
Ownership of Gold:
Branch staff must verify the customer’s ownership of pledged jewelry and their capacity to own it
before loan disbursement. For pledged amounts exceeding 20 grams, the customer must
provide an ownership explanation (e.g., inheritance, gift, purchase). Loans on behalf of a third
party require a notarized Power of Attorney.
Issuance of Certificate of Purity:A certificate of purity will be included in the loan sanction letter, indicating the permissible loan
amount. Only jewelry of 22 carats will be accepted. If purity is below 22 carats, weight may be
adjusted proportionately to reflect 22-carat value.
Loan to Value (LTV):
Loan rates comply with RBI guidelines and are centrally updated in a non-editable format within
the CBS. Interest rates and scheme changes are similarly updated and communicated to
branches.
Renewal of Loans:
Loan renewals require full repayment of principal and interest. Eligible loan amounts for
renewals will be calculated per current LTV. Large renewals may be monitored with options like
shorter tenure or reduced LTV. T o manage renewal risks, renewed loans without sufficient cash
flow will not exceed 40% of the Company’s gold loan portfolio.
Digital Transactions:
Using “Web Pay” and “One Capital” applications, customers can access differences between
the loan amount and eligible amount based on the day’s LTV. Renewals will transfer excess
funds only to the registered bank account to prevent fraud.
Safety Measures Branches must have:
• Strong rooms or FBR safes
• Armed guard(s)/watchman at vulnerable locations
• Burglar alarms, CCTV, and necessary safety devices
• Insurance against burglary/fire/natural calamities
Non-eligible Items:
• Melted bars or primary gold
• Religious institution jewelry
• Items on the negative list or where ownership proof is missing
• Items restricted by RBI
Release of Jewelry:Jewelry is released only to the borrower upon full repayment, after verifying KYC and pawn
ticket (token). In case of token loss, an indemnity is required. In case of the customer’s death,
the ornament will be released to legal heirs as per Company procedure.
Fraud Prevention:
Any fraud or attempted fraud must be immediately reported to Management.
Spurious/Stolen Gold:
Any suspicion of spurious or stolen gold is reported to the Chief Vigilance Officer, Regional
Vigilance Officer, and local police.
Inspection:
Branches undergo regular inspections by internal audit staff to verify pledged gold quantity and
purity and ensure compliance with Company guidelines.
Auction:
If a loan account is overdue, the pledged ornaments will be auctioned following a 14-day notice
by an authorized auctioneer. The auction will be publicly announced in newspapers. Neither
One Capital nor its affiliates may bid in these auctions. Net auction proceeds will go toward
outstanding loans, and excess funds (if any) will be refunded to the customer.
Auction Procedure:
The auction process will follow the policy approved by the Board.
Staff Training:
All employees are trained in jewelry purity assessment upon joining, with regular refresher
courses provided.
Code of Conduct for Directors & Senior Management of Muthoot Finance Limited
Preamble
The Code of Conduct for Directors & Senior Management of Muthoot Finance Limited (referred
to as “the Code”) sets standards for business conduct at Muthoot Finance Limited (referred to
as “the Company”). It provides guidance for ethical decision-making and ensures compliance
with relevant laws and regulations governing the Company’s operations. The Code’s primary
purpose is to foster ethical behavior and prevent wrongdoing, thereby safeguarding the
Company’s and stakeholders’ best interests. The principles in the Code are crucial to upholding
the Company’s values and reputation, essential for shareholders, business associates, and
partners.Objective of the Code
1. Ethical Conduct: T o establish a framework that encourages ethical behavior among
Directors and Senior Management.
2. Legal Compliance: T o ensure compliance with all relevant laws, regulations, and policies.
3. Protection of Interests: T o protect the Company’s interests and those of its shareholders
and other stakeholders.
Scope
The Code applies to all Directors and members of the Senior Management team. It serves as a
binding document for conduct and decision-making within the Company’s operations.
Key Principles of the Code
1. Integrity and Honesty: Directors and Senior Management are expected to act with
honesty, integrity, and transparency in all dealings and interactions, both internal and external.
2. Compliance with Laws: Adherence to applicable laws, regulations, and Company
policies is mandatory. Directors and Senior Management must stay informed about legal
requirements and ensure that Company activities align with them.
3. Confidentiality: All information about the Company, its customers, and stakeholders that
is non-public and confidential should be protected. Disclosure of such information is restricted
unless legally required or authorized by the Company.
4. Conflict of Interest: Directors and Senior Management should avoid situations where
personal interests conflict with the interests of the Company. They are expected to disclose any
potential conflicts promptly and recuse themselves from decisions that could be influenced by
personal interest.
5. Protection of Company Assets: Directors and Senior Management are responsible for
safeguarding the Company’s assets and ensuring their efficient and lawful use.
6. Fair Dealing: All business dealings should be conducted fairly and with respect for
stakeholders. Directors and Senior Management should foster an environment of fairness and
mutual respect.
7. Corporate Opportunities: Directors and Senior Management should not exploit for
personal gain any opportunity discovered through the use of Company property, information, or
position.
8. Insider Trading: Directors and Senior Management should refrain from trading in
Company securities while in possession of unpublished, price-sensitive information about the
Company.9. Health and Safety: A commitment to providing a safe and healthy work environment for
employees and stakeholders is paramount. Directors and Senior Management are expected to
comply with health and safety regulations and promote a culture of safety within the Company.
10. Reporting Violations: Any violation of the Code or unethical behavior should be reported
through the appropriate channels. The Company has a Whistleblower Policy to ensure that
concerns can be raised confidentially and without fear of retaliation.
Implementation and Enforcement
The Board of Directors is responsible for implementing the Code, with support from Senior
Management. Violations of the Code are subject to investigation and may lead to disciplinary
action, including termination. Directors and Senior Management are expected to periodically
reaffirm their commitment to the Code and undergo training on its principles and the Company’s
values.
Amendments and Updates
The Company reserves the right to amend or modify the Code as needed to reflect changes in
legal requirements, industry practices, or business needs. Directors and Senior Management
will be informed of any updates to ensure ongoing compliance.
Conclusion
This Code of Conduct is essential for maintaining the integrity and reputation of Muthoot
Finance Limited. Adherence to the Code reflects a commitment to ethical conduct, compliance
with laws, and the promotion of a culture that prioritizes the Company’s and stakeholders’ best
interests.
Responsibilities of Board Members and Senior Managers of Muthoot Finance Limited
In alignment with the values and fiduciary responsibilities at Muthoot Finance Limited, all Board
Members and Senior Managers are expected to uphold the following standards and duties as
part of their commitment to the Company’s integrity and success. This code was adopted by the
Board of Directors on July 23, 2010.
Core Duties and Expectations
1. Act in the Company’s Best Interest
• Act in the best interests of the Company, fulfilling fiduciary duties with loyalty and
integrity.
2. Uphold Ethical Standards
• Conduct themselves with honesty, fairness, and integrity.• Maintain a professional, courteous, and respectful demeanor, avoiding any improper use
of their position
3. Fair Dealings Stakeholders
• Treat all stakeholders fairly and equitably, fostering trust and accountability in all
interactions.
4. Compliance with Laws and Regulations
• Abide by all relevant laws, rules, and regulations that govern the Company’s operations.
5. Exercise Good Faith and Due Diligence
• Act responsibly and diligently, exercising independent judgment and due care without
undue influence.
6. Avoid Misuse of Position and Resources
• Refrain from using Company property, information, or position for personal gain or any
purpose detrimental to the Company’s interests.
7. Preserve Company’s Reputation
• Behave in ways that enhance and uphold the Company’s reputation, promoting trust and
confidence among stakeholders.
8. Conflict of Interest Disclosure
• Disclose any personal interest that may present a conflict with the Company’s affairs.
• Abstain from participating in discussions or decisions where a conflict of interest exists or
could arise.
9. Avoid Competing Interests
• Refrain from serving as a Director, employee, or service provider to any company that
competes directly with Muthoot Finance Limited.
10. Respect Confidentiality
• Protect the confidentiality of Company information acquired through their role, disclosing
such information only when authorized or legally mandated.
• Avoid using confidential information for personal gain or for the benefit of another entity.
11. Foster a Culture of Compliance and High Ethical Standards• Encourage and contribute to a culture that prioritizes ethics, integrity, and compliance
with all Company policies and guidelines.
Commitment to Ethical Leadership
This Code of Conduct reflects Muthoot Finance Limited’s commitment to high ethical standards
and responsible governance. By adhering to these principles, Directors and Senior Managers
demonstrate leadership that aligns with the Company’s core values and objectives, fostering a
workplace culture grounded in trust, accountability, and dedication to excellence.
Privacy Policy:
The information we collect from you may be used in one of the following ways:
1. To personalize your experience
Your information helps us to better respond to your individual needs.
2. To improve our website
We continually strive to improve our website offerings based on the information and
feedback we receive from you.
3. To improve customer service
Your information helps us to respond more effectively to your customer service requests
and support needs.
4. To process transactions
Your information, whether public or private, will not be sold, exchanged, transferred, or
given to any other company for any reason whatsoever, without your consent, other than
for the express purpose of delivering the purchased product or service requested.
5. To administer a contest, promotion, survey or other site feature
6. To send periodic emails
The email address you provide may be used to send you information, respond to
inquiries, and/ or other requests or questions.
HOW DO WE PROTECT YOUR INFORMATION?
We implement a variety of security measures to maintain the safety of your personal information
when you enter, submit, or access your personal information.
DO WE DISCLOSE ANY INFORMATION TO OUTSIDE PARTIES?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable
information. This does not include trusted third parties who assist us in operating our website,conducting our business, or servicing you, so long as those parties agree to keep this
information confidential. We may also release your information when we believe release is
appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights,
property, or safety. However, non-personally identifiable visitor information may be provided to
other parties for marketing, advertising, or other uses.
ONLINE PRIVACY POLICY ONLY
This online privacy policy applies only to information collected through our website and not to
information collected offline.