S. E. INVESTMENTS LTD.

FAIR PRACTICE CODE INTRODUCTION

This is a compulsory Code, which sets minimum standards of business practices for the NBFCs to follow when they are dealing with individual customers. It provides protection to you and explains how NBFCs are expected to deal with you for your business operations. The Code does not replace or supersede regulatory or supervisory instructions of the Reserve Bank of India (RBI) and we will comply with such instructions/directions issued by RBI from time to time. Provisions of the Code may set higher standards than what is indicated in the regulatory instructions and such higher standards will prevail as the Code represents best practices voluntarily agreed to by us as our commitment to you. In the Code, you denotes the customer and we, the NBFCs the customer deals with. The customer shall include borrower as well as depositor. 1.1 Objective of the Code The Code has been developed to: Promote good and fair business practices by setting minimum standards in dealing with you. Increase transparency so that you can have a better understanding of what you can reasonably expect of the services. Encourage market forces, through competition, to achieve higher operating standards. Promote a fair and cordial relationship between you and your Financial Institution. Foster confidence in financing system.

The standards of the Code are covered by the key commitments in Section 2. 1.2 Application of the Code This Code applies to the i. ii. Loan facility provided by our branches and HO. Fixed Deposit Accounts

iii. Safe Deposit Lockers (Vaults facility) Last two facilities are being provided at our Head Office only.

2. KEY COMMITMENTS
2.1 2.1.1 Our Key Commitments To You To Act Fairly And Reasonably In All Our Dealings With You By: Meeting the commitments and standards in this Code, for the services and products we offer, and in the procedures and practices we follow Making sure our services and products meet relevant laws and regulations in letter and spirit Ensuring that our dealings with you rest on ethical principles of integrity, honesty and transparency 2.1.2 To Help You To Understand How Our Financial Products And Services Work By: 2.1.3 Giving you information about them in Vernacular language Ensuring that our advertising and promotional literature is clear and not misleading Ensuring that you are given clear information about our products and services, the terms and conditions, interest rates/service charges, which apply to them and approach for gradation of risk. Giving you information on what are the benefits to you, how you can avail of the benefits, what are their financial implications and whom you can contact for addressing your queries and how. To Deal Quickly And Sympathetically With Things That Go Wrong By: mistake b) Handling your complaints promptly c) Telling you how to take your complaint forward if you are still not satisfied (see para No. 7) d) Providing suitable alternative avenues to alleviate problems arising out of technological failures. 2.1.4 To Treat All Your Personal Information As Private And Confidential We will treat all your personal information as private and confidential subject to matters mentioned in para No. 4 below. 2.1.5 To Publicise The Code We Will: a) Make available this Code at every branch, HO and on our website b) Ensure that our staff are trained to provide relevant information about the Code and to put the Code into practice. 2.1.7 To Adopt And Practice A Non - Discrimination Policy We will not discriminate on the basis of age, race, gender, marital status, religion or disability. a) Correcting mistakes promptly and cancelling any service charges that we apply due to our

3. INFORMATION - TRANSPARENCY
You can get information on interest rates, fees and charges determined in accordance with the internal principles and procedures through any one or more channels that can be used to access our services and products. 3.1 General Prior to establishment of a customer relationship, we will: a) Give you clear information explaining the key features of the services and products you tell us you are interested in, including applicable interest rates and other necessary terms and condition, by way of sanction letter. b) Tell you what information we need from you to prove your identity and address (KYC), for us to comply with legal, regulatory and internal policy requirements. c) Give you information on your rights and responsibilities especially regarding availing of nomination facility offered on all deposit accounts, articles in safe custody and safe deposit vaults. d) Request for additional information about you and your family/associates/group companies to build a client database. 3.2 Fees & Charges a) b) We will give you details of any charges applicable to the products and services chosen by you. We will also provide you information about the penalties leviable in case of non-

observance/violation of any of the terms and conditions governing the product/ services chosen by you. 3.2.1 Changes in Fees & Charges Any change in interest or charges will be notified with in stipulated time prior to the effective date. 3.3 Terms and Conditions a) b) We will advise you the relevant terms and conditions for the service you have asked us to provide. All terms and conditions will be fair and will set out respective rights especially with regard to nomination facility and liabilities and obligations clearly and as far as possible in plain and simple language. 3.3.1 Changes to Terms and Conditions a) b) We will tell you the changes to terms and conditions through appropriate channels. Changes will be made with prospective effect giving notice of within stipulated time period.

4. PRIVACY AND CONFIDENTIALITY

We will treat all your personal information as private and confidential [even when you are no longer a customer], and shall be guided by principles and policies. We will not reveal information or data relating to your accounts, whether provided by you or otherwise, to anyone, including other companies / entities in our group, other than in the following exceptional cases: a) b) c) If we have to give the information by law If there is a duty towards the public to reveal the information If our interests require us to give the information (for example, to prevent fraud) but we will not use this as a reason for giving information about you or your accounts [including your name and address] to anyone else, including other companies in our group, for marketing purposes d) e) If you ask us to reveal the information, or if we have your permission, in writing If we are asked to give a bankers reference about you because exchange of such information is usual practice adopted by banks and financial institutions. We will explain to you the extent of your rights under the existing legal framework for accessing the personal records that we hold about you.

5. COLLECTION OF DUES
Whenever we give loans, we will provide you the repayment schedule containing the details of amount, tenure and periodicity of repayment. However, if you do not adhere to repayment schedule, a defined process will be followed for recovery of dues. The process will involve reminding you by sending notices or by telecalling or by making personal visits and/ or repossession of security, if any but we will not resort to undue harassment. Our collection policy is built on courtesy, fair treatment and persuasion. We believe in fostering customer confidence and long term relationship. We shall ensure that the staff is adequately trained to deal with the customers in an appropriate manner.

6. COMPLAINTS, GRIEVANCES AND FEEDBACK

Our staff will help you with any question you have. In case of any complaint/grievance, the applicants/borrowers will have to inform in writing the concerned branch head of the company. In case of complaints received at Branch, the branch head would resolve the matter within 7 days from date of receipt. If complaint is not resolved within 7 days, then Branch Head would report the matter with

full details to Grievance Redressal Officer (GRO) at Corporate Office of the company. The Grievance Redressal Officer (GRO) at the Corporate Office of the company would, after examining the matter, take all necessary steps to redress and resolve the grievance / dispute, with in a maximum period of 30 days. If the complaint is not redressed within a period of one month, the customer may appeal to the Officer-inCharge of the Regional Office of DNBS of RBI. Complete details of Branch Heads, Grievance Redressal Officer (GRO) at Corporate Office and Officer-in-Charge of the Regional Office of DNBS of RBI are given hereunder :Branches Name of Branch Head Jaipur Mr. Satya Prakash Sharma Jodhpur Mr. Shailendra Singh Bhadouriya Mathura Mr. Mahadev Sharma Ahmedabad Mr. Pradeep Chahar Mumbai Aligarh Bareilly Mr. Gaurav Chaubey Mr. Anupam Mr. Pradeep Sharma Thiruvananthpuram Mr. Gaurav Chaubey 7738386151 04713258014 __ thiruvananthpuram@seil.in 9837000392 9286340886 7738386151 02242288888 05712421866 05812510755 __ bareilly@seil.in 0224228882 __ aligarh@seil.in mumbai@seil.in 9998123238 07927544830 __ ahmedabad@seil.in 9837000391 05652424310 __ mathura@seil.in 9929074758 02912638926 2912638926 jodhpur@seil.in 9314142990 01414068888 1414068810 jaipur@seil.in Mob. No. Ph. No. Fax No. Email Id

Grievance Redressal Officer (GRO) Designation Grievance Redressal Officer (GRO) Name Mr. Anurag Sinha Address M-7, Ist Floor, M Block Market, G.K.II, New Delhi Officer-in-Charge of the Regional Office of DNBS of RBI Officer & Designation The (Department Bankling Manager, of Non Supervision), 6, Address Sansad Marg, RBI Building, P.B. no. 123, New Delhi-110001 Phone No. 011-23714456 Fax No. 011-23713672 Telex No. 031-66361 Mob. No. 9837727603 Ph. No. 01143518888 Fax No. 01143518816 Email Id anurag.sinha @seil.in

Reserve Bank of India

7. PRODUCTS AND SERVICES

7.1. Loan Products 7.1.1 a) Applications for loans and their processing At the time of sourcing a loan product, we will provide as part of the loan application form,

information about the interest rates applicable whether floating rate or fixed rate, as also the fees/charges payable for processing, the amount of such fees refundable if loan amount is not sanctioned / disbursed, pre-payment options and charges, if any, penal rate of interest for delayed repayments, if any, and any other matter which affects the interest of the borrower, so that a meaningful comparison with those of other institutions can be made and informed decision can be taken by you. a) b) We shall invariably provide you with an acknowledgement of your loan application. We will give you the Most Important Terms and Conditions governing the loan / credit facility you have availed. c) All loan applications will be disposed of within a reasonable period from the date of receipt of duly completed loan applications i.e. with all the requisite information/papers. d) Normally all particulars required for processing the loan application will be collected by us at the time of application. In case we need any additional information we will contact you immediately.

7.1.2 LOAN APPRAISAL AND TERMS/CONDITIONS a) In accordance with companys prescribed risk based assessment procedures, each loan application will be assessed and suitable securities will be stipulated based on such risk assessment and company's extant guidelines, however without compromising on due diligence. b) We will provide you the sanction letter detailing particulars of amount sanctioned, annualized rate of interest, terms and conditions etc. Such terms and conditions as have been mutually agreed upon between the company and borrower prior to the sanction will only be stipulated. 7.1.3 DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS a)Disbursement of loans sanctioned is to be made immediately on total compliance of terms and conditions including execution of loan documents governing such sanction. b)Any change in the terms and conditions, including interest rate and service charges, will be informed individually to the borrowers in case of account specific changes and in case of others by Public Notice//through Print and or other Media from time to time. c) Changes in interest rates and service charges will be effected prospectively. d)Consequent upon such changes any supplemental deeds documents or writings are required to be executed, the same shall also be advised. e)Further availability of facility will be subject to execution of such deeds, documents or writings. f) We will supply authenticated copies of all the loan documents executed by you along with a copy each of all enclosures quoted in the loan document. g)We will give written receipt for all documents to title taken as security/ collateral for any loan received from you. 7.1.4 POST DISBURSEMENT SUPERVISION a)Before taking a decision to recall/accelerate payment or performance under the agreement or seeking additional securities the company would give reasonable notice to you. b)All securities pertaining to the loan would be released on receipt of full and final payment of the loans subject to any legitimate right or lien and set off for any other claim that the company may have against the borrowers. If such right is to be exercised, borrowers would be given due and proper notice with requisite details. 7.1.5 CLOSING OF ACCOUNT a) We will return all unrealised cheques given by you on receipt of full amount representing the EMI / entire debt.

b)

We will return to you all the securities / documents/title deeds to mortgaged property within 15 days of the repayment of all dues agreed to or contracted. If any right to set off is to be exercised for any other claim, we will give due notice with full particulars about the other claims and retain the securities/ documents/title to mortgaged property till the relevant claim is settled/paid.

7.1.6 GENERAL a) The company would refrain from interference in the affairs of the borrower except for what is provided in the terms and conditions of loan sanction documents (unless new information, not earlier disclosed by the borrower, has come to the notice of the company as lender). However this does not imply that company's right of recovery and enforcement of security under Law is affected by this commitment. b) c) d) The company will not discriminate on the grounds of gender, caste or religion in its lending policy and activity. In the case of recovery, company would resort to the usual measures as per laid down guidelines and extant provisions and would operate within the legal framework. In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of the NBFC, if any, should 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. 7.2 a) DEPOSIT ACCOUNTS Resident Individuals, Group of Persons, Domestic Companies, HUF, Charitable trusts and Minor (through their guardian) may open Fixed deposits accounts with us, You may open such accounts in the following styles: i. Single ii. Joint with payment condition such as b) First Name Depositor Either or Survivor Jointly

Nomination facility is available in such deposits. Such nomination is duly recorded on FDR receipts issued by us.

7.2.1 Opening and Operation of Deposit Accounts Before opening any deposit account, we will: a) b) fulfill KYC norms as prescribed by RBI and call for such papers in this regard. provide the account opening forms and other material to you. The same will contain details of essential information required to be furnished and documents to be produced for verification and/or for record for meeting the KYC requirements

c) d)

explain the procedural formalities and provide necessary clarifications sought by you while opening a deposit account issue you deposit receipt that is neither transferable nor negotiable and will be dispatched within one week from the date of the receipt realization of the cheque by the Regd. Post/ Courier.

7.2.2 When you place a fixed deposit with us we will: a) Provide you all related information like procedure of payment on or before maturity, interest rate, payment condition in case of joint account, renewal on maturity and related provisions of Income Tax Act, 1961. b) c) Obtain Form 15 H / 15 G from you at the time of application if you are not liable to pay tax on your interest income Issue the requisite certificate if we deduct tax from interest accrued on your deposits.

7.2.3 Settlement of Claims In Respect Of Deceased Account Holders In the event of death of first named depositor, the payment of deposit amount or interest shall be made to the surviving depositor/s in the case of joint holding with survivor clause, or to the nominee or the legal heirs/s of the deceased depositor, on the request of the surviving depositor/ nominee/ legal heirs, and only against submission of proof of death, to the satisfaction of the company, as appearing in the application form, on the production of death certificate without reference to the heirs and /or legal representative of the deceased. 7.2.4 Nomination Facility Where a nominee has been appointed by the depositor in the application form, the nominee would receive payment of deposit amount or interest in case of death of all other depositors appearing on the application form, on the production of the relevant death certificate without reference to the heirs and /or legal representative of the deceased. The company shall be absolved of its liability on such payment to the nominee. In any other case it will be necessary for the legal representative of the deceased depositor to produce succession certificate/ letter of the Administration/ Probate of the Will etc. to the satisfaction of the company in this regard. 7.2.5 Repayment/ Renewal of Deposits The Deposit Receipt duly discharged should be sent to the Administrative office of the company at least 4 weeks before the date of maturity to enable the company to repay the deposit. Request for renewal should be accompanied by the Application Form duly filled and to be sent at least 20 days before the maturity date of the deposit at the Administrative office. When the due date of any payment falls on Sunday, Bank Holiday or any other day on which the companys office remains closed, the payment will be made on the next working day.

7.2.6 Premature withdrawal in case of need other than in case of death of the depositor Fixed Deposit will be repaid only on maturity and not on demand or notice except at the sole discretion of the Company. For the purpose of calculating interest in case of premature payment, the rate applicable is as per RBI guidelines as amended from time to time. 7.2.7 Loan against Deposits We also provide facility of loan against fixed deposit as per policy of the company. The depositor is required to send an application together with original deposit receipt for availment of loan against deposit. The rate on such loan shall be chargeable @ + 2% and maximum amount of loan shall not exceed 75% of deposit amount. 7.2.8 General

1. Company reserves the right:

(a) to waive or vary the above terms and conditions. (b) to reject any Application for a fresh deposit or for renewal without assigning any reason. (c) to repay the Deposit prematurely before the due date. 2. Acceptance, renewal and repayment of fixed deposits shall be subject to the Non-Banking Financial Companies (Reserve Bank) Directions 1977 as amended from time to time. 3. Acceptance of deposits/disputes arising there from would be subject to the jurisdiction of Courts of

Agra. 4. In case of non-repayment of the deposit or part thereof as per the terms and conditions of such deposit,
the depositor may approach the Northern Bench of Company Law Board whose full address is given hereunder: Company Law Board, Northern Region Bench, 5th Floor, A Wing, Shashtri Bhawan, New Delhi-110 001. 5. In case of any deficiency of the company in servicing its deposit, the depositor may approach the National Consumers Disputes Redressal Forum, the State Level Consumers Dispute, Redressal Forum or the District Level Consumers Disputes Redressal Forum for relief. 6. The company is having a valid certificate of Registration dated 12/01/2004 issued by RBI under section 45-1A of the RBI Act, 1934. However, the Reserve Bank of India does not accept any responsibility or guarantee about the company or for the correctness of any of the statement of representations made or opinions expressed by the company and repayment of deposits/discharge of the liabilities by the company. 7.3 SAFE DEPOSIT LOCKERS We give the complete details of the rules and the procedures applicable for the safe deposit lockers (vaults) to customers who wish to hire a locker from us.

8. PROTECTING YOUR ACCOUNTS

8.1 Keeping Us Up To Date Please make sure you let us know as soon as possible when you change your: a. Name b. Address c. Phone number d. E-mail address (if this is how we communicate with you). 8.2 Checking Your Account We recommend that you check your statement regularly. If there is an entry, which seems to be wrong, you should tell us as soon as possible so that we can investigate the same.

8.3 Force Majeure The commitments outlined and made by us are applicable under a normal operative environment. In the event of force majeure, we will not be able to fulfill the commitments under the fair practice code to the entire satisfaction of yours, the other stake holder and the public in general.

9. REVIEW OF THE CODE

This Code will be reviewed from time to time. The review will be undertaken in a transparent manner.