Caution Notice

It has come to our notice that certain individuals misrepresent themselves to be associated with Axis Finance Ltd. (hereby referred to as "AFL") and based on this deception, they make fictitious offers for loan products using our brand name or logo. AFL is not associated with such individuals / entities and the general public is hereby cautioned not to deal with such fraudsters who claim to be representatives of AFL, through web / email or otherwise. Any person entertaining such individuals / entities without verifying and confirming with AFL shall be doing so at his / her own risk and cost and AFL shall not be liable for any loss, damages or consequences thereof to any such person.

General public are advised not to accept any such loan offers and not to divulge any personal / other information to such callers offering loans without interest, loans secured by insurance payable annually, etc. in the name of AFL unless the identity of the person or entity is established and verified. If you come across suspicious product offers and loan proposals, please contact the local police station (cyber cell unit) and intimate us of the same.

Any person found to be indulging in such misrepresentation, cheating, fraud, dishonest and malafide actions will be dealt with strictly, including filing of criminal charges against them for damaging the interest of AFL.

THE AXIS FINANCE EDGE

The Axis Finance Brand symbolizes trust and is supported by a strong leadership team.

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NEWS & AWARDS

MD & CEO, Mr. Bipin Saraf’s term extended.

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Code of Conduct

• The Directors shall attend the Board Meetings regularly and effectively.

• The Directors shall study the Board papers thoroughly and use the good offices of the Chief Executive for eliciting any information at the Board Meetings, wherever necessary.

• The Directors shall ask the Chairman to furnish the Board Papers and Follow Up Reports on a definite time schedule.

• The Directors shall involve themselves in general policy formulation and also ensure that the performance of the Company is monitored adequately at the Board levels.

• The Directors shall be familiar with the broad objective of the Company and the policies laid down by the concerned regulatory authorities.

• The Directors may make valuable contributions by suggesting constructive ideas for better management of the Company.

• The Directors shall work as a team and not sponsor or be prejudiced against individual proposals. The management on its part is supposed to furnish full facts and complete papers in advance.

• The Directors shall try to give as much of their wisdom, guidance and knowledge as possible to the management.

• The Board of Directors shall guide the Senior Management of the Company.

• The Directors shall try to analyze the trends of economy, assist in the discharge of management's responsibility to public and formulation of measures to improve customer service and be generally of constructive assistance to the management.

• The Directors shall not send any instruction or give direction to any individual officer of the Company.

• The Directors shall not involve themselves in matters of personnel administration - whether it is appointment, transfer, posting or a promotion or a redressal of individual grievances of any employee.

• The Directors shall not interfere in the day-to-day functioning of the Company.

• The Directors shall not approach or influence for sanction of any kind of facility from an individual branch manager or any other officer of the Company.

• The Directors shall not involve themselves in the routine or everyday business and in the management functions of the Company.

• The Directors shall not reveal any information relating to any constituent of the Company to anyone as they are under oath of secrecy and fidelity.

• The Directors shall not send for individual officers of the Company or give directions to such officers on any matter.

• The Directors shall discourage the individual employee or unions approaching them in any matter.

• The Directors may indicate their directorship of the Company on their visiting card/letter head, but the logos or distinctive design of the Company should not, however, be displayed on the visiting card/ letterhead.

• The Directors shall not directly call for papers/files/notes recorded by various departments for scrutiny etc. In respect of agenda items to be discussed in the meetings, all information/ clarification that may be required for taking a decision shall be made available by the executives.

• The Directors shall ensure confidentiality of the Company's agenda papers/notes. Ordinarily, it is suggested that by way of abundant precaution, the Board papers may be returned to the Company after the meeting.

• The Directors shall not sponsor any loan proposal, building and sites for Company's premises, enlistment or empanelment of contractors, architects, doctors, lawyers, etc.

• The Directors shall abstain from doing anything, which will interfere with and/or be subversive of maintenance of discipline, good conduct and integrity of the staff.

• The Board Members and Senior Managers shall act in the best interests of, and fulfill their fiduciary obligations to the Company.

• The Board Members and Senior Managers shall act honestly, fairly, ethically and with integrity.

• The Board Members and Senior Managers shall conduct themselves in a professional, courteous and respectful manner and not take improper advantage of their position.

• The Board Members and Senior Managers shall deal fairly with all stakeholders.

• The Board Members and Senior Managers shall comply with all applicable laws, rules and regulations.

• The Board Members and Senior Managers shall act in good faith, responsibly, with due care, competence and diligence, without allowing their independent judgment to be subordinated.

• The Board Members and Senior Managers shall help create and maintain a culture of high ethical standards and commitment to compliance.

• The Board Members and Senior Managers shall not use the Company's property or position for personal gain.

• The Board Members and Senior Managers shall not accept from or give to stakeholders, gifts or other benefits not customary in normal social interaction.

• The Board Members and Senior Managers shall not use any information or opportunity received by them in their capacity as Directors or senior management in a manner that would be detrimental to the Company's interests.

• The Board Members and Senior Managers shall not use confidential information acquired in the course of their service as Directors or senior management for their personal advantage or for the advantage of any other entity.

• The Board Members and Senior Managers shall abstain from discussion, voting or otherwise influencing a decision on any matters that may come before the Board in which they may have a conflict or potential conflict of interest.

• The Board Members and Senior Managers shall disclose any personal interest that they may have regarding any matters that may come before the Board.

Whistleblower Policy

It was observed that in many organizations employees were permitted to remain anonymous while making a disclosure. Employees were given a platform for reporting their concern without fear of retribution or vengeful action from the persons against whom the complaint was submitted. The facility to report wrongdoing in an anonymous manner was hence found to be an effective means of receiving quick feedback from the ground level.

It was felt that a significant change be made in the policy tenets to include the handling of anonymous complaints. This was also in view of the fact that the Company is growing rapidly and needs to enhance the scope of this formalized mechanism for early detection of frauds and malpractices. Further, for an effective impact of the Policy it was felt that employee awareness be reinforced through appropriate dissemination. The Whistleblower Policy would now form a part of the welcome kit material to be handed over to all new employees on joining. The concept and the salient features of the revised policy are reproduced herein below. All employees are advised to go through the policy contents carefully and exercise their right judiciously.

1. Preface
A central tenet in the Company’s Policy on corporate governance is commitment to ethics, integrity, accountability and transparency. To ensure that the highest standards are maintained in these aspects on an on-going basis and to provide safeguards to various stakeholders (including shareholders, depositors and employees) the Company has formulated a “Whistleblower Policy” (“the Policy") that provides employees with the opportunity to address serious concerns arising from irregularities, malpractices and other misdemeanors committed by the Company’s personnel by approaching a Committee set up for the purpose (known as the Whistleblower Committee). In case the offences are committed by senior management, the Policy enables the Company’s staff to report the concerns to the Audit Committee of the Board. As detailed in this document, the Policy is intended to encourage employees to report suspected or actual occurrence(s) of illegal, unethical or inappropriate actions, behaviors or practices by staff without fear of retribution.

2. Glossary of Terms
A glossary of terms used in the Policy is outlined below.
(a) “Whistleblower” refers to an employee who voluntarily reports suspected occurrence(s) of illegal, unethical or inappropriate actions, behaviors or practices by staff within the Company.
(b) “Employee” refers to the personnel of the Company (employed in India or overseas).
(c) “Protected Disclosure” refers to any communication by the Whistleblower.
(d) “Subject” refers to an employee against whom a Protected Disclosure has been made or against whom evidence has been gathered during the course of an investigation.
(e) “Designated Authority” refers to the Whistleblower Committee or the Chairman of the Audit Committee of the Board.
(f) “Ethical Counselor” refers to a person who is appointed by the Company to provide clarity to employees with reference to the applicability of the Whistleblower Policy.

3. Scope and Coverage of the Whistleblower Policy
As stated above, the Policy is intended to address the concerns of employees relating to any wrongdoing within the Company, enabling them to report suspected occurrence(s) of illegal, unethical or inappropriate actions, behaviors or practices.
Employees who wish to remain anonymous while reporting a wrongdoing may do so under the Policy.
As the range of activities that constitute offence under the Whistleblower Policy is large and it may be difficult to list these exhaustively, the key wrongdoings are stated below:
(a) Violation of Code of Conduct for employees
(b) Misuse of office and authority.
(c) Violation of laid down rules and regulations or communicated procedures of the Company (relating to accounting, internal control, operations etc.)
(d) Any fraud in preparation of financial statement of the Company.
(e) Failure to comply with legal, compliance and regulatory requirements.
(f) Misappropriation of funds.
(g) Actual or suspected fraud or irregularities including forgery or alteration of documents.
(h) Criminal offences committed or likely to be committed that may implicate the Company or otherwise adversely affect its reputation.
(i) Discrimination against a member of staff, service recipient or service provider on grounds of sex, caste, religion or disability.
(j) Cases of conflict of interest – e.g. sanction of loans, investment decisions, purchase of goods and hiring of services where an employee may have an interest.
(k) Any other form of inappropriate/unethical/unlawful action or conduct (conduct may be considered unethical if it undermines universal core ethical values such as integrity and honesty).
(l) Complaints of sexual harassment received by the Whistleblower Committee will be referred to a body set up specifically for the purpose (in terms of a Supreme Court directive of 1997) : the Complaints Committee (Sexual Harassment at Work Place).
(m) An employee who has submitted three complaints or protected disclosures which are seen to be in bad faith will no longer be eligible for further protected disclosures or complaints under the Whistleblower Policy.

4. Role of the Whistleblower
(a) A Whistleblower is a person who will merely report a misdemeanor, as stated earlier, without acting as an investigator and will not, therefore, act on his own in conducting an investigative activity, other than as requested by the Designated Authority or the Audit Committee of the Board.
(b) Following from the above, on detecting a wrong-doing or misdemeanor, the Whistleblower will not determine corrective or remedial action that may be warranted under the circumstances.
(c) The Whistleblower should provide specific and verifiable details in the Protected Disclosure in appropriate language that is not offensive.
(d) The Whistleblower can discuss all matters related to the Whistleblower Policy, including his role and the implications of submitting the Protected Disclosure with the Ethical Counselor. The final decision to submit information under Protected Disclosure will, however, be the sole decision of the employee.
(e) Though they would not necessarily be required to conclusively prove the points contained in the Protected Disclosure, in order to support their disclosure, the Whistleblower should provide sufficient evidence to establish a prima facie case for investigation.

5. Protection available to the Whistleblower
(a) The identity of the Whistleblower (in case revealed) shall be kept confidential and will not be revealed unless required in terms of an order of a court of law.
(b) Complete protection will be given to the Whistleblower against retaliation or retribution consequent upon his/her having reported a Protected Disclosure.
(c) A Whistleblower will not get protection under the Policy if he is himself found guilty of misconduct. In other words, while the Committee will take cognizance of the Protected Disclosure, the employee’s misconduct will be dealt with separately.
(d) The Company will take steps to minimize difficulties that a Whistleblower may face in the submission of a Protected Disclosure. For instance, he will be reimbursed expenses incurred in travel, boarding and lodging for tendering evidence, if warranted.
(e) Suitable disciplinary action (including termination of service) may be taken against the Subject in case he is found guilty of misconduct against the Whistleblower, in retaliation of a complaint submitted.
(f) In case any action has been initiated against the Whistleblower (for acts of omission or commission attributed to him) the disciplinary authority in such cases would be one level higher than the disciplinary authority in the normal course of action.
(g) Any employee who assists in investigating a Protected Disclosure will also be protected to the same extent as the Whistleblower.
(h) In case the protection to the Whistleblower as well as employees assisting in the investigation (as outlined above) is violated in any manner, the same may be reported to the Whistleblower Committee or the Chairman of the Audit Committee.

6. Composition of the Whistleblower Committee
The Whistleblower Committee of the Company will comprise of the following members:
(I) Mr. Bipin Kumar Saraf – MD & CEO
(II) Mr. Bal Krishna Thakur – Senior Vice President & CRO
(III) Mr. Amith Iyer – Vice President & CFO
Mr. Bipin Kumar Saraf would be the Chairman of the Whistleblower Committee.

7. Role of the Whistleblower Committee
(a) The Committee will consider the credibility of the complaint submitted through the Protected Disclosure, the gravity of the issue raised and the likelihood of proving the allegation(s) from independent, verifiable sources.
(b) The Committee would have the discretion to appoint any official or officials in the Company (considered suitable for the purpose) to carry out a preliminary investigation to establish the applicability of Whistleblower Policy.
(c) The Committee will decide on carrying out further investigation upon the receipt of the report of the official undertaking the preliminary investigation.

8. Ethical Counselor
The Company has appointed an Ethical Counselor to assist employees who have witnessed offences and are in need of counseling about their roles and responsibilities in seeking a redressal of the wrongdoings. To provide clarity to employees with reference to the applicability of the Whistleblower Policy, the Company has appointed Mr. Vishal Sharan, Senior Vice President as the Ethical Counselor. His e-mail ID and contact numbers are as follows:

Email ID - vishal.sharan@axisfinance.in
Telephone no. +91 22 6226 1130
Mobile no. – 9819459402

9. Procedure for Reporting Protected Disclosures
(a) All Protected Disclosures reported against officials in the ranks of Senior Vice President and below should be addressed to the Whistleblower Committee which may be reported through the following channels :

• Email to the Whistleblower Committee at whistleblower@axisfinance.in or
• Email to any of the members of the Committee ( bipin.saraf@axisfinance.in, bal.thakur@axisfinance.in, amith.iyer@axisfinance.in ) or

(b) Protected Disclosures against the members of the Whistleblower Committee and employees in the rank of President and above (including MD & CEO) should be addressed to the Company Secretary (who in turn will forward the same to the ACB.)

The Chairman,
Audit Committee of the Board
Axis Finance Ltd.
Axis House,
Wadia International Centre
Pandurang Budhkar Marg, Worli
Mumbai – 400 025

(c) There may be occasions when a Whistleblower submits a complaint to a person in the Company other than the members of the Whistleblower Committee. It is proposed that Protected Disclosures received by officials, in the rank of VP and above, be forwarded to the Whistleblower Committee for necessary action.
(d) Protected disclosures should preferably be reported in writing in order to ensure a precise understanding of the issues raised and should either be typed or written in legible handwriting in English, Hindi or in the regional language of the place of employment of the Whistleblower.
(e) It is suggested that the Protected Disclosure be forwarded under a covering letter (or as an attachment to the email message) such that only the covering letter/email message bears the identity of the Whistleblower. The Whistleblower should, preferably, not disclose personal details in the Protected Disclosure that may identify him.
(f) In case the Whistleblower has a personal interest in the matter, it should be disclosed at the outset in the forwarding letter/email message.
(g) The covering letter/email message should prominently indicate that the Protected Disclosure/complaint is being made under the “Whistleblower Policy”.
(h) Copies of documents that may help in establishing the veracity of the Protected Disclosure report/complaint may be attached to the Protected Disclosure.
(i) The envelope containing the Protected Disclosure/complaint (when made in paper form) should be marked “Confidential”.
(j) The Designated Authority shall detach the covering letter/email message and forward only the Protected Disclosure to the Investigators for investigation.
(k) In order that the confidentiality of the Whistleblower (in case of an employee who has revealed his/her identity) is maintained, an acknowledgement of receipt of the Protected Disclosure/complaint will be sent to the Whistleblower only through email.

10. Investigation and Redressal of the Complaint
(a) The Protected Disclosure or complaint received by the Whistleblower Committee will be examined by it within 15 days to determine if a prime-facie case exists for further investigation.
(b) Further investigation will be initiated within 15 days of the receipt of the Protected Disclosure to ensure prompt action.
(c) However, the decision to conduct an investigation is by itself not an acceptance of the allegations. In other words, the investigation process is to be treated as a neutral fact-finding process.
(d) The Subject will normally be informed of the allegations at the outset of a formal investigation and will have the opportunity to provide his inputs during the investigation.
(e) The identity of the Subject(s) as well as the Whistleblower will be kept confidential to the extent possible given the legitimate needs of law and the stage of the investigation.
(f) A Subject will have the right to consult with a person or persons of their choice, other than the Investigators and/or members of the Audit Committee and/or the Whistleblower (Subjects shall be free at any time to engage counsel at their own cost to represent them in the investigation proceedings).
(g) The Whistleblower will be informed about the final decision normally within 60 days of receipt of the Protected Disclosure.
(h) The Investigation Report with its recommendations will be submitted to the Deputy Managing Director/ACB as the case may be.
(i) If either the Whistleblower or the Subject is dissatisfied with the disposal of his Protected Disclosure report, they may approach the MD & CEO and/or the Chairman of the ACB for review.

11. Outcome of Investigations into Allegations under a Whistleblower Policy
If an investigation leads the Designated Authority to conclude that an improper, unethical, fraudulent act or misconduct has been committed, the Designated Authority shall recommend to the management of the Company to take such disciplinary or corrective action against the erring officials (Subjects) as the disciplinary authority may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject(s) as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or Staff Conduct and Disciplinary Procedures.

12. Reporting to the Audit Committee of the Board (ACB)
A quarterly report on the findings under the Whistleblower Policy will be submitted to the ACB for information. The Compliance department will be the convener of the Whistleblower Committee and will monitor and will submit the quarterly reports to the ACB.

13. Display and Notification
The Whistleblower Policy shall be displayed on the Company’s intranet, and a paper copy of this will be made available to any person on demand from any of the offices of the Company. New employees in the Company will be informed about the Policy as part of their joining formalities.

14. Administration of the Whistleblower Policy
The Compliance Officer is responsible for the administration, revision, interpretation and application of this Policy. The Policy will be reviewed and revised as needed.
Please bring the contents of this circular to all the employees of the Company.

Caution Notice

It has come to our notice that certain individuals misrepresent themselves to be associated with Axis Finance Ltd. (hereby referred to as "AFL") and based on this deception, they make fictitious offers for loan products using our brand name or logo. AFL is not associated with such individuals / entities and the general public is hereby cautioned not to deal with such fraudsters who claim to be representatives of AFL, through web / email or otherwise. Any person entertaining such individuals / entities without verifying and confirming with AFL shall be doing so at his / her own risk and cost and AFL shall not be liable for any loss, damages or consequences thereof to any such person.

General public are advised not to accept any such loan offers and not to divulge any personal / other information to such callers offering loans without interest, loans secured by insurance payable annually, etc. in the name of AFL unless the identity of the person or entity is established and verified. If you come across suspicious product offers and loan proposals, please contact the local police station (cyber cell unit) and intimate us of the same.

Any person found to be indulging in such misrepresentation, cheating, fraud, dishonest and malafide actions will be dealt with strictly, including filing of criminal charges against them for damaging the interest of AFL.

Fair Practice Code

This has reference to Circular No. 2012-13/416/DNBS. CC. PD No. 320 /03.10.01/2012-13 dated 18th February, 2013, wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices Code for NBFCs to implement the same.

The Fair Practices Code, as mentioned herein below, is in conformity with these Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular. This sets minimum Fair Practice standards for the Company to follow when dealing with customers. It provides information to customers and explains how the Company is expected to deal with them on a day to day basis.

Objective of the Code
The code has been developed with an objective of:
(a) Ensuring fair practices while dealing with customers
(b) Greater transparency enabling customers in having a better understanding of the product and taking informed decisions
(c) Building customer confidence in the company

(i) Applications for Loans and their processing
(a) Axis Finance Limited (“The Company/AFL) offers various financial products including Loan against securities, structured products, IPO financing, Loan against property, Acquisition Funding among others. All communications to the borrower shall be in vernacular language as understood by the borrower.
(b) The ‘Application Form / appropriate documents’ of AFL for each of these products offered by the Company is different depending upon the requirement of each product and will include all information that is required to be submitted by the Borrower. Necessary information will be provided by AFL to facilitate the Borrower in making a meaningful comparison with similar terms and conditions offered by other Non-Banking Finance Companies (NBFCs) and taking an informed decision based on the aforesaid comparison.
(c) The ‘Application Form/ appropriate documents’ of AFL may also indicate the list of documents required to be submitted by the Borrowers along with the Application form.
(d) AFL has a mechanism of giving an acknowledgement for receipt of Application from to its Borrower for availing loans. AFL would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.

(ii) Loan appraisal and terms/ conditions
AFL shall convey in writing to the Borrower by way of a sanction letter or otherwise, the amount of limit sanctioned along with all the terms and conditions including annualized rate of discount/ interest and method of application thereof and keeps the acceptance of these terms and conditions by the borrower on AFL’s record. Any clause relating to penal interest charged for late repayment will be specified in bold in appropriate documentation. AFL at the time of sanction / disbursements of loans will furnish a copy of loan agreement to the borrower.

(iii) Disbursement of loans including changes in terms and conditions
(a) Through its published website or as appropriate if specific to a customer, AFL will give Notice to all its Borrowers, of any change in the terms and conditions of the sanction. AFL will also ensure that changes in discount/ interest rates and charges are effected only prospectively.
(b) Decision to recall/ accelerate payment or performance under the Agreement will be in consonance with the respective loan Agreement.
(c) AFL will release all securities of its Borrower only on repayment of all dues by such Borrower, or only on realization of the outstanding amount of the Borrower’s availed limit, subject to any legitimate right or lien for any other claim which AFL may have against its 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 conditions under which AFL will be entitled to retain the securities till the relevant claim is settled or paid by the Borrower.

(iv) General
(a) AFL will refrain from interference in the affairs of its Borrower except for the purposes provided in the terms and conditions of the respective loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of AFL).
(b) In case of receipt of request from the Borrower for transfer of Borrower account, the consent or otherwise i.e. objection of AFL, if any, is generally conveyed to such Borrower within 21 days from the date of receipt of the Borrower’s request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.
(c) In the matter of recovery of outstanding dues of its Borrower, AFL does not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc. Training will be imparted to ensure that staff is adequately trained to deal with customers in an appropriate manner.

(v) Regulation of Excessive Interest charged
The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.
The Company has adopted an interest rate model taking into account cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances.
The rate of interest to be charged depends much upon the gradation of the risk of borrower viz. the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower etc.

(vi) Grievance Redressal Mechanism
Borrowers and others who have grievances in respect of decisions of AFL’s functionaries may write to us at the below mentioned address:
Axis Finance Limited
Axis House, Wadia International Centre
Pandurang Budhkar Marg, Worli
Mumbai- 400 025

In case the complaint is not resolved within the given time or if he/she is not satisfied with the solution provided by AFL, the customer can approach the Complaints Redressal Officer. The name and contact of the Complaint Redressal Officer is as follows:
Mr. Rajneesh Kumar
Tel: No.+91 22 6226 1117.
Email: rajneesh.kumar@axisbank.com

In case the response received through the above channels are not satisfactory, customer can write to our Complaint Redressal Head at bal.thakur@axisbank.com We assure a response to letters / emails received through this channel within 7 working days.
If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non Banking Supervision of RBI under whose jurisdiction the Registered Office of the AFL falls. The details of DNBS are given below:
Asst. General Manager, Department of Non-Banking Supervision
Reserve Bank of India, Mumbai Regional Office
Dr. Annie Besant Road, Near Worli Naka, Worli, Mumbai – 400 018
Tel. No.: +91-22-24939930-38
Email ld: dnbs@rbi.org.in

To register complaints, the customers may use the channels mentioned above. If the complaint has been received in writing, AFL will endeavour to send an acknowledgement / response within a week.
Once the matter is examined, AFL endeavours to either send a final response to the customer or an intimation seeking more time within one month upon receipt of complaint.
Complaints that are received at our end will be seen in the right perspective and would be analysed from all possible angles.
The communication of AFL’s stand on any issue will be provided to the customers. Complaints that require some time for examination of issues involved will be acknowledged promptly.
The aforesaid policy will be reviewed periodically /revised as and when there are any new changes incorporated by AFL in handling complaints / grievances of the customer which includes introduction of new grievance channels, if any.
This Fair Practices Code will be available on the website of the company, for the information of its Borrowers and various stakeholders. Any enhancement(s) or change(s) in the scope of this code will be uploaded from time to time in future on the said website.

Privacy Policy

Use of Information and Materials
The information contained in this website is for general information purposes only "as is" basis without any representations or warranties. While we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk. By accessing this site and any pages thereof, you agree to be bound by the terms and conditions below. If you do not agree to the terms and conditions below, do not access this site or any pages thereof.

Terms of use
The information and materials contained in these pages - and the terms, conditions, and descriptions that appear - are subject to change. Not all products and services are available in all geographic areas. Your eligibility for particular products and services is subject to final Axis Finance Limited determination and acceptance. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them. Every effort is made to keep the website up and running smoothly. However we take no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control. This web site and its contents is copy right of Axis Finance Limited. All rights are reserved. Nothing on this website constitutes, or is meant to constitute, advice of any kind. If you require advice in relation to any financial matter you should consult an appropriate professional.

Limitation of Liability
In no event will Axis Finance Limited be liable for any damages, including without limitation direct or indirect, special, incidental, or consequential damages, losses or expenses arising in connection with this site or use thereof or inability to use by any party, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Axis Finance limited, or representatives thereof, are advised of the possibility of such damages, losses or expenses. Hyperlinks to other internet resources are at your own risk; the content, accuracy, opinions expressed, and other links provided by these resources are not investigated, verified, monitored, or endorsed by Axis Finance Limited.

Submissions
All information submitted to Axis Finance Limited via this site shall be deemed and remain the property of Axis Finance Limited. Axis Finance Limited shall be free to use, for any purpose, any ideas, concepts, know-how or techniques contained in information a visitor to this site provides Axis Finance Limited through this site. Axis Finance Limited shall not be subject to any obligations of confidentiality regarding submitted information except as agreed by the Axis Finance Limited, entity having the direct customer relationship or as otherwise specifically agreed or required by law. Axis Finance is committed to safeguard the confidentiality and security of information of the users of this web site. Axis Finance may disclose any information that is provided through this web site to: any company within the Axis Bank Group, to any other person or entity with the consent of the client, or if Axis Finance has a right or duty to disclose or is permitted or compelled to so disclose such information by law, for the time being in force. For example, Axis Finance may share/provide information with/to judicial bodies and regulatory authorities who have jurisdiction over Axis Finance. Axis Finance may also enter into agreement(s) with other company(ies) to provide services to Axis Finance or make services and products available to its clients and they may thus receive information about the users, but they may only use it for those purpose(s) that Axis Finance specifies.

No warranties
This web site, the information and materials on the site, and any software made available on the web site, are provided "as is" without any representation or warranty, express or implied, of any kind, including, but not limited to, warranties of merchantability, non-infringement, or fitness for any particular purpose or warranty of any kind, express or implied, regarding third party content. Inspite of AFL's best endeavours, there is no warranty of the website being free of any computer viruses. Some jurisdictions do not allow for the exclusion of implied warranties, so the above exclusions may not apply to you.

Unlawful use of this website We reserve the right to investigate complaints or reported violations of this Privacy Policy and to take any action as deemed appropriate including but not limited to reporting any suspected unlawful activity to law enforcement officials, regulators, or other third parties and disclosing any information necessary or appropriate to such persons, or entities relating to users profiles, e-mails, addresses, usage history, posted materials, IP addresses etc.

Governing law and jurisdiction
This website is for informational purposes only and should not be construed as technical advice of any manner and by viewing it you are deemed to agree to jurisdiction of the courts at Mumbai, India in respect of any action arising there from or related thereto.

Reasonableness
By using this website, you agree that the exclusions and limitations of liability set out in this website disclaimer are reasonable. If you do not think they are reasonable, you must not use this website.

Unenforceable provisions
If any provision of this website disclaimer is, or is found to be, unenforceable under applicable law, that will not affect the enforceability of the other provisions of this website disclaimer.

Other parties
You accept that, as a limited liability entity, we have an interest in limiting the personal liability of its officers and employees. You agree that you will not bring any claim personally against our officers or employees in respect of any losses you suffer in connection with the website.

Policy on Corporate Social Responsibility

1. The Company recognizes the importance of good corporate governance and corporate social responsibility in promoting and strengthening the trust of its shareholders and other stakeholders.

2. The CSR Policy shall be guided by the Company’s corporate vision and the aspiration to be the Company of Choice for Customers, Shareholders, Employees and Community.

3. The Company’s CSR Policy has been framed in accordance with Section 135 of the Companies Act 2013 and the rules framed thereunder. The Policy shall apply to all CSR programs undertaken/sponsored by the Company executed through Axis Bank Foundation or through any other Trust and to the contributions made by the Company to Prime Minister's National Relief Fund or any other fund set up by the Government.

CSR Purpose Statement
To make a meaningful and measurable impact in the lives of underprivileged and vulnerable communities of the country by supporting initiatives aimed at creating conditions suitable for sustainable livelihood in these communities. The Company also aims to promote literacy among the disadvantaged and differently-abled people.

CSR Guiding Principles
1. To create meaningful socio-economic impact in the lives of vulnerable and underprivileged sections of the society that include differently-abled, street children, destitute women, children of sexually exploited women and people suffering from natural disasters.
2. To create sustainable livelihood, as stated above, through interventions that facilitate access to Government’s programs, schemes and infrastructure, particularly relating to the areas of education, natural resource management, agriculture, horticulture and livestock development, micro-enterprise, vocational training and skill development.
3. To ensure project management through application of results-based management approach, focusing on appropriately defined systems and processes that measure the impact of the various projects and activities.
4. To develop as a learning organization through focus on documentation, qualitative research and dissemination to internal and external stakeholders.

CSR Program Areas

1. Axis Finance will support programs and activities in the following areas.
1.1. Education
a. Special education for the disabled:
Support basic, secondary and vocational education for children and youth with disability. Increase outreach to the disabled and provide them with access to education (at the primary, secondary and higher secondary levels) and vocational training.
b. Access to quality education for street children and children of sexually-exploited women:
Provide education to street children and children of sexually exploited women and facilitate access to age-appropriate formal education and vocational opportunities.

1.2. Vocational education and training
a. Support vocational education, life skill coaching and career counselling:
Provide orientation and handholding support to children of secondary and higher secondary level on available career options, and employable vocational and technical skills.
b. Skill development through vocational education and training:
Provide skilling, re-skilling and multi-skilling support to youth for gainful employment.

2. Livelihood enhancement and rural development
a. Natural resource management, soil and water conservation:
Management of natural resources leading to more productive outcome for agriculture and associated livelihood. Support rural and village communities through non-farm based livelihood development.
b. Access to finance/financial inclusion and entrepreneurship development:
Support creation of sustainable income sources through micro-finance and microenterprise development and strengthen mechanisms for alternative livelihood.

3. Medical relief and trauma care:
The Company has been working on providing medical relief and trauma care for victims of accidents through its Foundation. It also seeks to create a trained community of service providers who can provide immediate assistance to victims of accidents. The Company shall continue working on such programs as part of its overall contributions towards promoting healthcare.

4. Capacity building of personnel and NGO partners:
The Company will build the capabilities of its own personnel as well as that of executing and implementing agencies through training, conferences and experience sharing programmes.

5. Humanitarian relief:
The Company will support relief efforts during natural calamities in India.

6. Armed Forces Veterans:The Company will institute a program for the benefit of armed forces veterans, war widows and their dependents, widows of armed forces injured in action.


CSR Budget
1. The CSR Committee will abide by the provisions relating to annual expenditure on CSR activities as laid down in Section 135 of the Companies Act 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.
2. The surplus arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company.

Validity of CSR policy
1. The Committee may amend the CSR Policy as may be required from time to time.

Execution of CSR
1. The Company shall implement its programs through its Foundation as well as through other agencies and entities as it deems suitable for executing its strategy for CSR.

CSR Governance Structure

Roles and responsibilities: Axis Finance Board of Directors
The Board of Directors of the Company will be responsible for:
1. Approval of the CSR Policy of the Company.
2. Disclosure of the Policy in its report and placing the same on the Company’s website as prescribed under Section 135 of the Companies Act 2013.
3. Ensure that it specifies the reasons in its report for not spending the earmarked amount in case the Company does not spend such amount during the financial year.
4. It will have the power to make any change(s) in the constitution of the CSR Committee.


Monitoring and Reporting Framework
The Company will institute a well-defined monitoring and evaluation mechanism to ensure that each CSR project has:
1. Clear objectives developed out of societal needs that are determined through baselines studies and research.
2. Precise targets, time lines and measureable parameters wherever possible.
3. A progress monitoring and reporting framework aligned to the requirements of Section 135 of the Companies Act.

Budget Monitoring
1. The Company will establish an accounting system to ensure project-wise accounting of CSR spends.

Reporting Framework
1. The progress of CSR projects and expenditure will be reviewed by the CSR Committee once a quarter.
2. The Company will report on CSR performance in its annual report as per the structure and format prescribed in the notified CSR Rules.

Interest Rate Policy

Interest Rate Rationale

Policy for Determining Interest Rates, Processing & Other Charges
Reserve Bank of India ( RBI) had vide its Circular DNBS / PD / CC No. 95/ 03.05.002/ 2006-07 dated May 24, 2007 advised that Boards of Non-Banking Finance Companies(“NBFC”) to lay out appropriate internal principles and procedures in determining interest rates, processing and other charges. Further, vide circular DNBS (PD)C.C. No. 133 /03.10.001/ 2008-09 January 2, 2009, RBI advised the NBFCs to adopt appropriate interest rate models taking into account relevant factors and to disclose the rate of interest, gradations of risk and rationale for charging different rates of interest to different category of borrowers.

Keeping view of the RBI Guidelines as cited above, the following internal guiding principles and interest rate model are therefore laid out by the board of Axis Finance Limited (the “Company”). This policy should always be read in conjunction with RBI guidelines, directives, circulars and instructions. The Company will apply best industry practices so long as such practice do not conflict with or violate RBI guidelines.

The policy of the Company for determining Interest Rates, Processing and Other Charges is as follows:

Interest Rate :
Rate of interest is determined by Axis Finance on the basis of various factors including but not limited to cost of funds, matching tenure cost, return on asset required, external credit rating, internal returns threshold, regulatory policies / environment, inherent credit and default risk in the product and the clients, nature and value of primary and collateral securities, haircut margin, carrying cost, operating cost or any other relevant factor such as prevalent market lending rates in the industry, etc.

Fund Transfer Pricing (FTP) Methodology
Interest rates for assets shall be determined as under:
Minimum Rate of Interest = Matching tenor cost for the respective type of product (as narrated hereunder) plus Proportionate Operating Cost as a percentage of Assets (as calculated hereunder) plus AFL’s margin of 1.50%.

Matching Tenor Cost shall be determined as under:

ASSET TYPE MATCHING TENOR COST
(TO BE ADVISED BY CFO FROM TIME-TO-TIME)
EVENT BASED ASSETS (LIKE IPO / FPO FUNDING, OPEN OFFER FUNDING, ETC.) CP COST FOR THE 7-45 DAYS BUCKET.
MARGIN TRADE FUNDING (MTF) CP COST FOR THE 2-3 MONTH BUCKET.
LOAN AGAINST SHARES (LAS) – RETAIL LOAN AGAINST PROPERTY (LAP) – RETAIL CP COST FOR THE 6 MONTH BUCKET.[*]
LOAN AGAINST SHARES (LAS) - CORPORATE CP COST FOR THE 1 YEAR BUCKET.[*]
CORPORATE REAL ESTATE / STRUCTURED FUNDING BORROWING COST THROUGH ISSUE OF NCDS FOR THE RESPECTIVE TENOR. HOWEVER, IF THE PROPOSED LOAN TENOR IS UPTO 1 YEAR, THE MATCHING CP TENOR COST FOR THE TENOR SHALL BE CONSIDERED.

[*] or other matching maturity if need be.

Operating Cost as a percentage of Assets = Total Operating Cost for the previous financial year / Total Assets as on the last day of the previous financial year x 100.

For loans with tenor of 12 months & above, the percentage operating cost determined as above shall be considered. For loans with tenor of < 12 months, proportionate percentage operating cost shall be considered.

The sanctioning authority shall be empowered to approve a higher rate of interest for the loan / facility, subject to an overall cap of 20% p.a. Further, the sanctioning authority shall be empowered to approve a lower rate of interest for the loan / facility after adequately justifying the same in the approval note.

The interest rate and yield for each of the loan product would be decided by the Asset Liability Management Committee (ALCO Committee) from time to time considering the above mentioned factors.

The business will charge different rates of interest for different customers under similar products or different rates for the same customers under different products, depending on gradation or risk of the customer and of the products. Accordingly, the rate of interest charged is in the range of 10% to 20%.

Axis Finance adopts discrete interest rate model / policy whereby the rate of interest for each disbursement would be evaluated independently giving due consideration to any or a combination of a few or all factors listed above.

Interest rates shall be intimated to the customers at the time of sanction/ availing of the loan and the repayment schedules shall be made available to the customer.

Interest rate changes would be prospective in effect and intimation of change of interest, if any, or other charges would be communicated promptly to the customer.

Besides interest, other financial charges like processing fees, cheque bouncing charges, pre-payment / foreclosure charges, part disbursement charges, cheque swaps, cash handling charges, RTGS / other remittance charges, commitment fees, charges on various other services like issuing NO DUES certificate, NOC, letters ceding charges on assets / security, security swap & exchange charges etc. would be levied by the Company wherever considered necessary. Besides the base charges, the service tax and other cess would be collected at applicable rates from time to time. These charges would be decided by respective business heads in consultation with Operations & Financial Accounting teams.