I.  INTRODUCTION

Sehgal Televisions Private Limited (“the Company”), a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India, carries on its digital lending business under the brand name “Just Rupee” (the “Platform”). The Company regards customer satisfaction as central to its operations and has framed this Grievance Redressal Policy (“Policy”) to give every customer a clear, accessible and time-bound way to raise complaints, seek resolutions, and share feedback about their dealings with Just Rupee.

This Policy has been framed with reference to the following regulatory requirements:

–    Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, as amended from time to time;

–    Guidelines on the Fair Practices Code for Non-Banking Financial Companies issued by the Reserve Bank of India;

–    The Reserve Bank – Integrated Ombudsman Scheme, 2021;

–    The Reserve Bank of India’s Digital Lending Directions, 2025.

Any circular, amendment or clarification issued by the RBI from time to time on this subject shall be treated as forming part of this Policy to the extent it applies.

II.  OBJECTIVES OF THE POLICY

The Company believes that quick and fair grievance handling is key to earning and keeping customer trust. This Policy aims to:

1. Treat every customer fairly, equally and with respect at all times;
2. Address complaints promptly, courteously and without avoidable delay;
3. Give priority attention to complaints from senior citizens, pensioners and persons with disabilities;
4. Keep customers aware of every escalation route open to them within the Company, and of their right to seek other remedies if still dissatisfied;
5. Handle every complaint efficiently and fairly, safeguarding both the Company’s standing and the customer’s interest;
6. Ensure that every employee acts in good faith, without bias, and in the customer’s best interest.

Any customer dissatisfied with the services of Just Rupee, or of any person acting on the Company’s behalf, may lodge a complaint under this Policy.

III. SCOPE OF THE POLICY

This Policy applies to:

1. All offices, functions and operations of Just Rupee;
2. Every employee of the Company, whether permanent or engaged on a contractual basis;
3. All customer-facing activity carried out through the Just Rupee Platform or otherwise.

For the purposes of this Policy:

“Customer” means any person who has availed, or applied for, a loan or service through the Just Rupee Platform or any other channel operated by the Company.

“Complaint” means any written or electronic communication expressing dissatisfaction or alleging a deficiency concerning:

–    The services, products, policies or procedures of the Company;

–    The conduct of the Company’s employees, or of persons acting for the Company, in their dealings with customers;

–    The confidentiality, safety or security of a customer’s personal, sensitive personal, or financial information.

IV. CORE COMMITMENTS

Fair and Transparent Dealings

–    Every product and service offered through Just Rupee complies with applicable law and regulatory requirements;

–    All customer interactions are carried out honestly, transparently and with integrity;

–    Our systems and processes are designed and run keeping the customer’s interest at the centre.

Customer Assistance and Information

–    Customers are given relevant information about products and services in English or in a local language of their choosing;

–    The financial implications of any product or service are explained clearly before the customer commits to it;

–    Customers are helped to identify the product or service best suited to their needs.

Error Rectification

Where an error, omission or lapse occurs on the Company’s part, the following steps are taken as a priority:

–    Prompt correction of the error;

–    Redressal of the customer’s complaint;

–    Guidance to the customer on further escalation, if they remain dissatisfied;

–    Reversal of any charge, including interest, wrongly levied because of the Company’s error or lapse.

V.  GROUNDS FOR FILING A COMPLAINT

A customer may submit a written complaint clearly describing the grievance or deficiency. Grounds for a complaint include, without limitation, those recognised under Clause 8 of the Reserve Bank – Integrated Ombudsman Scheme, 2021 and the Ombudsman Scheme for NBFCs, such as:

1. Failure to communicate the sanctioned loan amount and its terms in writing, including the annualised rate of interest and how it is applied;
2. Failure or refusal to issue a sanction letter or the applicable terms and conditions;

III.     Unreasonable delay in returning security documents once all dues under a loan have been repaid, levy of charges without adequate prior notice, or the absence of a valid repossession clause in the loan agreement;

1. Non-compliance with any direction issued by the Reserve Bank of India applicable to NBFCs;
2. Non-adherence to any provision of the RBI’s Fair Practices Code guidelines for NBFCs, or of Just Rupee’s own Fair Practices Code.
   
   
   VI. HOW TO FILE A COMPLAINT

Just Rupee maintains a Grievance Redressal Mechanism (“GRM”), approved by its Board of Directors, under which every dispute arising from a decision of the Company’s staff is heard, and if unresolved, taken up at the next higher level.

Level 1: Customer Engagement Team

For any service request or complaint, customers may write to the customer engagement team at care@justrupee.com.

On receiving a request or complaint, the Company will send an acknowledgement within 3 (three) working days by email, letter, SMS, WhatsApp or any other valid electronic mode, and will aim to resolve the matter within 7 (seven) working days. Where a complaint calls for detailed investigation, cooperation from the customer to trace the person responsible, root-cause analysis, or is under litigation (including a matter pending before the police), resolution may reasonably take longer than 7 working days.

If the customer remains dissatisfied with the response given at Level 1, the matter may be escalated to Level 2.

Level 2: Grievance Redressal Officer

Customers must first approach the customer engagement team as described under Level 1. If the complaint is not resolved within 7 days, or the customer is unhappy with the response received, they may write to the Grievance Redressal Officer (GRO) of Just Rupee at gro@justrupee.com.

Grievance Officer: Just Rupee (Sehgal Televisions Private Limited)

Working Hours: Monday to Friday, 10:00 AM to 6:00 PM

The Company will make every effort to resolve complaints at this level within the next 7 working days. If the customer is dissatisfied with the GRO’s decision, or the complaint is rejected by the GRO’s office, an appeal may be filed within 30 days of receiving the decision or rejection, with:

Consumer Education and Protection Department, Reserve Bank of India

A complaint may also be lodged through the RBI’s Complaint Management System (CMS) portal at https://cms.rbi.org.in, or, for reporting fraud or unregulated lending entities, through the Sachet portal at https://sachet.rbi.org.in.

The Company follows the Reserve Bank – Integrated Ombudsman Scheme, 2021 (“Scheme”), as amended, in full. For the benefit of customers, the key features of the Scheme are summarised below. A complaint under the Scheme may be filed:

–    Online, through the Integrated Ombudsman portal at https://cms.rbi.org.in;

–    By email, to CRPC@rbi.org.in;

–    In physical form, at the Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160017;

–    Through the toll-free helpline 14448 (9:30 a.m. to 5:15 p.m.), available in Hindi, English and regional languages.

VII. REVIEW OF THE POLICY

This Policy will be reviewed, and revised where necessary, by the Board of Directors of Sehgal Televisions Private Limited. The Company may amend this Policy at any time to reflect a change in law, a regulatory direction, or its own governance requirements. If any part of this Policy conflicts with applicable law or an RBI direction, the law or direction will prevail.