The Code has seven elements:

• Dhanam will ensure to disburse the loan commensurate with the borrower's ability to repay. It will ensure a limit of maximum 50 percent on the outflows on account of repayment of monthly loan obligations of a household as a percentage of the monthly household income.
• The computation of loan repayment obligations shall consider all outstanding household loans.
• Dhanam will ensure that the interest rates and other charges/fees on microfinance loans are not usurious, and there will not be any prepayment penalty charges.
• Dhanam will ensure that the household income is computed correctly by considering the income of the borrower, spouse, and unmarried adult children.
• Dhanam will use a valid CCIR (Comprehensive Credit Information Report) for the borrower and all the household members of the borrower before sanctioning any loan. Further, such a valid CCIR must be used for all loans including small value top-up loans, and second and subsequent cycle loans.
• Dhanam will ensure that the CCIR remains current and valid. Dhanam shall mandatorily submit timely (preferably daily) and accurate information including household income and other parameters to the Credit Information Companies (CICs).
• Dhanam will not sanction/disburse a loan to a borrower with non-performing (delinquency > DPD 90 days) accounts with another RE or any other microfinance provider.

Dhanam will provide key information to the borrower and include it in the loan documents, such as the loan application, loan agreement, and loan card. This must include:

• Identity and address of the RE.
• Identity and address of the borrower.
• Product details (simplified factsheet on pricing in the format specified in the RBI regulations, including instalments received, the final discharge, and other vital terms and conditions).
• Details of customer grievance redressal system.

• Dhanam will ensure that the issuance of third-party products is done with the full consent of the borrowers, kept voluntary, and the fee structure for such products is explicitly communicated to the borrower.
• Dhanam will communicate with the borrower in vernacular/a language understood by the borrower. The communication could pertain to the terms and conditions of the loan, entries in the loan card, fair practices code, standard form of loan agreement, factsheet on pricing of the microfinance loan, and other such communication pertaining to the loan and non-credit products and their servicing.
• Dhanam will take measures (such as training, assessment, and periodic interactions with borrowers) to ensure that borrowers fully understand the contract's products, process, and terms.
• Dhanam will provide a receipt/acknowledgement for every payment, including the digital payments, received from the borrower.
• Dhanam will emphasise educating customers on the importance of timely repayment for good credit history with the CICs, benefits, risks and necessary safeguards of digital financial transactions and grievance redressal mechanism including internal and external escalation mechanism.
• Dhanam will educate customers against blind trust on group and centre leaders and how any default in the fictitious loan (also referred to as ghost lending/pipelining taken by group/centre leader in customer's name) can ruin her credit records and access to credit in the future. This should be a part of the Group Recognition Training (GRT) and Compulsory Group Training (CGT). Dhanam staff shall strive to ensure customer attendance in the group meetings. Any training offered to customers should be free of cost.
• Dhanam will disclose the reason to the customer if her loan is rejected.

• The Company must obtain copies of KYC documents from customers as per RBI norms.
• The Company must upload accurate and comprehensive customer data with all RBI approved Credit Information Companies' (CICs) as per the Uniform Credit Data Format on a daily basis.
• Dhanam will take the borrower's consent to check her CCIR and her acceptance of the terms and conditions of the loan. Consent will also be obtained from the borrower's household members to check their CCIRs per the extant regulations and laws.
• Dhanam will promptly address any dispute raised by the borrower about her data with CICs.
• Dhanam will have systems to safeguard borrower and borrower household members' data as per the accepted principles of data protection including collection limitation, purpose specification, use limitation, incorporation of access controls etc.

• Dhanam has a board-approved customer grievance redressal policy covering the process to register, resolve and escalate the complaints, internal and external escalation mechanism, complaint categories and TAT, review/audit of the redressal system, and reporting to the board and top management.
• Dhanam will provide a robust customer grievance redressal system to address complaints effectively and promptly. It will provide easy access to the redressal system to all its borrowers through a dedicated phone number or a staff-assisted procedure at the branch to register grievances.
• Dhanam will clearly communicate the details of the customer grievance redressal system in branches, loan documents, and other communication materials.
• Dhanam will have a mechanism as part of its grievance redressal framework for the redressal of recovery-related grievances, the details of which must be provided to the borrower at the time of loan disbursal. The idea is to identify and promptly address recovery-related grievances.
• Dhanam has a Principal Nodal Officer to oversee the customer grievance redressal function.
• Dhanam will record and analyse individual and aggregate level data for grievance redressal systems, capturing the nature of complaints, action taken, and turn-around time. Reports on grievances received, resolved, and pending along with the nature of complaints should be shared with the board for review.

• Dhanam will recruit a candidate from another RE based on a satisfactory reference check and will not confirm the employee without a relieving letter from the previous employer.
• Dhanam will participate in the Employee Bureau to submit its employee's data and check candidate's employment records.
• Dhanam will give comprehensive induction training to the employees on policies, processes, and regulations. Emphasis will be given to CoC related aspects on borrower-interface aspects such as fair treatment, household and income assessment, the privacy of data, service quality, customer grievance redressal system, POSH, relationship management, dealing with borrower facing difficulty in repayment, etc.
• Dhanam will regularly assess employee's understanding of the above elements and conduct refresher training to address the gaps in understanding.
• Dhanam will train its employees on understanding and dealing with gender issues, including appropriate interaction with women colleagues and customers.
• Dhanam will orient its employees on professional conduct and integrity issues, including expected behaviour and not indulging in unlawful and anti-social activities.
• Dhanam will engage new employees in branch-level business operations only after completion of their induction training.
• Dhanam will ensure that employees directly responsible for the grievance redressal system receive detailed training about the system, processes, and soft skills required for resolving complaints.
• Dhanam will set targets for the branch-level employees based on reasonable objective criteria, including an understanding of microfinance requirements and repayment capacity in an area.
• Dhanam will have a well-defined protocol to be followed by employees to handle risks arising from going to difficult areas and cash handling.
• The staff's Compensation matrix will be designed to align their behaviour with fair interaction practices, as mentioned in this COC.
• While recruiting an employee, Dhanam will honour the notice period as mutually agreed between the prospective employee and his/her current employer.
• Dhanam will respond to requests from other RE/microfinance providers for reference checks within 15 calendar days/a reasonable time-period from the receipt of such communication.