Grievance Redressal Policy

1. Scope and Applicability

This Grievance Redressal Policy ("Policy") applies to Ayuda Solutions and all its employees, agents, contractors, and sub-processors engaged in the delivery of Business Process Outsourcing (BPO) services on behalf of regulated financial institutions, including but not limited to:

• Non-Banking Financial Companies (NBFCs) — including Micro-Finance Institutions (NBFC-MFIs), Housing Finance Companies (HFCs), and Investment and Credit Companies (NBFC-ICCs)
• Banks and Scheduled Commercial Banks (SCBs)
• Insurance companies, Insurance Brokers, and Insurance Repositories
• Asset Management Companies (AMCs), Mutual Fund Distributors, and Portfolio Management Services
• Payment Aggregators, Payment Gateways, and Prepaid Payment Instrument (PPI) issuers
• Fintech companies operating under an RBI sandbox or regulatory framework

This Policy governs grievances raised by end-customers of Ayuda Solutions' BFSI clients, where Ayuda Solutions acts as the Outsourced Service Provider (OSP). It supplements and does not supersede the grievance policies of the client financial institution, which retain primary regulatory accountability.

2. Policy Objectives

This Policy has been formulated to:

• Ensure every customer grievance is acknowledged, registered, and resolved within prescribed timelines
• Protect the interests and rights of customers of NBFC/BFSI clients for whom Ayuda Solutions provides outsourced services
• Establish a transparent, accessible, and multi-channel grievance mechanism
• Define a clear escalation hierarchy with accountability at each level
• Ensure compliance with RBI guidelines on outsourcing, the NBFC Ombudsman Scheme 2018, and the Digital Personal Data Protection (DPDP) Act 2023
• Maintain comprehensive records of all grievances for audit, reporting, and continuous improvement purposes
• Enable the client financial institution to fulfil its regulatory reporting obligations to the RBI and other statutory bodies

3. Definitions

• Grievance / Complaint: Any expression of dissatisfaction by a customer about the service rendered by Ayuda Solutions on behalf of a BFSI client, where the customer seeks a response or resolution.
• Customer: An individual or entity who is an existing or prospective customer of the BFSI client on whose behalf Ayuda Solutions operates.
• OSP (Outsourced Service Provider): Ayuda Solutions, acting under a contractual arrangement with a regulated financial institution.
• Nodal Officer: The designated point-of-contact at Ayuda Solutions responsible for receiving, tracking, and escalating grievances for a specific client engagement.
• Principal Grievance Officer (PGO): The senior officer at Ayuda Solutions with overall responsibility for grievance redressal governance across all BFSI engagements.
• TAT (Turnaround Time): The maximum permissible time period within which a grievance must be resolved or escalated.
• NBFC Ombudsman: The authority appointed by the RBI under the NBFC Ombudsman Scheme 2018 to handle unresolved complaints against NBFCs.
• DPDP Act: The Digital Personal Data Protection Act, 2023 (India), governing the processing of digital personal data.

4. Grievance Receipt Channels

Ayuda Solutions ensures that customers can submit grievances through multiple accessible channels, as mandated by client contracts and applicable RBI guidelines:

4.1 Direct Channels (Ayuda Solutions Operations)

• Voice / IVR: Dedicated toll-free or DID lines operated by Ayuda Solutions' contact centre agents for the client engagement, available as per contracted service hours
• Email: Dedicated grievance email addresses configured per client engagement (e.g., grievance.[clientcode]@ayudasolutions.com)
• Written / Postal: Complaints submitted in writing to Ayuda Solutions' registered office or any client-designated branch address
• Chat / Messaging: Where applicable, via live chat or messaging platforms operated by Ayuda Solutions on behalf of the client
• In-Person: Walk-in customers at client branch locations where Ayuda Solutions staff are embedded

4.2 Client-Owned Channels (Forwarded to Ayuda Solutions)

• Client's website grievance portal or mobile application
• Client's branch network and customer-facing staff
• Complaints forwarded by the client's internal Nodal Officer or Compliance team
• Regulatory forwarding from RBI, NBFC Ombudsman, or SEBI

All channels must ensure that the receipt of a grievance is acknowledged to the customer within 24 hours of submission, with a unique reference / ticket number.

5. Escalation Matrix and Timelines

All grievances are handled through a structured three-tier escalation model in alignment with RBI guidance for NBFC outsourcing:

Tier	Handler	Acknowledgement	Resolution TAT	Escalation Trigger
Tier 1	Front-line Agent / Team Lead (Ayuda Solutions Operations)	Within 24 hours of receipt	Within 7 calendar days	Unresolved or customer dissatisfied after 7 days
Tier 2	Nodal Officer — Ayuda Solutions (per client engagement)	Immediately upon escalation	Within 15 calendar days of original complaint	Unresolved after 15 days; or regulatory / legal threat; or repeat complaint
Tier 3	Principal Grievance Officer (PGO) — Ayuda Solutions + Client Compliance Head	Immediately upon escalation	Within 30 calendar days of original complaint	Unresolved after 30 days → Customer may approach NBFC Ombudsman / RBI CMS

5.1 Priority Classification

Grievances are classified by severity to govern handling priority:

• Critical (P1): Involves financial loss, fraud, identity theft, loan harassment, data breach, or a regulatory complaint filed with RBI / SEBI / IRDAI. TAT: 24 hours. Immediate escalation to PGO and client Compliance Head.
• High (P2): Billing disputes, EMI deduction errors, KYC rejection without cause, unlawful recovery calls, or repeated failed service requests. TAT: 7 days.
• Medium (P3): Service quality issues, incorrect information provided, delays, or failed digital transactions not involving immediate financial loss. TAT: 15 days.
• Low (P4): General queries misclassified as complaints, feedback, or suggestions. TAT: 7 days for closure or reclassification.

6. Nodal Officer & Principal Grievance Officer

6.1 Nodal Officer (per Client Engagement)

For each NBFC/BFSI client engagement, Ayuda Solutions designates a Nodal Officer who is responsible for:

• Acting as the single point of contact for Tier 2 escalations from that client engagement
• Coordinating with the client's internal grievance team and compliance officer
• Maintaining the grievance register for that engagement
• Submitting periodic grievance reports to the client as contractually agreed
• Ensuring timely closure and documentation of all escalated cases

The Nodal Officer details for each engagement are communicated to the client in writing at the commencement of the contract and updated within 7 days of any change.

6.2 Principal Grievance Officer (PGO)

The Principal Grievance Officer holds overall governance responsibility for grievance redressal across all BFSI engagements at Ayuda Solutions. The PGO's responsibilities include:

• Overseeing Tier 3 escalations and ensuring final resolution
• Reviewing the monthly Grievance Summary Report across all engagements
• Ensuring this Policy remains current and compliant with regulatory changes
• Liaising with client Compliance Heads and regulatory authorities where required
• Approving remediation actions and systemic fixes arising from complaint trend analysis

Principal Grievance Officer — Ayuda Solutions
Email:
Phone: +91 9931812910
Address: C/O MIMEC IT PARK, 5th Floor, Plot No. 3/P, Industrial Area, Namkum, Ranchi 834010, Jharkhand, India

7. Grievance Handling Process

7.1 Receipt and Acknowledgement

• All incoming grievances are logged in the designated CRM / Grievance Management System (GMS) within 2 hours of receipt
• A unique grievance reference number is generated and communicated to the customer within 24 hours via the channel through which the complaint was received
• The acknowledgement must state the name of the handling agent, the expected resolution date, and the Nodal Officer contact details

7.2 Investigation

• The assigned agent or Nodal Officer conducts a thorough investigation, including reviewing call recordings, transaction logs, CRM notes, and correspondence
• Where the grievance involves a financial discrepancy, the Finance or Operations team lead is looped in within 24 hours
• For complaints involving alleged misconduct by Ayuda Solutions staff, a parallel HR investigation is initiated

7.3 Resolution and Communication

• The resolution must be communicated to the customer in clear, plain language — avoiding financial or technical jargon
• Where a complaint cannot be fully resolved, the customer must be informed of the reason, the steps being taken, and the revised expected resolution date
• All resolutions and closures must be documented in the GMS with outcome codes
• For monetary resolutions (refunds, fee waivers), a confirmation from the client's Finance team is required before communicating to the customer

7.4 Closure

• A grievance is deemed closed only when (a) the customer confirms satisfaction, or (b) the prescribed TAT expires without further response from the customer after a final resolution communication is sent
• Forced closure without customer confirmation is not permitted for P1 (Critical) complaints
• All closed grievances are retained in the GMS for a minimum of 5 years from the date of closure, as required for regulatory audit purposes

8. Regulatory Escalation Pathways

If a grievance remains unresolved after exhausting the internal three-tier mechanism, customers of BFSI clients have the following regulatory escalation options. Ayuda Solutions is required to inform customers of these rights and must cooperate fully with regulatory authorities:

• NBFC Ombudsman (RBI): Customers may file complaints at cms.rbi.org.in under the Centralised Receipt and Processing Centre (CRPC) or via the RBI NBFC Ombudsman Scheme 2018.
• RBI Integrated Ombudsman Scheme (RBI IOS 2021): For complaints against banks, NBFCs, payment service providers, and digital lending apps operating under RBI.
• SEBI SCORES: For grievances related to securities, mutual funds, or capital market intermediaries (scores.gov.in).
• IRDAI Bima Bharosa: For insurance-related complaints (bimabharosa.irdai.gov.in).
• Consumer Courts: Under the Consumer Protection Act, 2019, customers may approach District, State, or National Consumer Dispute Redressal Commissions.
• Data Protection Board (DPDP Act 2023): For grievances related to unauthorised processing of personal data, the customer may approach the Data Protection Board of India once it is constituted.

9. Data Privacy and Confidentiality

All grievance-related data constitutes personal data under the Digital Personal Data Protection (DPDP) Act, 2023 and is handled with the following safeguards:

• Grievance data is collected only for the purpose of resolving the complaint and fulfilling regulatory obligations
• Access to grievance records is restricted on a need-to-know basis; agents can only access records relevant to their assigned cases
• Grievance data is stored in encrypted form and is not shared with any third party except as required by law, regulation, or explicit client instruction
• Customers have the right to request access to their grievance history under applicable data protection law
• Retention of grievance records follows the schedule outlined in Section 7.4 (minimum 5 years), after which records are securely destroyed
• Any data breach affecting grievance records is treated as a Critical (P1) incident and notified to the client and applicable regulatory authority within 72 hours, in compliance with the DPDP Act and RBI cybersecurity guidelines

10. Staff Training and Awareness

Ayuda Solutions ensures that all staff involved in customer-facing BFSI processes receive appropriate and ongoing training:

• Induction Training: All new agents handling NBFC/BFSI processes undergo mandatory training on this Policy, applicable RBI guidelines, client-specific grievance SOPs, and the DPDP Act before going live on the floor.
• Refresher Training: Quarterly refresher sessions covering policy updates, regulatory changes, and case studies from recent escalations.
• Quality Audits: Grievance calls and written responses are audited by the Quality Assurance team. A minimum of 10% of all P1/P2 grievance interactions are mandatorily reviewed each month.
• Compliance Certification: Nodal Officers and team leads are required to complete annual compliance certification on RBI outsourcing guidelines and NBFC regulations.
• Prohibited Conduct: Staff are strictly prohibited from discouraging customers from filing complaints, making misleading statements about the escalation process, or engaging in coercive recovery practices that contravene RBI Fair Practices Code.

11. Monitoring, Reporting & Audit

11.1 Internal Monitoring

• Real-time dashboards track open grievance counts, TAT adherence, and escalation rates per client engagement
• Breach alerts are triggered automatically when a grievance approaches 80% of its TAT without resolution
• Daily stand-up reviews are conducted for all P1 and P2 open cases by the Nodal Officer

11.2 Reporting to Clients

• Daily: Exception report for all new P1 Critical grievances
• Weekly: Open grievance ageing report with status and resolution notes
• Monthly: Grievance Summary Report — total volume, category-wise breakdown, TAT adherence rate, root cause analysis, and corrective actions
• Quarterly: Trend analysis and process improvement recommendations submitted to client Compliance team

11.3 Regulatory Reporting

Ayuda Solutions supports its NBFC/BFSI clients in meeting their regulatory reporting obligations, including but not limited to:

• Providing grievance data in the format required for the NBFC's Annual Report to the RBI
• Supporting the client's submission under RBI's Complaint Management System (CMS)
• Furnishing records and audit trails for RBI/SEBI/IRDAI inspections or special audits

11.4 Internal Audit

• The Grievance Redressal function is subject to an annual internal audit by Ayuda Solutions' Compliance team
• Findings and corrective action plans are reviewed by senior management and shared with the client's compliance team
• The PGO must present a grievance governance report to the Ayuda Solutions leadership committee at least once per year

12. Policy Review

This Policy is reviewed at least annually, or earlier in the event of:

• Material changes to applicable RBI, SEBI, or IRDAI guidelines governing outsourcing or grievance redressal
• Enactment or amendment of the DPDP Act or related rules
• Significant changes in the nature or volume of BFSI client engagements
• Regulatory observations or adverse findings during an inspection

All revisions to this Policy are version-controlled. The current version supersedes all previous versions. Updates are communicated to all relevant staff and Nodal Officers within 7 days of approval.

13. Contact Details

For grievances related to Ayuda Solutions' BPO services in NBFC/BFSI engagements, please contact:

Principal Grievance Officer — Ayuda Solutions
Email:
Phone: +91 9931812910
Address: C/O MIMEC IT PARK, 5th Floor, Plot No. 3/P, Industrial Area, Namkum, Ranchi 834010, Jharkhand, India
Grievance Portal: www.ayudasolutions.com/contact

For regulatory escalations pertaining to NBFC complaints, customers may also contact:

Reserve Bank of India — Centralised Receipt and Processing Centre (CRPC)
Portal: cms.rbi.org.in
Toll-Free: 14448