Customer Grievance Redressal Policy

Version 1.0.0

Customer Grievance Redressal Mechanism of C2FO Factoring Solutions Private Limited 

  1. Introduction

C2FO Factoring Solutions Private Limited (“C2FO”) has adopted this Customer Grievance Redressal Policy (“Policy”), for the functioning of Trade Receivables Discounting System or TReDS platform (“C2FO TReDS Platform”) run by C2FO . Grievances and complaints received by C2FO from its clients (“Clients”) need to be redressed in an efficient and timely manner.

  1. Purpose

The purpose of this Policy is to ensure that the Client’s Grievances and complaints

are handled and replied in a suitable manner within a specified Turn Around Time (“TAT”).

  1. Scope

The Policy applies to all the types of grievances and complaints received from the Clients directly or through any Regulatory or Law enforcement authorities.

  1. Responsibility

It shall be the responsibility of the Customer Care and Grievance Officer of the Company to address the Grievances and complaints in a timely and effective manner. 

  1. Policy
  1. Definitions:

“Client(s)” shall mean the clients of the Company, who are availing the services of C2FO through the C2FO TReDS Platform by undertaking trade receivables discounting transactions.

“Company” shall mean C2FO FSPL or CFSPL.

“Grievance” shall mean and include complaint, disagreement etc. arising out of or in connection with the practices, procedures and codes, followed by CFSPL in its dealing with the parties, and shall include a dispute.

“RBI” shall mean the Reserve Bank of India.

“RBI Regulations” shall mean the notifications, circular and guidelines issued by the RBI.

“System Participants” shall have the same meaning as assigned under the Payment and Settlement Systems Act, 2007. (“PSS Act”)

  1. Regulatory Requirements:

As required by the RBI Regulations, a designated e-mail id and a dedicated customer service number shall be made available to the Clients for the purpose of registering queries/ complaints by Clients. The e-mail id and the customer service number shall be stated/ disclosed on the website of the Company. The customer service team shall have access to the said designated e-mail id and customer service number.

All complaints received from Client(s) will be allotted a ticket number and category. 

Complaints will be classified under three categories – Operational, Technical and Others. Ticket no. will be intimated to the Client(s) so that the Client(s) are able to get an update on their ticket from the customer service dept.

All complaints shall be replied/resolved by the customer service department in consultation with CFSPL’s Compliance Officer and within a stipulated TAT for each category. The Client shall be intimated in case of delay and steps shall be taken for redressal of the same by the customer service department. The intimation shall also mention about the likely TAT within which the complaint will be resolved. Where the complaints are received by post/courier, the actual TAT shall commence from the date of receipt of the same.

The database of all the complaints shall be maintained detailing the date of receipt of complaint, name and address of the entity/person initiating the complaint along with contact details, particulars of complaint, amount claimed, date of reply, resolution date, brief description of the redressal provided, whether referred to arbitration, name of the person who handled the complaint, etc.

  1. Complaints received from Clients through RBI/consumer protection courts/Economic Offense Wing/other regulatory authorities:

On receipt of a complaint from regulatory authorities, the customer Service department shall co-ordinate with the nodal person of the concerned departments. including customer service team, where the issue has originated and shall collect the relevant facts and data pertaining to the complaint. It shall include the records of the correspondence exchanged with the Client and call recordings, if any.

  1. Arbitration:

Where the Client refers the matter to arbitration as defined in PSS Act , written submissions shall be drafted and submitted to the RBI by Legal/Compliance officer before the stipulated due date after analyzing the matter and collecting the records, documents applicable to the matter.

In accordance with, section 24 of PSS Act; 

  1. C2FO shall create a panel consisting of not less than three System Participants other than the System Participants/Clients who are parties to the dispute to decide the disputes between System Participants/Clients in respect of any matter connected with the operation of the payment system.
  2. Where any dispute in respect of any matter connected with the operation of the payment system arises between two or more System Participants/Clients, CFSPL shall refer the dispute to the panel referred to in sub-section 1 above.
  3. Where any dispute arises between any System Participant/Clients and CFSPL or where any of the System Participants/Clients is not satisfied with the decision of the panel referred to in sub-section 1 above, the dispute shall be referred to the RBI.
  4. The dispute referred to the RBI for adjudication under sub-section 3 above shall be disposed of by an officer of the RBI generally or specially authorized on this behalf and the decision of the RBI shall be final and binding.
  1. Complaint Register:

An electronic/physical complaint register shall be maintained by the customer service department, wherein details of the complaints shall be recorded. The data shall be maintained and updated in electronic/physical form by the customer service department. CFSPl will retain the records pertaining to customer interactions for a period of ten (10) years or till complete resolution of the Grievance, subject to applicable laws. 

  1. TAT and Escalation Matrix

This is applicable for all categories of complaints – Operational, Technical and Others.

Step 1: Complaint Redressal

For complaints received through any channel including through the portal or through e-mail, call center, etc. customer response will be provided within two working days by TReDS.

Customer Grievances can be emailed to - grievance.support@c2treds.com or they can be reached on 1800-309-1192

Step 2: Write to Head - Customer Service

We aim to resolve all complaints at the first point of contact. If the customer is not satisfied with the first resolution or response, the same shall be immediately escalated to the Head - Customer Service who shall respond and attempt to resolve within eight working days.

Step 3: If the customer is still not satisfied with the resolution provided, the7 same shall be escalated to the Managing Director ("MD”) of CFSPL.

All customer escalations which remain unresolved for more than ten days shall be reported on a weekly basis to the MD and CEO of CFSPL  for review.

Escalation Matrix
EscalationLevelCategoriesAuthorityAction
Level 1Operations, Technical &OthersCustomer Support TeamResponse to be provided to the customer within two (2) working days.
Level 2Operations, Technical & OthersHead - Customer Service (Designated as GrievanceOfficer)If the query remains unresolved within  two (2) working days, it will be escalated to Head - Customer Service who will respond within eight(8) working days.
Level 3Operations, Technical & OthersMD, CFSPLIf the query remains unresolved for more than ten (10) working days, it will be escalated to MD CFSPL, who will respond within 24 working days.

Monthly MIS of the complaints shall be reported within 10th of the next month by the Customer Service Department to the Grievance Committee which will be headed by GM of C2FO. If there is any pending complaint for more than one month then MD CFSPL shall be consulted for effective closure of the complaint.

  1. Review - The Policy shall be reviewed for its effectiveness at regular intervals and amendments shall be made as required and in case of change in regulatory requirements.