Introduction

Matters relating to customer service are required to be deliberated by the board to ensure that the instructions issued by Reserve Bank of India on Customer Service are implemented in its true spirits. Commitment of hassle-free customer service at large and the common person in particular are the major responsibility of the Board.

This policy meets the regulatory requirement and explain in detail the Customer Service framework put in place by the bank in line with the guidelines applicable to payments banks.

Objective

The key objectives of the policy are as under:

• Ensure courteousness, fairness and reasonableness in all the dealings with the customers.
• Ensure transparent communication of information pertaining to products, services and related procedures.
• Ensure privacy and confidentiality of customer information.
• Handle customer complaints quickly and empathetically.
• Review product approval process with respect to suitability and appropriateness for the customers.
• Formulate mechanism for implementation and adherence to the Fair Practices Code including matters such as transparent communication regarding the service charges, processing fees and interest rates, non-discrimination between customers and redressal of customer complaints.
• Facilitate continuous improvement in quality of the customer service in the Bank.
• Take steps proactively to protect customer’s interests.

Applicability

This Policy is applicable to all customers of the Airtel Payments Bank.

Branch Level Customer Service Committee

Branch Level Customer Service Committee of the Board acts as a forum to enable customers to meet and interact with the Bank Staff and provide feedback on services provided by the Bank and help in building trust amongst the customers. This committee consists of the Branch staff and customers of the Branch (including one senior citizen customer).

Customer Service Committee of the Board

The members of Customer Service Committee of the Board, interalia, include learned independent directors. An illustrative role of the Customer Service Committee are as under:

• Formulation of comprehensive deposit policy, customer service policy and customer communication strategies of the bank.
• Ensure customers are treated fairly all the times and complaints raised by them are dealt with courtesy and in time; examine any other issues having a bearing on the quality of customer service rendered.
• Monitoring the implementation of awards under the Banking Ombudsman Scheme.
• Submit a detailed memorandum to the Board of Directors, once every six months, on review of customer service / customer care aspects including initiation of prompt corrective action wherever service quality / skill gaps have been noticed.
• Formulate and approve Fair Practices Code to customers and oversee implementation of commitments towards customers.
• Ensure that all regulatory instructions regarding customer service are followed by the Bank.
• Carry out any other function as is referred by the Board from time to time or enforced by any statutory notification / amendment or modification as may be applicable.
• Deliberate and review the awards given by the Banking Ombudsman and all the awards remaining unimplemented for more than three months with the reasons thereof.

Standing Committee on Customer Service

This body consists of senior management officials of the Bank.

The Committee focuses on building and strengthening customer service orientation in the Bank through initiating various measures including simplifying processes for improvement in customer service levels. The Committee holds periodic meetings to discuss service updates, ongoing projects specifically targeted towards improvement of customer service and appropriate actions arising from discussions.

The Committee carries out the following specific functions:

• Evaluate feedback on quality of customer service received. 
• Review the practice and procedures prevalent in the bank and take necessary corrective action, on an ongoing basis by ensuring through formulation of procedures and operational practices.
• Review comments/feed-back on customer service and implementation of Bank’s Code of Commitments to Customers formulated by Banking Codes and Standards Board of India (BCSBI).
• Review complaints related to non-compliance of Code of Commitment.

Channels for Raising Complaints

The Vision of the bank is to enrich the lives of its customers. It strives to enhance its customer experience and build a lasting relationship by delivering better results every time. Customer service is a priority objective along with profit, growth and fulfillment of social obligations. Towards this objective the bank, has this board approved policy covering the following sub-policies.

• Comprehensive Deposit Policy : The important functions of the Payments Bank are to accept deposits from the public, facilitate financial inclusion and enable the account holders to participate in the banking services. This policy document outlines the guiding principles in respect of formulation of various deposit products offered by the bank and terms and conditions governing the conduct of the account. The deposit policy recognizes the rights of depositors and aims at dissemination of information with regard to various aspects of acceptance of deposits, conduct and operations of various deposits accounts, etc.
• Customer Compensation Policy : Airtel Payments Bank offers high levels of service to its customers. In the event, for  reasons beyond the control of the bank or inadvertently, the bank is unable to meet the service levels committed in the dealings with individual customer, compensation policy will be applicable. The Compensation policy is therefore, designed to cover areas relating to unauthorized debiting of account, remittances within India, foreign exchange services, etc. The policy is based on principles of transparency and fairness in the treatment of customers.
• Customer Grievance Redressal Policy : Airtel Payments Bank believes that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. This policy document aims at minimizing instances of customer complaints and grievances through proper service delivery, review mechanism and to ensure prompt redressal of customer complaints and grievances The policy document highlights important points viz. complaint, complaint registration process, complaint management system, timeline for resolution, escalation matrix and the stakeholders entrusted with the task of implementing this policy.

Dissemination of Bank's Policies

Airtel Payments Bank will ensure that wide publicity is given to its policies by placing them prominently on the web-site and its salient features at its branches/touch points. The customers are clearly apprised of the assurances of the bank on the services on these aspects at the time of establishment of the initial relationship as a depositor. The bank will also take necessary steps to keep the customers duly updated of the changes in the important policies applicable to customers through various channels.

Rights of Transgenders Persons

Airtel Payments Bank ensures to include ‘third gender’ in all forms/applications etc. wherever gender classification is envisaged.

Opening/Operation of Deposit Accounts

• Comply with KYC guidelines : Airtel Payments Bank complies with RBI directions on KYC / AML and has a board approved KYC policy for Customer Identification, Customer Acceptance, obtaining recent photograph of the prospective customer, monitoring of transactions in the accounts etc.
• Savings Bank Rules : Airtel Payments Bank consider issuing statement of accounts through various modes (internet, mobile and at touch points at a nominal printing cost). Terms and Conditions of savings bank account will form part of account opening form, copy of the same will be made available on request and updated on the website as well.
• Minimum balance in savings bank accounts : At the time of opening the accounts, the bank will inform their customers in a transparent manner the requirement of maintaining minimum balance and levying of charges, etc., if the minimum balance is not maintained. Any charge levied subsequently will be transparently made known to all depositors in advance with one month’s notice. The bank will inform, at least one month in advance, the existing account holders of any change in the prescribed minimum balance and the charges that may be levied if the prescribed minimum balance is not maintained.
• Penal charges to be levied for not maintaining the minimum balance is decided with the approval of Board of the bank. It will be ensured that such penal charges are reasonable and not out of line with the average cost of providing the services. Further, it will be ensured that the balance in the savings account does not turn into negative balance solely on account of levy of charges for non-maintenance of minimum balance. These guidelines will be brought to the notice of customers apart from being disclosed on the bank's website.
• Entries in the statement of accounts : Airtel Payments Bank consider issuing statement of accounts through various modes (internet banking, m-pass book, and at touch points at a nominal printing cost).  Bank will give constant attention to ensure entry of correct and legible particulars in the pass books and statement of accounts. With a view to avoiding inconvenience to depositors, bank will avoid inscrutable entries in statement of accounts and ensure that brief, intelligible particulars are invariably entered.
• Address / Telephone Number in Statement of Accounts : Airtel Payments Bank ensures that full address / phone no. /email id of the bank are mentioned in the statement of accounts
• Printing of IFSC code on statement of account : The bank ensures the printing of the Indian Financial System Code (IFSC) is a pre-requisite for National Electronic Funds Transfer (NEFT) and Real Time Gross Settlement (RTGS) transactions in the statement of account.
• Payment of interest on accounts frozen by bank: With regard to the savings bank accounts frozen by the Enforcement authorities, Airtel Payments Bank will credit the interest to the account on a regular basis.
•  Acknowledgement by bank at the time of submission of Form 15-G / 15-H:  Bank will not deduct TDS from depositors who submit declaration in Form 15-G/15-H under Income Tax Rules, 1962.
•  Timely Issue of TDS Certificate to Customers: With a view to protect the interests of the depositor and for rendering better customer service, bank will provide TDS Certificate in Form 16A, to their customers in respect of whom the bank has deducted tax at source. Bank has put in place systems that will enable them to provide Form 16A to the customers well within the time-frame prescribed under the Income Tax Rules.

Acceptance of Cash Over the Counter

Airtel Payments Bank will ensure that their branches invariably accept cash over the counters from all their customers who desire to deposit cash at the counters. Further, the bank will refrain from incorporating clauses in the terms and conditions which restrict deposit of cash over the counters.

Display of Information by Bank

• Notice Board at branch/access points : Airtel Payments Bank will disseminate salient features of various products offered by the bank and its terms and conditions to customers at its branches/touch points, which, is one of the modes of imparting financial education. This enables customers to take considered decision regarding products and services of the bank and be aware of their rights as also the obligations of the bank. It also disseminates information on grievance redressal mechanism, enhances the quality of customer service and improves the level of customer satisfaction.
• Dissemination through website : Airtel Payments Bank ensure that the customers are able to easily access the relevant information from the Home Page of the bank’s web-sites through various hyperlinks in a user friendly manner. The information, among others, include relating to interest rate on deposits, service charges, fee for various services and grievance redressal mechanism.
• Bank will also ensure that only latest updated information is placed on their web-sites.

Grievance Redressal Mechanism

Airtel Payments Bank has in place a Customer Relationship Management (CRM)/Complaint Management System (CMS) to enable efficient and effective tracking and resolution of complaints. 

All complaints from the customers, shall be logged into CRM/CMS. With this the bank shall not only ensure that all the complaints received are recorded and resolved, but shall also ensure effective monitoring / escalation mechanism to the senior functionary responsible so as to make sure that none of the complaints remain unresolved.

The internal mechanism for recording and resolution of complaints shall function efficiently at all times and shall be monitored on daily basis. The staff are adequately trained for handling complaints efficiently.

The system will also be used to deal with the issues relating to services provided by outsourced agencies/Business Correspondents/Access points and the bank will ensure that the respective stakeholders resolve customer issues expeditiously and effectively.

The system will also be available for resolving issues related to the insurance distribution undertaken by the bank as a certified corporate agent.

Resolution of Complaints

• General Guidelines
• i.      The complaints will be analyzed from all possible angles. Specific timelines have been established for handling complaints and disposing them at all levels. 
• ii.      Details of the Complaints not redressed within one month will be sent by the concerned branch/Relationship Official to the Principal Nodal Officer and keep him updated regarding the status of the complaint.
• iii.      Branch and customer service officials must send action taken report on complaints received to the Head office on a real time basis.
• The Bank shall ensure that information on banking ombudsman scheme is available on the bank website.
• Timeline for responding/resolving complaints
• a.    Normal cases (other than the one mentioned below): 7 working days
• b.    Fraud cases, Legal cases and cases which need retrieval of documents and exceptionally old records): 15 working days
• c.    Cases involving third party including other banks): 30 working days
• d.    NEFT/RTGS complaints will be resolved within 7 working days.
• e.    Chargeback related cases: 45 to 90 working days or as per Card Network Operator  Guidelines
• f.     If any case needs additional time, the Bank will inform the customer, the reasons for the delay in resolution and provide expected time lines for resolution of the issue
• For more details, the Customer Grievance Redressal Policy may please be referred.
• Mandatory Display of Information on the website
• -  Names, complete address and contact details of the officials who can be contacted for redressal of complaints.
• -  Name and contact details of the Principal Nodal Officer and Banking Ombudsman under whose jurisdiction the branch/access point falls.

Compensating the Customer in Fraud Case

The bank shall investigate the matter in its entirety and if the bank is convinced that an irregularity /fraud has been committed by its staff towards any constituent, the bank will acknowledge its liability and pay the just claim.

In cases where the bank is at fault, the bank will compensate the customer without demur. In cases where neither the bank nor the customer is at fault, but the fault lies elsewhere in the system, the matter would be required to be referred/escalated  to the appropriate Grievance Redressal Mechanism/authorities.

For more details, bank’s Customer Compensation Policy may be referred.

Nomination Facility

a. Nomination Procedure

 The bank will generally insist that the person opening a deposit account makes a nomination. In case the person opening an account declines to fill in nomination, the bank will explain the advantages of nomination facility. If the person opening the account still does not want to nominate, the bank will record the fact in the digital account opening form and proceed with opening of the account if otherwise found eligible. Under no circumstances, a bank will refuse to open an account solely on the ground that the person opening the account refused to nominate.

The bank will take action to register nominations or changes therein, if any, made by their depositor.

 b. Nomination Facility – Clarifications

I.         Nomination facility is intended for all deposit accounts.

II.        Nomination shall be made only in favor of individuals. Any nomination other than in favor of an individual will not be valid. 

III.       There cannot be more than one nominee.

IV.       Bank will allow variation/cancellation of a subsisting nomination.

V.        The nomination facility is intended to facilitate expeditious settlement of claims in the accounts of deceased depositors and to minimize hardship caused to the family members on the death of the depositors.

VI.       The nominee is only a trustee or custodian. It is the responsibility of the nominee to distribute the assets as per the will or according to laws.

VII.      The bank will ensure that account opening form will contain space for nomination also so that the customers could be educated about availability of such facilities.

c. Settlement of claims in respect of deceased depositors  

Bank will adhere to the provisions of Sections 45 ZA to 45 ZF of the Banking Regulation Act, 1949 and the Banking Companies (Nomination) Rules, 1985.

In case where the deceased depositor had not made any nomination or in the absence of nominee (nominee is dead, absconding or missing etc. (to be validated with First Information Report) Airtel Payments Bank will adopt a simplified procedure for repayment to legal heir(s) of the depositor keeping in view the imperative need to avoid inconvenience and undue hardship. In this context, bank will, keep in view their risk management systems, fix a minimum threshold limit, for the balance in the account of the deceased depositors, up to which claims in respect of the deceased depositors could be settled without insisting on production of any documentation other than a letter of indemnity and other related documents.

In view of the above, in case where the deceased depositor had not made any nomination or in the absence of nominee (nominee is dead, absconding or missing etc. (to be validated with First Information Report) and the balance in the account is up to INR 25,000/- (Rupees Twenty Five Thousand Only), Airtel Payments Bank will pay the amount outstanding in the savings bank account/individual current account of deceased depositor to claimant (s) on submission of notarised Affidavit cum Indemnity Bond (as per Annexure I) and other relevant documents (such as death certificate, KYC documents etc.).

For any claim (balance in the account), where the amount exceeds INR 25,000/- (Rupees Twenty Five Thousand Only), but less than Rs.50,000 ( Rupees fifty thousand including interest) payment to be made to the claimant on submission of duly executed and notarised affidavit cum indemnity bond (as per Annexure 2) backed by 2 sureties and letter of disclaimer in case another legal heirs relinquishing their rights in favour of one/more claimant. Bank details and KYC details of legal heirs to be obtained at the time of settlement of claim. KYC & bank account details of claimant/sureties to be collected along with death certificate. In case claim amount exceeds Rs.50,000 and above, claimant has to submit (where applicable under law) Will through probate or Succession Certificate issued by the competent court in the name of legal heir (s)/claimant.

d. Interest payable on the deposit account of deceased depositor 

The bank pays interest from the date of death of the depositor till the date of repayment to the claimant/s at the rate of interest applicable to savings deposit as on the date of payment.

e. Timeline for settlement of claims

Bank will settle the claims in respect of deceased depositor and release payments to survivor(s) / nominee(s) within a period not exceeding 7 days from the date of receipt of the claim subject to the production of proof of death of the depositor and suitable identification of the claim(s), to the bank's satisfaction.

Bank will report to the Customer Service Committee of the Board, at appropriate intervals, on an ongoing basis, the details of the number of claims received pertaining to deceased depositors and those pending beyond the stipulated period, giving reasons therefor.

f. Claim Forms to be made available

With a view to facilitate timely settlement of claims on the death of a depositor, bank will provide claim forms for settlement of claims of the deceased accounts, to any person/s who is/are approaching the bank / branches/access points for forms. Claim forms will also be put on the bank’s website prominently so that claimants of the deceased depositor can access and download the forms without having to visit the concerned bank/branch for obtaining such forms for filing claim with the bank.

g. Simplified procedure for settlement of claims

The bank will follow a simplified procedures for settlement of claim in line with applicable statutory provisions, instructions by following the Model Operating Procedure formulated by the IBA.

Settlement of Claims in Respect of Missing Persons

As per the provisions of Section 108 of the Indian Evidence Act 1872, presumption of death can be raised only after a lapse of seven years from the date of his/her being reported missing. As such, the nominee / legal heirs have to raise an express presumption of death of the subscriber under Section 107/108 of the Indian Evidence Act before a competent court. If the court presumes that he/she is dead, then the claim in respect of a missing person can be settled on the basis of the same.

In the normal course, the bank may consider settlement of claims in respect of missing persons on production of FIR, non-traceable report issued by police authorities and letter of indemnity by claimant(s) without prejudice to the right the bank to call for such additional document as it may deem fit taking into account the facts and circumstances of each case.

Unclaimed Deposits / Inoperative Accounts in Bank

Bank will make an annual review of accounts in which there are no operations (i.e., no credit or debit other than crediting of periodic interest or debiting of service charges) for more than oSne year. The bank will approach such customers and inform them in writing that there has been no operation in their accounts and ascertain the reasons for the same.

The bank may also consider contacting the account holder telephonically or sending SMS/email to the customers and if there is no response, the bank may put on enquiry to find out the whereabouts of customers or their legal heirs to know whether the customer is alive or not.

An account will be treated as inoperative / dormant if there are no transactions in the account for over a period of two years. In case any reply is given by the account holder giving the reasons for not operating the account, bank will continue classifying the same as an operative account for one more year within which period the account holder will be requested to operate the account. However, in case the account holder still does not operate the same during the extended period, bank will classify the same as inoperative account after the expiry of the extended period. 

For the purpose of classifying an account as ‘inoperative’ both the type of transactions i.e., debit as well as credit transactions induced at the instance of customers as well as third party will be considered. However, the service charges levied by the bank or interest credited by the bank will not be considered.

There will be instances where the customer has given credit mandates for crediting through ECS/NACH towards dividend on shares and debit mandate towards utility bills, loan repayment etc. Since such credit/debit are afforded as per the mandate of the customer, the same will be treated as a customer induced transaction. As such, the account will be treated as an operative account. The Savings Bank account can be treated as inoperative account only after two years from the date of the last credit/debit entry provided there is no other customer induced transaction.

The segregation of the inoperative accounts is from the point of view of reducing risk of frauds etc. The classification is there only to bring to the attention of dealing staff, the increased risk in the account. However, the customer should not be inconvenienced in any way, just because his/her account has been rendered inoperative. The transaction will be monitored at a higher level both from the point of view of preventing fraud and for making a Suspicious Transactions Report. However, the entire process will remain un-noticeable by the customer.  

Operation in such accounts will be allowed after due diligence as per risk category of the customer. Due diligence would mean ensuring genuineness of the transaction, verification of the signature and identity etc. However, it has to be ensured that the customer is not inconvenienced as a result of extra care taken by the bank.  

Charges if any for reactivating the inoperative account will be levied in an upfront manner with due notification to the customer.  

Bank will ensure that the amounts lying in inoperative accounts ledger are properly audited by the internal auditors / statutory auditors of the bank.  

Interest on savings bank accounts will be credited on regular basis whether the account is operative or not.  

Bank will also give on the same website, the information on the process of claiming the unclaimed deposit/re-activating the inoperative account and the necessary forms and documents for claiming the same.  

The bank will allot a different “product code” in their CBS to all such accounts opened by bank so that the stipulation of inoperative/dormant account due to non-operation does not apply while crediting proceeds as mentioned above.

Transfer to Depositor Education and Awareness Fund Scheme

Section 26 of the Banking Regulation Act, 1949 provides, inter alia, that every banking company shall, within 30 days after close of each calendar year submit a return in the prescribed form and manner to the Reserve Bank of India as at the end of each calendar year (i.e., 31st December) of all accounts in India which have not been operated upon for 10 years.

The bank will play a more pro-active role in finding the whereabouts of the accountholders of unclaimed deposits/ inoperative accounts. It will display the list of unclaimed deposits/inoperative accounts which are inactive / inoperative for ten years or more on its website. The list will contain only the names of the account holder(s) without account number, type, etc. The list so published by the bank will also provide a “Find” option to enable the public to search the list of accounts by name of the account holder  

The bank note to adhere to the Depositor Education and Awareness Fund Scheme, 2014 –Section 26A of Banking Regulation Act, 1949- Operational Guidelines and transfer funds lying in inoperative accounts for more than 10 years to the fund maintained by Reserve Bank of India as per the operating guidelines indicated above.

Customer Confidentiality Obligation

The bank is obliged to maintain secrecy arises out of the contractual relationship between the banker and customer. No information about the customer will be divulged to third parties except under circumstances which are well defined. The following exceptions to the said rule are normally accepted:

      i)         Where disclosure is under compulsion of law

     ii)         Where there is duty to the public to disclose

    iii)         Where interest of bank requires disclosure and

   iv)         Where the disclosure is made with the express or implied consent of the customer.

Collecting Information from Customers for Cross-selling Purposes

Bank will treat the information collected from the customer for the purpose of opening of account as confidential and not divulge any details thereof for cross selling or any other purposes without the express or implied consent of the customer.

Wherever bank desires to collect any information about the customer for a purpose other than KYC requirements, it will not form part of the account opening form. Such information will be collected separately, purely on a voluntary basis, after explaining the objectives to the customer and taking his/her express approval for the specific uses to which such information could be put.

Co-ordiantion with Officers of Central Board of Direct Taxes

The bank will extend necessary help/co-ordination to tax officials whenever required. The bank will also view with serious concern in cases where the staff connive/assist in any manner with offences punishable under the Income Tax Act. In such cases, in addition to the normal criminal action, such staff member(s) will also be proceeded against departmentally.

Accepting Standing Instructions of Customers

The bank may consider acceptance of Standing Instructions. The scope of standing instructions, interalia, include payments of taxes, rents, bills, school / college fees, licenses, etc.

Rounding Off of Transactions

Payment of interest on deposits will be rounded off to the nearest rupee i.e., fractions of 50 paise and above shall be rounded off to the next higher rupee and fraction of less than 50 paise shall be ignored.

Code of Bank’s Commitment to Customers

Bank will follow various provisions of the Code of Bank’s Commitment to Customers, implementation of which is monitored by the Banking Codes and Standards Board of India (BCSBI).

Reporting Requirements

A brief report on the performance of the Standing Committee during its tenure indicating, inter alia, the areas reviewed, procedures / practices identified and simplified / introduced may be submitted periodically to the Customer Service Committee of the Board."

Record Keeping

As defined in Record Retention Policy of Airtel Payment Bank Ltd

Policy Review & Updates

The Customer Experience team is the owner of this Policy document and shall review it every year for organizational appropriateness, taking into consideration the state of the business / technology environment and compliance with legal and regulatory requirements. *Any changes to this Policy shall be approved by the Committee of Directors. Changes to this Policy shall be incorporated as and when necessitated and placed before the Board of Directors for ratification.

Regulatory References

This Policy should be read in conjunction with other Bank policies and procedures. This Policy should also be read in conjunction with the regulatory guidelines and shall be updated in line with the changes made in the regulatory guidelines as and when required.