Legal

Complaint Redressal Officer: 

Complaint Redressal Appellate Officer: 

 

BHARAT FINOPS IFSC PRIVATE LIMITED

Complaint Handling and Grievance Redressal Policy

 

DOCUMENT APPROVAL

This document has been reviewed for use by:

Name	Designation	Date
Krishna Subramanyan	Director	02 February 2026
Oana-Raluca Chiciu	Director	02 February 2026
Version	V1	02 February 2026
Previous version	NA	NA
Approved on	Board of Directors	02 February 2026

1.    Background

Bharat Finops IFSC Private Limited (the “Company”) is a private limited company, having obtained the in-principle approval from International Financial Services Centres Authority (“IFSCA”) vide e-File No. IFSCA-FMPP0BR/11/2025-Banking/001 dated 12 August 2025 to act as a Payment Service Provider (“PSP”) under sub-clause 1 to clause 9 of IFSCA (Payment Services) Regulations, 2024 (“PSP Regulation”).
authorized to act as a Payment Service Provider (“PSP”) under sub-clause 1 to clause 9 of IFSCA (Payment Services) Regulations, 2024 (“Payment Service Regulation”). 
The Company intends to carry the following payment services:
a.    Account issuance service
b.    E-money issuance service
c.    Cross-border money transfer service
d.    Merchant acquisition service
As per clause 3(A)(a) of the Circular on Complaint Handling and Grievance Redressal by Regulated Entities in the IFSC dated 2 December 2024, the Company is required to formulate a policy on handling of complaints and grievance redressal, duly approved by its governing body or its Board of Directors. 
In line with these requirements, the Company has put in place a board approved Complaint Handling and Grievance Redressal Policy (hereinafter referred to as ‘Policy’).

2.    Applicability

This Policy is applicable to all the employees, key managerial personnels, and contractors where applicable, involved in the day to day operations, commercial and key operations of the Company. 
Further, it shall be the responsibility of the Principal Risk & Compliance Officer of the Company to ensure that handling and disposal of complaints are in accordance with the Policy and any other regulatory requirements as may be specified by IFSCA. 

3.    Definitions 

“Customer” or “Client” - mean a person or entity who is engaged in a financial transaction or activity with the Company and includes a person on whose behalf the person engaged in the transaction or activity, is acting.    
“Complaint” means an issue raised by a client relating to the financial products and services provided by the Company and supported by documents. 

The following will not be considered complaints: 1) Anonymous complaints (except whistleblower complaints); 2) Incomplete or un-specific complaints; 3) Allegations without supporting documents; 4) Suggestions or seeking guidance/explanation; 5) Complaints on matters not relating to the financial products or services provided by the Company; 
6) Complaints about any unregistered/ un-regulated activity; 7) References in the nature of seeking information or clarifications about financial products or services.

“Complaint Redressal Officer” means the Company’s employee responsible for handling of complaints received from its clients (e.g. the person responsible to manage the customers relationship operations).

“Complaint Redressal Appellate Officer” means the senior person designated for handling  appeals of Clients against the decision taken by the Complaint Redressal Officer of the Company. This person should be at the level of or one level below a Key Managerial Personnel.

4.    Complaint handling

4.1.    The Policy will be posted on the Company website under the heading “Complaint Handling and Grievance Redressal”. 
4.2.    A dedicated email address will be created and posted on the website. At the same time, the name of the two officers and their contact details will be displayed as well.
4.3.    All complaints received will be recorded in the Complaints Register.
4.4.    The Compliant Register will include all the details of the complaints including but not limited to:
(a)    Complaint registration number
(b)    Client name
(c)    Full name and contact details of the person making the complaint
(d)    Date the complaint was made
(e)    Date of appeal if applicable
(f)    Nature and data of the complaint and the department associated (IT, client management, finance etc), including the employee to support the complaint investigation
(g)    Reasons for rejection of complaints, if any
(h)    Timelines for processing of complaints
(i)    Outcome of the complaint (result of the investigation and actions taken)
(j)    Date the complaint was closed and any recommendations.
4.5.    On receipt of a complaint, the Complaint Redressal Officer, with support from the departments involved, will make an assessment on the merits of the complaint.
4.6.    In case of acceptance, acknowledgement, including the complaint registration number, will be sent to the client within maximum 3 working days from the complaint’s date.
4.7.    In case of non-acceptance (the matter does not meet the compliant definition), the Complaint Redressal Officer will inform the complainant within 5 working days from the compliant date along with reasons.
4.8.    If additional information is required for complaint resolution, the Complaint Redressal Officer may ask for additional information from the client.
4.9.    If the Complaint Redressal Officer was involved in the conduct of the financial transaction which is the subject matter of the complaint, the complaint will be handled by the Client Success Operations Head or its representative.
4.10.    The complaint should be resolved preferably within 15 calendar days, but not later than 30 calendar days of acceptance of complaint.
4.11.     In the event the investigation or the resolution of the complaint involves a financial expense, approval from the Company’s Managing Director must be received in writing before incurring the expense.
4.12.     In case the compliant is rejected, the Complaint Redressal Officer will send the  reasons for rejection of the complaint, in writing, to the client.
4.13.     To ensure all open complaints are being handled as per process and within the stipulated timeline, this will be a standing agenda item at the Policy and Compliance Committee meetings.

5.    Appeal Mechanism

5.1.    If the client is not satisfied with the resolution provided by the Company or if the complaint has been rejected, the client may file an appeal before the Complaint Redressal Appellate Officer within 21 calendar days from the receipt of the decision from the Company. 
5.2.    The appeal will be dispose within a period of 30 calendar days from the date of receival. 

6.    Maintenance of Records

6.1.    The Company will maintain all records relating to handling of complaints, including the following: 
(a)    Complaints received and processed
(b)    All correspondence exchanged between the Company and the client
(c)    All information and documents examined and relied upon while processing of the complaints
(d)    Outcome of the complaints
(e)    Reasons for rejection of complaints, if any
(f)    Timelines for processing of complaints
(g)    Data of all complaints handled by it. 

6.2.    The Company will maintain the records in electronic format for at least 10 years from the date of disposal of complaint.
6.3.    In case of any pending litigation or legal proceeding relating to the complaint, the record will be maintained for 10 years after final disposal of the proceeding.

7.    Reporting

7.1.    The Company will file reports on handling of complaints in the form and manner specified by the Authority from time to time.
7.2.    The Company will have a section under heading “Complaint Handling and Grievance Redressal” in its Annual Report, including data of all complaints received, resolved, rejected and pending during the year. 
7.3.    The company will display the information on complaint handling on its website on an annual basis.

8.    External Escalation
If the client is not satisfied with the decision of the Company and has exhausted the appellate mechanism of the Company, the client may file a complaint before the Authority through email to grievance-redressal@ifsca.gov within 21 calendar days from the receipt of the decision from the Company.