Nehat Tech Solutions Private Limited’s Grievance Redressal & Merchant On-Boarding Policy

1. Introduction:

Nehat Tech Solutions Private Limited (the 'Company' or 'our' or 'we' or 'us') has put in place this Merchant onboarding Policy (the 'Policy') to ensure adequate due diligence is performed on the Merchants that intend to avail the services of the Company.

The Policy is to be read in conjunction with the KYC AML CFT Policy adopted by the Company.

2. Definitions:

1. Merchant means individuals or legal entities with whom the Company has entered into a contract for the purpose of providing payment solutions. 
2. Officially Valid Document (OVD) means the passport, the driving license, proof of possession of Aadhaar number, the Voter's Identity Card issued by the Election Commission of India, job card issued by NREGA duly signed by an officer of the State Government and letter issued by the National Population Register containing details of name and address.
3. Politically Exposed Persons (PEPs) means individuals who are or have been entrusted with prominent public functions in a foreign country e.g., Heads of States / Governments, senior politicians, senior government / judicial / military officers, senior executives of state-owned corporations, important political party officials, etc 
4. Equivalent e-document means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.

3. Merchant Onboarding Process

The Company follows two onboarding processes viz. one for Merchants onboarded for the Company’s Spend Management Solutions and the other for Merchants onboarded for the Company’s Receivable/ Payment Collection Services. Both the processes are detailed below:

1. Merchant Onboarding Process in relation to Spend Management Solutions

   Merchants interested in availing the Spend Management Solutions through the Company’s platform follow the below process:

   Contract	The Merchants for Spend Management Solutions are either sourced through the banks or directly by the Company. In the event the Merchant is sourced through the bank, the Company enters into an agreement with the Merchant along with the respective bank. In other scenarios, the Company has a direct contractual agreement with the Merchant. These agreements are digitally signed, and the Terms and Conditions are accepted by the Merchant as part of the onboarding process.
   Registration	As part of due diligence, the Merchant is required to register on the Company’s platform by providing the below information / document.
   Adding Beneficiary	The admin user / maker of the Merchant can now add their beneficiaries to whom the payments need to be made. Such beneficiaries can be added in the below mentioned categories.
   Beneficiary Validation	In this stage, the beneficiary added by the Merchant for making vendor payments are checked for authenticity. The Company has tied up with entities providing such validation services.
   Beneficiary activation	Upon successful match, the Company shares the list of validated beneficiaries with the bank. The bank then activates the beneficiary for payment purposes. Payments cannot be disbursed to beneficiaries that are not activated at the nodal bank’s end.

2. Merchant Onboarding Process in relation to Receivable/ Payment Collection:

   The Company will ensure the proposed process flow for facilitating its Receivable/ Payment Collection Services for existing Merchants as well as new Merchants:

   1. Merchant management

      Merchant Onboarding will entail a three-step process during the life cycle of the Merchant and will comprise of the following steps therein:

   2. Onboarding/Registration
      • Obtaining of the requisite details from the Merchant either physically or digitally through web/mobile interface (Refer to Annexure 1) along with the Merchant application form.
      • Verification and scrutinization of the of the duly filled application form and the requisite documents by the onboarding team
      • Undertaking of various checks such as background, negative business list, PEP, restricted business list (Refer to Annexure 2), UN sanctions list, etc. using the information and documents provided.
      • Granting of approval for onboarding of the Merchant by the Company upon satisfaction of checks and authenticity of the information / documents provided by the Merchant.
      • Agreement of the terms and conditions between both the parties i.e., the Company and the Merchant, and finalization of the commercials by way of executing a Merchant agreement.
      • Undertaking of the risk categorization of the Merchant onboarded (either low / medium / high category depending upon the type of business, any adverse / discouraging feedback etc.) post signing of the agreement
      • Registration of the Merchant upon successful completion of all the above steps and sharing of the activation details / credentials for login.
      
      
   3. Continuous monitoring

      A registered Merchant will be continuously monitored and supervised by the Company in order to prevent any unlawful or malicious activity. Such evaluation and ongoing due diligence is typically based on risk categorization assigned to any Merchant or its business model, etc. and include checking the transaction history, refunds initiated, transaction volumes in line of business, transaction amount of the Merchant, scrutinizing the Merchant’s disputes, verifying Merchant URL from where the transactions are undertaken, detecting any spike in transactions, total chargebacks, monitoring the Merchant website for any unwarranted business, checking social media for any adverse comments on the Merchants, etc. These business rules for monitoring / identification vary depending on the risk category of the Merchant.

      Based on the indications/ alerts received as part of the monitoring activity, risk categorisation of the Merchant may be changed from low to medium or medium to high as the case may be if there is a need. This will also follow up with obtaining additional documents/ information from the Merchant. In some cases, the Company may also decide to terminate the agreement with the Merchant.

4. Exit / termination process of the Merchant agreement

Termination of the agreement with the Merchant can be initiated by either of the parties i.e., the Company or the Merchant upon giving prior notice to the other party. The exit / termination process of the Merchant can occur in two scenarios:

1. Termination requested by the Merchant

   In case the Merchant wishes to culminate his contract with the Company, the same may be done by giving a notice to the Company. The Company assesses the account of the said Merchant and checks for any pending / outstanding dues. The Company also verifies any chargebacks / refunds pending on the Merchant’s account. Successful verification of the termination notice and the account of the Merchant will entail settlements of due with the Merchant and subsequent termination of the Merchant id.

2. The Company chooses to terminate the Merchant

   The Company at its own discretion can terminate the Merchant agreement with immediate effect in certain scenarios (listed below) and as deemed fit.

   • merchant has indulged in a fraudulent activity; or
   • merchant is involved in criminal or illegal activity; or
   • merchant has misused the platform for collecting payments for any illegal / prohibited goods.

5. Annexure 1

General Information:

• Personal details: Name, email id, phone number, address;
• Business details: Legal business name, registered address, business address, website address, constitution, etc.;
• Banking details: Bank Name and address, Type of account and account no. etc.
• Tech related information; •Financial information; and •Declarations; if any.

List of KYC documents: Below listed are the set of documents collected from the merchant along with the application form.

Where the OVD furnished by the merchant does not have updated address, the following documents or the equivalent e-documents thereof will be deemed to be OVDs for the limited purpose of proof of address:

1. Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill);
2. Property or Municipal tax receipt;
3. Pension or family pension payment orders (PPOs) issued to retired employees by Government

Departments or Public Sector Undertakings, if they contain the address;

• Letter of allotment of accommodation from employer issued by State Government or Central Government Departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies and leave and license agreements with such employers allotting official accommodation.

Note –The Company will ensure to obtain the OVD with current address updated within a period of three months of receiving the above documents.

6. Annexure 2:

List of Restricted businesses:

• Illegal arms trading
• Gambling
• Smuggling
• Child abuse
• Human trafficking
• Pornography
• Hawala
• Organs trading
• Extortion
• Illegal trading of animals
• Illegal drugs supply and handling
• Cryptocurrency

7. Review of Policy

The Company will periodically review and assess the Policy in light of any material changes in regulatory framework or for business or operational reasons and recommend changes, if any, to the Board. Any such updates/ changes to this Policy will be approved by the Board and communicated to the relevant Merchants/ staff/ stakeholders.

8. Our Partners

1. Transcorp International Ltd

   +91 7597182222 | [email protected]