APNA GODAM TECHNOLOGIES PRIVATE LIMITED

Chapter 1: Grievance Redressal Mechanism

1. Introduction :

The Platform has a holistic approach towards setting up service standards and continuously improvising experience of each Market intermediary (MI) based on market practice as well as their feedback across multiple channels.

The Platform ensures to provide multiple channels to MI”s to provide feedback on the services of the Platform as well as lodge their grievances. The Platform aims to ensure quick and effective handling of MI’s grievance, as well as prompt corrective & preventive action (including correction of the process, wherever required) in order to avoid recurrence.

In order to meet the above objective, the Platform has outlined a framework for redressal of MI grievances and documented it in the form of a policy for the reference of MI touchpoints. The Platform shall ensure that the MI Grievance Redressal Policy is also available in public domain (on its website).

2. Scope and Objectives :

The objective of the policy is to spell out the framework for Grievance Redressal in the Platform as outlined to ensure that:

• a) All MI is treated fairly and in an unbiased manner at all times
• b) All issues raised by MI are dealt with courtesy and resolved on time
• c) MI is made completely aware of avenues to escalate their grievance within the Platform and their rights to alternate remedies if they are not fully satisfied with the response or resolution to their grievance

Through this policy, the Platform shall ensure that a suitable mechanism exists for receiving and addressing grievances from its MI and their constituents including Farmers/Traders and Processors etc. with specific emphasis on resolving such cases fairly and expeditiously regardless of source of the case.

The policy entails adherence to the provisions prescribed by the APMC Rules prescribed by various State Governments and Department of marketing Inspection and Other Regulators which are relevant for one or more part of the entire transaction.

3. Tenets of grievance redressal :

The Platform shall be guided by the following tenets in its approach to grievance redressal:

• a) MI”s Awareness: The Platform shall endeavor to make continuous efforts to educate its MI”s to enable them to make informed choices regarding channels to approach for grievance redressal.
• b) Impartiality, Fairness & Transparency: The MI”s grievances shall be examined in all fairness and the Platform shall take a balanced approach to resolve the same. Platform shall ensure MI”s grievances are resolved in a timely and efficient manner.
• c) Independent investigation: All MI”s grievances shall be independently investigated without any conflict of interest.
• d) Remedial actions: After the conclusion of the independent investigation, the Platform where appropriate will undertake remedial actions in relation to a legitimate MI’s grievance.
• e) Escalation: All responses to MI’s grievances will provide an escalation matrix mentioning the details of the next level of grievance redressal for the MI.
• f) Review: The Platform shall have a regular process of internal review of MI’s grievances at multiple hierarchies to enhance quality and effectiveness of MI service

4. Definition of Request, Query and Complaint:

The Platform has clearly defined Requests, Queries and complaint’s so that MI issues are logged accurately. It is to be noted that examples mentioned below are illustrative.

• a. Request :

  A Request is an ask made by the MI for Platform services / products:

  Examples of requests:

  • i. MI is requesting for TDS ,GST, Mandi Tax, Compliance Documents
  • ii. MI is requesting for Wallet Refund
  • iii. MI is requesting for Trade Limit Reinstatements
• b. Query:

  A Query is:

  • I. Any doubt/ enquiry
  • II. MI seeking/ cross-checking clarification/more information
  • III. MI enquiring/ cross checking before the expiry of specified turnaround time (TAT) for service/ deliverables
  • IV. MI checking status/ progress

  Examples of queries:

  • i. Non-receipt of Truck Consignment
  • ii. Query on Loan Application Status
  • iii. Quality Assaying Reports
• c. Complaint:

  A Complaint is:

  • a) Service deficiency or error on the part of other MI of the Platform in offering any service and /or
  • b) Non-conformance in any of the Platform's product / process leading to
  • c) A dispute / grievance / protest / grumble /

  accusation / objection Examples of complaint’s:

  • i. TAT Related : Delay in providing any product / service of the Platform beyond the stipulated / committed TAT e.g.
    • - GST/TDS/Mandi Tax Documents not received
    • - Settlement of Mandi/GST/TDS pending
    • - Pay Out not received from Clearing Member
  • ii. Custody Related issues : Deficiency in performance leading to
    • a. Weight Shortage
    • b. Material quality deteriorated
    • c. Consignment delayed
  • iii. Settlement related issues:
    • a. Wrong penalty levied by Member
    • b. Excess Brokerage Charge
    • c. Excess deferred payment Charges deducted

5. Process of handling MI grievances

• a) Touch points to report MI grievances:

  MI will be informed about the channels available for referring/seeking redressal of grievances. These are:

  • i. IVR Number
  • ii. Email
  • iii. Website
  • iv. Letter
  • v. Social Media
  • vi. Grievance Redressal officer
  • vii. Principal Nodal officer
  • viii. Corporate office
• b) Sources of grievances (in addition to above mentioned channels):

  Grievances received through APMC of the State, Department of market inspection, consumer forum etc.

• c) Logging and tracking of MI grievances:

  Any grievance received - either verbally, by email or in writing, if not resolved and responded immediately shall be logged in system and complain Id to be issued.

  The Platform system has the capability to record and categorize grievances into different types and maintain turnaround times (TAT) for specific category / sub-category. It also has an auto escalation mechanism for cases not resolved within defined TAT.

  With this the Platform shall not only ensure that all the issues are recorded and resolved, but shall also ensure effective monitoring /escalation mechanism to the senior functionary responsible in case of the grievance not being resolved within defined timelines.

  Acknowledgement is provided for every grievance logged in the form of a Reference Number. MI is informed about the expected date of closure of the grievance.

• d) Turnaround time:

  Depending on the nature of the grievance, specific timelines have been set for the resolution. Grievances shall be resolved in a proper and time bound manner with detailed advice to the MI. The MI is kept informed in case of any delay envisaged by the Platform in resolution of the grievance beyond the stated timelines.

• e) Mode of response:

  Platform shall ensure that the mode of response is as per the mode of MI intimation received e.g., cases received through e-mail shall be responded though e-mail and cases received through letter may be responded through registered email ID.

• f) Escalation of grievances:

  The Platform has a three-tier escalation mechanism for MI grievances, as given below:

  • i. 1st Level -Member :

    All front-end channels as mentioned above

  • ii. 2nd Level -Platform :

    Grievance Redressal Officer (GRO)

  • iii. Arbitrator :

    As appointed by the Platform

    In line with the APMC Rules, the Platform will appoint GRO. The Platform will prominently display the name and contact details (Telephone/mobile number and E-mail ID) of the GRO.

6. Review & Oversight of monitoring MI grievances:

Primary responsibility of review and monitoring of the MI grievances would be with the respective front-end channels. The Platform shall establish a Complaint’s Management Cell to monitor the MI grievances logged in the Platform on a regular basis. This cell, as part of its monitoring, shall perform the following activities:

• a) Analyze/conduct a root-cause analysis of the complaints logged on a quarterly basis. The analysis shall be carried out basis the nature and type of complain with a view to identify areas of complaints which are endemic in nature and require process review / procedural change.
• b) The analysis shall also include review of closure of case (adequacy of closure as well as timelines). Key aspects of the analysis shall be highlighted to the senior management.
• c) Pro-active monitoring by the complaint’s Management Cell shall be carried out at a monthly frequency on sample basis for frequent areas of complaints to raise issues to the concerned units including for cases not resolved or inadequately resolved or incorrectly logged.
• d) Net promoter Score (NPS)

  The Net Promoter Score (NPS) is a customer experience and loyalty metric used to measure the likelihood of customers recommending the organization’s products or services to others. It is widely used to assess overall customer satisfaction and the strength of customer relationships

  Under this framework, customers are asked to respond to the following question:

  “On a scale of 0 to 10, how likely are you to recommend our products or services to a friend, colleague, or business associate?”

  Based on their responses, customers are classified into three categories:

  • • Promoters (Score 9–10):

    Customers who are highly satisfied and likely to recommend the organization’s products or services. These customers contribute positively to growth through repeat usage and referrals.

  • • Passives (Score 7–8):

    Customers who are satisfied but not enthusiastic. They are less likely to actively promote the organization and may switch to competitors if a better alternative becomes available.

  • • Detractors (Score 0–6):

    Customers who are dissatisfied with the products or services and may negatively impact the organization through unfavourable feedback or complaints.

  The Net Promoter Score (NPS) is calculated as follows:

  NPS = Percentage of Promoters − Percentage of Detractors

  The resulting score ranges from −100 to +100, where a higher score indicates stronger customer loyalty and satisfaction.

  The organization may periodically conduct NPS surveys to evaluate customer perception, identify areas for improvement, and enhance the quality of services offered. The results of such surveys may be used for internal performance monitoring, service enhancement initiatives, and strategic decision-making.

  NPS Score	Meaning
  Above 50	Excellent
  30-50	Good
  0-30	Average
  Below 0	Poor

Chapter 2: AGTPL Logo

The Platform Policy permits the members, a restricted use of the Platform logo. However, below conditions need to be followed:

• a. Logo can be used by Client/TM/TCM/STCM on all documents which are auto generated like
  • • Electronic Contract Notes
  • • Wallet Statements
  • • Limit Statements
  • GST Invoices / E-way bills
  • • GST invoice ,e-way bill ,e-invoice ,Niryat Partivedan/form22 as per the Mandi requirement
• b. Logo can be used in Agreements where the format of the agreement is provided by Platform

Chapter 3: Tax Laws

Mandi Tax

Agriculture is a state subject. Every state has different mandi-tax laws so, the person who is trading on the platform may not be aware about the tax rate of every state. Hence, the platform will display the taxation of every state so that the buyer and Seller are aware of Mandi-tax Payment status. The price quoted on the Platform is always Mandi-tax paid up to the time of delivery in a warehouse or a factory. It is a responsibility of the member to deduct or release Mandi-tax amount from the wallet of client.

GST

The Platform will always display the GST rate applicable on any agriculture produce. The price quoted on the Platform is Mandi-tax paid but exclusive of GST. The GST is recovered from the buyer in addition to the commodity price. Although GST rate is published by the platform and taken care of during settlement but the Clearing Members are required to cross check from GST portal.

TDS

Under section 194(o) of income tax act the buyer is required to deduct TDS @0.10% of the total Trade value above Rupee 50,000. The Clearing Member will hold TDS amount from the seller pay out and will release the amount only after the seller submits form 26 to Platform If the Seller fails to produce form 26 then the amount will be kept on hold till the expiry of last date of TDS return of the quarter in which the transaction took place.

CHAPTER 4: CONTRACT NOTES

• A. Electronic Contract Note and E-invoice

  When any trade is executed on the platform in SBT product then it is the responsibility of Clearing Member to share with the MIs an Electronic Contract note by any mode of communication. After the delivery is marked by the seller to the buyer then it is a responsibility of the clearing member to generate an invoice and must be pushed to buyer and Clearing Member. The invoice of pushed by the seller on the member’s web application will be treated as sufficient discharge of duties of seller.

• B. Issue of Contract Notes under Digital Signature

  Members can issue the electronic contract note to the market participants under digital signature of the member in accordance with Information Technology Act, 2000 and such digitally signed contract notes shall have the same validation as physical contract notes. The Platform further stated that all contract notes whether signed in physical form or issued under digital signature, shall be generated on the same day the deal is concluded. In addition, the Platform advised the members to keep the required records of all contract notes, in whatever form, for the purpose of inspection and/or audit by the respective APMC and/or the Platform as prescribed under its Rules, Bye laws and Regulations.

CHAPTER 5: KYC Registration Agency (KRA)

Registration with KYC Registration Agency (KRA)

The Platform has appointment Singodwala Warehousing and Logistics Private Limited (SWLPL) as repository for the purpose of keeping records related to KYC pertaining to every user, Client, trading member, Clearing Member or any other Market Intermediary. There will be unique Client code UCC for every market Participants. Uniform Client Registration will be obtained through SWLPL.

CHAPTER 6: UNIFORM CLIENT REGISTRATION PROCESS

• A. Common/ Uniform Client Registration Form/ Process
  • i. The Platform prescribes the uniform and common client registration forms including Member Client Agreement and “Know your client” form, wherein the client will be required to fill in only one set of documents while registering for multiple Marker intermediaries. A tariff sheet specifying various charges, including brokerage, payable by the client, to avoid any dispute at a later date.
  • ii. Information on Three levels of grievance redressal so that the client can approach them in case of any grievance.
• B. guidelines on Common / Uniform Client Registration through KYC Registration Agency (KRA)

  The KRA system shall be made available to the members for uploading / downloading details for all the new client accounts opened. It is advised to all members to upload KYC details & documents on the KRA system/ server for all the new client accounts opened, if not already in existence on the KRA system and in case of NRIs and Foreign Nationals, self-attested copies of statutory approval must be attached with KYC, further requiring the members to upload the KYC details & documents of all their existing clients on the KRA system/ server.

CHAPTER 7: COMPLIANCE OF STATE & CENTRAL LAWS

• Compliance of State Laws for Delivery Obligations

  The Platform advises the members to note that a person under an obligation to give or take physical delivery of any commodity has to ensure compliance of the applicable State laws for giving/ taking physical delivery and as per the Platform settlement process in all delivery contracts, the sellers have choice to mark the center where they propose to give delivery. Even though buyers may mark preferred delivery center of their choice and the Platform system gives preference to allocate delivery at such delivery center of choice, but there is no assurance that buyer will get delivery at his chosen center. Therefore, members should advise their clients, seller as well as buyers, to become familiar with the above provisions.

  The Platform suggest the members to advise their clients that the stocks of any essential commodity held by them through Commodity demat account and/or otherwise should not exceed the stock limits prescribed under the applicable control orders issued under Essential Commodities Act, 1955 and further requiring the members to advise their clients (who intend to give delivery, particularly at centers where such stock limits are in force) that it is the obligation of selling clients to ensure that the goods are free for physical delivery and transfer to the corresponding buyer/s.

• Members are advised to ensure compliance of applicable laws including the local State laws (at the place of delivery) in respect of deliveries effected by / through them, the Platform advises the members to ensure that while effecting deliveries, valid registrations with the concerned GST Authorities are available for their clients/constituents who intend to deliver or their settlement agents, as the case may be and that all related legal requirements in respect of such deliveries should be complied with by members/ clients/ their settlement agents.

CHAPTER 8: STAMP DUTY

Stamp duty on Contract Note

The Platform will issue time to time a schedule of stamp duty payable on a contract note issued by a member to his client in the same State and further clarified that the Information compiled is advisory in nature and the stamp duty particulars contained in the said schedule are based on the opinions obtained by the Platform from its Solicitors in Jaipur. The Platform notified that since the opinions are untested in any court of law, they are subject to interpretation by Courts/Authorities in the respective States and disclaimed accepting no responsibility / liability for the consequences in case of use of the information contained in the schedule by any member, thereby suggesting the members to consult their lawyers on the stamp duty to be paid from time to time

CHAPTER 9: MISCELLANEOUS

Reporting requirement under Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS)

The Platform advises that the Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the Government of the United States of America (USA) with a view to combat tax evasion by U.S. citizens and residents through the use of offshore accounts, whereby FATCA requires financial institutions globally to share information about the financial accounts held by U.S. citizens/ residents for tax purposes to the Internal Revenue Services (IRS) of the Govt. of US.

On similar lines, Organization for Economic Co-operation and Development (OECD) issued a standard for Automatic Platform of Information (AEOI) in tax matters called as ‘Common Reporting Standard’ (CRS), requiring financial institutions globally to share information about the financial accounts held by the non-residents (other than U.S. citizens and residents for tax purpose.)

To enable financial institutions in India too comfily with FATCA and CRS, the Government of India (GOI) joined the Multilateral Competent Authority Agreement (MCAA) on 3rd June, 2015 and signed the Inter-Governmental Agreement (India IGA) with the US Govt. on 9th July, 2015.

For implementing India IGA and MCAA, necessary amendments were made to section 285BA of the Income-tax Act, 1961 (Act). Further, the Government of India notified Rules 114F to 114H (hereinafter referred as “the Rules”) under the Income Tax Rules, 1962 and form no. 61B for furnishing of statement of reportable accounts as specified in the Rules.

The Platform advised all market participants to take note of the aforesaid circulars of Regulator and take necessary steps for complying with the reporting requirements under FATCA and CRS.

End Of Document