Loans Sourced by the Company through Digital Lending

The Company will, irrespective of whether they lend through their own digital lending platform or through an outsourced lending platform, adhere to this Fair Practices Code.

RBI vide its circular dated September 2, 2022, has issued “Guidelines on Digital Lending” (“RBI Guidelines”). As per RBI Guidelines, the Company will make following disclosure to borrowers or all digital lending products of the Company:

• Annual Percentage Rate (APR) will be disclosed as a part of the Key Fact Statement (KFS).
• The Company will provide a KFS to the borrower before the execution of the contract. Any fees, charges, etc., which are not mentioned in the KFS will not be charged by the Company to the borrower at any stage during the term of the loan.
• The Company will ensure that digitally signed documents will automatically flow to the borrowers on their registered and verified email/ SMS upon execution of the loan contract/ transactions.
• The Company will prominently publish the list of their Digital Lending Apps/ Platforms (DLAs), Lender Service Provider (LSP) and DLAs of LSPs with the details of the activities for which they have been engaged, on its website.
• The Company will ensure that its DLAs or DLAs of its LSPs at on-boarding/sign-up stage, prominently display information relating to the product features, loan limit and cost, etc., so as to make the borrowers aware of these aspects.
• The Company will communicate to the borrower, at the time of sanctioning of the loan and also at the time of passing on the recovery responsibilities to an LSP or change in the LSP responsible for recovery, the details of the LSP acting as recovery agent who is authorised to approach the borrower for recovery.
• The Company will ensure that DLAs of the Company and LSPs have links to Company’s website where further/ detailed information about the loan products, the lender, the LSP, particulars of customer care, link to Sachet Portal, privacy policies, etc. is available.
• The Company will ensure that it and its LSPs have a suitable nodal grievance redressal officer to deal with FinTech/ digital lending related complaints/ issues raised by the borrowers.