Fair Practices Code

1. Objective

This Fair Practices Code sets out the standards followed by Aditsh Fintech Private Limited to ensure fair, transparent, ethical, and legally compliant lending practices across the borrower lifecycle.

• Protect the interests and rights of customers, especially retail borrowers
• Provide a structured framework for customer interaction and grievance handling
• Support compliance with Reserve Bank of India directions applicable to NBFCs

2. Scope and Applicability

This policy applies to all employees of Aditsh Fintech Private Limited and all Lending Service Providers (LSPs) acting on its behalf. It covers the full loan journey, including application, processing, sanction, disbursement, servicing, recovery, and closure.

3. Loan Application and Processing

• Loan application forms must be clear, easy to understand, and include all relevant disclosures
• Borrowers must be informed of interest rates, fees, charges, and required documents
• Every application should be acknowledged and assigned a reference number for tracking

4. Loan Sanction and Documentation

• Sanction terms must be communicated in writing in the borrower's preferred language
• A Key Fact Statement (KFS) must be provided before disbursement in the RBI-prescribed format
• The KFS should clearly disclose APR, tenure, total cost of credit, interest rate, fees, charges, penal charges, and key recovery contacts
• A legally binding loan agreement must be executed and a signed copy must be made available to the borrower

5. Disbursement, Transparency, and Disclosures

• Loans are to be disbursed strictly as per agreed terms, without unauthorized modification
• Borrowers may request a loan account statement without charge
• Interest rates, processing fees, and service charges must be published on the website and displayed at branch offices
• Any change in terms must be communicated in advance and rate changes must apply only prospectively

6. Communication and LSP Compliance

• All oral and written communication must be in a language understood by the borrower
• Technical or legal jargon that may confuse customers should be avoided
• All LSPs must comply with this Fair Practices Code and relevant RBI digital lending guidelines
• LSPs must be trained on customer interaction, grievance escalation, and compliant handling of customer data
• LSPs must not access personal or financial data beyond their authorized scope

7. Recovery and Collection Practices

• Recovery activity must be ethical, courteous, and properly documented
• Recovery agents must not use coercive or abusive language
• Calls should only be placed during reasonable hours, between 8:00 AM and 7:00 PM
• Customers should not be approached at inappropriate locations such as workplaces unless permitted by law and process
• The company must use valid and dedicated communication channels for recovery-related outreach

8. Grievance Redressal and Customer Rights

• Complaints may be raised through phone, email, web form, or in person
• Complaint details of the Grievance Redressal Officer must be displayed at branches and on the website
• Complaints should be acknowledged within 48 hours and resolved within 7 working days
• Customers are entitled to clear information, privacy, fair treatment, and a defined escalation path

9. Monitoring, Review, and Public Access

The Compliance Officer is responsible for implementation, internal monitoring, oversight of LSP adherence, and reporting non-compliance to senior management. Periodic audits and implementation reviews are to be conducted.

• This policy must be reviewed at least annually or earlier if RBI directions or business operations change
• Any amendment requires Board approval and communication to relevant stakeholders
• A copy of this Fair Practices Code must remain available on the website, at branch locations, and to customers on request without charge

10. Governance Note

This policy has been approved by the Board of Directors and is monitored through periodic reporting to the Board or the relevant committee.

Approved By: Board of Directors

Effective Date: February 16, 2026

Next Review Date: April 2, 2027