Interest Rate Policy

1. Policy Objective

This Interest Rate Policy provides the framework used by Aditsh Fintech Private Limited to determine lending rates in a transparent, fair, and risk-aligned manner.

• Define the methodology for computing lending interest rates
• Ensure borrowers are treated equitably and informed clearly
• Maintain consistency, regulatory compliance, and effective risk management

2. Scope and Applicability

This policy applies to all loan products, all departments involved in pricing or servicing loans, and all Lending Service Providers acting on behalf of Aditsh Fintech.

3. Components of the Interest Rate

The base rate is reviewed and approved by the Risk and Credit Committees and is built using the following components:

• Cost of funds based on the weighted average cost of borrowings
• Operational costs including servicing, processing, and administration
• Target return on capital to sustain business operations and risk coverage

Base Rate Formula: Base Rate = Cost of Funds + Operational Cost + Profit Margin

4. Borrower Risk Premium

The final lending rate is determined by adding a risk premium to the base rate. This premium may vary based on:

• Credit score, including CIBIL or equivalent bureau assessment
• Income profile and cash-flow analysis
• Debt serviceability and existing liabilities
• Loan amount, tenure, and product structure
• Collateral or security, where applicable
• Business continuity or employment stability

5. Rate Matrix and Approval Process

• A risk-based pricing model classifies borrowers into low, medium, and high risk categories
• Each risk category is assigned a pre-approved interest rate band with minimum and maximum limits
• The Interest Rate Matrix is reviewed quarterly and updated based on cost of capital, market trends, and RBI requirements
• Changes are approved by the Credit Committee and ratified by the Board

6. Interest Calculation and Customer Disclosure

• Interest may be charged on either a reducing balance basis or a flat rate basis depending on the loan product
• The calculation method must be clearly disclosed through the Key Fact Statement and loan agreement
• The Key Fact Statement must be provided in the RBI-prescribed format and acknowledged before disbursement
• Interest rate, processing fees, late charges, and other key terms must be disclosed on the website, in sanction communication, and in loan documents
• Any change in applicable pricing during the loan term must be communicated in advance

7. Review, Monitoring, and Fair Practice

• This policy is reviewed annually by the Board
• Interest rates and their implementation are audited for consistency and fairness
• Any anomaly or non-adherence must be reported to the Risk and Compliance Committee
• No borrower may be discriminated against on the basis of caste, religion, gender, or region
• Lending decisions and pricing must be based on creditworthiness and risk assessment only

8. 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

Responsible Department: Risk & Credit Committee