Fair Practices Code

[INSERT LEGAL NAME OF NBFC] ("Company") adopts this Fair Practices Code to ensure transparent, fair and responsible conduct in its dealings with applicants and borrowers. The Code applies to all lending products, channels, employees, agents, Lending Service Providers ("LSPs"), Digital Lending Apps ("DLAs"), Direct Sales Agents and recovery personnel acting for the Company.

• Communications will be in English, Hindi, a vernacular language, or another language understood by the borrower.
• Application forms will disclose information that materially affects the borrower's interests, including indicative pricing, charges and documents required.
• The Company will acknowledge completed applications and indicate an expected disposal timeline of [INSERT NUMBER] working days, subject to receipt and verification of information.
• Rejection, where required by applicable directions or Company process, will be communicated through an appropriate channel without disclosing confidential underwriting logic.

• Creditworthiness will be assessed using relevant information such as identity, age, occupation / business, income / cash flow, existing obligations, credit history, bank / Account Aggregator data and permitted fraud-risk indicators.
• Before execution of every applicable retail or MSME term-loan contract, the borrower will receive a Key Facts Statement ("KFS") containing the annual percentage rate ("APR"), charges, net disbursed amount, repayment schedule and other prescribed information.
• The sanction letter / loan agreement will state the sanctioned amount, annualised interest rate, method of application, tenure, instalments, security, conditions, prepayment treatment and material consequences of default.
• A copy of the executed loan agreement and all referenced enclosures will be furnished digitally or physically to the borrower.

Disbursement will follow sanctioned terms, applicable end-use conditions and RBI fund-flow requirements. Changes to interest rates, service charges, repayment schedule or other terms will be notified in a language understood by the borrower and will operate prospectively unless law requires otherwise.

Rates will be determined under the Company's Board-approved Interest Rate Policy. Penal charges, if levied, will be reasonable, non-discriminatory within the applicable product category, applied only to the amount under default / material non-compliance, not capitalised and separately disclosed in the KFS and loan agreement. No charge omitted from the KFS will be recovered during the loan term without the borrower's explicit consent, subject to law.

• The Company will not use intimidation, public humiliation, threatening or anonymous communications, misleading representations, muscle power or persistent contact at inappropriate hours.
• Recovery personnel will identify themselves, disclose their authorisation and follow the Recovery Agent Code of Conduct.
• Before an assigned recovery agent contacts a digital-loan borrower, the Company will communicate the agent's particulars through SMS / email or another recorded channel.
• Genuine hardship representations may be considered under applicable policy; restructuring or settlement is not an automatic right.

On repayment of all dues, securities and title documents will be released within applicable timelines, subject to a lawful lien or set-off for another disclosed claim. Any repossession will follow an enforceable contractual clause, prior notice, a final repayment opportunity where applicable, inventory / custody safeguards and a transparent sale or auction procedure. Requests to transfer a borrowal account will be addressed within the regulatory timeline.

The Company will not discriminate unlawfully, including against persons with disabilities, and will provide reasonable assistance. Borrower information will be protected and shared only as permitted by law, consent, contract or regulatory obligation. Complaints may be lodged through the channels in the Grievance Redressal Policy.