Interest Rate Policy

This policy explains the approach used by the Company to price loans and advances fairly and transparently. It covers [INSERT PRODUCT NAMES] offered directly or through merchants, partners, LSPs and DLAs.

The annualised rate offered to a borrower may comprise a benchmark / base lending rate plus product, tenor and borrower-specific risk premiums, subject to approved minimum and maximum ranges. Pricing inputs may include:

• weighted cost of funds and liquidity / asset-liability costs;
• operating, origination, servicing, technology and collection costs;
• expected credit loss, fraud risk and portfolio performance;
• capital charge, target return and reasonable margin;
• loan amount, tenor, repayment frequency, security and end use;
• borrower credit profile, cash flows, bureau history, leverage, stability, geography and channel performance;
• subvention or commercial support paid by an OEM, merchant or other permitted party.

Borrowers with different risk characteristics may receive different rates. The approach will be consistently applied to similarly placed borrowers and will not use prohibited or irrelevant discriminatory factors. Exceptions require approval under the delegated authority matrix and an auditable reason.

• Annualised interest rate, rate type and method of application will be disclosed in the application / sanction documentation.
• APR will include interest and applicable charges as required and will be presented in the KFS with an amortisation schedule.
• Fixed / flat-rate descriptions will not obscure the annualised reducing-balance APR.
• Changes in rates or charges will apply prospectively after appropriate notice.
• Current indicative product ranges and the approach to risk gradation will be maintained at [INSERT WEBSITE LINK].

The Board / [INSERT COMMITTEE] will approve the pricing methodology and review it at least annually. Finance, Risk and Compliance will monitor funding costs, portfolio losses, exceptions, customer outcomes and regulatory changes. Updated website disclosures will be published whenever approved rates or methodology materially change.