Fair Practices Code

• Promote good and fair practices by setting minimum standards in dealing with customers.
• Increase transparency, so customers understand what they can reasonably expect from the Company.
• Encourage market forces, through competition, to achieve higher operating standards.
• Promote a fair and cordial relationship between customers and the Company.
• Foster confidence in the non-banking financial system.

All communication with the borrower shall be in English or in a language understood by the borrower.

Loan application forms shall include the information necessary for the borrower to make a meaningful comparison with the terms offered by other lenders and an informed decision, including:

• the documents required to be submitted with the application;
• the fees and charges payable for processing the application, and whether any fee is refundable if the loan is not sanctioned;
• the pre-payment or foreclosure charges, if any;
• the penal charges applicable to the loan; and
• the grievance redressal mechanism.

The Company shall acknowledge receipt of every loan application and indicate the time within which the application will be decided.

Where an application is rejected, the Company shall convey the main reasons for rejection in writing or electronically, subject to any restriction under law, including the Credit Information Companies (Regulation) Act, 2005.

The Company shall convey to the borrower in writing, in a language understood by the borrower, by means of a sanction letter or otherwise, the amount of the loan sanctioned along with all its terms and conditions, including the annualised rate of interest, the method of application of interest, the tenure, the repayment schedule, all fees and charges, and the penal charges. The Company shall keep the borrower's acceptance of these terms on record.

Before the loan agreement is executed, the Company shall provide the borrower a Key Facts Statement in the format prescribed by the Reserve Bank of India, setting out the all-in cost of the loan as an Annual Percentage Rate (APR).

The penal charges applicable for late repayment or any other breach shall be stated in bold in the loan agreement and the Key Facts Statement.

The Company shall furnish a copy of the loan agreement and all enclosures quoted in it to every borrower at the time of sanction or disbursement, free of cost.

Loans shall be disbursed directly into the bank account of the borrower. The Company shall not route disbursements or repayments through any pool account of a Lending Service Provider or other third party.

The Company shall give notice to the borrower, in a language understood by the borrower, of any change in the terms and conditions, including the disbursement schedule, interest rate, service charges, pre-payment charges and penal charges. Changes in interest rates and charges shall take effect only prospectively.

Any decision to recall or accelerate payment or performance under the loan agreement shall be in accordance with the loan agreement.

The Company shall release all securities, if any, on repayment of all dues or on realisation of the outstanding loan amount, subject to any legitimate right or lien for any other claim against the borrower. If such a right of set-off is exercised, the borrower shall be given notice with full particulars of the remaining claims.

• The Company shall not interfere in the affairs of the borrower except for the purposes provided in the loan agreement, unless new information not earlier disclosed by the borrower comes to the Company's notice.
• The Company shall not discriminate on grounds of sex, caste, religion or disability in extending loans or services. This does not prevent participation in credit-linked schemes framed for weaker sections of society.
• On a request from a borrower for transfer of the loan account, the Company shall convey its consent or objection, if any, within 21 days of receipt of the request.
• The Company shall ensure that its staff and agents are trained to deal with customers courteously and appropriately.

In the matter of recovery of loans, the Company shall not resort to undue harassment, including persistently contacting borrowers at odd hours or using force or intimidation. In particular:

• Borrowers shall not be contacted for recovery before 8:00 am or after 7:00 pm, unless the borrower has asked to be contacted at another time.
• All communication shall be civil and respectful, and free of threats, abuse or profane language.
• Loan details shall not be disclosed to the borrower's family, friends, employer or any other third party, except co-borrowers or guarantors or as required by law.
• The Company shall not publish or share borrower information publicly, including on social media, as a means of recovery.
• Calls or visits on inappropriate occasions, such as a bereavement in the family, shall be avoided.

Any recovery agent engaged by the Company is bound by the Code of Conduct for Recovery Agents set out in the annexure to this Code. The names of recovery agencies engaged by the Company are published on the Company's website.

Where the Company engages a Lending Service Provider (LSP) or offers loans through a Digital Lending App (DLA), it shall ensure that:

• the Company's name is disclosed to the borrower as the lender at every stage;
• the LSP or DLA is bound by a written agreement requiring it to follow this Code;
• the names of all LSPs and DLAs, and the activities they perform, are published on the Company's website; and
• the Company remains responsible for the conduct of the LSP and for resolving any grievance arising from it.

The Company has an Interest Rate Policy setting out the model for determining interest rates, processing and other charges, the approach for gradation of risk, and the rationale for charging different rates to different categories of borrowers. The rates of interest and the approach for gradation of risk are published on the Company's website and updated whenever they change.

The Company has a Grievance Redressal Policy under which all disputes arising from decisions of the Company's functionaries are heard and disposed of at least at the next higher level. A customer may contact:

• Grievance Redressal Officer: Mohit Agarwal
• Email: grievance@maitryfin.com
• Telephone: 033 4602 3312
• Address: 23A NS Road, Fortuna Tower, 7th Floor, Room No. 29, Kolkata - 700001

If a complaint is not resolved within 30 days, or the customer is not satisfied with the response, the customer may approach the Reserve Bank of India under the Reserve Bank – Integrated Ombudsman Scheme, 2021:

• Online complaint portal: https://cms.rbi.org.in
• Email: CRPC@rbi.org.in
• Toll-free contact centre: 14448 (9:30 am to 5:15 pm, on working days)
• Post: Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh - 160017

This Code is published on the Company's website. Its salient features, including the grievance redressal contacts, are displayed at the Company's offices, and a copy is available to any customer on request.

The Board of Directors of the Company is responsible for adopting this Code, laying down the grievance redressal mechanism, and periodically reviewing compliance with the Code and the functioning of the grievance redressal mechanism at various levels of management. This Code shall be reviewed at least annually, or earlier if required by a change in regulation.

Every recovery agent engaged by the Company shall:

1. carry an identity card and an authorisation letter issued by the Company, and show them on request;
2. identify themselves and the Company at the start of any interaction;
3. contact the borrower only between 8:00 am and 7:00 pm, unless the borrower has asked otherwise;
4. not use threats, abuse, intimidation or any language likely to cause alarm or distress;
5. respect the borrower's privacy and not disclose loan details to any third party;
6. not accept any payment except against a receipt issued by the Company or through the Company's authorised payment channels; and
7. report any dispute or hardship raised by the borrower to the Company promptly.

Any breach of this code may lead to termination of the agent's engagement and, where appropriate, reporting to the authorities.