FAIR PRACTICES CODE (FPC)

1. PREAMBLE

Shatabdi Leaprofin Private Limited (“Shatabdi” or “the Company”) is a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI) and engaged in providing short-term, unsecured lending solutions through digital and assisted channels.

This Fair Practices Code (“FPC”) has been framed in compliance with:

• RBI Master Direction – Non-Banking Financial Company (Scale Based Regulation) Directions, 2023
• RBI Guidelines on Fair Practices Code for NBFCs
• RBI Digital Lending Guidelines
• Applicable circulars, notifications, and regulatory advisories issued by RBI from time to time

This Code is approved by the Board of Directors and is applicable to all products, employees, agents, and outsourced service providers of the Company.

2. OBJECTIVES OF THE FAIR PRACTICES CODE

The key objectives of this Code are:

• To ensure fair, transparent, and ethical practices in all lending operations
• To promote clear disclosure of loan terms, pricing, and borrower obligations
• To ensure non-discriminatory treatment of all customers
• To establish an effective grievance redressal mechanism
• To ensure full compliance with RBI regulations and consumer protection standards

3. KEY COMMITMENTS OF THE COMPANY

Shatabdi commits to:

• Conducting business with integrity, fairness, and transparency
• Providing clear and simple disclosures regarding interest rates, fees, and charges
• Ensuring data privacy and protection of customer information
• Offering responsive and timely grievance redressal
• Adhering strictly to all regulatory requirements

4. APPLICATION FOR LOANS AND PROCESSING

• Loan applications may be sourced through digital platforms and/or assisted channels.
• All communications shall be in English or a language understood by the borrower.
• The borrower shall be provided with clear information either upfront or through the Key Fact Statement (KFS), including:
  • Loan amount
  • Loan tenure
  • Annualised rate of interest
  • Processing fees and other charges
  • Penal charges (if applicable)
• Acknowledgement of loan application shall be provided along with indicative Turnaround Time (TAT).
• Loan applications shall be processed within a reasonable time frame.
• Rejection of applications shall be communicated through appropriate channels without assigning reasons, unless required by law.

5. LOAN APPRAISAL AND TERMS & CONDITIONS

• Loan appraisal shall be conducted in accordance with the Company’s approved Credit Policy and risk assessment framework.
• The sanction letter / loan agreement shall clearly disclose:
  • Sanctioned amount
  • Interest rate (annualised)
  • Repayment structure
  • All applicable fees and charges
• Borrower consent shall be obtained via valid digital mechanisms such as OTP, e-sign, or click-wrap acceptance.
• Borrowers shall be provided with:
  • Loan Agreement
  • Key Fact Statement (KFS)
  • Schedule of Charges (SOC)
• Lending decisions shall be non-discriminatory and based on objective credit criteria.

6. DISBURSEMENT AND CHANGES IN TERMS

• Disbursement shall be done only after borrower acceptance of all terms.
• Any changes in terms (interest rate, charges, etc.) shall be:
  • Communicated in advance
  • Applied prospectively
• Loan recall, foreclosure, or acceleration shall be governed by the loan agreement and RBI norms.

7. GENERAL CONDUCT

• The Company shall not interfere in borrower affairs except as permitted under the loan agreement or law.
• The Company shall not resort to harassment or coercive practices for recovery.
• Lending shall not be discriminatory based on gender, religion, caste, or other prohibited grounds.
• This Fair Practices Code shall be available on the Company’s website and upon request.

8. GRIEVANCE REDRESSAL MECHANISM

• The Company shall maintain a structured grievance redressal framework.
• Complaints shall be acknowledged and resolved within RBI-prescribed timelines.
• Details of the Grievance Redressal Officer (GRO) shall be displayed on:
  • Website
  • Loan documents
  • Customer communications
• If unresolved, customers may escalate complaints under the RBI Integrated Ombudsman Scheme.

9. INTEREST RATE MODEL AND CHARGES

• The Board shall approve the Interest Rate Policy considering:
  • Cost of funds
  • Credit risk
  • Operational costs
  • Market conditions
• Interest rates shall be disclosed on an annualised basis.
• Penal charges shall be:
  • Reasonable and proportionate
  • Clearly disclosed
  • Non-discriminatory
• No hidden charges shall be levied.

10. CODE OF CONDUCT FOR RECOVERY

• Recovery practices shall be ethical, lawful, and respectful.
• Borrowers shall be contacted between 09:00 AM to 07:00 PM, unless agreed otherwise.
• Recovery personnel shall:
  • Identify themselves clearly
  • Maintain professionalism
  • Avoid intimidation or harassment
• Customer confidentiality shall be maintained at all times.
• Acceptance of gifts or bribes is strictly prohibited.

11. REVIEW AND AMENDMENT

This Policy shall be reviewed periodically by the Board and updated based on:

• RBI guidelines and circulars
• Regulatory observations
• Industry best practices

The Company shall ensure strict compliance with this Code.