This is in reference to the guidelines issued by the Reserve Bank of India on fair practices code for all Non-Banking Financial Companies (NBFCs) vide RBI circular & as amended from time to time.

RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 01, 2015 which has been adopted as a good grievance practice by the company.

Introduction:

KKSV Business Services Pvt Ltd (Company) has adopted the FPC for implementation with an endeavor to achieve fair and transparent practices while dealing with Lender’s Customer/ borrowers. This FPC intends to promote good and fair practices by setting minimum standards to be followed while dealing with the customers. Further, the FPC also seeks to increase transparency so that the customers can have better understanding of the products/ services being offered by the lender.

This FPC shall apply across all aspects of the Company’s lending facilitation business operations including digital lending, marketing, loan origination, processing, servicing, collection activities etc. KKSV Services Business Pvt Ltd commitment to the FPC would be demonstrated in terms of employee accountability, monitoring and auditing programs, training and technology.

The Company’s Board of Directors and the management are responsible for establishing practices designed to ensure that its operations reflect a strong commitment to the FPC and that all employees are aware of the FPC.

(i) Applications for loans and their processing

(a) All communications to the borrower shall be in English, as it is commonly understood by all the customer of company. If a customer explicitly requests communication in another language, company will acknowledge this preference, and all subsequent communications with that client will be in the requested language.

(b) Loan application forms shall include necessary information including but not restricted to processing fees/ charges, if any, non-refundable fees in case of rejection of loan proposal, pre-payment options etc., which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower.

(c) The Company shall give an acknowledgment of the receipt for all loan applications. The Company shall endeavor to provide the time frame within which the decision of the loan application shall be communicated.

(d) The loan application form shall indicate the document required to be submitted along with the application form. If any additional details/documents are required, the same shall be reasonably intimated to the borrowers.

(ii) Loan appraisal and terms/conditions

The company shall facilitate in writing to the customer, by means of sanction letter or any other document (KFS etc) provided by the company, the amount of loan sanctioned along with terms and condition including applicable rate of interest and shall maintain in it records the acceptance of these terms and conditions by the customer.

Upon the execution of the loan agreement, the company shall facilitate a copy of the loan agreement along with copy of annexures attached to the loan agreement, to the customer.

Company shall mention the penal interest charges for late payment in bold letter in the loan agreement. Company will furnish copy of loan agreement in English along with all the relevant enclosures quoted in loan agreement to all the borrowers at the time of sanction/disbursement of loan.

(iii) Disbursement of Loan and Changes in Terms & Conditions:

Company shall give notice to customer regarding any changes in terms and condition including disbursement schedule, interest charges, service charges, bounce charges etc. of lender.

Changes in the interest rates and charges shall be only made effective prospectively. A suitable condition in this regard is incorporated in the loan agreement, as applicable.

(iv) General:

(a) Company shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the borrower, has been noticed).

(b) In the matter of recovery of loans, the Company do not resort to undue harassment viz; persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc. Company ensures that the staff are adequately trained to deal with the customers in an appropriate manner.

(c) As a measure of customer protection and also in order to bring in uniformity with regard to prepayment of various loans by borrowers, Company shall not charge foreclosure charges/ pre-payment penalties on all floating rate term loans sanctioned to individual borrowers, with immediate effect.

(d) Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalization of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.

(e) The Company shall not introduce any additional component to the rate of interest and ensure compliance in both letter and spirit. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category.

(f) The quantum and reason for penal charges shall be clearly disclosed by the Company to the customers in the loan agreement and most important terms & conditions / Key Facts Statement (KFS) as applicable, in addition to being displayed on the Lender`s website under Interest rates and Service Charges.

(g) Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.

(h) The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions.

(i) A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement shall be furnished to all the borrowers at the time of sanction / disbursement of loans.

(v) Language and Mode of Communicating the FPC:

Company, in accordance with the Guidelines on FPC and RBI Master Directions, shall put in place the FPC in English language. The Company shall also make the FPC available in regional/ vernacular languages for the customers who request for the FPC in vernacular language. (Customer need to write to hello@salarynow.in)

(vi) Code with respect to Rate of Interest:

Pursuant to RBI Master Directions, the Board approved Interest Rate Policy of the Lender is already in place, mentioning internal principles and procedures in determining interest rates, processing charges and other charges. The Interest Rate Model adopted by the Lender takes into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for the loans and advances extended by it.

Company, in the application form and the sanction letter, will disclose to Lender`s borrowers rate of interest.

The approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers.

The rates of interest and approach for gradation of risk shall also be made available on the website of Lender.

The rate of interest being charged by the Lender shall be annualized rate to make the customer aware of the exact rates that would be charged to the account.

(vii) Responsibility of Board of Directors

Board of Directors of the Company has laid down appropriate grievance redressal mechanism. The Board of Directors shall annually review the compliance of the FPC and the functioning of the GRM. A consolidated report in this regard shall be submitted to the Board every year.

(viii) Grievance Redressal Officer (GRO)

Name: Mr. Kanhaiya Singh

Contact No: +91-7669065390

Email: grievance@salarynow.in

The GRO shall be reached on the number provided above anytime between 10:00 and 19:00 from Monday to Saturdays except public holidays or through the e-mail address above. The GRO shall endeavor to resolve the grievance within a period of (14) fourteen days from the date of receipt of a grievance.

If the Borrower does not receive a response from the GRO within 14 (fourteen) days of making a representation, or if the Borrower is not satisfied with the response received from the GRO, the Borrower shall reach the Nodal Officer anytime between 10:00 to 19:00 from Monday to Saturdays except public holidays or write to the Nodal Officer.

Name: Mr. Nikhil Dhamija

Contact No: +91-9654579927

Email: nodal@salarynow.in

If any complaint lodged by the borrower against the Company, or the borrower is not satisfied with the reply; or the borrower has not received any reply within 30 days of receipt of complaint by the Company, the said borrower can lodge a complaint over the Complaint Management System (CMS) portal under the Reserve Bank-Integrated Ombudsman Scheme (RB-IOS)10 or send a physical complaint to “Centralized Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector -17, Central Vista, Chandigarh - 160017”

Definition:

Company: KKSV Business Services Pvt Ltd Lender: Entity, which provides loan. (Zed Leafin Pvt Ltd / Finkurve Financial Services Ltd)

FPC: Fair Practices Code