SUMMARY OF THE POLICY

FAIR PRACTICES CODE (FPC)

The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Financial Companies (NBFCs) through Circular no. DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 01, 2015, and Chapter V of Master Direction - Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 which laying down standards for fair business and corporate practices while dealing with their customers.

This Fair Practice Code is aimed to provide to all the stake holders, especially customers effective overview of practices followed by the company in respect of the financial facilities and services offered by the company to its customers.

FINAGLE FINANCIAL SERVICES PRIVATE LIMITED (hereinafter referred to as "FINAGLE" and "company") is a Non-Deposit taking Non-Systematically important Non- Banking Finance Company registered with the Reserve Bank of India ("RBI") engaged in the business of facilitating Loan and advances.

FINAGLE FINANCIAL SERVICES PRIVATE LIMITED (FINAGLE) hereby furnishes the Fair Practices Code (FPC) based on the guidelines issued by RBI. The Company shall also make appropriate modifications in the FPC from time to time to confirm the standards that may be prescribed by RBI. The Fair Practices Code, as adopted herein below, is in conformity with the Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circulars.

The Company's business will be conducted in accordance with prevailing statutory and regulatory requirements, with due focus on efficiency, customer-orientation and corporate governance principles. In addition, the Company will adhere to the Fair Practices Code in its functioning, the key elements of which are as follows:

PURPOSE

The Company has put in place the FPC with an endeavour to achieve synchronization of best practices when the Company is dealing with its stakeholders such as customers, employees, vendors, etc. The Company's Fair lending practices shall apply across all aspects of its operations including marketing, loan origination, processing, and servicing and collection activities. The Company's 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 fair lending and that all employees are aware of that commitment.

DEFINITIONS

1. "Board" means Board of Directors of the Company.
2. "Company" means FINAGLE FINANCIAL SERVICES PRIVATE LIMITED
3. "Directors" means individual Director or Directors on the Board of the Company.
4. "FPC" means Fair Practices Code.

KEY COMMITMENTS

The essence of the FPC lies in the following aspects that the Company shall strive to follow in spirit and in letter:

1. To act fairly and reasonably in all the dealings with borrowers by ensuring that:
   1. The Company's products, services, procedures and practices will meet the broad requirements and standards in the FPC;
   2. The Company's products and services will be in accordance with relevant laws and regulations as applicable for the time being in force;
   3. The Company's dealings with its borrowers will rest on ethical principles of honesty, integrity and transparency.
2. The Company will assist its customers in understanding as to what the broad features of its financial products and services are and what are the benefits and risks involved in availing the same by:
   1. Providing information about the products and services in simple manner;
   2. Explaining the financial implications of using the products and services.
3. The Company will make every attempt to ensure that its customers would have trouble-free experience in dealing with it. However, in case of error of commission and/or omissions, it shall:
   1. Deal with the errors promptly and effectively;
   2. Deal with the Grievances redressal in a quick and efficient manner and to the satisfaction of the customers;
   3. Promptly handle Complaints;
   4. Have Escalation process, in the event of dissatisfaction of the borrower in handling his complaint(s);

APPLICABILITY OF FAIR PRACTICE CODE

The FPC will be applicable to the following broad areas:

1. Loan applications and processing thereof
2. Loan appraisal and terms/conditions
3. Disbursement of loans including changes, if any, in terms and conditions
4. Post disbursement supervision/monitoring
5. Other general provisions
6. Confidentiality of Information
7. Language and Mode of Communicating Fair Practice Code
8. Regulation of Rate of Interest
9. Loan applications and processing thereof:
   1. Loan Application Forms will be made available to the prospective borrowers.
   2. Loan documentation set will, inter alia, include the broad features and the terms and conditions governing the loan which would include necessary information, which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made thereby helping the borrower in making an informed decision. The said Form shall also specify the documents required to be submitted by the borrowers.
   3. The Company has system of giving acknowledgement for receipt of all loan applications.
   4. All the loan applications shall be disposed of within a period of 90 days from the date of receipt of duly completed Loan Application Forms together with the requisite documents and subject to receipt of all documents complying with prevailing rules and regulations by the borrower.
   5. All communications to the borrower shall be in vernacular language or a language as understood by the Borrower.

GRIEVANCE REDRESSAL MECHANISM

The Board of Directors of the Company shall be responsible to lay down a proper grievance redressal mechanism to handle the dispute arising out of the internal decision making. The purpose of such a robust mechanism will be to ensure that all the disputes relating to the Company's lending decisions and other functions are heard and disposed of promptly atleast at the next higher level.

The company also lay down the proper grievance redressal mechanism to handle complaints/grievances of its borrowers/customers.

The Company shall display the information pertaining to its grievance redressal mechanism, details of its Grievance Redressal Officer and the information of the Regional Office of the RBI prominently at its websites, office/place of business for resolution of complaint of its customers.

Further, the Company has also laid down a comprehensive robust Grievance Redressal Mechanism for the speedy disposal/ remedy of its customers' complaints/grievances. The same has been adopted, and approved, by the Board in detail under the Grievance Redressal Policy.

ESCALATION PROCESS

If the customer is not satisfied with the customer care channel, they can raise their concerns by following the escalation procedure explained hereinafter. In order to escalate a complaint to the next level, the customer will be required to share their ticket/ complaint number. Further, the turnaround time mentioned under each escalation stage shall apply only when the aforesaid escalation matrix is followed.

The Company shall provide for a below Grievance Redressal Mechanism to resolve any of its customers query or grievance:

Level 1: Grievance Redressal Officer

If customer is not satisfied by the resolution provided by the customer care department then that customer may register their query/ complaint to the Grievance Redressal Officer. The details of the Grievance Redressal Officer are given as follows:

(Between 10:00 a.m. and 6:30 P.M., from Monday to Saturday (except on public holidays))

Complaint to GRO shall be filled within 10 working days from the date of last resolution from customer care department.

Level-2: Nodal Officer of the Company

If the customer is not satisfied with the resolution provided by Grievance Redressal Officer or the complaint is not resolvedsatisfactorily then customer may register their query/ complaint to Nodal officer of company. The details of nodal officer is given below:

(Between 10:00 a.m. and 6:30 P.M., from Monday to Saturday (except on public holidays))

Complaint to NO shall be filled within 15 working days from the date of last resolution from GRO.

Level-3: Reserve Bank of India

If the customer is not satisfied with the redressed provided by above-mentioned channels then customer may register complainant within 30 days from the date of receipt of receipt of communication of Award or rejection of the complaint to RBI NBFC Ombudsmen on below mentioned address:

The Reserve Bank of India

RBI Ombudsmen,

C/o Reserve Bank of India

6, Sansad Marg, Sansad Marg Area, New Delhi, Delhi 110001

FORCE MAJEURE

The various commitments outlined and made by FINAGLE FINANCIAL SERVICES PRIVATE LIMITED shall be applicable under the normal operating environment. In the event of any Force Majeure circumstances, the Company may not be able to fulfil the objectives under the FPC to the entire satisfaction of the borrowers, the stakeholders and the public in general.

REVIEW

The Board of Directors will annually review the compliance of this Fair Practices Code and the effectiveness of the Company's Grievance Redressal Mechanism. The Board shall also make appropriate modifications in the FPC from time to time in conformity to the changes or additions to the guidelines as issued by the RBI.

DISCLAIMER

The Company is abide by all guidelines, directives, instructions, and advice of the Reserve Bank of India as in force from time to time. The content in this document shall be read in conjunction with these guidelines, directives, instructions and advices. The Company will consistently apply better practice so long as such practice does not conflict with or violate Reserve Bank of India regulations.