SUMMARY OF THE POLICY

TABLE OF CONTENTS

Glossary

1. INTRODUCTION

The master direction on Know Your Customer (KYC) issued by the Reserve Bank of India and Anti-Money Laundering (AML) standards advised all Non-banking financial companies ensure that a proper policy framework on KYC and AML measures be formulated and put in place with the approval of the Board of the company.

In view of the master direction on Know Your Customer DBR.AML.BC.No.81/14.01.001/2015-16 dated February 25, 2016, with any amendment/re-enactment thereof issued by Reserve Bank of India from time to time and Prevention of Money Laundering Act, 2002 ("Act") read with the PreventionofMoney-laundering(MaintenanceofRecords)Rules,2005("Rules")withanyfurtheramendments/re-enactments thereof issued from time to time, the Board of Directors of FINAGLE FINANCIAL SERVICES PRIVATE LIMITED has adopted a policy on Know Your Customer (KYC) & Anti-Money Laundering (AML) norms.

FINAGLE FINANCIAL SERVICES PRIVATE LIMITED(hereinafter referred to as "the Company" or "FINAGLE") is a Non-Deposit taking Non-Systematically important Non- Banking Finance Company registered with the Reserve Bank of India ("RBI") to carry out the business of a Non-banking financial company with an objective to provide financial assistance to the individuals, MSMEs, and Corporates.

This policy is applicable to all categories of products and services offered by the Company.

2. OBJECTIVE

Objective of RBI guidelines is to prevent NBFCs being used, intentionally or unintentionally by criminal elements for money laundering activities.

The guidelines also mandates making reasonable efforts to determine the true identity and beneficial ownership of accounts, source of funds, the nature of customer's business, reasonableness of operations in the account in relation to the customer's business, etc. which in turn helps the Company to manage its risks prudently.

Accordingly, the main objective of this policy is to enable the Company to have positive identification of its customers.

3. KEY DEFINITIONS

1. "Act" and "Rules" means the Prevention of Money-Laundering Act, 2002 and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, respectively and amendments thereto.
2. "Authentication", in the context of Aadhaar authentication, means the process as defined under sub-section (c) of section 2 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016.
3. "Board" means Board of Directors of the Company.
4. "Central KYC Records Registry" (CKYCR) means an entity defined under Rule 2(1)(aa) of the Prevention of Money Laundering Rules, to receive, store, safeguard and retrieve the KYC records in digital form of a customer;
5. "Certified Copy" means a comparative copy of the proof of possession of Aadhaar number where offline verification cannot be carried out or officially valid document so produced by the customer with the original and recording the same on the copy by the authorized officer of the company.
6. "Company" means FINAGLE FINANCIAL SERVICES PRIVATE LIMITED.
7. "Customer" means a person who is engaged in a financial transaction or activity with a company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.
8. "Customer Due Diligence (CDD)" means identifying and verifying the customer and the beneficial owner
9. "Designated Director" means Managing Director or a whole-time Director, or any director duly authorised by the Board of Directors of the Company to ensure overall compliance with the obligations imposed under chapter IV of the Prevention of Money Laundering Act and the Rules;