Fair Practice Code

Introduction

This Fair Practice Code ("FPC") is aimed to provide all borrowers/customers an effective overview of practices followed by Credilab Micro Finance Private Limited (CIN: U65990DL2021PTC380666) operating under the brand name "NCR Fincorp" (the "Company"), in its capacity as a Lending Service Provider ("LSP"), in respect of financial products and services offered through partnerships with RBI-regulated Non-Banking Financial Companies ("NBFCs"), including its NBFC partner Aasra Fincorp Private Limited (6/3/8B, A.N. Jha Marg, George Town, Prayagraj – 211002, Uttar Pradesh).

This FPC is in accordance with Reserve Bank of India Master Direction RBI/2015-16/16DNBR (PD) CC.No.054/03.10.119/2015-16 dated 1st July 2015 and applicable RBI Guidelines on Digital Lending.

Objective

This FPC has been developed to:

• Promote good, fair, and trustworthy practices by setting standards in dealing with borrowers
• Ensure transparency in the Company's dealings with its borrowers
• Ensure compliance with legal norms in matters relating to recovery of advances
• Enable borrowers to have a better understanding of the services offered
• Reckon with market forces through competition and strive for higher operating standards
• Strengthen mechanisms for redressal of borrower grievances

Application For Loans and Their Processing

All loan application forms shall contain detailed information relating to the terms and conditions governing the loan facility and other relevant information affecting the interest of the borrowers.

The Company shall explain to borrowers the contents of loan documents in the vernacular language and ensure that the borrower understands the terms and conditions. Loan application forms shall include necessary information to enable meaningful comparison with terms offered by other NBFCs.

The Company shall follow the system of issuing acknowledgements for receipt of all loan applications and will evaluate each proposal at its sole discretion. The completed loan application form shall indicate the loan amount, annualised rate of interest, processing fee (if any), EMI dates, loan tenure, etc.

Loan Appraisal and Terms and Conditions

The Company shall convey or explain to the borrower in the vernacular language:

• Sanctioned loan amount
• Annualised rate of interest to be charged
• Tenure of loan
• Instalment amount and structure
• EMI payment dates
• Terms and conditions of the loan
• Method of making the loan application

The Company shall furnish a copy of the loan agreement along with all enclosures to all borrowers at the time of sanction/disbursement. Penal interest charged for late repayment shall be mentioned in bold in the loan agreement.

Disbursement of Loans Including Changes in Terms and Conditions

The Company will give notice to all borrowers in the vernacular language for any change in conditions, disbursement schedules, rates of interest, service charges, or other prepaid charges. Changes in interest rates and other charges will be effected prospectively, other than under circumstances arising from regulatory instructions.

Recall of Loan

Any decision to recall or accelerate the payment or performance will be carried out as per the loan agreement.

Release of Securities

The Company will release 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. If any right of set-off is to be exercised, borrowers will be given notice with full particulars about the remaining claims.

General Clauses

The Company shall not interfere in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement.

Whenever a request for transfer of a loan account is received, the Company shall respond within 21 days of receipt.

The Company does not resort to coercive measures (such as persistently bothering at odd hours, use of muscle power, rude behaviour, or harassment) for recovery of loans. Staff is adequately trained to deal with borrowers in an appropriate manner.

Cooling Off / Look-up Period: Borrowers are given a window to exit digital loans:

• 3 days for loans with a tenor of 7 days or more
• 1 day for loans with a tenor of less than 7 days

During this period, a borrower may exit by paying the principal and proportionate Annual Percentage Rate (APR) without any penalty.

Interest Rates and Gradation of Risk

The Company lays down appropriate internal guidelines for determining interest rates and processing charges, keeping in view transparency as indicated in this FPC. The interest rate for customers is arrived at based on:

• Risk profile of the customer/borrower
• Interest rate trends prevailing in the money market
• Cost of borrowings
• Primary and collateral security (if any)
• Structure of the deal
• Interest rates charged by competitors
• Historical track record of the customer

The Company does not charge foreclosure charges or pre-payment penalties on floating rate term loans sanctioned to individual borrowers. Interest rates and gradation of risks are disclosed on the Company's website at https://ncrfincorp.com/ and are updated whenever there is a change.

Responsibility of Board of Directors

The Board of Directors shall adopt an interest rate model taking into account cost of funds, margin, and risk premium, and determine the rate of interest for loans and advances. The Board shall also lay down appropriate grievance redressal mechanisms and provide for periodic review of FPC compliance.

Grievance Redressal and Borrower Relationship Management

Customer service and satisfaction are prime areas of focus. The Company has built a structured grievance redressal system to ensure disputes are handled justly and fairly.