This revised draft has been prepared by updating the Company's existing Fair Practices Code to incorporate the requirements introduced under the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Third Amendment Directions, 2026. The amended Directions come into effect from 1 January 2027.
This Code is aimed to provide to all the stake holders, including but not limited to the Company’s customers, an effective overview of the practices followed, in respect of the services offered by the Company.

1. The objectives of this Code are:

• To implement and promote fair and transparent practices while dealing with customers;
• To promote a fair relationship between the customer and the Company and to ensure fair practice while dealing with customers;
• To provide adequate disclosures on the terms and conditions of a loan to borrowers including applications for loan, appraisal, disbursement etc.
• To ensure compliance with applicable laws RBI directions relating to lending, collection and recovery of loan dues;
• To ensure that recovery and collection activities are carried out in a fair, transparent, respectful and non-coercive manner
• To provide an effective mechanism for redressal of customer and recovery-related grievances;

2. Definition Clause:

• “Borrower” (s) or you or End-Users shall mean any person who accesses, downloads, uses, or otherwise avails of the Platform and/or the Services of the Company.
• “Loan” shall mean the loan sanctioned and granted by the Company to the Borrower subject to the applicable terms and conditions of the Loan Agreement.
• “Loan Agreement” shall mean the agreement executed between the Company and the Borrower for granting the Loan whether in physical or electronic form as may be applicable from time-to-time.
• “Recovery Agency” means an entity or individual, other than the Company's own employees, engaged by the Company under an outsourcing arrangement to assist in recovery of loan dues from a borrower in default, including taking possession of a security.
• “Recovery Agent” means a representative of a Recovery Agency who is involved in recovery-related activities on behalf of the Company at the point of customer interface. Where an individual is directly engaged by the Company under an outsourcing arrangement for recovery/possession-related activities, the requirements applicable to a Recovery Agency and Recovery Agent shall apply to such individual.
• “Outstanding Amount” (s) shall mean all amounts due and payable by the Borrower to the Company under or in connection with the Loan Agreement, including the principal amount, applicable interests, charges, fees and other amount, as may be contractually and legally payable.
• “Platform shall” mean, collectively, the application, website and/or other digital interface operated or made available by or on behalf of the Company for providing the Services to the Borrower, as applicable from time to time.
• “Services” shall mean the services provided by the Company in connection with the sourcing, processing, sanction, disbursement, servicing, collection and recovery of loans and other related services, as may be offered by the Company from time to time.
• “User Data” shall mean any personal data, information, documents, records or other materials provided, submitted, generated or otherwise made available by a customer to the Company in connection with the use or availing of the Services, subject to applicable law and the Company's privacy/data protection policies.
• “Website” shall mean the website of the Company, presently available at https://www.agarwalassignments.com/ managed and operated by the Company for the provision of Services.

3. Target Audience

• The Fair Practice code shall be made available in the public domain on the Company’s Website and shall be displayed at Company’s offices/branches.
• It shall also be made available in a language understood by the borrower, wherever applicable.

4. Loan Application

• The Company shall give the notice to the borrower, in a vernacular language or a language as understood by the borrower, of any material change in the terms and conditions, including the disbursement schedule, interest rates and service charges, as applicable.
• Changes in interest rates and charges shall be effected prospectively unless otherwise permitted by applicable law/RBI directions.
• Any decision to recall or accelerate payment/performance under the Loan Agreement shall be in accordance with the terms of the Loan Agreement and applicable law
• The Company shall give an acknowledgement of receipt for all loan applications. The Company shall endeavour to provide the time frame within which loan applications shall be processed.
• There will not be discrimination of its customers based on caste, creed, religion, language and regions.
• The loan application form shall indicate the list of documents required to be submitted along with the application form.
• If any additional details/ documents are required, the same shall be reasonably intimated to the customers.

5. Loan Appraisal and Terms & Conditions

• The Company shall convey in writing to the Borrower, in a vernacular language or a language understood by the borrower, the loan sanctioned and the applicable terms and conditions including applicable rate of interest and shall maintain, in its record, the acceptance of these terms and conditions by the Borrower.
• The pricing, charges and other applicable terms shall be clearly stated in the Loan Agreement
• Any penal charges/late payment charges applicable to the loan shall be clearly disclosed in the Loan Agreement.
• Upon execution of the loan agreement, the Company shall furnish a copy of the loan agreement along with a copy of all annexures if any attached to the loan agreement, to the customer.
• Loan appraisal shall be carried out in accordance with the applicable RBI directions and the Company's approved credit policies.

6. Disbursement of loans including changes in terms and conditions

• The Company shall give (7 working days) notice in the vernacular language or a language as understood by the borrower of any change in the terms and conditions – including disbursement schedule, interest rates, service charges, prepayment charges etc.
• The Company shall, in the loan agreement to be executed between the Company and the customer, ensure that changes in interest rates and charges are effected only prospectively.
• Any decision to recall/accelerate payment or performance under the loan agreement shall be inconsonance with the respective loan agreement.

7. Interest Charged

• The Company shall maintain appropriate internal principles and procedures for determining interest rates, processing charges and other charges.
• The Company would adopt an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, as applicable.
• The rates of interest and the approach for gradation of risks shall be disclosed and updated whenever there is change.
• The rate of interest shall be stated on an annualized basis so that the Borrower is aware of the rate applicable to the Loan.

8. Grievance Redressal Mechanism

The company has laid an appropriate grievance redressal mechanism for resolving Borrower grievances. Recovery related grievances shall be handled through the dedicated mechanism as set out in the code. The details of the concerned Grievance Redressal Officer shall be communicated to borrowers through the Loan Agreement and relevant recovery related communications.

9. Non-Coercive Methods of Recovery

• The Company shall have a Board approved Policy is in place with regard to Code of Conduct by field staff and systems for their recruitment, training and supervision. The policy shall cover triggers for initiation of recovery, graded actions under an escalation matrix, Code of Conduct, recovery in case of demise of a borrower, and a structured framework for borrowers facing financial distress, including documented pre-escalation engagement and guidance regarding available resolution options.
• Calling for collection will be held between 8.00 am to 7.00 pm.

10. Financial Distress and Pre- Escalation Engagement

The Company shall identify borrowers facing repayment-related difficulties and engage with such borrowers before escalation, wherever appropriate. Such engagement shall be documented and the borrower shall be guided regarding resolution options available under the Company's policies and applicable regulatory framework.

11. Training and Certification

The Company shall ensure that employees of the Company who are engaged in recovery activities are appropriately trained and comply with all applicable regulatory requirements, including the requirements prescribed by the Reserve Bank of India (RBI) from time to time. Wherever applicable, such employees shall obtain the prescribed certification from the Indian Institute of Banking and Finance (IIBF) upon completion of the applicable Debt Recovery Agent training programme, within the timelines prescribed by the RBI. The Company shall maintain and implement a Code of Conduct applicable to its employees engaged in recovery activities. The Company shall ensure that such employees comply with the Code of Conduct and all applicable RBI directions, guidelines and fair recovery practices while undertaking recovery activities.

12. Intimation of Borrower Before Recovery Visit

Where a case is assigned to an employee of the Company for recovery through an in-person visit, the Company shall intimate the borrower/guarantor of the details of the concerned employee at least one day before the first visit. In case the employee assigned to the case is changed during the ongoing recovery process, the borrower/guarantor shall be promptly informed of such change and the details of the employee subsequently assigned to handle the recovery process.

13. Protection and Limited Sharing of Borrower Information

Information relating to a Borrower/guarantor shall be shared with employee only to the extent necessary for performing recovery-related duties. The Company shall put in place appropriate controls, including contractual and penal provisions, to prevent misuse of customer information.

14. Call Recording and Recovery Records

• The Company shall document the time and number of recovery calls made by its employees to Borrowers.
• The Company shall ensure recording of the content/text of calls made by employees to Borrowers/guarantors and calls made by Borrowers/guarantors to the telephone/mobile number communicated by the Company.
• Such records shall be retained for six months from the date of the call, or, where the matter is sub judice, until disposal of the matter
• Reasonable precautions shall be taken, including informing the Borrower/guarantor that the conversation is being recorded.

15. Recovery Targets and Incentives

The Company shall ensure that recovery targets and incentive structures applicable to employees do not induce or encourage harsh, unlawful, abusive or otherwise inappropriate recovery practices.

16. Technology Based Recovery Mechanism

The Company shall not deploy a technology-based mechanism to restrict or disable functionalities of a borrower's mobile device, tablet or laptop as a recovery tool, except where specifically permitted for a device whose acquisition was financed by the Company and subject to all applicable RBI conditions. Where such mechanism is deployed, the Loan Agreement and recovery policy shall clearly provide for notice, gradual restrictions, essential functionalities, visibility, prompt reversal, grievance redressal and other applicable safeguards. The Company and any third-party service provider shall not access or use personal data available on the device, including contacts, SMS, call logs, photographs or location history, for recovery purposes.

17. Identification and Conduct During Recovery Visits.

• Employees of the Company visiting a Borrower/guarantor shall identify themselves by displaying their valid Company identity card.
• Only duly authorised employees of the Company shall visit the Borrower's/guarantor's premises for recovery activities.
• Employees undertaking recovery visits shall carry the necessary authorization issued by the Company, wherever applicable.
• Recovery matters shall ordinarily be discussed only with the Borrower/guarantor, as applicable.
• Employees shall treat the Borrower/guarantor with civility, dignity and respect and shall not engage in any conduct that may cause harassment, intimidation or humiliation.
• The Borrower/guarantor's preferred place of contact shall ordinarily be respected.
• In the absence of a specific choice, or where the Borrower fails to appear at the chosen place on two or more successive occasions, contact may be made at the residence or place of business/occupation, subject to applicable law and the Company's policies and procedures.

18. Calling and Visiting Hours

Employees shall contact/visit Borrowers/guarantors only between 8:00 AM and 7:00 PM. Calls or visits outside these hours shall be made only where the Borrower/guarantor has expressly requested or authorised the same. A request by the Borrower/guarantor to avoid contact at a particular time shall ordinarily be honoured.

19. Sensitive Occasions

Employees shall avoid making recovery calls or visits on inappropriate occasions, including bereavement in the family, medical emergencies, marriage functions and other similar calamitous or sensitive occasions.

20. Recovery Communications and Receipts

• Written communication issued by an employee for recovery purposes shall have prior approval of the Company and shall contain the name and contact details of the sender.
• Proper acknowledgement/receipt shall be promptly provided for any recovery/payment collected from the borrower/guarantor.

21. Prohibited/ Harsh Recovery Practices

Employees shall not use harsh methods for collection/recovery. This includes, without limitation:

• use of minatory, threatening or abusive language;
• posting or circulating videos, audio recordings or personal details of borrowers/guarantors on social media;
• sending inappropriate messages through mobile or social media;
• excessive calling or messaging, or contacting outside prescribed hours;
• making threatening or anonymous calls;
• intimidating or harassing borrowers/guarantors or their relatives, referees, friends or co-workers, including public humiliation or intrusion into privacy;
• using or threatening violence or similar means against the borrower/guarantor or family, assets or reputation; and
• making false or misleading representations, particularly regarding the extent of debt or consequences of non-payment.

22. Monitoring, Review and Control

• The Company shall maintain a management structure to monitor and control the activities of Employees engaged in recovery and ensure that their conduct does not adversely affect the Company's integrity or reputation.
• Agreement shall contain necessary provisions and recovery processes and make improvements based on operational experience, complaints, audit fundings and regulatory developments.
• The Company shall periodically review its recovery processes and make improvements based on operational experience, complaints, audit findings and regulatory developments.

23. Compensation for Non-Compliant Recovery Actions

The Company's recovery policy shall provide for appropriate compensation to borrowers/guarantors for loss arising from recovery-related actions of the Company which are not consistent with applicable RBI Directions.

24. Compliance with other Applicable Regulations

The Company shall comply with applicable RBI directions and other regulatory requirements relating to outsourcing, financial and IT services, recovery practices and commercial communications, including applicable requirements issued by the Telecom Regulatory Authority of India from time to time.

25. General

• The Fair Practice Code in vernacular language shall be displayed in all offices and branch premises.
• The minimum/ maximum interest rates, applicable charges and grievance redressal mechanism shall be displayed in all the offices and in the literature issued by the company (in vernacular language) and on the website,
• The Company shall comply with applicable KYC requirements and undertake due diligence in accordance with applicable regulatory requirements and Company policies.
• The Company shall take adequate steps to ensure that the loan application process is not unnecessarily cumbersome and that loan disbursements are carried out within the applicable/pre- determined timeline.
• Requests for transfer of a Borrower account shall be dealt with in accordance with transparent contractual terms and applicable laws and regulatory requirements

26. Effective Date and Review

This revised Fair Practices Code shall be effective from 1 January 2027, or such earlier date as may be approved by the Board/Company for implementation. The Code shall be reviewed periodically and whenever there is a material change in applicable RBI directions or other applicable law.