Whistle Blower Policy

Chhotaria Securities Private Limited (hereafter referred to as “CSPL” or “the Company”) is a Non-Banking Financial Company classified under the Base Layer (NBFC-BL) of the Reserve Bank of India's Scale Based Regulation (SBR) framework, engaged in lending. The purpose of this Policy is to establish a framework that encourages responsible and secure whistleblowing. It aims to protect employees and third parties who wish to raise concerns within the Company.

While this Policy is designed to safeguard genuine whistleblowers from unfair treatment resulting from their disclosures, any misuse of this protection through the submission of frivolous or malicious complaints is strictly prohibited. Employee(s) who file complaints with malicious intent that are subsequently determined to be false will face stringent disciplinary action.

The Board of Directors of the Company has adopted this Whistleblower Policy (“Policy”) in compliance with the Companies Act, 2013, the Reserve Bank of India (Non-Banking Financial Companies – Governance) Directions, 2025 and the Reserve Bank of India (Non-Banking Financial Companies – Credit Risk Management) Directions, 2025.

Any individual employed by the Company, whether on a regular, temporary, ad-hoc, or daily wage basis, irrespective of gender, is included within the definition of “Employee” for the purposes of this Policy.

This encompasses all individuals, including interns, who may be engaged directly by the Company or through an intermediary, such as a contractor or agent, regardless of whether this engagement is conducted with the Company's explicit knowledge. Furthermore, this definition extends to those associated with the Company for remuneration, as well as those participating on a voluntary basis, ensuring that all individuals engaged with the Company in any capacity are afforded protections and responsibilities.

The Company seeks to maintain the highest ethical and business standards during the conduct of its business by promoting transparency and ethical conduct in all spheres of business operations. The Whistleblower Policy provides a mechanism for its staff, vendors, borrowers or customers, and encourages them to disclose any unethical and/or improper practice(s) taking place in the Company, for appropriate action and reporting, without any fear of retaliation.

All Employees are required to report any Reportable Matters of which they become aware. This Policy enables proactive disclosures without fear of reprisal or negative employment consequences.

The role of a Whistleblower is strictly that of a reporting party, not an investigator. Complaints must be factual rather than speculative and include specific details to facilitate an accurate inquiry.

Any Whistleblower who identifies any unfair practice, malpractice, discriminatory practice, or suspected fraud may submit a written disclosure to the Vigilance Officer. Where the complaint involves the Vigilance Officer, it should be submitted directly to the Designated Director or the Board of Directors.

Disclosures should outline the issues clearly along with any available supporting documentary evidence.

The identity of the whistleblower, subject, and any assisting employee is kept strictly confidential at all times, except during necessary legal proceedings.

The Company guarantees full protection against:

• Retaliation, threat, termination, or suspension of services;
• Adverse disciplinary action such as arbitrary transfer, demotion, or refusal of promotion;
• Direct or indirect abuse of authority obstructing routine daily performance of duties.

• Preliminary Review: The Designated Director conducts an initial assessment within reasonable time to determine if the disclosure merits detailed inquiry.
• Inquiry Officer: A senior managerial officer or committee may be appointed to conduct inquiries fairly and confidentially within a timeframe not exceeding 30 days.
• Reporting & Action: The Inquiry Officer submits a detailed report to the Designated Director to determine corrective remedies and apprise the Board.

No adverse or prejudicial action shall be taken against any Whistleblower for participating in inquiries or reporting reasonably suspected violations in good faith. Any retaliatory act will result in strict disciplinary measures, up to and including termination of employment or contractual associations.

Whistleblowers are encouraged to report observed incidents including:

• Practices inconsistent with Company ethics, culture, and business standards;
• Physical assault, verbal intimidation, or collective workplace bullying;
• Violations of the Code of Conduct, POSH policy, or KYC/AML norms;
• Manipulation of borrower credit records, financials, or loan terms;
• Coercive, unapproved, or abusive loan recovery or collection practices.

Disclosures can be written in English, Hindi, or the regional language and submitted via official email or sealed letter.

This Policy shall be reviewed annually by the Board of Directors or earlier upon any statutory/regulatory changes. Any amendments must be approved by the Board and published on the official company website.