POLICY DISCLOSURE

Fair Practice Code

The Company has framed and adopted this Fair Practice Code (FPC) setting out the principles for fair practice standards when dealing with customers.

INTRODUCTION

Chhotaria Securities Private Limited (“Company”), a Non-Banking Finance Company (“NBFC”) registered with Reserve Bank of India (“RBI”) is presently in the business of providing different types of loans which includes personal loans, Credit Builder Loan to its various customers. Such credit facilities are extended to different types of customers.

The Company has framed and adopted this Fair Practice Code (“Code” or “FPC”), which sets out the principles for fair practice standards when dealing with customers. As per the RBI directives, the Company has adopted and implemented this Code. The FPC has been duly approved by Board of Directors of the Company. This FPC applies to all categories of products and services offered by the Company, physically or through any digital lending platform (currently offered or which may be introduced at a future date).

The Company has developed the FPC for its lending operations based on the RBI guidelines, which intends to provide assurance to all the borrowers of the Company's commitment to fair dealing and transparency in its business transactions.

PURPOSE

A. To promote good and fair practices by setting minimum standards in dealing with customers;

B. To increase transparency so that the customer can have a better understanding of what they can reasonably expect of the services;

C. To promote a fair and cordial relationship between customer and Company.

KEY COMMITMENTS

The Company's key commitments to customers are as follows:

A. Act fairly and reasonably in all their dealings with customers by:

• Meeting the commitments and standards in this Code, for the products and services the Company offers and in the procedures and practices its staff/employees follow;

• Making sure that Company's products and services meet relevant laws and regulations in force in India;

• Company's dealings with customers will rest on ethical principles of integrity and transparency.

B. Help customers understand how Company's products work by explaining their financial implications; and

C. Deal quickly and sympathetically with things that go wrong by:

• Correcting mistakes quickly;

• Handling customer's grievances quickly; and

• Telling customers how to take their complaint forward if they are still not satisfied with the resolution.

D. Publicize this Code by displaying it on Company's website (www.chhotariasecurities.com) and have copies available for customers on request.

INFORMATION

A. The Company shall help customers choose products and services that meet their needs and give them clear information explaining the key features of the services and products of the Company they are interested in.

B. Inform customers about the documentary information the Company needs from them to establish customer's true identity and address and other documents to comply with legal and regulatory requirements vis-à-vis “Know Your Customer”.

C. The Company provides information on interest rates, common fees and charges through:

(i) Telephones or help lines.

(ii) Designated staff/help desk at its office.

(iii) Publishing on the website of the Company.

APPLICATIONS FOR LOANS
& PROCESSING

A. All communications to the borrower will be made in English or any vernacular language.

B. The loan application forms include necessary information affecting the interest of the borrower, so that a meaningful comparison with terms offered by other NBFCs or lenders can be made, and an informed decision can be taken by the borrower.

C. The loan application form clearly indicates the documents required to be submitted.

D. In case of digital lending products, the sanction letter is accompanied by a standardised Key Fact Statement (KFS), providing information about the APR, recovery mechanism, details of grievance redressal, and applicable charges and fees.

E. The Company, before sanctioning the loan, assesses the ability of the borrower to repay the loan.

F. Issues acknowledgement over an email to the borrower for each application after disbursement subject to receipt of complete information.

G. Applications complete in all respects are processed within a reasonable timeframe (within 30 days from receipt). In case the proposal is not approved, the borrower is intimated accordingly.

LOAN APPRAISAL &
TERMS / CONDITIONS

A. Convey in writing over an email to the borrower in English or vernacular language the amount of loan sanctioned along with annualized rate of interest, overdue interest, late payment charges and method of application (EMI schedule) thereof.

B. Mention the charges for late repayment in the loan agreement. Any interest, charge or fee other than those specified in the sanction letter or KFS shall not be levied.

C. Furnish a copy of the loan agreement along with all enclosures to all borrowers within 3 business days from the time of disbursement.

DISBURSEMENT & CHANGES
IN TERMS

A. Borrower enters into a loan agreement containing all standard and specific terms and conditions with the Company before seeking disbursement.

B. Notice in writing or electronic means is given of any change in terms and conditions including EMI schedule, interest rates, service charges, overdue interest charges, etc.

C. Complete disbursal of the loan amount is made strictly to the borrower's bank account without any pass-through accounts.

D. Changes in interest rates and other charges are effected only prospectively.

E. Decision to recall or accelerate payment will be in consonance with the loan agreement.

F. Release of all securities (if any) is made on repayment of all dues, subject to any legitimate right or lien for any other claim.

COLLECTION OF DUES

A. Repayment process is explained upfront by way of amount, tenure and periodicity. If the customer does not adhere to the schedule, a defined legal recovery process is followed.

B. Representatives identify themselves, display authorization letter and identity card upon request. Collections are deposited strictly in the bank account of the Company, without pass-through accounts.

C. Interaction Standards:

• Customer contacted ordinarily at place of choice or residence/business.

• Identity and authority made known at first instance; customer's privacy respected.

• Civil interaction; no threatening, abusive language, violence or harassment of family/friends/co-workers.

• Contact only between 08:00 hrs and 19:00 hrs.

• No misleading claims about the extent of debt; borrower names are never published.

• Strict adherence to the Board-approved collection policy.

GENERAL GUIDELINES

A. The Company refrains from interference in the affairs of the borrower except for purposes provided in the loan agreement.

B. Accountable for behavior of employees and outsourced agency staff; timely grievance redressal provided.

C. Requests for transfer of borrowed account are responded to within 21 days.

D. No resort to undue harassment (odd hours calls, muscle power, etc.); staff are adequately trained.

E. Confidentiality: Customer details are not revealed except under legal obligation, regulatory directions, auditor/confidential adviser review, or with borrower consent.

F. Digital Lending Oversight: Names of DLPs disclosed on website; upfront disclosure of agency relationship; sanction letter on Company letterhead; effective oversight maintained.

FURTHER ASSISTANCE

A. An internal grievance redressal mechanism ensures disputes are resolved and escalated appropriately. Details are available on the website and communicated via email.

B. Periodic review of compliance and functioning of grievance mechanism at various management levels.

C. If complaint is not redressed within 30 days, customers may appeal to the NBFC Ombudsman via the RBI portal (https://cms.rbi.org.in).

REGULATION OF RATE
OF INTEREST

A. The Interest Rate Policy is separately maintained and published on the Company's website.

B. Annualized percentage rates (APR) are communicated so borrowers know the exact effective charges.

BOARD APPROVED
COLLECTION POLICY

The Company has adopted a separate Board-approved Collection Policy governing recovery of loans and engagement of recovery agents. The policy lays down principles for fair, transparent, ethical, and lawful recovery practices, repossession procedures, agent training, and compliance with regulatory guidelines.

NON-DISCRIMINATION

The Company treats all customers fairly and without discrimination based on religion, caste, creed, gender, marital status, disability, age, or ethnicity. Credit decisions are based strictly on creditworthiness, repayment capacity, risk profile, and approved credit policies.

PRIVACY &
CONFIDENTIALITY

The Company maintains the confidentiality and privacy of all customer information. Data is collected, processed, and stored only for legitimate business purposes in accordance with applicable statutory requirements and the Company's Privacy Policy.

DISPLAY OF CODE

The Fair Practices Code is displayed at all offices, customer service locations, and on the Company's website (www.chhotariasecurities.com). Copies are available free of cost upon request in English or vernacular languages.

TRAINING OF
RECOVERY AGENTS

All employees and outsourced recovery agents receive adequate training on legal norms, customer service standards, ethical conduct, grievance handling, and the FPC provisions. Periodic assessments and monitoring are conducted.

RECORDING OF
RECOVERY CALLS

The Company records telephonic conversations and maintains records of recovery communications wherever legally permissible. Records are preserved for internal monitoring, complaint resolution, audit, and regulatory oversight.

COOLING-OFF /
LOOK-UP PERIOD

For applicable digital lending products, borrowers are provided a cooling-off/look-up period (1 day) during which they may exit the loan by repaying the principal together with proportionate APR, without any penalty. Terms are disclosed in the KFS and loan agreement.

PENAL CHARGES

Penal charges, if any, are reasonable, transparent, non-discriminatory, and not used as additional interest income. The Company does not levy any undisclosed charge or fee. Currently, the Company is not levying penal charges on its loan products.

GRIEVANCE REDRESSAL
OFFICER

The Company has designated a Grievance Redressal Officer to address complaints:

• Name: Ms. Avneet Bagga

• Email: grievance@chhotariasecurities.com

• Phone: +91 91099 57420

• Office: Offices No. 425 - 455, 4th Floor, Magneto Offizo, Raipur (C.G.) – 492006

Complaints are resolved within timelines prescribed under applicable RBI regulations.

OUTSOURCED RECOVERY
AGENCIES

The Company remains fully responsible and accountable for the actions of its outsourced agencies and recovery agents, ensuring compliance with RBI directions, the Fair Practices Code, and the internal Code of Conduct.

CUSTOMER EDUCATION
& AWARENESS

The Company endeavours to educate borrowers regarding loan product features, APR, fees, repayment obligations, consequences of default, and grievance mechanisms in a clear and simple manner.

RESPONSIBLE LENDING
PRACTICES

Credit decisions are based on proper assessment of repayment capacity, financial position, and credit history. Over-indebtedness is discouraged and credit is not extended without verified repayment capacity.

LOAN CLOSURE &
RETURN OF DOCUMENTS

Upon full repayment of all outstanding dues, the Company issues a No Objection Certificate (NOC), updates credit bureaus, and releases original security documents within regulatory timelines.

NO FORCED SELLING

Borrowers are not coerced or compelled to purchase insurance or any third-party products as a condition for obtaining a loan. Any third-party product offered is entirely optional and based on informed consent.

EMPLOYEE & AGENT
CODE OF CONDUCT

All staff and representatives conduct themselves with professionalism, courtesy, fairness, and integrity. No abusive language, intimidation, coercion, or unfair practices are permitted, and customer dignity is respected.

POLICY REVIEW &
CONCLUSION

This policy is reviewed annually or earlier whenever revised guidelines are issued by the RBI. Amendments are approved by the Board of Directors. This policy supersedes all previous credit-related fair practice policies.