Fair Practice Code

SIDDHI TRADERS PRIVATE LIMITED - Trade Name: V-PAY FINANCE

1. Introduction

SIDDHI TRADERS PRIVATE LIMITED under the trade name V-Pay Finance is a non-deposit taking non-systematically important NBFC, classified as Base Layer NBFC as per Scale Base Regulations 2023, as amended from time to time, holding valid COR as on date is engaged in providing lending services to its customers by way of offer to multiple products suitable to respective borrower as per their business and personal financial requirements.

The organisation endeavours to review and follow the policy guidelines laid by Reserve Bank of India as amended from time to time, to set up fair business practices while dealing with its customers.

Accordingly this fair practice code ("FPC or Code") has been amended pursuant to the Master Direction – Reserve Bank of India (Non-Banking Financial Company –Scale Based Regulation) Directions, 2023, has also issued directions for sourcing of loans over Digital Lending Platforms (Digital lending) and outsourcing of Financial Services - Responsibilities of regulated entities employing Recovery Agents and Guidelines on Digital lending respectively.

V-Pay Finance is presently in the business of providing different types of loans which includes Personal Loans, EV Loan, Solar Loan, Financing to purchase new Batteries for EV, Unsecured Loan to SMEs, Micro Retail LAP etc., to its various customers. Such credit facilities are extended to different types of customers, which include Individuals, Partnership Firms, Companies, self employed and other Legal entities. Hence, in compliance with the said directions, this Code has been framed, approved and reviewed by Board of Company from time to time. The Company shall at all times adopt best business and customer service practices from time to time and make appropriate modifications, as necessary to this Code.

The Fair Practice Code sets out the principles for fair practices/ standards while dealing with its customers.

The Company has adopted this Fair Practices Code ("the Code") and have implemented it. The Code applies to all categories of products and services offered by the Company (currently offered and which may be introduced in future).

2. Objectives of the FPC

• Promote good and fair practices by setting up minimum service standards for customer dealing and loan services
• Maintain transparency with customer to make them understand what they reasonable expect from the V-Pay Finance for its services
• Promote a fair and cordial relationship with the customer
• Increase awareness among the borrowers and prospective customers
• Enable its borrower to make comparison of loan offered by V-Pay Finance with other financial institutions to take informed decision either by accepting the loan offer or denial

3. Application of FPC

• Coverage: FPC shall apply to all the products and services provided by the company, at its branches, over the counter, over telephonic calls, through post, e mail, internet or by any other method. The FPC shall also apply in case of outsourcing of services and lending through DLA (Digital Lending Application) /LSP (Lending Service Provider).
• Applicability: This FPC will applicable to all borrowers (which as the context permits may include prospective borrowers, borrowers who have applied for loan with us but loan not sanctioned / disbursed in addition to the borrowers who are in receipt of loan amount from the Company).

4. V-Pay Finance's Key Commitments

5. Information

• Product Selection: Helping customer to choose products and services, which meets their needs, and give them clear information by explaining the key features of the services and products they are interested.
• Documentation: Inform customer by way of providing checklist about the documents and information's the company needs to establish customer's true identity, address and other documents to comply with legal and regulatory requirements.
• Consent Management: Inform Customer about the exclusive consent taken from them during loan cycle, its use, storage, sharing with third parties, denial / revocation of consent, type of consent which is irrevocable due to financial relationship with the company.

6. Application for Loan and their Processing

• Communication: All communication with borrower shall be in English or the language understood by them. All of our customers are educated and do understand English Language. It is implicit that all of the borrower or prospective borrower understood English Language. All of our Service Executives understand regional language, English and Hindi and we explain the most important Terms and conditions over telephonic call to the customer before disbursement and offer them to select the language understood by them and accordingly the Most Important Terms and Conditions are explained in their preferred language.
• Application Form: The loan Application form of the company will include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower.
• Documentation List: Loan Application contains list of documents required to be submitted with the application form.
• Interest Information: At the time of loan sourcing company will provide information about the indicative range of annualized rate of interest (ROI) for the loan product availed along with the method of interest calculation (factors which affect interest of the borrower), pre payments options, Upfront and incidental charges, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower.

7. Loan Appraisal and Terms/Conditions

• Information Collection: All the information's required for processing the application shall be collected at the time of loan application itself. In case any additional information is required for income assessment, credit assessment and risk assessment, the customer shall be contacted again by the employee or the representative of the company.
• Due Diligence: The company shall conduct a due diligence on the credit worthiness of the customer, which will be an important parameter for taking decision on the application. The assessment would be in line with the Company's credit policies, norms and procedures in respect thereof.
• Sanction Communication: The Company will convey in writing to the borrower in the English or language understood by the borrower by means of sanction letter and KFS, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. The Company will mention the penal charge which will be charged for late repayment and / or any other default on the part of the customer, in bold in the loan agreement.
• Repayment Schedule: The exact due dates for repayment of a loan, frequency of repayment, breakup between principal and interest, examples of SMA/NPA classification dates, etc. shall be communicated to the borrower at the time of loan sanction and also at the time of subsequent changes, if any, to the sanction terms/ loan agreement till full repayment of the loan.
• Document Provision: The company shall provide copies of all the loan documents executed by the customer along with a copy of each of its enclosures as per the Loan Documentation to every customer, subsequent to loan disbursement.

8. Penal Charges in Loan Account

Note: A separate Policy on Fair Lending Practice- Penal Charges on Loan accounts has been put in place and duly approved by the Board of Directors in its meeting held on 24 June, 2025.

9. Disbursement of Loans Including Changes in Terms and Conditions

• Disbursement Schedule: Disbursement shall be made in accordance with the disbursement schedule and/or terms agreed with the customer as per the loan Agreement/ sanction Letter.
• Change Notifications: The Company shall give notice to the customer in English or a language as understood by the customer of any change in the terms and conditions including disbursement schedule, RoI, service charges, pre-payment charges, other applicable fee/charges etc. The Company shall also ensure that changes in RoI and charges are effected only prospectively with prior intimation to the customer.
• Security Release: The Company will release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against borrower.

10. Responsible Lending Conduct – Release of Movable/Immovable Property Documents

A Standard Operating Procedure (SOP)- Property Documents Handover & Charge Release Process in line with RBI guidelines has been put in place:

a) Release of Movable/Immovable Property Documents

• The Company shall release all the original movable / immovable property documents and remove charges registered with any registry within a period of 30 days after full repayment/settlement of the loan account.
• The borrower shall be given the option of collecting the original movable/ immovable property documents either from the branch where the loan account was serviced or any other office of the Company where the documents are available, as per her/his preference.
• The timeline and place of return of original movable/immovable property documents shall be mentioned in the loan sanction letters.

b) Compensation for Delay in Release

11. Collection of Dues

• Explanation of Process: At the time of giving a loan to the customer Company shall explain to the customer the repayment process including instalment amount, tenure, bounce charges, penal charges, and periodicity of repayment.
• Recovery Process: However, if the customer does not adhere to the repayment schedule, a defined process in accordance with the laws of the land shall be followed for recovery of loan dues. The process will involve reminding the customer by sending him / her notice or by making personal visits and / or repossession of security if any.
• Prohibited Practices: In the matter of recovery of loans, the Company or its agents will resort only to remedies which are legally and legitimately available to it and will not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts.

12. Grievance Redressal Mechanism

The Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard which ensures that all disputes arising out of the decisions of the Company's functionaries are heard and disposed of at the next higher level.

In line with the captioned process the Company follows a two (2) tier approach for redressal of customer grievances, as detailed below:

13. General

• Non-Discrimination: No discrimination on grounds of sex, caste & religion in the matters of lending.
• Privacy: The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
• Confidentiality: All personal information of customer and information related to the transactions with the Company shall be treated confidential, shall not be revealed to anyone, except with customer's prior written consent and/or required by laws and regulations.
• Code Availability: The Company shall:
  • Provide customer with a copy of this Code, whenever requested
  • Disclose this Code on the website of the Company
  • Conduct periodic trainings to all the customer facing staff about the fair business practices as mentioned in this Code

14. Policy for Determining Rate of Interest, Processing and Other Charges

• The Board of Directors has adopted an interest rate model for determining the rate of interest to be charged on loans and advances, processing and other charges taking into account relevant factors such as, cost of funds, margin and risk premium, etc.
• The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
• The rates of interest and the approach for gradation of risks shall also be made available on the website of the company. The information published on the website shall be updated whenever there is a change in the rates of interest.
• The rate of interest shall be annualised rate.