Solfin Sustainable Finance Private Limited

1. Introduction

2. Applicability

1. (a)The FPC shall apply to all the products and services offered by the Company.
2. (b)The Code shall apply to all the employees, its agents, representatives, third party vendors, service providers, Directors of the Company and other persons authorised to represent the Company in its normal course of business.
3. (c)The Company's Code shall apply across all aspects of its operations including marketing, loan origination, processing, servicing and collection activities.

3. Regulatory Context

This Code takes into account regulatory documents published by regulatory bodies (referred as 'Applicable Laws'), in particular: -

1. (a)Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 dated 28th November 2025.
2. (b)Applicable circulars, guidelines and clarifications as may be issued from time to time by RBI.
3. (c)Pursuant to any subsequent amendments in the above stated guidelines or other applicable acts/ regulations, if there is any change in any of the parameters framed by the Board then the Act/ Regulation will have overriding effect on the parameters.

4. Relevant Documents

This Code shall be read along with the other policies of the Company as applicable and amended from time to time.

5. Objectives

The Company has put in place the FPC with an endeavour to achieve synchronization of best practices when the Company is dealing with its stakeholders. The primary objectives for adopting the FPC is as mentioned below:

1. (a)To promote good and fair practices by setting minimum standards in dealing with customers;
2. (b)To increase transparency so that the customer can have a better understanding of what they can reasonably expect of the services;
3. (c)To promote a fair and cordial relationship between customer and the Company;
4. (d)To ensure that the products and services meet relevant laws and regulations in force in India;

The Company's Board of Directors and the management are responsible for establishing practices designed to ensure that its operations reflect a strong commitment to fair lending and that all employees are aware of that commitment.

6. Non-Discrimination Policy

The Company will not discriminate between its customers on the basis of gender, physical ability, race or religion. The Company will also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from participating in credit-linked schemes framed for weaker sections of the society.

7. Loan Application & Processing

1. (a)The Company shall ensure that all communications to the borrower shall be in the English language or in the vernacular language or a language understood by the borrower. For this purpose, the Company shall obtain relevant declaration from the customer towards the language understood by the customer.
2. (b)The loan application form of the Company shall cover loan requirements, KYC, declarations and all such other information and documents which will enable the Company to make an informed judgement on the loan approval and at the same time inform the borrower on his legal and commercial responsibilities. The loan application form shall indicate the documents required to be submitted with the application form.
3. (c)The Company shall indicate on its website, or on loan documents, as the case may be, complete list of documents that are required to be submitted by the borrower along with the loan application.
4. (d)The Company shall provide an acknowledgement for receipt of all loan applications through appropriate mode indicating the time frame within which the loan application will be disposed of.
5. (e)The Company shall verify the loan applications within a reasonable period of time and if additional details / documents are required, it would intimate the borrowers immediately. In case the loan application is not approved by the Company, the borrower would be intimated about such rejection.

8. Loan Appraisal and Terms & Conditions

1. (a)All loan applications shall be evaluated by the Company on the predefined eligibility criteria for the financial products on the basis of the information and documents provided by the applicant. If required, the Company may verify all or any information/ document in a manner permissible by law.
2. (b)Upon approval of loan application, the Company shall convey in writing to the borrower the amount of loan being sanctioned by means of sanction letter, Key Fact Statement ("KFS") and Loan Agreement.
3. (c)The Company shall inform the borrower by means of a written sanction letter in the English language or in the vernacular language or a language understood by the borrower, 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 issued by the borrower on its record.
4. (d)The Company shall mention the penal charges in bold in the loan documents.
5. (e)Acceptance of Loan sanction letter to be kept on record.
6. (f)Copy of Executed Loan agreement to be sent to Borrower along with all documents/annexures at the time of disbursement.
7. (g)The Company shall also furnish a copy of the loan agreement as understood by the borrower, along with a copy of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction/disbursement of loans.

9. Disbursement of Loans Including Changes in the Terms and Conditions

1. (a)The Company shall give a notice to the borrower in the vernacular language as understood by the borrower, of any changes in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company shall also ensure that the changes in the interest rates and charges are effected only prospectively. A suitable condition in this regard will be incorporated in the loan agreement.
2. (b)Any decision to recall/accelerate the payment or performance under the loan agreement shall be in consonance with the loan agreement.
3. (c)All securities offered by the borrower shall be released on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against the borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.

10. Penal Charges in Loan Accounts

1. (a)Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as 'penal charges' and shall not be levied in the form of 'penal interest' that is added to the rate of interest charged on the advances. There shall be no capitalization of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.
2. (b)The Company shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit.
3. (c)The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category.

1. (d)The Company shall not, without adequate and reasonable reasons, differentiate between Individual and non-individual borrowers for penal charges for non-compliance with similar terms and conditions for loans other than business.
2. (e)The quantum and reason for penal charges shall be clearly disclosed by the Company to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable.
3. (f)Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefore shall also be communicated.

11. Recovery Mechanism

1. (a)The staff of the Company as well as the representatives of external agencies engaged by the Company for recovery of loans shall be properly trained to communicate appropriately with the customers with due care and sensitivity, considering aspects such as soliciting customers, hours of calling, privacy of customer information and conveying the correct terms and conditions of the products etc.
2. (b)The Company's collection policy/ process shall be built on courtesy, fair treatment and persuasion. The Company believes in fostering customer confidence and long-term relationship.
3. (c)All the staff members of the Company or third-party recovery agents shall follow the guidelines set out below in collection of dues:
   1. i.Customer would be contacted ordinarily on his registered mobile number; or at the place of his/ her choice and in the absence of any specified place, at the place of his/ her residence.
   2. ii.Identity and authority to represent the Company shall be made known to the customer at the first instance.
   3. iii.Customer's privacy shall be respected.
   4. iv.Interaction with the customer shall be in a civil manner and the customer should not be called at odd hours i.e. before 8:00 a.m. and after 7:00 p.m.
   5. v.Customer's request to avoid calls at a particular time or at a particular place shall be honoured, as far as possible.
   6. vi.All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
   7. vii.During visits to customer's place for dues collection, decency and decorum shall be maintained.
4. (d)The Company and their agents shall not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude the privacy of the customers' family members, referees and friends, making threatening and anonymous calls or making false and misleading representations.
5. (e)The Company shall ensure that prior intimation of the details of the recovery agent authorised to approach the borrower for recovery and any changes thereon is given to the borrower.

12. Responsibility of Board of Directors

1. (a)The Board of Directors of the Company has laid down the appropriate grievance redressal mechanism within the organization. The mechanism ensures that all disputes arising out of the decisions of lending institutions' functionaries are heard and disposed of at least at the next higher level.
2. (b)The Board of Directors periodically reviews the compliance of the Code and the functioning of the grievance's redressal mechanism at various levels of management.

13. Integrated Ombudsman Scheme for Non-Banking Financial Companies

1. (a)The Company shall adhere to Reserve Bank – Integrated Ombudsman Scheme, 2021 (RBI – IOS), as amended time to time.
2. (b)Under the RBI – IOS, the Company has appointed a Principal Nodal Officer (PNO) and/ or Nodal Officer (NO) who shall be responsible for representing the Company and furnishing information to the Ombudsman in respect of complaints filed against the Company.
3. (c)For the benefit of the customers, at the places where business is transacted, the name and contact details (Telephone/Mobile number and email) of the PNO and NO along with the details of the complaint lodging portal of the Ombudsman (https://cms.rbi.org.in) shall be displayed.
4. (d)A complaint can be filed through any of the following methods:
   1. i.Online – on CMS portal of RBI at https://cms.rbi.org.in.
   2. ii.Physical complaint (letter/post) in the form as specified to "Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017".
   3. iii.Complaints with full details can be sent by email (crpc@rbi.org.in).
5. (e)The salient features of the Scheme are displayed prominently at the offices and website of the Company in such a manner that a person visiting the office has adequate information on the Scheme.

14. Grievance Redressal Mechanism

The Company shall set up a Grievance Redressal Policy. The same shall be displayed on the website of the Company.

15. Language and Mode of Communicating Fair Practice Code

1. (a)This code as established by the Company has been documented in English language or in the vernacular language or a language understood by the borrower and is based on the guidelines as outlined by the RBI, the same is approved by its Board of Directors.
2. (b)For the information of various stakeholders, the Company shall place this Code on the Company's website in language understood by its customers.

16. General Provision

1. (a)The Company has framed appropriate internal principles and procedures for determining and ensuring that the interest rates and processing and other charges are not excessive. The Company shall at the time of disbursement, ensure that these rates and charges are in strict adherence to the principles and procedures of the Company.
2. (b)The Company shall refrain from interfering in the affairs of the borrower except for the purposes provided in the Loan Agreement, unless new information not earlier disclosed by the borrower has come to the notice of the Company.
3. (c)In case of receipt of request from the borrower for transfer of borrower's account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.
4. (d)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.
5. (e)The borrower shall be given the option of collecting the original movable/ immovable property documents either from the banking outlet/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 issued on or after the effective date.
6. (f)In case of delay in releasing of original movable/immovable property documents or failing to file charge satisfaction form with relevant registry beyond 30 days after full repayment/settlement of loan, for reasons solely attributable to the Company, maximum compensation to borrower shall not be more than ₹5,000 for each day of delay.

17. Review

This Code shall be reviewed annually by the Board of Directors of the Company. Any change/amendment in applicable laws with regard to maintenance of an appropriate Code shall be deemed to be incorporated in this Code by amendment and this Code shall be accordingly amended as and when required.