Fair Practice Code

Preamble

This Fair Practices Code ("FPC" or "Policy" or "Code") has been devised by Sajan International Private Limited ("Company" or "we" or "our" or "us") in accordance with the Guidelines issued by the Reserve Bank of India ("RBI") on FPC for non-banking financial companies ("NBFC") through its master circular bearing no. RBI/DOR/2025-26/362 DOR.MCS.REC.No.281/01-01-039/2025- dated November 28, 2025. ("RBI Circular") wherein standards for fair business and corporate practices while dealing with their customers are set.

The FPC as mentioned herein below, is in conformity with the Guidelines on Fair Practices Code for NBFC's as contained in the aforesaid RBI Circular. The guidelines inter alia, cover general principles on adequate disclosures on the terms and conditions of a loan and adopting a non-coercive recovery method.

The Company has displayed the FPC prominently at all offices and customer service centres, as well as on its website for the benefit of all customers, and shall follow it in letter and spirit.

Objective of the Code

The Company's fair lending practices shall apply across all aspects of its operations including marketing, loan origination, processing, servicing and collection activities. The Company's commitment to the FPC would be demonstrated in terms of employee accountability, monitoring and auditing programs, training and technology.

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.

The Code has been developed with an objective of:

• Ensuring fair practices while dealing with customers;
• Following transparent, fair, ethical and legally tenable practices while conducting business;
• Providing all necessary information and inputs to customers / prospective customers and promoting a mutually beneficial long-term relationship; and
• Building customer confidence in the Company.

Key Commitments

The key commitments which the Company promises to follow in its dealings with its customers are:

• To provide professional, efficient, courteous, diligent and speedy services
• Not to discriminate on the basis of religion, caste, sex, descent in any manner
• To be fair and honest in any advertisement and marketing of loan products;
• To provide customers with accurate and timely disclosure of terms and conditions, costs, rights and liabilities as regards loan transactions
• To provide assistance or advise to customers seeking loans
• To attempt in good faith to resolve any disputes or differences with customers by setting up complaint redressal system within the Company
• To comply with all the regulatory requirements in good faith and
• To implement compensation and other policies that align the interests of owners and management.

Applications for Loans and Their Processing

• All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
• Loan application forms of the Company will include necessary information which are likely to affect the interests of the borrower as well as details of all documents that are required to be submitted by the borrower.
• The Company will provide the necessary information to facilitate the borrower in making a meaningful comparison with similar terms and conditions offered by other NBFC's and taking an informed decision.
• The Company has a mechanism of giving an acknowledgement for receipt of the loan application forms to its borrowers and will inform the borrower about its decision within reasonable period of time from the date of receipt of all the required information in full.

Loan Appraisal and Terms/Conditions

• The Company will convey in writing to the borrower in the vernacular language as understood by the borrower by means of sanction letter or otherwise, 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. As complaints received against the company are generally pertain to charging of high interest/penal charges, The Company shall mention the penalties charged for late repayment in bold in the loan agreement.
• The Company shall furnish a copy of the loan agreement in the vernacular language or a language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.

Disbursement of Loans Including Changes in Terms and Conditions

• The Company will give notice to the borrower in the vernacular language or a language as understood by the borrower, of any change in the terms and conditions of the loan, including changes in disbursement schedule, interest rate, service charges, prepayment charges etc. The Company will also ensure that changes in interest rates and charges are affected only prospectively. A suitable clause to this effect shall be duly incorporated in the loan agreement.
• Decisions to recall/accelerate payment or performance under the loan agreement will be in consonance with the respective loan agreement.
• The Company will release all securities of its borrower only on repayment of all dues by such borrower, or only on realization of the outstanding amount of the borrower's availed limit, subject to any legitimate right or lien for any other claim which the Company may have against the borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars about the remaining claims and conditions under which the Company will be entitled to retain the securities till the relevant claim is settled or paid by the borrower. Due No Objection Certificate ("NOC") will be issued to the borrower on fulfilment of said terms within fifteen (15) workings days of completion of formalities.

General

• The Company will refrain from interference in the affairs of its borrowers except for the purposes provided in the terms and conditions of the respective loan agreements (unless information, not earlier disclosed by the borrower, has been noticed).
• Our field staffs shall not call on the borrowers before 6 am and after 8 pm and shall not visit their residence or work place on days of festival, marriage etc., or any mourning occasions for the purpose of recovery.
• We shall ensure that the procedure for application of loan is not cumbersome and loan disbursements are made as per pre-determined time schedule driven through the well-defined process.
• In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e., objection of the Company, if any, will be conveyed to the borrower within twenty-one (21) days from the date of receipt of the borrower's request. Such transfer will be as per transparent contractual terms in consonance with applicable law.
• In the matter of recovery of outstanding dues of its borrower, the Company shall not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans/dues, etc. Training will be imparted to ensure that Company's staff is adequately trained to deal with customers in an appropriate manner.

Language and Mode of Communicating FPC

• The FPC has been formulated by the Company in English language, duly approved by the board of directors of the Company and is based on the relevant guidelines as outlined by the RBI in this regard.
• The FPC has been published by the Company on its website for information of all concerned stake holders.

Regulation of Excessive Interest Charged

• The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.
• The board of directors of the Company has adopted an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium for determining rate of interest to be charged for loans and advances.
• The rate of interest and the approach for gradation of risks will also be made available on the website of the companies. The information published on the website shall be updated where there is change in the rate of interest. The rate of interest will be annualised rate.

Complaints about excessive interest charged by NBFCs

The Company acknowledges that it has received guidance from the Reserve Bank regarding customer complaints on high interest rates and charges in the NBFC sector. While interest rates are determined by the Company in line with its internal policies and market conditions, the Company is committed to ensuring that such rates and charges are fair, transparent, and justifiable. The Company believes that its pricing practices are sustainable, reasonable, and consistent with sound financial principles and applicable regulatory expectations.

Repossession of vehicles financed by NBFCs

The Company have built-in re-possession clause in the contract / loan agreement with the borrower which shall be legally enforceable. To ensure transparency, the terms and conditions of the contract/loan agreement shall will also have the provisions regarding:

1. Notice period before taking possession;
2. Circumstances under which the notice period can be waived;
3. The procedure for taking possession of the security;
4. A provision regarding final chance to be given to the borrower for repayment of loan before the sale/ auction of the property.
5. The procedure for giving repossession to the borrower; and
6. The procedure for sale/auction of the property.

A copy of such terms and conditions will be given to the borrower. The Company will invariably furnish a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction/ disbursement of loans, which forms a key component of such contracts/ loan agreements.

Loan facilities to the physically / visually challenged

The Company shall not discriminate in extending products and facilities including loan facilities to physically / visually challenged applicants on grounds of disability. All branches, if any of the company shall render all possible assistance to such persons for availing of the various business facilities. The company shall include a suitable module containing the rights of persons with disabilities guaranteed to them by the law and international conventions, in all the training programmes conducted for their employees at all levels. Further, the company will ensure redressal of grievances of persons with disabilities under the Grievance Redressal Mechanism already set up by them.