Fair Practices Code

Swagat Hire Purchase and Finance Company ("the Company") is committed to conducting its lending business with the highest standards of fairness, transparency, and integrity. This Fair Practices Code ("FPC") has been formulated in compliance with the guidelines issued by the Reserve Bank of India (RBI) under Chapter VII of the NBFC (Scale Based Regulation) Directions, 2023, and RBI Circular DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 01, 2015, as updated by subsequent RBI circulars.

The objective of this Code is to ensure that all borrowers and customers receive fair treatment at every stage of their interaction with the Company — from loan application through disbursement, servicing, and where necessary, recovery.

2.1 Loan Application Forms

All loan application forms shall be:

• Available in English and in a language understood by the borrower (vernacular language where practicable).
• Simple, clear, and transparent about all fees, charges, and conditions that affect the borrower's interest.
• Inclusive of a list of all documents required to be submitted.
• Accompanied by a declaration option for the borrower's preferred language of communication.

2.2 Acknowledgement of Applications

• Upon receipt, the Company shall provide a written or electronic acknowledgement with a reference number and the expected timeline for processing.
• In case of rejection, the reason shall be communicated to the borrower in writing.
• In case of sanction, a formal Sanction Letter on Company letterhead shall be issued.

2.3 Credit Assessment

• All applications shall be assessed based on the borrower's income, repayment capacity, credit bureau report (CIBIL / CIC), collateral quality, and Loan-to-Value (LTV) ratio.
• The credit appraisal shall be recorded in writing in an auditable format and retained on the borrower's file.

With effect from October 1, 2024, the Company issues a standardised Key Facts Statement (KFS) to every borrower for all retail and MSME term loans, before execution of the loan agreement and disbursement. The KFS contains:

• Loan account number, type of loan, and sanctioned amount.
• Disbursement schedule and loan tenure.
• Applicable interest rate (fixed/floating) and the Annual Percentage Rate (APR) — an all-inclusive annualised rate covering processing fees and other upfront costs.
• EMI amount and commencement date.
• All fees and charges payable, and contingent charges (penal charges, foreclosure charges).
• Details of the Grievance Redressal Officer.

Your Sanction Letter and Loan Agreement will contain the following mandatory information:

• Amount of loan sanctioned and disbursement schedule.
• Annualised rate of interest and the method of calculation (reducing balance basis).
• Complete EMI schedule with the split between principal and interest for each instalment.
• Foreclosure / prepayment charges (if applicable) — disclosed clearly.
• Penal charges for late payment — disclosed in bold.
• Security / collateral details and creation timelines.
• For floating rate loans: the reference benchmark, spread, reset mechanism, and six options available to you at each rate reset (switch to fixed, increase/decrease EMI, extend/contract tenure, prepay, or accept elongation as default).

• Disbursement shall be made only after all documentation and security creation requirements are completed.
• Interest shall be calculated from the date of actual disbursement, not from the date of sanction or documentation.
• Disbursement shall be made by online transfer to your bank account. Where a cheque is issued, your acknowledgement of receipt shall be obtained.
• If an advance EMI is collected at disbursement, interest shall be charged on the net disbursed amount (after netting the advance EMI).
• Any change in the disbursement schedule shall be communicated to you in writing in advance.

In compliance with RBI Circular dated April 29, 2024, the Company commits to the following fair interest charging practices:

• Interest rates are determined based on a transparent, Board-approved Interest Rate Policy covering cost of funds, operating costs, and borrower risk profile.
• The annualised rate of interest and APR shall be disclosed in your application form, KFS, sanction letter, and on our website.
• Interest rates shall be reasonable and not usurious.
• The Company shall NOT charge interest from the date of sanction — only from the date of actual disbursement.
• The Company shall NOT charge interest on amounts already repaid.
• Any change in interest rate shall be communicated in writing before it takes effect.

The approach for gradation of risk and rationale for charging different rates to different categories of borrowers is published in our Interest Rate Policy.

Penal charges are levied for non-compliance with material terms of your loan contract. In compliance with RBI guidelines effective January 1, 2024:

• Penal charges are NOT interest and shall NOT be capitalised or compounded.
• Charges are reasonable and non-discriminatory within the same loan category.
• For individual borrowers (non-business purposes), charges shall not be higher than those for non-individual borrowers.
• When a penal charge is levied, you shall be informed in writing of the reason and amount.

• All changes (interest rates, charges, disbursement schedule, prepayment terms) shall be made only prospectively with advance written notice.
• Where a change is to your disadvantage, you shall be given the option to close your account or switch within 60 days without any additional charges or interest.
• All consent to changed terms shall be documented by the Company.

The Company and all recovery agents engaged by it are strictly prohibited from:

• Any form of intimidation or harassment — verbal, physical, or digital — against borrowers, guarantors, or their family members.
• Publicly humiliating borrowers (including through social media, posters, or other public means).
• Making recovery calls before 8:00 AM or after 7:00 PM.
• Making anonymous, threatening, or abusive calls or messages.
• Making false or misleading representations about outstanding amounts, legal consequences, or the caller's identity.
• Interfering in your personal affairs beyond what is necessary for recovery of legitimate dues.

• Before initiating repossession, the Company shall send a formal written notice specifying the default and providing a minimum of 30 days to remedy it.
• Repossession shall follow due legal process under the hire purchase agreement and applicable law.
• Repossessed assets shall be valued and sold through a transparent and fair process.
• You will receive a statement of outstanding dues before sale and a realisation statement after sale.
• Any surplus after settlement of all dues shall be returned to you promptly.

In compliance with RBI guidelines effective December 1, 2023:

• All original property documents and title deeds shall be released to you within 30 days of full and final repayment of all dues.
• All registered charges on your property shall be removed within 30 days of final settlement.
• If there is a delay beyond 30 days due to the Company's fault, the Company shall pay you a penalty of ₹5,000 per day of delay.
• In case of loss or damage of documents by the Company, we shall assist you in obtaining certified copies at the Company's cost.
• If you are deceased, documents shall be returned to your legal heirs.

We take all customer grievances seriously. Here is how to raise a complaint:

• Step 1: Contact our Grievance Redressal Officer (GRO) — details below. Complaints shall be acknowledged within 5 working days and resolved within 30 calendar days.
• Step 2: If unresolved within 30 days, or if you are not satisfied with the resolution, you may escalate to the RBI Integrated Ombudsman Scheme.

The Company shall not discriminate in the provision of financial services on the basis of sex, caste, religion, gender, race, disability, or any other ground prohibited by law. All credit decisions are based solely on objective financial and creditworthiness criteria applied uniformly.

Risk-based differential pricing is applied through a transparent risk gradation framework — the rationale for which is disclosed in our Interest Rate Policy.