Fair Practices Code (FPC)

1. Preamble & Application of the Code

The purpose of this document is to define the Fair Practice Code of the Company in accordance with Reserve Bank of India directions for Non-Banking Financial Companies. It provides transparent information to customers and explains how the Company is expected to deal with them on a day-to-day basis.

This Fair Practices Code applies to all categories of products and services offered by us: (1) Loan and other products in the nature of financial assets; and (2) Third Party products offered through a Company’s Agent or Partner, irrespective of whether provided physically, over phone, internet or futuristic digital channels.

2. Objectives of the FPC

• To promote good, fair and trustworthy practices by setting minimum standards in dealing with customers.
• To enable greater transparency for customers in having a better understanding of the product, taking informed decisions and reasonably expect of the services.
• To ensure compliance with legal norms in matters relating to recovery of advances.
• To ensure building customer confidence in the Company.
• To promote a fair and cordial relationship between customer and the Company.
• To strengthen mechanisms for redressal of customer grievances.

3. Key Commitments

The Company commits to acting fairly and reasonably in all dealings with customers, meeting commitments and standards in this Code, ensuring compliance with relevant Indian laws and regulations, and adhering to ethical principles of integrity and transparency.

We help customers understand how our products work by explaining their financial implications. We deal quickly and sympathetically with mistakes, handle grievances expeditiously, and publicize this Code by displaying it on the Company’s website (https://www.taplend.in).

4. Information & Documentary Transparency

The Company assists customers in choosing products and services that meet their needs and gives them clear information explaining key features.

We inform customers upfront regarding documentary information required to establish identity and address (Know Your Customer requirements), and provide information on interest rates, common fees and charges through helplines, designated helpdesks, and website publications.

5. Application for Loans & Their Processing

• All communications to the borrower are made in English or vernacular language.
• At the application stage, Kaynet provides all necessary information including processing fees/charges, non-refundable fees in case of proposal rejection, and pre-payment options so meaningful comparison with other NBFCs can be made.
• The loan application form clearly indicates the documents required to be submitted.
• In case of digital lending products, the sanction letter is accompanied by standardized Key Fact Statements (KFS) detailing the APR, recovery mechanism, grievance redressal details and all applicable charges.
• The Company assesses the repayment capacity of the borrower before sanctioning the loan.
• Acknowledgement is issued over email for each application, and completed applications are processed within a reasonable timeframe (maximum 30 days).

6. Loan Appraisal and Terms and Conditions

The Company conveys in writing to the borrower (in English or vernacular language) by sanction letter or otherwise the loan amount sanctioned along with all terms and conditions including annualized rate of interest, overdue interest, late payment charges and method of application, maintaining borrower acceptance on record.

Penal interest for late repayment is explicitly mentioned in the loan agreement; no charges or fees other than those specified in the sanction letter or KFS are levied.

A copy of the loan agreement along with all enclosures is furnished to the borrower at the time of sanction and disbursal.

7. Disbursement of Loans & Changes in Terms

• The borrower enters into a loan agreement containing all standard and specific terms prior to disbursement.
• Complete disbursal of the loan amount is made strictly to the borrower’s own bank account without any pass-through accounts.
• Notice is given in writing or electronically of any changes in repayment schedules, interest rates, service charges, or overdue interest.
• Changes in interest rates and charges are effected only prospectively; suitable conditions are incorporated in loan agreements.
• All securities (if any) are released on repayment of all dues, subject to any legitimate right of set-off for other claims, with full written particulars provided to the borrower.

8. Collection of Dues & Recovery Code of Conduct

• A defined process in accordance with the law of the land is followed for recovery of dues: reminders via email, calls, SMS, WhatsApp, personal visits or repossession of security.
• Company staff or authorized representatives must identify themselves, display the authority letter issued by the Company, and upon request display their Company-issued ID card.
• Borrowers are contacted ordinarily at their place of choice, residence, or place of business/occupation.
• Borrower privacy is respected, and interactions are conducted in a civil and courteous manner.
• Zero tolerance: staff and agents shall NOT use threatening or abusive language, threats of violence, or harass relatives, friends, or co-workers.
• Representatives contact borrowers strictly between 07:00 AM and 07:00 PM (1900 hrs), unless special circumstances of business require otherwise.
• The Company does NOT mislead borrowers regarding debt extent or non-repayment consequences, and does NOT publish debtor names.
• Time and number of calls and contents of conversations are documented; disputes are handled orderly and amicably.

9. General Clauses & Digital Lending Oversight

• The Company refrains from interference in the affairs of the borrower except as provided in the loan agreement.
• The Company is accountable for inappropriate behavior by employees or outsourced agencies and provides timely grievance redressal.
• Requests for loan transfer are responded to within 21 days with consent or objections.
• Customer details are kept confidential and disclosed only under applicable legal obligations, regulatory directions, or confidential third-party audit/assignment.
• Digital Lending Platforms (DLPs) engaged as agents are disclosed on the website; DLPs disclose upfront that they interact on behalf of the Company; sanction letters are issued on Company letterhead.

10. Regulation of Rate of Interest

The Board of Directors has adopted an interest rate model for determining the rate of interest to be charged on loans, processing fees and other charges taking into account cost of funds, margin and risk premium.

The rate of interest and approach for gradations of risk are disclosed on the website and provided to borrowers as annualized rates.

11. Grievance Redressal Mechanism & Escalation Matrix

• Level 1 — Grievance Redressal Officer: Mr. Mohit Asoliya, 4800-24 Second Floor, Bharat Ram Road, Daryaganj, Darya Ganj, Central Delhi, New Delhi, Delhi, India, 110002. Tel: +91-93558 71314, Email: grievance@taplend.in. Available 10:00 AM to 6:00 PM, Monday to Saturday. Endeavours to resolve grievances within 30 days.
• Level 2 — Nodal Officer: If unresolved or dissatisfied within 30 days, escalate to Mr. Rahul Kumar, 4800-24 Second Floor, Bharat Ram Road, Daryaganj, Darya Ganj, Central Delhi, New Delhi, Delhi, India, 110002. Tel: +91-93558 71315, Email: nodal@taplend.in. Available 10:00 AM to 6:00 PM, Monday to Saturday (except public holidays).
• Level 3 — Reserve Bank of India: If unresolved within 30 working days from submission, escalate to RBI: CMS Portal (https://cms.rbi.org.in), Sachet Portal (https://sachet.rbi.org.in), or Regional Office: Department of Supervision (NBFC), Reserve Bank of India, 6, Sansad Marg, New Delhi – 110001.

12. Board Review & Committee Oversight

The Fair Practice Code Committee oversees the implementation of this Code and reviews its functioning periodically.