1. INTRODUCTION:
   

   Si Creva Capital Services Private Limited is a private limited company, incorporated under the provisions of the Companies Act, 2013, having Corporate Identification Number CIN: U65923MH2015PTC266425 (“Si Creva” / “Company”). Si Creva is a Middle Layer Non-Deposit taking Non-Banking Financial Company, bearing Registration no. N-13.02129, registered and regulated by the RBI Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, as amended from time to time and such other rules, regulations, directions, circulars, notifications, and orders issued in this regard from time to time (“RBI Directions”).

   Si Creva is in the business of extending consumer and personal loans.

2. PURPOSE AND OBJECTIVE:
   
   1. 2.1. Reserve Bank of India (RBI) vide its notification number DNBS (PD) CC No.80/03.10.042/2005-06 dated September 28, 2006, and subsequently through various other notifications has prescribed the broad guidelines on fair practices that are to be followed and approved by the Board of Directors of all Non-Banking Financial Companies (“NBFCs”). As a result, Si Creva has framed, in conformity with RBI guidelines, this comprehensive Fair Practice Code (“Code”), which is covered in this document.
   2. 2.2. This Code aims to inter alia provide the customers effective overview of practices, which will be followed by Si Creva in respect of the financial facilities and services offered by Si Creva to its customers. Further, the Code will also facilitate customers to take an informed decision in respect of the financial facilities and services to be availed by them and will apply to any loan that Si Creva may sanction and disburse.
   3. 2.3. This Code has been developed to: (a) promote good, fair, and trustworthy practices by setting minimum standards in dealings with the customers; (b) increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services. (c) Promote a fair and cordial relationship between the customers and Si Creva. (d) fostering customer confidence in Si Creva.
3. 3. KEY COMMITMENTS AND DECLARATIONS:
   

   Si Creva makes the following key commitments to its customers:

   1. 3.1. Si Creva would act fairly and reasonably in all their dealings with customers by:
      1. 3.1.1. Meeting the commitments and standards enumerated in this Code, for the financial products and services, Si Creva offers, and the procedures and practices its staff follow.
      2. 3.1.2. making sure that their products and services meet relevant laws and regulations.
      3. 3.1.3. carrying out dealings with customers on ethical principles of integrity and transparency.
      4. 3.1.4. providing professional, courteous, and speedy services.
      5. 3.1.5. providing accurate and timely disclosure of terms and conditions; costs, rights, and liabilities as regards financial transactions.
   2. 3.2. Si Creva shall help the customer understand how our financial products and services work by –
      1. 3.2.1. giving verbal information about the financial schemes and all other communications in Hindi and/or English and/or local vernacular language / the language as understood by the borrower;
      2. 3.2.2. ensuring that our advertising and promotional literature is clear and not misleading;
      3. 3.2.3. explaining the financial implications of the transactions;
      4. 3.2.4. helping the customer to choose the financial scheme.
   3. 3.3. Si Creva shall deal quickly and proactively with things that go wrong by:
      1. 3.3.1. Correcting mistakes quickly;
      2. 3.3.2. Attending to customer complaints quickly as per the Customer Grievance Redressal Mechanism laid out by the Company;
      3. 3.3.3. Telling our customers how to take their complaints forward if the customers are still not satisfied with our assistance;
      4. 3.3.4. Reversing any charges that we apply due to our mistake.
   4. 3.4. Si Creva shall publicize this Code, display it on Si Creva’s website in English and all possible major vernacular languages/ the language as understood by the borrower; of the Country and have copies available for customer on request.
4. LOAN APPLICATIONS AND PROCESSING
   
   1. 4.1. All communications to the borrowers shall be made in the vernacular language upon request received from the customer or a language as understood by the borrower.
   2. 4.2. Si Creva will offer credit to eligible qualified applicants who express their need to borrow through their loan request letter or loan application forms.
   3. 4.3. Loan application forms issued by Si Creva shall 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 an informed decision can be taken by the borrower.
   4. 4.4. Si Creva shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 (thirty) days, from the date of receipt of the application form complete in all respects. In any case, the Customer will be kept informed by the salesperson with regard to the status of his application from time to time. The Customer may also contact Si Creva’s customer service team at the prescribed toll-free number or email id to obtain an update on the status of the application.
   5. 4.5. If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.
   6. 4.6. The Company would inform the applicant of the reasons for the rejection of his/her application.
5. NON-DISCRIMINATION POLICY

   Si Creva is strictly prohibited from engaging in any form of discrimination towards Si Creva’s existing as well as potential customers on the basis of gender, race, or religion.

6. LOAN APPRAISAL AND TERMS/CONDITIONS
   1. 6.1. Si Creva shall conduct due diligence on the creditworthiness of the borrower, which will be an important parameter for taking the decision on the application. The assessment would be in line with Si Creva’s credit policies, norms, and procedures in respect thereof.
   2. 6.2. The borrower would be informed in writing in Hindi or English or the vernacular language as understood by the borrower by means of a sanction letter or otherwise, the amount of loan sanctioned. The said letter shall contain the terms and conditions including the annualized rate of interest and the method of application thereof. Si Creva shall keep on record the acceptance of these terms and conditions by the borrower.
   3. 6.3. Si Creva shall invariably be bound to furnish a copy of the loan documents containing the terms and conditions of the loan (“Loan Documents”), in Hindi or English or the vernacular language as understood by the borrower, along with a copy of all enclosures quoted in the Loan Documents to all the borrowers at the time of sanction/ disbursement of loans. Si Creva shall ensure that the Loan Documents and all enclosures furnished to all borrowers contain the terms and conditions and the rate of interest. Further, Si Creva shall mention the penal interest to be charged for late payment in bold in the Loan Documents.
7. DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS / CONDITIONS
   1. 7.1. The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower.
      Si Creva shall give notice to the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. Si Creva shall also ensure that changes in interest rates are affected only prospectively and not introduce any additional component to the rate of interest.

      It is abundantly clarified that penal interest will be levied only in case where funds are involved i. e. the event of delay in repayment of EMIs or the entire loan as per terms of the loan agreement. Further, 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 capitalisation 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.

8. POST-DISBURSEMENT SUPERVISION
   1. 8.1. Any decision to recall/accelerate payment or performance under the Loan Documents shall be in consonance with the Loan Documents.
9. RATE OF INTEREST AND PROCESSING FEE
   1. 9.1. Si Creva shall frame appropriate internal principles and procedures for determining the interest rates and processing and other charges, if any, and also ensure that they are not excessive. Si Creva shall, at the time of disbursal, ensure that the interest rate and other charges, if any, on loans and advances are in strict adherence to the above-referred internal principles and procedures.
   2. 9.2. Si Creva shall disclose the rate of interest to the borrower in the application form/ loan agreement and explicitly communicate it in the sanction letter.
   3. 9.3. The broad range for rates of interest and the approach for gradation of risks shall also be made available on the website of Si Creva in the case of simple products. The information published on the website or otherwise published would be updated whenever there is a change in the rates of interest.
   4. 9.4. The rate of interest would be annualized rates so that the borrower is aware of the exact rates that would be charged to the account.
   5. 9.5. An interest rate model taking into account the cost of funds, margin, and risk premium for determining the rate of interest to be charged for loans and advances shall be laid down by Si Creva.
   6. 9.6. The rate of interest to be charged depends much upon the gradation of the risk of the borrower viz; the financial strength, business, regulatory environment affecting the business, competition, past history of the borrower, etc.
   7. 9.7. The processing fee, if any, shall be determined on the basis of the quantum of work involved in credit appraisal, the volume of documentation, and other expenses involved in the transaction. The rate of interest is subject to change, as the situation warrants due to market compulsions and changes in regulatory norms and is subject to the discretion of the management on a case-to-case basis.
   8. 9.8. The Company shall provide a cost less online repayment option to the borrowers.
10. GENERAL
    1. 10.1. Si Creva shall not interfere in the affairs of the borrower except for the purposes provided in the loan agreement executed with the borrower unless new information not earlier disclosed by the borrower has come to the notice of Si Creva.
    2. 10.2. In the matter of recovery of loans, Si Creva shall not resort to undue harassment like bothering the borrowers at odd hours/ use muscle power for recovery of loans.
    3. 10.3. Si Creva shall ensure that the entire process of enforcing its security, valuation and realization thereof is fair and transparent.
    4. 10.4. Si Creva shall ensure that the staff is adequately trained to deal with the customers in an appropriate manner.
    5. 10.5. In case of receipt of a request from the borrower for transfer of the borrower account, the objection, if any, by Si Creva, shall be conveyed within 21 (twenty-one) days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms in consonance with law.
    6. 10.6. Considering that at present, all the loans granted by Si Creva are unsecured, there will be no eventuality of return of securities representing movable or immovable assets hypothecated / mortgaged to the Company. To this extent, the RBI guidelines vide Circular dated September 13, 2023 are not applicable, for the time being.
    7. 10.7. On receipt of a request from a customer to update the credit information by making an appropriate correction, addition or otherwise, and on such request the Company shall take steps to update the credit information within thirty (30) days after being requested to do so.
11. CUSTOMER GRIEVANCE REDRESSAL MECHANISM

    The customer grievance redressal mechanism (“Redressal Policy”) has been adopted by the Board, pursuant to recommendation of the Audit Committee and has been put up for display at all the borrowers’ touch points/head office and the website of Si Creva, informing the customers about the escalation mechanism and the Grievance Redressal Officer (including the name and contact details).

12. A periodical review of this Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by Si Creva and a consolidated report of such reviews shall be submitted to the Audit Committee at regular intervals.

Si Creva shall abide by this Code following the spirit of the Code and in the manner as may be applicable to its business.