Fair Practices Code

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 (“NBFC”), in accordance with the Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025 dated 28th November 2025, as amended from time to time bearing Registration no. N-13.02129 and is governed by such other applicable rules, regulations, directions, circulars, notifications, and orders issued by the Reserve Bank of India (“RBI”) in this regard (collectively referred to as the “RBI Directions”).

Si Creva is in the business of the provision of secured and unsecured loans by using two digital lending applications viz; ‘Kissht’ and ‘PaywithRing’ which are owned by its 100% holding Company viz., OnEMI Technology Solutions Limited. Besides this, it is also lending through the mobile app and web-based applications on the platforms of other Lending Service Providers (“LSPs”). The Company is also having co-lending arrangements with other regulated entities.

PURPOSE AND OBJECTIVE:

• Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 (Circular No. RBI/DOR/2025-26/362 DOR.MCS.REC.No.281/01-01-039/2025-26 dated November 28, 2025) ) (as modified, amended, and updated from time to time) lays down regulations pertaining to Fair Practices Code to be adhered by Non-Banking Financial Companies (NBFCs). As a result, Si Creva has framed, in conformity with RBI guidelines, this comprehensive Fair Practices Code (“Code”), which is covered in this document and duly approved by the Board of Directors.
• 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 taking 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.

• This Code has been developed to:

  • promote good, fair, and trustworthy practices by setting minimum standards in dealings with the customers.
  • increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services.
  • Promote a fair and cordial relationship between the customers and Si Creva.
  • fostering customer confidence in Si Creva.
  • To ensure compliance with legal norms in matters relating to recovery of advances.
  • To strengthen mechanisms for redressal of customer grievances.
  • Comply with all applicable regulations set by the RBI regarding fair practices

KEY COMMITMENTS AND DECLARATIONS:

Si Creva makes the following key commitments to its customers:

• Si Creva would act fairly and reasonably in all their dealings with customers by:

  • 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.
  • making sure that its products and services meet relevant laws and regulations.
  • carrying out dealings with customers on ethical principles of integrity and transparency.
  • providing professional, courteous, and speedy services.
  • providing accurate and timely disclosure of terms and conditions; costs, rights, and liabilities as regards financial transactions.

• Si Creva shall help the customer understand how our financial products and services work by –

  • 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 based on customer request;
  • ensuring that our advertising and promotional literature is clear and not misleading;
  • explaining the financial implications of the transactions;
  • helping the customer to choose the financial products.

• Si Creva shall deal quickly and proactively, within the turnaround time, in case of customer feedbacks / concerns:

  • Attending to customer complaints quickly as per the Customer Grievance Redressal Mechanism laid out by the Company;
  • Informing the customers how to take their complaints forward if the customers are still not satisfied with our resolution of the complaint.
• 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; and make copies available for the customer on request in any other vernacular language.

LOAN APPLICATIONS AND PROCESSING

• All communications to the borrowers shall be made in English or the vernacular language upon request received from the customer or a language as understood by the borrower.
• Si Creva will offer credit to eligible applicants who express their need to borrow through their loan request letter or loan application forms.
• The loan application form shall indicate the documents required to be submitted along with the application form. The Company shall collect all necessary documents to comply with Know Your Customer (‘KYC’) norms of RBI.
• Loan application forms issued by Si Creva shall include necessary information which impacts the interest rate applicable to 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.
• Si Creva shall devise a system of giving an acknowledgement for receipt of 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 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 given toll-free number or email id to obtain an update on the status of the application.
• If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.

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, or race, or religion.
• Si Creva shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability. All branches of Si Creva shall render all possible assistance to such persons for availing of the various business facilities. Si Creva 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, Si Creva shall ensure redressal of grievances of persons with disabilities under the Grievance Redressal Mechanism already set up by them.

LOAN APPRAISAL AND TERMS/CONDITIONS AND KEY FACTS STATEMENT FOR LOANS AND ADVANCES

• 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/ underwriting policies, norms, and procedures in respect thereof.
• The company, upon approval of the loan, shall provide a KFS to all prospective borrowers to help them take an informed view before executing the loan contract, as per the standardised format followed by sanction letter or otherwise, the amount of loan sanctioned, the most important terms and conditions (MITCs) including the annualized rate of interest and the method of application thereof, as per interest rate policy of the Company hosted on its website. Si Creva shall keep on record the acceptance of these terms and conditions by the borrower.
• The KFS shall also include a computation sheet of annual percentage rate (APR), and the amortisation schedule of the loan over the loan tenor.
• The Company shall provide KFS with a unique proposal number and shall have a validity period of at least three working days for loans having tenor of seven days or more, and a validity period of one working day for loans having tenor of less than seven days.
• Si Creva shall ensure that the KFS is written in a language understood by the borrower and contents of KFS shall be explained by the Si Creva team to the borrower and an acknowledgement shall be obtained that they have understood the same.
• To ensure that the Customers are not charged excessive interest rate, the Company has adopted interest rate model considering relevant factors such as cost of funds, processing fee and charges for other expenses, margin & risk premium, etc., duly approved by Board. The quantum and reason for penal charges, as applicable shall be clearly disclosed to the customers upfront in the MITC / KFS and loan agreement in addition to being displayed on the website under Interest Rate and Service Charges .The Company shall also draw a reference in the sanction letter to the interest rate model policy placed on its website and communicate the rate of interest explicitly in the sanction letter, as mentioned in para 9.2 hereinbelow.
• Si Creva shall furnish a copy of the loan agreement as understood by the borrowers along with all the enclosures quoted in the loan documents to 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 KFS, the MITCs and the rate of interest. Further, The KFS shall be presented in the form of a summary box and shall form an integral part of the loan agreement.
• The Company shall not charge any fees, charges, etc. which are not mentioned in the KFS, to the borrower at any stage during the term of the loan, without explicit consent of the borrower.
• Charges collected by the Company from borrowers on behalf of third-party service providers (e.g., insurance, legal fees) shall be included in the APR and disclosed separately. The Company will provide borrowers with receipts and relevant documents for these charges within a reasonable time.
• Si Creva shall mention the penal charges to be levied for late payment or penal charges in the event of non-adherence to the MITCs, in bold fonts in the Loan Documents.
• Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the penal charges for such non-compliance shall also be communicated simultaneously. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS / CONDITIONS

• The disbursement of the sanctioned amount can 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. Any changes to the above charges shall also be updated on the Company website. Si Creva shall also ensure that changes in interest rates and charges are affected only prospectively and not introduce any additional component to the rate of interest on the existing loans.
• It is abundantly clarified that penal charges will be levied only in case of non-compliance with material terms and conditions of the loan agreement. To expressly clarify, the penal charges shall be levied where funds are involved i. e. the event of delay in repayment of Equated Monthly Instalments (‘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’ and will not be 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 and all the outstandings including the pending penal charges shall become payable by the customer.
• Si Creva shall follow the instructions and clarifications, if any, issued by Central Board of Indirect Taxes & Customs (CBIC) with regard to applicability of GST on penal charges.

POST-DISBURSEMENT SUPERVISION

• Any decision to recall/accelerate repayment or performance under the Loan Documents shall be in line with the material terms and conditions of the loan.
• All securities pertaining to the loan would be released on receipt of full and final payment of the loans, subject to any legitimate right or lien, and set-off for any other claim that Si Creva may have against the borrowers, as part of the loan agreement. 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 Si Creva is entitled to retain the securities until the relevant claim is settled / paid.

RATE OF INTEREST, PROCESSING FEE AND OTHER CHARGES:

• 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 policy, internal principles and procedures.
• To ensure that the Customers are not charged excessive interest rate and charges including penal charges on loans and advances, the Board has adopted a Policy for determining Interest Rates, Processing and Other Charges. Interest Rate Policy and list of applicable processing & other charges are put up on Si Creva’s website.
• Si Creva shall disclose the rate of interest to the borrower in the Loan Agreement/ Key Fact Statement and explicitly communicate it in the sanction letter.
• The rates of interest and the approach for gradation of risks i.e. forming part of Interest Rate Policy shall also be made available on the Si Creva’s website. The information published on the website or App/ platform would be updated whenever there is a change in the rates of interest.
• The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
• The rate of interest would be annualized rate (APR) so that the borrower is aware of the exact rates that would be charged to the account.
• 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.
• The rate of interest to be charged depends much upon the gradation of the risk of the borrower viz; overall indebtedness of the borrower, business, source of repayment, regulatory environment impacting the business, competition, past history of the borrower for loan servicing, etc.
• Penal charges shall be reasonable and proportionate to the non-compliance of material loan terms, without discrimination within a loan/product category. While penal charges may vary based on loan amount within the same product, the structure must remain consistent regardless of the borrower’s constitution. For loans to individual borrowers for non-business purposes, penal charges shall not exceed those applicable to non-individual borrowers for similar breaches.
• 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 Pre-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.
• Foreclosure/ pre-payment charges shall be applied according to Company Policy as disclosed in loan documents (KFS, Sanction Letter and Loan Agreement) issued to the customer and shall be guided by the regulatory guidelines as prescribed, if any, by RBI from time to time and to the extent applicable.
• Pre-payment charges, if levied by the Company, shall be based on the amount being prepaid and period thereof.
• Si Creva shall not levy any charges where pre-payment is effected at the instance of the company.
• Si Creva at its discretion, may provide relief measures such as waiver / reduction of various fees and charges in respect of customers in the areas where a calamity has been declared, for a period not exceeding one year.

RELEASE OF IMMOVABLE PROPERTY DOCUMENTS

• Si Creva will release all original property documents and remove charges registered with any registry within 30 days after full loan repayment or settlement.
• Borrowers shall have the option to collect their original documents from the branch where the loan was serviced or any other Si Creva office.
• Loan sanction letters issued shall specify the timeline and location for document return.
• Si Creva will have a clear procedure for returning documents to legal heirs in case of the borrower’s demise, which will be published on the Company’s website alongside other similar policies and procedures for customer information.
• 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, reasons for such delay shall be communicated to the borrower.
• In case where the delay is attributable to the Company, compensation at the rate of Rs. 5,000 for each day of delay shall be provided to the borrower.
• Compensation for delay in release of movable/immovable property documents shall be extended to the borrower as per the applicable regulations in case of occurrence of the same.
• In case of loss of such documents, the Company shall assist the borrowers in obtaining duplicate/certified copies of the same and bear all the additional costs in this regard. in addition to paying compensation as indicated above. In such cases, an additional 30 days timeline will be available to the Company to complete the procedure and delayed period penalty will be calculated after 60 days.

LOANS SOURCED OVER DIGITAL LENDING PLATFORMS

Wherever digital lending platforms are engaged as agents to source borrowers and/ or to recover dues, the Company shall publish on the Company’s website the following information :

• Details of all of its digital lending products and nomenclature of its Digital Lending Apps DLAs;
• Details of Lending Service Providers (LSPs) and the DLAs of the LSPs along with the details of the activities for which they have been engaged for;
• Particulars of Si Creva customer care and internal grievance redressal mechanism;
• Link to RBI’s Complaint Management System (CMS) and Sachet Portal;
• Privacy policies and other details, as required under extant guidelines of the RBI.
• Company shall ensure that digitally signed documents (on the letter head of the company) viz., KFS, summary of loan product, sanction letter, terms and conditions, account statements, privacy policies of the company / LSP with respect to storage and usage of borrowers’ data, loan agreement, etc. shall automatically flow to the borrower on the registered and verified email/ SMS upon execution of the loan contract/ transactions.
• The borrower shall be given an explicit option to exit a digital loan by paying the principal and the proportionate APR without any penalty during an initial “cooling off period” as provided for in the KFS.
• The Company has adopted a sperate policy on Digital Lending to outline detailed guidelines for the purpose of loans issued over digital lending platforms.
• The Company and the LSPs which have an interface with the borrower, shall designate nodal grievance redressal officers to deal with digital lending related complaints/ issues raised by the borrower.

GENERAL

• 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.
• Si Creva shall keep borrower personal information strictly confidential.

• Si Creva shall disclose borrower’s information to third party only under the following conditions:

  • Customer/ Borrower has provided his consent for such disclosure.
  • It is legally or Regulatory required to do so.
    • In the matter of recovery of loans, Si Creva shall follow the prescribed measures as per laid down guidelines and would operate within the legal framework and in compliance with the applicable laws and regulations and code of conduct for the recovery agents as approved by the Board. Further, Si Creva would not resort to undue harassment like bothering the borrowers at odd hours/ use muscle power for recovery of loans.
• Si Creva shall ensure that the entire process of enforcing its security, valuation and realization thereof is fair and transparent.
• Si Creva shall ensure that the staff is adequately trained to deal with the customers in an appropriate manner.
• Si Creva’s collection policy is built on courtesy and fair treatment. Si Creva believes in customer confidence and long-term relationships. Si Creva’s staff or any person authorized to represent us in collection of dues will identify himself/herself and interact with our customers in a courteous manner.
• Si Creva shall provide customers with all the information regarding dues and shall give sufficient notice for payment of dues. All customers will be contacted ordinarily at the location which is stated in the loan application journey or at the place of their choice (to the extent possible), in the absence of a specified place at the residence of the customer and if the customer is unavailable at the residence, at the customer's place of business/occupation as available on the Company’s records.
• Si Creva shall respect privacy of the customer and all interactions shall be in a civilised manner. All assistance shall be provided to the customers to resolve differences or disputes in a mutually acceptable manner, if any, regarding the dues.
• In case of receipt of a request from the borrower for transfer of his 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.
• On receipt of a request from a customer to update the credit information by making an appropriate correction, addition or otherwise, as may be required, the Company shall take steps to update the credit information within thirty (30) days after being requested to do so.

CUSTOMER GRIEVANCE REDRESSAL MECHANISM

The customer grievance redressal mechanism (“Grievance 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 and its DLAs viz., Kishht and Paywithring, informing the customers about the escalation mechanism and the Grievance Redressal Officer (including the name and contact details).

INTEGRATED OMBUDSMAN SCHEME:

The Integrated Ombudsman Scheme, 2026 is effective from July 01, 2026.. Relevant details of the scheme are published on the Company’s website. The Company shall strictly adhere to the timelines for redressal of the customer complaints as per the Ombudsman Scheme.

REVIEW OF POLICY:

A periodical review (at least annually) of this Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by the Company and a consolidated report of such reviews shall be submitted to the Audit Committee on quarterly basis. The same shall be reviewed and approved by the Board of Directors of the Company.

OMNIBUS CLAUSE:

All extant & future master circular/directions/guidance/guidance notes issued by RBI from time to time would be the directing force and will super cede the contents of this Code.

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