RPT Policy

Last updated on: 21st March 2026

• Background

  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 . 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.

  Si Creva is in the business of the provision of consumer and personal loans by using digital lending applications viz; ‘Kissht’ and ‘PaywithRing’ which are owned by OnEMI Technology Solutions Limited (functioning as a Loan Service Provider – LSP) as also its 100% holding company. Besides this, Si Creva is also lending through the mobile app and web-based applications on the platforms of other Lending Service Providers (“LSPs”).The company also offers loan against property.

• Purpose and Objective

  The Companies Act, 2013 and the rules framed thereunder, read with the circular(s) and notification(s) issued in this regard from time to time (“Act”), contain detailed provisions relating to identification of related parties and compliances around entering into related party transactions (“RPTs”). While the Act does not specifically mandate the Companies to frame a policy in respect of regulating and monitoring RPTs, it is deemed fit by the Board of Directors of the Si Creva, being a regulated entity, to frame this Policy so as to provide for several measures around regulation and monitoring of the RPTs. The Policy governs the transactions with the related parties of the Company keeping in view the potential or actual conflict of interest which may arise upon the transactions entered into by the Company with the related parties and whether such transactions are consistent with the interest of the Company and its members.

  The Reserve Bank of India has issued the Non-Banking Financial Companies – Credit Risk Management Directions, 2025, Reserve Bank of India (Non-Banking Financial Companies – Credit Risk Management) – Amendment Directions, 2026 and the Non-Banking Financial Companies – Financial Statements: Presentation and Disclosures Directions, 2025 and Reserve Bank of India (Non-Banking Financial Companies – Financial Statements: Presentation and Disclosures) Directions, Amendment Directions, 2026, which provide comprehensive guidelines on various aspects related to lending to related parties. These directions cover the general principles for lending to related parties, define materiality thresholds, outline the monitoring of loans to related parties, and specify requirements for disclosures in financial statements, particularly in the notes to accounts concerning related-party transactions.

  The Policy envisages to create documented guidelines for regulating transactions of the Company with its related parties to ensure the following:

  • All transactions with Related Parties are approved as per the policy.
  • Nature of agreement / Basis of transactions are well established and evidenced.
  • Appropriate disclosure of all transactions, as applicable.

• Applicability

  The policy shall apply to all the transactions which fall within the ambit of the Policy on dealing with Related Party Transactions.

• SCOPE

  This policy sets the definition of related party transactions and dealing with related party transactions.

• DEFINITION

  • “Arm’s length transaction” / “Arm’s Length Basis” means a transaction between two related parties that is conducted as if they were unrelated so that there is no conflict of interest.

  • “Associate Company” shall have the same meaning as provided in Section 2(6) of the Companies Act, 2013 wherein an "Associate Company" in relation to another company, means a company in which that other company has a significant influence, but which is not a subsidiary company of the company having such influence and includes a joint venture company.

    For the purposes of this term 'Associate Company', "significant influence" means control of at least twenty per cent of total share capital, or of business decisions under an agreement.

  • “Audit Committee” or “Committee” means the audit committee of the Company as constituted by the Board. Where the Company doesn’t have an audit committee, the word “Audit Committee” to be read as the “Board” itself throughout the Policy.
  • “Board of Directors” or “Board” in relation to a Company, means the collective body of Directors of the Company (Section 2(10) of the Companies Act, 2013).
  • ‘Control’ shall have the same meaning as assigned to it under Section 2(27) of the Companies Act, 2013.
  • ‘Director or any other entity’ shall mean a director appointed/elected to the Board of the entity.
  • ‘Entity’ in the context of a ‘related party’ shall mean a ‘person’ other than an individual and a Hindu Undivided Family.
  • Holding Company: - a company having one or more subsidiaries.

  • Key Management Personal (KMPs) shall include following key managerial personnel as per section 2(51) of the Companies Act, 2013.

    • The Chief Executive Officer or the Managing Director or the Manager;
    • The Company Secretary;
    • The Whole-time Director;
    • The Chief Financial Officer;
    • Such other officer, not more than one level below the directors who is in whole-time employment, designated as key managerial personnel by the Board; and
    • Such other officer as may be prescribed;

  • Relatives of KMPs at the minimum, shall include following relatives as defined under section 2(77) of the Companies Act, 2013 and Rule 4 of the Companies (Specification of definitions details) Rules, 2014.

    • they are members of a Hindu Undivided Family;
    • they are husband and wife; or
    • one person is related to the other in such manner as may be prescribed;
  • ‘Committee on lending to related parties’ shall mean a committee of the Board of the Company entrusted with sanctioning of loans to related parties.
  • ‘Lending’ in the context of a ‘related party’ shall mean extending funded or/ and non-fund-based credit facilities to related parties. While investments in debt instruments of related parties shall be covered for this purpose, equity investments shall be excluded.
  • Person shall have the same meaning as assigned to it under Section 3 (23) of Part I of Insolvency and Bankruptcy Code (IBC), 2016.

  • “Material Related Party Transactions” means any contract/ arrangement with a related party as defined under Section 188(1) of the Act, which is equal to or exceeds the limits mentioned under Rule 15(3) of the Companies (Meetings of the Board and its powers) Rules, 2014 as per the last audited financial statements of the Company.

    For the purposes of first proviso to sub-section (1) of section 188, except with the prior approval of the company by a resolution, a company shall not enter into a transaction or transactions, where the transaction or transactions to be entered into,—

    • as contracts or arrangements with criteria as mentioned below –

      • sale, purchase or supply of any goods or materials; directly or through appointment of agent, amounting to ten per cent. or more of the turnover of the company as mentioned in clause

        • and clause (e) respectively of sub-section (1) of section 188;
        • selling or otherwise disposing of, or buying, property of any kind directly or through appointment of agent, amounting to ten per cent. or more of net worth of the company , as mentioned in clause (b) and clause (e) respectively of sub-section (1) of section 188;;
        • leasing of property of any kind; amounting to ten per cent or more of the turnover of the company as mentioned in clause (c) of sub-section (1) of section 188;
        • availing or rendering of any services; directly or through appointment of agent, amounting to ten per cent. or more of the turnover of the company , as mentioned in clause (d) and clause (e) respectively of sub-section (1) of section 188:
        • appointment of any agent for purchase or sale of goods, materials, services or property;
        • such related party's appointment to any office or place of profit in the company, its subsidiary company or associate company; and
        • underwriting the subscription of any securities or derivatives thereof, of the company

    Provided that no contract or arrangement, in the case of a company having a paid-up share capital of not less than such amount, or transactions not exceeding such sums, as may be prescribed, shall be entered into except with the prior approval of the company by a resolution:

    further that no member of the company shall vote on such resolution, to approve any contract or arrangement which may be entered into by the company, if such member is a related party

    also that nothing contained in the second proviso shall apply to a company in which ninety per cent. or more members, in number, are relatives of promoters or are related parties:

    also that nothing in this sub-section shall apply to any transactions entered into by the company in its ordinary course of business other than transactions which are not on an arm’s length basis.

    also that the requirement of passing the resolution under first proviso shall not be applicable for transactions entered into between a holding company and its wholly owned subsidiary whose accounts are consolidated with such holding company and placed before the shareholders at the general meeting for approval.

    It is hereby clarified that the limits specified in sub-clauses (i) to (iv) shall apply for transaction or transactions to be entered into either individually or taken together with the previous transactions during a financial year.

    • “Ordinary Course of business” shall mean the usual transactions, customs and practices of the business of the Company and would include activities to be carried out incidental to or to facilitate the business of the Company and is usual or customary to the Company.
    • “Policy” means this Policy on Dealing with Related Party Transactions, as amended from time-to-time.
    • ‘Specified employees’ mean all employees who are positioned upto two levels below the Board and any employee designated as such as per its policy.

    • “Related Party” in respect to the disclosure as per regulatory guidelines, shall include all related parties as per the applicable accounting standards. Further, related party shall also include following related parties defined under Section 2(76) of the Companies Act, 2013. :

      • a director or his relative ;
      • a key managerial personnel or his relative ;
      • a firm, in which a director, manager or his relative is a partner;
      • a private company in which a director or manager or his relative is a member or director;
      • a public company in which a director or manager is a director and holds along with his relatives, more than two per cent of its paid-up share capital;
      • any body corporate whose Board of directors, managing director, or manager is accustomed to act in accordance with the advice, directions or instructions of a director or manager;

      • any person under whose advice, directions or instructions a director or manager is accustomed to act:

        Provided that nothing in sub-clauses (vi) and (vii) shall apply to the advice, directions or instructions given in a professional capacity;

      • any body corporate which is –

        • a holding, subsidiary or an associate company of such company;
        • a subsidiary of a holding company to which it is also a subsidiary; or
        • an investing company or the venturer of the company

        Explanation.— For the purpose of this clause, “the investing company or the venturer of a company” means a body corporate whose investment in the company would result in the company becoming an associate company of the body corporate.

      • Such other person as may be prescribed.

      In accordance with Indian Accounting Standard (Ind AS) 24- Related Party Disclosures, A related party is a person or entity that is related to the entity that is preparing its financial statements:

      • A person or a close member of that person’s family is related to a reporting entity if that person:

        has control or joint control of the reporting entity; has significant influence over the reporting entity; or is a member of the key management personnel of the reporting entity or of a parent of the reporting entity.

      • An entity is related to a reporting entity if any of the following conditions applies:

        • The entity and the reporting entity are members of the same group (which means that each parent, subsidiary and fellow subsidiary is related to the others).
        • One entity is an associate or joint venture of the other entity (or an associate or joint venture of a member of a group of which the other entity is a member).
        • Both entities are joint ventures of the same third party.
        • One entity is a joint venture of a third entity and the other entity is an associate of the third entity.
        • The entity is a post-employment benefit plan for the benefit of employees of either the reporting entity or an entity related to the reporting entity. If the reporting entity is itself such a plan, the sponsoring employers are also related to the reporting entity.
        • The entity is controlled or jointly controlled by a person identified in (a).
        • A person identified in (a)(i) has significant influence over the entity or is a member of the key management personnel of the entity (or of a parent of the entity).
        • The entity, or any member of a group of which it is a part, provides key management personnel services to the reporting entity or to the parent of the reporting entity.

        In accordance with RBI directions, Related Party’ with respect to a NBFC shall mean a related person, or any of the following entities:

        • where a related person is a partner, manager, KMP, director or a promoter; or
        • where a related person is a shareholder with more than ten per cent of paid up equity share capital; or
        • where a related person is having control, whether singly or jointly with another person; or
        • where a related person controls more than twenty per cent of voting rights on account of ownership or through a voting agreement or through any other arrangement; or
        • where a related person has the power to nominate a director to its Board; or
        • which is accustomed to act on the advice, direction, or instruction of a related person; or
        • where a related person is a guarantor or a surety; or
        • where a related person is a trustee or an author or a beneficiary and where the entity is in the form of a private trust; or
        • which is related to the related person as a subsidiary or a parent company or a holding company or an associate or a joint venture.

        Provided that nothing sub-clause (e) above shall apply in cases where the authority to nominate a director arises exclusively from a lending or financing arrangement.

        Provided further that nothing in sub-clause (f) above shall apply to the advice, directions or instructions given in a professional capacity.

    • ‘Related Person’ with respect to a Si Creva shall mean a person, and the relatives of such a person, where the person:

      • is either a promoter, or a director, or a KMP of the Si Creva; or
      • owns more than five per cent of paid-up equity share capital of the Si Creva or can, either singly or jointly, exercise more than five per cent of the voting rights of the Si Creva on account of either ownership or voting agreement or through shareholders’ agreement or through any other arrangement; or
      • can, through an agreement with the Si Creva, nominate a director to its Board; or
      • is either singly or jointly, in control of the Si Creva

    • “Relative” means relative as defined in Section 2(77) of the Companies Act, 2013.

      Accordingly, ‘‘relative’’, with reference to any person, means anyone who is related to another, if—

      • They are members of a Hindu undivided family;
      • They are husband and wife;
      • one person is related to the other in such manner as may be prescribed.

      As per Rule 4 of Companies (Specification of definitions details) Rules, 2014 includes a person who shall be deemed to be the relative of another, if he or she is related to another in the following manner, namely: -

      • Father (including step-father)
      • Mother (including step-mother)
      • Son (including step-son)
      • Son’s wife
      • Daughter
      • Daughter’s husband
      • Brother (including step-brother)
      • Sister (including step-sister)

      In accordance with Indian Accounting Standard (Ind AS) 24- Related Party Disclosures, close members of the family of a person are those family members who have potential to influence, or be influenced by, that person in their dealings with the entity including: (a) that person’s children, spouse or domestic partner, brother, sister, father and mother; (b) children of that person’s spouse or domestic partner; and (c) dependants of that person or that person’s spouse or domestic partner.

    • Related Party Transactions - A related party transaction as mentioned in Section 188 of the Companies Act, 2013.

• IDENTIFICATION OF RELATED PARTY AND RELATED PARTY TRANSACTIONS:

  • Contracts / arrangements will be treated as Related Party Transaction if the same has been entered into with any entity which falls within the definition of “Related Party” as per Indian Accounting Standard (Ind AS) 24 and/or definition given under Section 2(76) of the Companies Act, 2013.
  • All related party contracts/arrangements shall be entered into on arms' length basis.
  • In exceptional circumstances, where permitted by law, related party contracts / Arrangements may deviate from the principle of arm's length, after approval from the Board.
  • All related party contracts / arrangements shall comply with the Companies Act, 2013.
  • All related party contract / arrangements shall comply with Indian Accounting Standards.
  • All domestic related party contracts / arrangements shall, wherever applicable, comply with Domestic Transfer Pricing Requirement under section 92BA of Income Tax Act, 1961 including certification from independent accountants under the Transfer Pricing Regulations.
  • All international related party contract / arrangements shall comply with International Transfer Pricing Requirement under section 92B of Income Tax Act, 1961 including certification from independent accountants under the Transfer Pricing Regulations.
  • Every Director & Key Managerial Personnel will be responsible for providing a declaration in the format as per Annexure 1 on an annual basis.
  • Every Director and the Key Managerial Personnel will also be responsible to update to Company Secretary of any changes in the above relationships, directorships, holdings, interests and/or controls immediately on him/her becoming aware of such changes.

  • Every Director, Key Managerial Personnel authorized to enter into contracts/ arrangements will be responsible for providing prior notice to the Company Secretary of any potential Related Party Transaction. Further, they will also be responsible for providing additional information about the transaction that the Board may request, for being placed before the Board as mentioned below:

    • Name of the Related Party and nature of relationship.
    • Nature and duration of the contract/arrangement/transaction and particulars thereof.
    • Material terms of the contract or arrangement or transaction including the value, if any.
    • In case of existing or approved contracts, transactions, details of proposed variations to the duration, current price / value and / or material terms of the contract or arrangement including a justification to the proposed variations.
    • Any advance paid / received or to be paid / received for the contract or arrangement, if any.
    • Manner of determining the pricing and other commercial terms, whether or not included as part of contract.
    • Whether all factors relevant to the contract/arrangement/transaction have been considered, if not, the details of factors not considered with rationale for not considering those factors.
    • Copy of the draft MOU, agreement, contract, purchase order or correspondence etc. if any.
    • Applicable statutory provisions, if any.
    • Valuation reports in case of sale or purchase or leasing / renting of capital assets or securities.
    • Justification as to the arm’s length nature of the proposed transaction.
    • Declaration whether the transaction is in the ordinary course of business.
    • Persons / authority approving the transaction.
    • Any other information which may be relevant or important for the Board to take a decision on the proposed transaction.

  The Company ensures the following additional steps / procedure after its Identification of Related Party:

  • Related parties are as defined as per the Policy
  • Identification and confirmation of related party status are followed periodically.
  • In case of KMP/ Directors, the disclosure is in the form of declarations which should be taken on the appointment and event-based.

• Approval and Review of Related Party transactions

  • All the transactions which are identified as RPTs should be pre-approved by the Audit Committee before entering into such transaction (whether at a meeting or through electronic mode). The Audit Committee shall consider all relevant factors while deliberating on the RPTs for its approval.

    To review a RPT which requires approval of the Audit Committee, the Audit Committee will be provided with all relevant material information to assist it in deciding whether or not to approve the transaction.

    Any member of the Audit Committee who has a potential interest in any RPT will recuse himself and abstain from discussion and voting on the approval of the Related Party transaction.

    The list of Related Parties shall be updated whenever necessary and shall be reviewed at least once a year, as on 1st April every year.

    Provided that the above provisions shall not apply to a transaction, other than for the transaction referred to in Section 188 of the Act, between the Company and the Holding Company.

  • Related Party Transactions to be entered into by the Company should be on arm’s length basis and in the ordinary course of business and can be ordinarily entered into if they meet the criteria of Arm’s Length and Ordinary Course of Business, without any prior approval of the Board and the Board can take a note of the same from time to time as may be required.
  • Specific approval of the Audit Committee/ Board of Directors is required for Related Party Transactions not in ordinary course of business under the Act.
  • Transaction exceeding the threshold defined under rule 15(3) of Companies (Meeting of the Board and its Powers) Rules 2014 also require approval of the shareholders. Nothing in this Policy shall override any provisions of Applicable Law made in respect of any matter stated in this Policy.

  • The Audit Committee may grant omnibus approval for related party transactions which are repetitive in nature and subject to such criteria/conditions as mentioned under the provisions of the Companies Act, 2013 and such other conditions as it may consider necessary in line with this Policy and in the interest of the Company. Such omnibus approval shall be valid for a period not exceeding one year and shall require fresh approval after the expiry of one year. The omnibus approval shall specify:

    • The name(s) of the related party, nature of transaction, period of transaction, maximum amount of transactions that shall be entered into;
    • The indicative base price / current contracted price and the formula for variation in the price if any; and
    • Such other conditions as the Audit Committee may deem fit:

    Omnibus approval shall not be made for transactions in respect of selling or disposing of the undertaking of the company.

  • The Audit Committee shall review, on an annual basis, the details of related party transactions entered into by the Company pursuant to the omnibus approval.
  • RPTs entered into by the Company, which is not under the omnibus approval or otherwise pre-approved by the Audit Committee, will be placed before the Audit Committee for ratification in accordance with the provisions of Section 177 of the Act.
  • Subject to the applicable laws, the Board shall have the power to ratify, revise or terminate the RPTs, which are not in accordance with this Policy.

  • The approval of RPT shall follow the below guidelines and in doing so, shall consider the key transaction identification parameters and other related considerations (as below) included under this section:

    • Omnibus approval criteria
    • Arm’s length determination
    • Evaluation of transaction under Ordinary Course of Business
    • Evaluation of Materiality

    • Omnibus Approval Criteria

      • Criteria for Omnibus Approval as approved in the Policy.
      • The transaction is / shall be frequent/regular/repetitive in nature.
      • The transaction is / shall be in the ordinary course of business and at arm’s length.
      • Such other criteria as may be laid down by the Audit Committee.
      • Such approval shall remain valid for a period not exceeding one year, during which period the commercial terms of approved RPTs may change, provided that, arm’s length criterion shall be ensured at the time of each such change.

      • Omnibus Approval shall specify

        • Name of the related party;
        • Nature of the transaction under the ordinary course of business at Arm’s length;
        • Period of the transaction;
        • The maximum amount of transactions that can be entered into;
        • Any other information relevant or important for the audit committee to take a decision on the proposed transaction.

    • Arm’s Length Determination

      The Audit Committee/the Board shall, in respect of the RPTs referred to them for approval, after considering the information/ documents placed before them;

      • Judge if the transaction is at an arm’s length basis.
      • At the time of determining the arms’ length nature of the price charged for the Related Party Transaction, a permissible method of arms’ length pricing as per applicable law would be considered.
      • The Audit Committee/ the Board may seek views of professionals/ specialists (on a need basis) for analyzing the appropriateness of the transactions from ‘arm’s length’ perspective.

    • Evaluation of transaction under Ordinary Course of Business

      • Transactions entered in pursuance of the business objective of the Company and necessary for Company’s operations or related financial activities
      • The Audit Committee/the Board shall, in respect of the RPTs referred to them for approval, after considering the information/ documents placed before them; judge if the transaction is in the ordinary course of business.
      • The Audit Committee/ the Board may seek views of professionals/ specialists (on a need basis) for analyzing the appropriateness of the transactions from ‘ordinary course of business’.

    • Evaluation of Materiality:

      The RPTs which cross the Materiality thresholds under the Companies Act, 2013 as per Rule 15 of the Companies (Meetings of Board and its Powers) Rules, 2014 shall be entered by the Company only with prior approval of shareholders of the Company by a resolution, as per applicable provisions of the Act, as may be amended from time to time.

• Board of Directors

  • In case any RPTs are referred to by the Company to the Board for its approval due to the transaction being

    • not in the ordinary course of business, or
    • not at an arm’s length price, such transactions shall be affected only with prior approval of the Board of Directors of the Company, on recommendation of Audit Committee.
  • The Board will consider such factors as, nature of the transaction, material terms, the manner of determining the pricing and the business rationale for entering into such transaction. On such consideration, the Board may approve the transaction or may require such modifications to transaction terms as it deems appropriate under the circumstances.
  • Any member of the Board who has any interest in any related party transaction will recuse himself and abstain from discussion and shall not vote to approve the related party transaction. However, such interested member of the Board shall be allowed to be a part of discussion and vote in relation to same if prior disclosure is provided to the Board.

• Shareholders

  If a related party transaction is not in the ordinary course of business, or not at arm’s length price and is a Material Related Party Transaction, it shall require shareholders’ approval by a resolution.

• Related Party not approved in the Policy:

  In the event of entering into a Related Party Transaction with a Related Party that has not been approved under this Policy prior to its consummation, the matter shall be reviewed by the Audit Committee. The Audit Committee shall consider the relevant facts and circumstances regarding the Related Party Transaction and shall evaluate all options available to the Company, including ratification, revision or termination of the Related Party Transaction.

  In any case, where the Audit Committee determines not to ratify a Related Party Transaction that has been commenced without approval, the Audit Committee, as appropriate, may direct additional actions including, but not limited to, immediate discontinuation or rescission of the transaction.

• Lending to Related Parties:

  • General Principles on Lending to Related Parties:

    The company shall adopt the following principles when dealing with related parties. These provisions shall form part of the Company’s business model loan policy:

    • All lending to related parties shall be undertaken only with prior approval of the Board of Directors or a Committee of the Board.
    • Lending shall be conducted strictly on an arm’s length basis.
    • Directors, key managerial personnel (KMP), and employees having any interest in a related party transaction shall abstain from appraisal, decision-making, and approval of such transactions.
    • Related party exposures shall undergo enhanced credit appraisal and due diligence, including independent assessment of creditworthiness, cash flows, and repayment capacity, in accordance with the Company’s internal process.
    • Lending to related parties shall, wherever applicable, be adequately secured, and no relaxation in collateral or security norms shall be allowed solely on account of the relationship.
    • No preferential treatment, waiver of dues, or deviation from standard credit norms shall be permitted in favor of related parties.
    • All transactions shall remain within the prescribed aggregate and individual exposure limits.
    • Complete supporting documentation shall be maintained for all terms, approvals, and justifications of related party transactions.

  • Loans and Advances to Specified Employees and their relatives:

    • Credit facilities extended to the specified employees and their relatives shall be reported to the Board on an annual basis.
    • No specified employees or any Committee comprising, inter alia, a specified employee as a member, shall, while exercising powers of sanction of any credit facility, sanction any credit facility to a relative of that senior employee. Such a facility shall be sanctioned by the next higher sanctioning authority under the delegation of powers.
    • Company shall obtain declaration from the borrower giving details of the relationship of the borrower to its specified employees for availing loans and advances aggregating INR 5 crore and above from the Company. Loans to borrower shall be recalled if any false declaration is given by the borrower.
    • Loans to specified employees or their relatives shall be granted strictly on an arm’s length basis, with terms, interest rates, and security requirements comparable to those applicable to loans extended to non-related parties.
    • Specified employees shall abstain from involvement in the appraisal, sanction, monitoring, or collection of loans granted to themselves or their relatives.

  • Whistleblower and Reporting Mechanism:

    • Employees are encouraged to confidentially report any irregular, unethical, or questionable lending involving related parties.
    • Reports may include violations of internal policies, conflicts of interest, quid pro quo arrangements, misrepresentation, or non-compliance with limits.
    • Employees may report concerns without fear of retaliation, victimization, or reprisal.
    • All reports shall be independently investigated by Internal Audit.
    • Appropriate corrective actions, including loan recall, disciplinary measures, or regulatory reporting, shall be taken based on findings.
    • The Company shall amend its Whistleblower Policy, as necessary, to explicitly cover irregularities in related party lending.

  • Aggregate Limits and Materiality Thresholds :

    • All loans, including personal loans to directors or KMPs, shall be subject to a materiality threshold.
    • The Company’s internal materiality threshold shall be set at ₹5 crore
    • Loans exceeding the internal materiality threshold shall require sanction by the Board of Directors, while the Board may, at its discretion, delegate sanctioning authority to a Board Committee (excluding the Audit Committee).
    • Loans below the internal materiality threshold may be sanctioned by Head of Finance.

  • Monitoring, Reporting, and Compliance

    • The company shall maintain a comprehensive and updated register of all related persons, related parties, and loans sanctioned to them. The register shall be periodically reviewed and updated.
    • Credit facilities sanctioned to specified employees and their relatives shall be reported to the Board annually.
    • Periodic reviews of related party lending shall be conducted at least quarterly (or shorter intervals as required) by Internal Audit to verify adherence to policy guidelines and procedures.
    • Any deviations from this policy shall be reported to the Audit Committee or the Board (where an Audit Committee is not constituted), along with the reasons for the deviation.
    • Any product, entity, or structure designed to circumvent related party lending restrictions (e.g., reciprocal lending or quid pro quo arrangements), identified by auditors, regulatory authorities, or investigative agencies, shall be treated as lending to related parties.

• Reporting and Disclosures

  Every contract or arrangement, which is required to be approved by the Board/shareholders under this Policy, shall be referred to in the Board’s report to the shareholders along with the justification for entering into such contract or arrangement.

  All the Disclosure would be done in compliance and in accordance with the requirement as specified under the Companies Act 2013 , IndAS 24 and regulatory requirement.

  Details of all material transactions with related parties shall be disclosed in the Annual Report and the Financial Statements in the prescribed format.

  The related party disclosure will be in accordance with the regulatory guidelines as per Reserve Bank of India (Non-Banking Financial Companies – Financial Statements: Presentation and Disclosures) Directions, 2025 and Reserve Bank of India (Non-Banking Financial Companies – Financial Statements: Presentation and Disclosures) Directions, Amendment Directions, 2026

  Sr.no.	Particulars	Previous Year	Current Year
  A. Loans to related Party
  1.	Aggregate value of loans sanctioned to related parties during the year
  2.	Aggregate value of outstanding loans to related parties as on 31st March
  3.	Aggregate value of outstanding loans to related parties as a proportion of total credit exposure as on 31st March
  4.	Aggregate value of outstanding loans to related parties which are categorized as:
  	(i) Special Mention Accounts as on 31st March
  	(ii) Non-Performing Assets as on 31st March
  5.	Amount of provisions held in respect of loans to related parties as on 31st March
  	B. Contracts and Arrangements involving Related Parties
  6.	Aggregate value of contracts and arrangements awarded to related parties during the year
  7.	Aggregate value of outstanding contracts and arrangements involving related parties as on 31st March

  The policy shall be placed on the Website of the Company.

• Policy Review

  The Board of Directors may in their discretion and on recommendation of the Audit Committee, make any changes/modifications and/or amendments to this Policy from time to time.

  This Policy shall be reviewed by the Board as and when any changes are to be incorporated in the Policy due to change in applicable laws. or at least once every year and updated accordingly.

• Omnibus Clause

  All extant & future Master Circular/Directions/Guidance/Guidance Notes issued by RBI and Companies Act, 2013 and its rules from time to time would be the directing force for the Related Party Transactions and will super cede the contents of this policy.

For Si Creva Capital Services Private Limited