Fair Practices Code

1.1 Acknowledgement of Applications

• All loan applications submitted through the Platform will be acknowledged within 3 working days of submission.
• An acknowledgement will be issued containing a unique application reference number and an indicative processing timeline.
• Applicants will be informed of the documents required to complete their application.

1.2 Processing Timelines

We are committed to fast and efficient processing, subject to the receipt of complete documentation and successful KYC verification:

• In-principle approval: Within 30 minutes of a complete application submission
• Final approval: Within 24 hours of all required documents being submitted and verified
• Disbursement: Within 15 minutes of execution of the loan agreement

1.3 Communication of Rejection

• In the event of rejection of a loan application, the applicant will be informed of the decision in a clear and respectful manner.
• To the extent permitted by applicable law and credit bureau guidelines, reasons for rejection will be communicated to the applicant.
• Applicants retain the right to seek reconsideration of their application by submitting additional documents or information.
• No application will be rejected on grounds of caste, religion, gender, or any other discriminatory basis. All credit decisions are based solely on creditworthiness and eligibility criteria.

2.1 Credit Evaluation Methodology

• Loan approvals are based on a holistic assessment of the applicant's creditworthiness, which may include credit bureau scores, business cash flows, bank statements, GST data, and other alternative data sources.
• For applicants with limited or no credit history ("thin-file" customers), alternative data such as digital transaction patterns, GST filings, and business vintage will be considered.
• Credit assessment criteria are applied consistently and transparently across all applicants.

2.2 Loan Amount Determination

• The sanctioned loan amount is determined on the basis of the applicant's assessed repayment capacity and business requirements, not arbitrarily.
• A clear explanation of how the loan amount has been arrived at will be provided upon request.
• Applicants will not be pressured or incentivised to borrow more than they require or can reasonably repay.

2.3 Interest Rate and Cost Disclosure

• All applicable interest rates are risk-based and disclosed upfront at the time of the loan offer, prior to the borrower's acceptance.
• The full cost of the loan is communicated in Annual Percentage Rate (APR) format, as required by RBI guidelines.
• There are no hidden charges. All fees, costs, and deductions are itemised and explained before the loan agreement is signed.

3.1 Terms and Conditions Disclosure

Every loan agreement executed through the Platform shall clearly set out the following:

• Loan amount and the date of disbursement
• Rate of interest, method of calculation (reducing balance or flat), and the APR
• Complete repayment schedule including the number, amount, and due dates of all EMIs
• All applicable fees and charges, including processing fee, late payment fee, bounce charges, and foreclosure fee
• Terms and conditions for prepayment and foreclosure
• Consequences of default, including credit bureau reporting and recovery actions

No loan agreement shall be executed unless the borrower has been given adequate time and opportunity to read and understand its terms.

3.2 Language Accessibility

• Loan agreements and key documents are made available in English, Hindi, and Bengali.
• A plain-language summary of key terms is provided to the borrower in their preferred language at the time of onboarding.
• Borrowers have the right to seek clarification on any term or condition before signing the agreement, and no pressure shall be applied to hasten the signing process.

3.3 Documentation

• A signed copy of the loan agreement and the amortisation schedule will be provided to the borrower at the time of disbursal, via the Platform or registered email.
• All documents submitted by the borrower will be returned upon request after the loan account is closed.

4.1 Transparency in Disbursement

• Loan amounts will be disbursed exclusively to the borrower's own registered and verified bank account. No disbursements will be made to third-party accounts or in cash.
• The borrower will receive an SMS and email confirmation immediately upon disbursement, with a clear breakdown of the amount disbursed, fees deducted, and the net amount credited.

4.2 No Advance Fee Collection

• No fees, charges, or amounts of any kind will be collected from the borrower prior to loan disbursement.
• The processing fee, if applicable, will be transparently deducted from the sanctioned loan amount at the time of disbursal.
• A clear, itemised breakdown of all deductions will be provided to the borrower.

5.1 Accepted Payment Methods

We accept repayments through the following modes:

• UPI Autopay (e-NACH) – primary repayment mode, set up at the time of loan acceptance
• UPI – manual payment through any UPI-enabled application
• NEFT / IMPS – to the designated repayment account

Cash payments are not accepted. All repayments are recorded digitally and a payment confirmation is issued for every transaction.

5.2 Collection Conduct

RinSetu and all personnel or agents acting on its behalf shall adhere to the following standards during repayment follow-up and collection:

• No calls or visits shall be made before 8:00 AM or after 7:00 PM on any day
• A maximum of 3 contact attempts per day shall be made to the borrower
• Contact shall not be made with the borrower's family members, relatives, employers, or colleagues for the purpose of loan recovery, except where such persons have been expressly designated as references or guarantors
• All communication shall be respectful, professional, and conducted in a language the borrower understands
• No threats, intimidation, abuse, or coercive behaviour shall be employed under any circumstances
• Recovery personnel shall carry valid identification and shall present it upon request

5.3 Payment Reminders

• An automated SMS and/or push notification reminder will be sent 3 days before the due date
• A reminder will be sent on the due date if the EMI has not yet been received
• A follow-up call will be initiated only if the EMI remains unpaid after the due date

6.1 Definition of Default

A borrower shall be considered to be in default if:

• Three (3) or more consecutive EMIs are missed, or
• The loan outstanding remains unpaid for a continuous period of 90 days or more from the due date

6.2 Recovery Process

Upon declaration of default, the following structured recovery process shall be followed:

1. Empathetic outreach call to understand the borrower's circumstances and explore repayment options
2. Communication of available options such as restructuring or rescheduling, where applicable
3. Field visit by an authorised representative, if required
4. Issuance of a formal written notice
5. Legal action, as a measure of last resort, in accordance with applicable law

6.3 Prohibited Recovery Practices

The following practices are strictly prohibited and will not be employed by RinSetu, its employees, agents, or recovery partners under any circumstances:

• Physical intimidation or threats of violence
• Verbal abuse, humiliation, or use of offensive language
• Public shaming of the borrower or disclosure of default to third parties
• Seizure of assets without a valid court order
• Obstruction of or interference with the borrower's business operations or access to their premises
• Misrepresentation of legal consequences or creating undue panic

Any violation of these prohibitions should be reported immediately to our Grievance Officer at nodal@rinsetu.online.

7.1 Accessibility

We are committed to ensuring that borrowers can reach us conveniently through multiple channels:

• Email Support: support@rinsetu.online — responses within 24 business hours
• In-App Chat Support: Available within the RinSetu mobile application during business hours
• Grievance Officer: nodal@rinsetu.online — for escalated concerns

7.2 Grievance Handling

• A dedicated Grievance / Nodal Officer has been appointed for the resolution of borrower complaints.
• All complaints are to be acknowledged within 24 hours and resolved within 7 working days.
• The full grievance escalation path is clearly communicated to borrowers on the Platform and in the loan agreement.

8.1 Disclosure of All Charges

All applicable fees and charges are disclosed prominently in the following places:

• The RinSetu website at rinsetu.online
• The RinSetu mobile application
• The loan agreement and sanction letter
• The welcome communication sent at the time of disbursal

8.2 No Hidden Charges

• No charges will be levied on the borrower that have not been disclosed prior to the execution of the loan agreement.
• Any additional charge, if proposed after loan sanction, will require the borrower's prior written consent.
• The borrower has the right to request a complete and itemised statement of all charges at any time, free of cost.

9.1 Data Collection

• Only such personal and financial data as is strictly necessary for the purpose of loan processing, KYC verification, credit assessment, and regulatory compliance will be collected.
• The purpose for which each category of data is being collected will be clearly communicated to the borrower at the time of collection.
• Explicit consent will be obtained before collecting any sensitive personal data, including Aadhaar details, biometrics, or device location.

9.2 Data Usage and Protection

• Borrower data will be used solely for the stated and consented purposes. It will not be shared with third parties for commercial or marketing purposes without explicit consent.
• All data is stored securely on India-based servers with appropriate technical safeguards, including encryption and access controls.
• For full details on our data practices, please refer to our Privacy Policy available at rinsetu.online.

11.1 Internal Audit

• Compliance with this Code shall be subject to a quarterly internal audit, covering call recordings, customer feedback, recovery practices, and complaint data.
• Any instances of non-compliance identified during audits will be subject to prompt corrective action.
• Customer satisfaction and feedback data will be analysed regularly to identify areas for improvement.

11.2 Board-Level Review

• Compliance with this Fair Practices Code is reported to the Board of Directors of Archway Commercial Solutions Private Limited on a periodic basis.
• This Code shall be subject to a comprehensive annual review to ensure continued alignment with RBI guidelines, regulatory updates, and best practices in the industry.
• The revised Code, if any, will be published on the Platform and brought to the attention of all relevant stakeholders.