Fair Practice Code (English)

Bhawana Capital Private Limited (formerly Bhawana Securities and Financial Services Limited) ("the Company") is a Non-Deposit Taking Non-Banking Finance Company registered with Reserve Bank of India ("RBI"). The Company is presently in the business of providing short term loans and advances.

The Company has put in place the Fair Practices Code ("FPC" or "Code") in conformity with the Guidelines on Fair Practices Code for NBFCs as contained in Chapter V of Master Direction - Non-Banking Financial Company - Non-Systemically Important Non-Deposit Taking Company (Reserve Bank) Directions, 2016 and has been duly approved by the Board of Directors. The FPC sets out the principles for fair practices, transparency and adequate disclosures while dealing with its customers.

The commitments outlined in this FPC adopted by the Company are applicable under normal operating environment; however, under situations beyond the control of the Company, it may not be possible for us to fulfil the commitments made thereunder.

This FPC applies to all categories of products and services offered by the Company.

The Company's key commitments to customers are:

1. Act fairly and reasonably in all dealings with customers by:
   • Meeting the commitments and standards specified in the Code for the products and services the Company offers and in the procedures and practices its staff follows.
   • Making sure that the Company's products and services meet relevant laws and regulations applicable to it.
   • Ensuring the Company's dealings with customers rest on ethical principles of integrity and transparency.
2. Help customers understand how the Company's products work by explaining their financial implications.
3. Deal quickly and sympathetically with things that go wrong by:
   • Correcting mistakes.
   • Handling customer complaints.
   • Telling customers how to take their complaint forward if they are still not satisfied.
4. Publicize the Code, place it on the Company's website, and make copies available to customers on request.

1. The Company will ensure that there is proper assessment of loan applications made by borrowers. The assessment would be in line with the Company's credit policies and procedures.
2. The Company shall convey in writing to the borrower in the vernacular language or a language as understood by the borrower, by means of sanction letter and or sanction mail or otherwise, the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof, and keep the acceptance of these terms and conditions by the borrower on its record.
3. The Company shall mention the penal interest charged for late repayment in bold in any of the documents, namely loan agreement, transaction documents, sanction letter and or mail communication sent for this purpose, mobile application, and charges section on the Company and products websites. The Company shall make available information related to interest rates and other charges on the website also.
4. The Company's digital platform and risk assessment model requires digital acceptance of all terms and conditions of the loan. It includes digital signing or Aadhaar-based OTP authentication, if applicable, or clickwrap or clickthrough acceptance on the loan agreement and or terms and conditions.
5. The terms and conditions of the respective financial products of the Company shall be applicable for all borrowers without discrimination.

1. The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement or as consented by the customer on the terms and conditions as part of the onboarding and disbursement process on mobile applications, unless new information not earlier disclosed by the borrower has come to the notice of the Company.
2. In case of receipt of a request from the borrower for transfer of the borrowal account, the consent or otherwise, namely objection of the Company if any, will be conveyed within 21 days from the date of receipt of the request. Such transfer shall be as per transparent contractual terms in consonance with law.
3. In the matter of recovery of loans, the Company will not resort to undue harassment such as persistently bothering borrowers at odd hours or use of muscle power for recovery of loans. To avoid rude behavior from the staff of the Company, the Company shall ensure trainings are provided on code of conduct to deal with customers in an appropriate manner.
4. The Company shall charge interest rate, processing fees, or other charges only in accordance with the Company's loan policy.
5. There shall be no discrimination in extending loans and other financial products to physically or visually challenged applicants on the ground of disability, subject to the eligibility criteria as per the Company's credit policy.

1. Interest rate model and other charges for each finance product category shall be adopted taking into account relevant factors such as cost of equity, cost of borrowed funds, margin, credit risk, operating cost, industry trend, and associated risks with the approval of the Board.
2. The rate of interest and the approach for gradation of risk and rationale for different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application and or website and communicated explicitly in the loan sanction letter or communication.
3. The Company would intimate the rate of interest to be charged from the borrower at the time of application or sanctioning of the loan.
4. The Company shall make available information related to interest rates and other charges, including late payment or otherwise, and the approach of risk on its website also.
5. The rate of interest should be annualized so as to make the borrower aware of the exact rates that would be charged to the account.
6. The Company would ensure that it will not unduly charge excessive interest rates to its borrowers. The interest rate for customers or borrowers would be arrived at taking into account broad parameters such as the risk profile of customers or borrowers, interest rate trends prevailing in the money market, cost of borrowings, primary and collateral security offered by customers or borrowers, structure of the deal, interest rate charged by competitors, and the historical credit track record of customers or borrowers.