Fair Practices Code

Version number: 2.0
Date: June, 2025

1. Introduction

In line with our ongoing commitment to customer satisfaction, compliance, and alignment with applicable regulatory requirements, cKers Finance Private Limited (cKers) is adopting the revised Fair Practice Code. The previous version referencing the RBI Master Circular (2015-16) is discontinued due to the superseding Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023. This updated Code of Conduct (2nd edition) will take effect from ____.

2. Preamble

RBI has issued expanded guidelines on Fair Practices Code (FPC) for NBFCs covering general principles of fair and transparent dealing, adequate disclosures, and non-coercive recovery methods.

3. Scope

This FPC applies to all financial products and services offered by cKers to MSME and retail borrowers, regardless of delivery channel (in person, phone, online, etc.).

4. Application for Loans and Their Processing

• All communications will be in a language understood by the borrower.
• Loan application forms will contain relevant information to enable informed comparison with other NBFCs.
• Required documents will be clearly listed.
• The Company will acknowledge receipt of loan applications and provide an estimated processing timeline.

5. Loan Appraisal, Terms & Key Facts Statement (KFS)

• Sanction letter / KFS will transparently specify loan amount, terms, interest, etc. in a language understood by the borrower.
• Penalties for late repayment will be highlighted in bold.
• Borrowers will receive a copy of the loan agreement and enclosures at sanction/disbursement.
• cKers will adhere to RBI’s KFS circular (April 15, 2024) and amendments.

6. Penal Charges in Loan Account

• Penalty in the form of penal charges (not capitalized, no further interest applied).
• No extra interest components will be added.
• Penal charges are covered under the Board-approved Policy on Interest Rates & Charges.
• Charges will be fair, reasonable, and non-discriminatory.
• Equal penal charges apply to individual vs. non-individual borrowers for similar non-compliance.
• Charges clearly stated in agreement, KFS, and displayed on the website.
• Effective for fresh loans from Jan 1, 2024, and existing loans from June 30, 2024.

7. Disbursement of Loans & Changes in Terms

• Borrowers will be notified of changes to loan terms (interest, charges, schedule) in advance.
• Recalls/accelerations will follow loan agreement terms.
• Securities will be released on full repayment, unless legitimate claims exist.

8. Responsible Lending – Release of Documents

• Company does not retain original property documents.
• Charges will be removed from registry within 30 days of full repayment.
• If delay attributable to NBFC, borrower will be compensated ₹5,000 per day of delay.

9. General

• No interference in borrower’s affairs unless contractually required.
• Loan transfer requests will be responded to within 21 days.
• Recovery practices will be respectful, avoiding harassment or undue pressure.

10. Responsibility of Board of Directors

• Board-approved grievance redressal mechanism exists.
• Board regularly reviews FPC implementation and grievance effectiveness.

11. Compliance with RBI – Integrated Ombudsman Scheme, 2021

Currently not applicable (AUM below ₹100 crore). Will be adopted once applicable.

12. Language & Mode of Communication

• FPC available in Hindi and English; vernacular translations upon request.
• FPC is published on the official website for easy stakeholder access.

13. Regulation of Excessive Interest

• Board-approved Policy on Interest Rates & Charges governs lending rates.
• Interest rates transparently disclosed in application, sanction letter, and KFS.
• Rates disclosed as annualised, and published on the website.

14. Repossession of Vehicles

Loan agreements will include repossession clauses specifying:

• Notice period before possession.
• Conditions for waiver of notice period.
• Possession procedure and borrower’s final repayment opportunity.
• Repossession return and sale/auction process.

15. Loan Facilities for Physically/Visually Challenged

• No discrimination against applicants with disabilities.
• Employees sensitised on disability rights.
• Grievance redressal mechanism covers disability-related grievances.

16. Policy Review & Approval

FPC will undergo periodic Board-approved reviews as required by regulations/statutes, with comprehensive reports submitted to the Board.