Fair Practice Code (FPC)

Golu Leasing and Finance Co. Private Limited ("the Company"), the RBI-registered NBFC (CoR No. B-14.01773) that lends through the Tap4Loan platform operated by its Lending Service Provider SVR TECH SOLUTIONS PRIVATE LIMITED, is regulated under the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025, Circular RBI/DOR/2025-26/362 DOR.MCS.REC.No.281/01-01-039/2025-26 dated November 28, 2025 ("Directions"), or any successions thereof. The Company acknowledges that fair conduct is not merely a regulatory requirement but a foundational element of responsible financial intermediation. This Code sets out a comprehensive system of principles, behavioural standards, and operational expectations to guide all employees, officers, authorised agents, outsourced partners, DLAs, LSPs, and any person or entity engaged on behalf of the Company.

The FPC aims to embed a culture of fairness across all facets of the credit lifecycle. The Company is committed to ensuring that customers are dealt with ethically, courteously, and transparently from the moment of first interaction until final closure of the loan.

This Code applies to all business units, branches, digital platforms, outsourced service partners, and personnel representing the Company, including its LSP SVR TECH SOLUTIONS PRIVATE LIMITED operating the Tap4Loan platform. It also governs every stage of the Company's lending activities including sourcing, marketing, application evaluation, KYC verification, credit appraisal, documentation, sanction, disbursement, servicing, collections, grievance redressal, and closure.

The Board of Directors of Golu Leasing and Finance Co. Private Limited bears ultimate responsibility for approving, reviewing, and supervising the implementation of this Code.

The Company shall ensure that all communications to the borrower shall be in the vernacular language or a language as understood by the borrower. Loan application forms shall contain all necessary information. The Company shall devise a system of giving acknowledgement for receipt of all loan applications.

The Company shall convey in writing to the borrower the amount of loan sanctioned along with the terms and conditions including annualised rate of interest. The Company shall mention penalties for late repayment in bold in the loan agreement. The Company shall furnish a copy of the loan agreement to all borrowers at the time of sanction/disbursement.

The Company shall give notice to the borrower of any change in terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. Changes in interest rates and charges shall be effected only prospectively.

The Company shall refrain from interference in the affairs of the borrower except for purposes in the loan agreement. Transfer requests shall be responded to within 21 days. In the matter of recovery, the Company shall not resort to undue harassment.

The Company shall draft the Fair Practices Code enhancing the scope of the guidelines and put it on its website.

The Board shall adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium. The rate of interest must be annualised so the borrower is aware of the exact rates.

The Company shall ensure that all interest rates and associated charges on loans are fair, transparent and in accordance with the interest rate policy.

The Company shall not discriminate in extending products and facilities to physically/visually challenged applicants on grounds of disability.

Compliance with this Code shall be reviewed periodically through internal audit, compliance checks, MIS reporting, and Board-level oversight. The FPC shall be reviewed annually.