FAIR PRACTICES CODE AND GUIDELINES

Social Worth Technologies Private Limited (‘Company’) (Fair Practices Code Policy (“Code”).

This is with reference to the guidelines issued by the Reserve Bank of India on Fair Practice Code for all Non-Banking Financial Companies (NBFCs) vide RBI circular RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 1, 2015, which has been adopted as a good governance practice by the Company.

This Code is aimed to provide to all the stake holders, including but not limited to the Company’s customers, an effective overview of the practices followed, in respect of the services offered by the Company.

The objectives of this Code are:

• To implement and promote industry standard practices in dealing with customers;
• To promote a fair relationship between the customer and the Company;
• To ensure compliance with applicable laws and regulations in matters relating to recovery of loan amount;
• To create and maintain adequate mechanisms for redressal of customer grievances;

Loan Application

• The Company shall provide the customer the information, required in relation to the services, so that the customer can make a meaningful comparison with the terms and conditions offered by other fintech companies and make an informed decision.
• The Company shall give an acknowledgement of receipt for all loan applications. The Company shall endeavour to provide the time frame within which the decision of the loan applications shall be communicated.
• The loan application form shall indicate the documents required to be submitted along with the application form.
• If any additional details/ documents are required, the same shall be reasonably intimated to the borrowers.

Loan Appraisal and Terms & Conditions

• The Company shall facilitate in writing to the customer, by means of a sanction letter or any other document provided by the Lender, the amount of loan sanctioned along with the terms and conditions including applicable rate of interest and shall maintain, in its record, the acceptance of these terms and conditions by the customer.
• Upon the execution of the loan agreement, the Company shall facilitate a copy of the loan agreement along with a copy of all annexures attached to the loan agreement, to the customer.

Disbursement of loans including changes in terms and conditions:

• The Company shall only facilitate the loan and does not provide any loan directly.
• The Company shall give notice in English, for any change in the terms and conditions.

Interest Charged:

• Theintrest rate according to the policies of the Lending Partner.
• The Company would facilitate disclosure of the interest rate clearly to the customer.

Grievance Redressal Mechanism:

The company aims to provide the best customer service and is consistently striving to create a robust and efficient customer service platform. If the customers have any issues or wish to register a complaint, they can reach the Company at any of the following coordinates:

• Step 1 Telephone: The customer can call us and log his/her grievances at 02067639797 . Email: Customers can write to us at the given e-mail ID: care@fibe.in . Alternatively, customers can also write to us at: Social Worth Technologies Private Limited Unit No. 404,The Chambers, Viman Nagar, Pune, Maharashtra 411014,India.

Customer(s) or you or End-Users shall mean any person who accesses, downloads, uses, views the Platform and the Services.

Loan shall mean the loan that you may apply for through the Platform (‘Fibe’) and which is sanctioned and granted by LENDER, subject to the applicable terms and conditions of the Loan Agreement.

Loan Agreement shall mean the loan agreement to be executed between LENDER and the Customer(s) for granting the Loan whether in physical or electronic form as may be applicable from time-to-time.

Online Stores shall mean Windows Store, Android Google Play, iOS App store or any other online store or portal where the App will be made available by the Company to the End-Users, from time to time.

Outstanding Amount(s) shall mean the Loan, interests and charges due and payable by you to LENDER, on respective due date(s).

Platform shall mean the App and the Website collectively.

Services shall mean the services of granting, sanctioning, lending of short term loans, through the Platform by LENDER.

Third Party Platforms shall mean social networking platforms, such as Facebook, LinkedIn and other similar platforms.

User Data shall mean any data, information, documents or materials submitted with the Company prior to or during the use of the Services.

Website shall mean www.fibe.in, managed and operated by the Company for the provision of Services.

SERVICES

Through the Services, you may apply for the Loan, subject to the fulfilment of the eligibility criteria laid down in the Mobile App. You understand that the Company has been appointed by LENDER to collect, authenticate, track your location, verify and confirm the User Data, documents and details as may be required by LENDER to sanction the Loan.

All transactions undertaken on your behalf by the Company will be on the basis of your express instructions/consent and will be strictly on a non-discretionary basis.

The sanctioned Loan shall be disbursed by the Lender as per the mode provided in the Mobile Application Form. You are required to repay the Outstanding Amount(s) to LENDER, on the respective due date(s) mentioned in the Mobile Application Form.

CONTENT AVAILABLE:

You acknowledge that the Company makes no representations or warranties about the material, data, and information, such as data files, text, facts and figures, computer software, code, audio files or other sounds, photographs, videos, or other images (collectively, the Content) which you may have access to as part of the Services, or through your use of the Platform. Under no circumstances, shall the Company be liable in any way for any Content, including, but not limited to any infringing Content, any errors or omissions in Content, or for any loss or damage of any kind incurred as a result of the use of any Content posted, transmitted, linked from, or otherwise accessible through or made available via the Platform. The Content on the Platform should not be regarded as an offer, solicitation, invitation, advice or recommendation to buy or sell investments, securities or any other instrument or financial products / schemes of the Company (including its affiliates), unless expressly covered in these Terms.

The Company shall endeavour:

REPUTATION: -

• Be presentable at all times.
• Respectfully decline any offer or gifts from customers or agencies and report such instances to your line manager/supervisor.
• Strictly observe and follow instructions issued by the organization.
• Must not communicate directly to the media or regulators, on any organizational matters be it implied or otherwise. Refer all communication with regulators or any external party, on matters pertaining to the organization to their supervisor.
• Must not give false reports to the organization.
• All collection activities should be in line with the guidelines provided and in compliance with the code for collection and issued by the organization and regulators.
• Customers concerns to be addressed promptly with relevant information.
• Ensure all interactions are captured on the collection system of the Company.
• Customers should not be misled.
• Customer Assistance Specialists should always identify themselves and the company that they represent at the very beginning of every interaction with customers.

FINANCIAL: -

• Customer details should not be disclosed to third party.
• Shall not manipulate performance records.
• Cash collection is strictly prohibited as repayment channel.
• Never channelize customers payment through personal bank account.
• Promises for waiver of financial charges/Settlement or any other commitments should not be given to the customer’s unless it is approved by the Company.

TREAT CUSTOMER FAIRLY: -

• Treat customers fairly and do not mislead them.
• Communicate with customers in a non-threatening and non-derogatory manner.
• Ensure all complaints are lodged properly and resolved as per the SLA.
• Customer queries and concerns to be resolved or to be routed to the appropriate channel.
• Do the right thing.
• agents do not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors' family members, referees and friends.
• Sending inappropriate messages either on mobile or through social media, making threatening and/ or anonymous calls, persistently calling the borrower (ex. repeatedly calling) and/ or calling the borrower before 8:00 a.m. and after 7:00 p.m. for recovery of overdue loans.

CUSTOMER CONFIDENTIALITY: -

• The customers information to be kept confidential and should never be used for personal gains.
• Never disclose any confidential data of the customers or the organization to a third party unless required by the regulator.
• Ensure system passwords are kept confidential at all times and never share it.
• Ensure that the assets are used for official purpose only. They should not be shared with anyone.
• Any access provided to an individual should not be shared with others at any given point.
• Act responsibly and within authority.
• Always use good judgement.

Dos and Don’ts

Do’s:

• Staff shall not use of threatening or abusive language, harass relatives, friends, or coworkers of the borrower and publish the name of borrowers.
• The Code of Conduct to be strictly followed at all times.
• Always greet the customers and identify yourselves.
• Always authenticate yourself as representatives of Social Worth Technologies Private Limited
• Always authenticate yourself with requisite identity proof
• Authenticate the identity of the customers and discuss the account details with the customers only.
• Customers to be called on their registered mobile numbers .
• Call or visit the customers between 08:00 hrs to 19.00 hrs, unless the special circumstances of your business or occupation require otherwise.
• Appropriate language to be used while conversing with the customers.
• Be fair and ethical in your dealings with the customers.
• Actively listen to and understand the customers’ requirements.
• Collections’ interaction should be based on courtesy, fair treatment and persuasion.
• Collection agent should, as far as possible, use the spoken language which the customer is comfortable with.
• Customers are entitled to privacy and the collection agent should respect this right and shall not divulge the Customer information to any third party.
• Update all interactions with the customers on the collections system of the Company.
• Use only recorded lines while interacting with the customers.
• In case text messages/ WhatsApp messages need to be sent to the customers, please make use of only those templates that have been validated by the Legal Team of the Company for the specific scenarios.
• Provide assistance for resolution of disputes or differences regarding dues in a mutually acceptable and orderly manner.
• In case of any grievances raised by the customers, please communicate all the available channels so that they can raise their concerns. Assistance to be provided in this regard.

Don’ts:

• Do not collect cash/ payments in personal account or any account not belonging to the Company through any instruments from the customers.
• Do not send any emails to the customers from personal id’s or any unofficial accounts.
• Do not make any promises to the customers including on the settlement amount, change in the bureau status or issuance of No Dues Certificate without prior approval from the respective authorized approver.
• Do not use non-recorded lines/ personal mobile numbers to converse with the customers.
• Do not use any unacceptable methods to reach out to the customers.
• Do not disclose any customer related information to the third party (family or others).
• Do not indulge in any illegal activity
• Do not use any Social Media partner to contact the customers.

PROPRIETARY RIGHTS OF THE COMPANY:

You understand, acknowledge and agree that the Company is the sole owner of all rights, title and interest, including any and all intellectual property rights in the Content, Platform, Services, logos, trade names, brand names, designs and any necessary software used in connection with the Platform.

There may be proprietary logos, service marks and trademarks found on the Platform whether owned/used by the Company or otherwise. By displaying them on the Platform, the Company is not granting you any license to utilize the proprietary logos, service marks, or trademarks. Any unauthorized use of the same may violate applicable intellectual property laws.

You understand and acknowledge that the Platform is owned by the Company. Nothing under these Terms shall be deemed to be a transfer in ownership, rights, title, from the Company to you or any third party, in the Platform. You are entitled to avail the Services offered by the Company during the validity of your registration with the Company.

LINKS TO THIRD PARTY SITES:

The Platform may contain links to other websites owned and operated by third parties who are not related to the Platform (Linked Websites). The Linked Websites are not under the control of the Company and the Company shall not be responsible for the content of any Linked Websites or any hyperlink contained in a Linked Website and makes no representation or warranty with respect to the content of any such third party sites.

The Platform provides these links to you as a convenience only and the inclusion of any link does not imply any endorsement of the Linked Website by the Company. Your access or use of such Linked Website is entirely at your own risk. The Company shall not be a party to any transaction between you and the Linked Website. Your use of a Linked Website is subject to these terms and conditions of that respective Linked Website.

The Platform may also contain third party advertisements, if any. The display of such advertisements does not in any way imply an endorsement or recommendation by/of the relevant advertiser, its products or services. You shall independently refer to the relevant advertiser for all information regarding the advertisement and its products and/or services. The Company accepts no responsibility for any interaction between you and the relevant third party and is released from any liability arising out of or in any way connected with such interaction.

ANCILLARY SERVICES:

You may get access to chat rooms, blogs, feedbacks, reviews and other features (Ancillary Services) that are/may be offered from time to time on the Platform and may be operated by us or by a third party on our behalf. You shall not (nor cause any third party to) use these Ancillary Services to perform any illegal activities (including without limitation defaming, abusing, harassing, stalking, threatening, promoting racism, or otherwise violating the legal rights, such as rights of privacy, of others) or immoral activities, falsely stating or otherwise misrepresenting your affiliation with a person or entity. Additionally, the Platform may contain advice/opinions and statements of various professionals/ experts/ analysts, etc. the Company does not endorse the accuracy, reliability of any such advices/opinions/ and statements. You may rely on these, at your sole risk and cost. You shall be responsible for independently verifying and evaluating the accuracy, completeness, reliability and usefulness of any opinions, services, statements or other information provided on the Platform. All information or details provided on the Platform shall not be interpreted or relied upon as legal, accounting, tax, financial, investment or other professional advice, or as advice on specific facts or matters. The Company may, at its discretion, update, edit, alter and/or remove any information in whole or in part that may be available on the Platform and shall not be responsible or liable for any subsequent action or claim, resulting in any loss, damage and or liability. Nothing contained herein is to be construed as a recommendation to use any product or process, and the Company makes no representation or warranty, express or implied that, the use thereof will not infringe any patent, or otherwise.

TERMINATION:

The Company reserves its rights to terminate these Terms in the event:

• you breach any provision of these Terms;
• the Company is required to do so under law; or
• the Company chooses to discontinue the Services being offered or discontinue to operate the Platform;
• the license granted to use the App expires;
• of non-payment of Outstanding Amount(s).

The Company reserves its right to Track you, even when you have uninstalled the App or even after termination of these Terms, until all your obligations, including but not limited to payment of the Outstanding Amount(s) is in subsistence.

Upon termination of these Terms, the rights and licenses granted to you under these Terms shall cease to exist, and you must forthwith stop using the Platform and the Services and repay the Outstanding Amount(s). Notwithstanding anything contained in these Terms or otherwise, the termination of these Terms for any reason whatsoever, shall not affect your obligations, including but not limited to repayment of the Outstanding Amount(s).

INDEMNITY:

You agree to indemnify and hold the Company, and its subsidiaries, affiliates, officers, agents, co- branders or other partners, and employees, harmless from any claim or demand, including attorneys’ fees, made by any third party due to or arising out of (i) your violation of these Terms; (ii) your violation of any rights of other users of the Platform; (iii) your use or misuse of the Platform or the Services; (iv) your violation of applicable laws.

VIOLATIONS:

Please report any violations or grievances with relation to these Terms to the Company at care@fibe.in.

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