Fair Practices Code

14th March 2018

1. Introduction

Etyacol Technologies Private Limited (herein referred to as "Cashkumar" or "the Company") is a peer-to-peer (P2P) lending platform. The Company has formulated this Fair Practices Code ("Code") in conformity with the Reserve Bank of India's ("RBI") Master Directions on Non-Banking Financial Company - Peer to Peer Lending Platform (Reserve Bank) Directions, 2017, updated from time to time. The policy has been duly approved by the Board of Directors and published on the company's website for the public benefit.

2. Purpose

The purpose of the Code is to provide an overview of practices which will be followed by Cashkumar while providing the loan facilitation services to the borrowers and lenders (henceforth, referred to as 'customers') on the peer-to-peer (P2P) lending platform.

The code will help the customers take informed decisions while transacting via Cashkumar, as well as set high standards of ethical business conduct and provide guidance applicable to every employee, officer and director of the company. The code will be applicable on all the services, rendered by the company from all of its operating/service locations covering its every single channel/establishment.

3. Key Commitments

Cashkumar will adhere to the below mentioned key aspects of the fair practices code:

3.1. Cashkumar shall display the following caveat on its platform:

"Reserve Bank of India does not accept any responsibility for the correctness of any of the statements or representations made or opinions expressed by the NBFC-P2P and does not provide any assurance for repayment of the loans lent on it."

3.2. Cashkumar shall obtain adequate declaration and affirmations from the lenders in relation to the risks associated with the proposed transaction viz., loan repayment, etc. including the risk of no guaranteed returns and the likelihood of loss of entire principal in case of default by a borrower.

3.3. Cashkumar shall communicate in writing (by an email) with the borrower whenever a loan offer is made.

3.4. All written communication to the borrowers shall be in English language, while all oral communication to the borrowers shall be in English language or in a vernacular language as understood by the borrowers.

3.5. The Code will ensure that the applicable laws are complied with and the customers are treated with principles of integrity and transparency.

3.6. Cashkumar shall not provide any assurance for the recovery of loans made by the lenders

3.7. Cashkumar shall ensure that the staff are adequately trained to deal with the participants i.e. the person who has entered into an arrangement with the company to lend on it or to avail of loan facilitation services provided by it in an appropriate manner for/during loan recovery and shall not resort to harassment viz; persistently bothering the borrowers at odd hours, use of coercion for recovery of loans, etc. All recovery practices will be bound by the Cashkumar Recovery Policy.

3.8. Cashkumar shall not reveal any information relating to the participants received by it to any third party without the consent of the participants.

3.9. Cashkumar shall convey to the lenders via the platform, information such as name, gender, age, city of residence, employer that will help them in making the choice to lend between the borrowers. This information will be subject to the data collected and information generated via Cashkumar's credit assessment process.

3.10. Cashkumar will display on its website, in the form of suitable metrics, the health of the sum total of all peer-to-peer (P2P) loans made via the platform. This will help lenders assess Cashkumar as a facilitator of P2P loans. This information will be updated monthly.

3.11. Participant complaints will be redressed as detailed in the Cashkumar Grievance Redressal Mechanism page.

3.12. The code shall be reviewed by the Board of Directors on an annual basis or earlier, if required, in light of change in regulatory compliance and business reasons.