Penal Charges Policy for Spot Loan Product

1. Objective

This policy outlines the framework for imposing penal charges on loan accounts of VISTRONEX PRIVATE LIMITED, ensuring compliance with RBI Circular No. RBI/2023-24/53 dated August 18, 2023, on ‘Fair Lending Practice — Penal Charges in Loan Accounts’. The goal is to ensure transparency, fairness, and reasonableness in the application of penal charges, while deterring defaults.

2. Scope

This Policy shall apply to all loan products offered by VISTRONEX PRIVATE LIMITED across all customer segments.

3. Penal Interest

The objective of the incremental interest rate is not to earn revenue, but to deter the customer from defaulting on the loan.

4. Collection Charges

Note 1 — Overdue Interest

• Charged to compensate the Company for the loss of interest arising due to delay or default in repayment by the borrower.
• For Instalment Loans, charged on a daily basis from the date of default, at a rate equivalent to the applicable annualized rate of interest on the loan.
• Charged once for each missed instalment of the loan.
• No Overdue Interest is charged on delinquent amounts relating to interest or service fees.

Note 2 — Late Payment Charges

• Levied to cover the administrative and recovery-related expenses incurred by the Company due to delay in repayment by the borrower.
• Applied from the 5th day following the date of default, charged once for each missed instalment of the loan.

5. Communication of Charges

Borrowers shall be duly informed of the applicable penal charges at the time of loan sanction. Any subsequent changes to such charges shall be communicated to borrowers in a timely manner through appropriate communication channels.

6. Fairness and Non-Discrimination

Penal charges shall be applied in a consistent, transparent, and fair manner across all borrower segments. Such charges shall not be discriminatory and shall remain within the framework of reasonable deterrence, in accordance with the Company’s policies and applicable regulatory guidelines.

7. Review and Compliance

This Policy shall be reviewed on an annual basis, or earlier if required, to ensure continued compliance with applicable regulatory guidelines and prevailing market conditions. Any revisions shall be made in accordance with updated directives issued by the Reserve Bank of India (RBI) or changes in the Company’s internal policies and procedures.

8. Grievance Redressal

Borrowers shall have the right to raise concerns or complaints regarding penal charges through VISTRONEX PRIVATE LIMITED’s grievance redressal mechanism. Such complaints shall be addressed promptly and resolved in accordance with the Company’s established customer grievance redressal framework and service standards.