Grievance Policy

Issue Date: 25/05/2025

Authorized By:

Not to be reproduced, copied, distributed, or transmitted in any form or means without the prior written consent of KGIL Fintech Solutions Private Limited.

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PREAMBLE

KGIL Fintech Solutions Private Limited (“Company”) has framed this Policy on Grievance Redressal Mechanism (the “Policy”) in accordance with the Reserve Bank of India (Digital Lending) Directions, 2025, released by the Reserve Bank of India (“RBI”) vide notification dated May 08, 2025, as amended from time to time (“Directions”).

The Company being a lending service provider (“LSP”) which is facilitating the process of lending of unsecured loans between the registered Non-Banking Financial Companies (“NBFCs”) (as ‘Regulated Entity’ or ‘RE’ defined under the Guidelines) and the customers of the Company (“Borrowers”) through the Company’s digital platform, ‘SwipeLoan’ (“DLA”), is governed by the Directions.

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SCOPE

In order to establish and maintain an appropriate grievance redressal mechanism within the organization to resolve the Complaints or Grievances (defined hereinafter) of its Borrowers in compliance with the Directions, the Company has formulated this Policy, setting out the procedure for receiving, registering and disposing of the inquiries, Complaints, and Grievances of the Borrowers concerning facilities offered by the Company including but not limited to the inquiries, Complaints, and Grievances in relation to the services provided by the third party agents or business facilitators appointed by the Company for providing such services on behalf of the Company.

For the purpose of this Policy, a “Grievance” or “Complaint” refers inquiries, complaints, and grievances of the Borrowers regarding:

• The services, products, or the conduct of the Company or its employees/representatives;
• The services, products, or the conduct of the Company’s third-party agents or business facilitators appointed by the Company for providing such services or products on behalf of the Company;
• Issues related to the loan facilitation process, documentation, or communication with its RBI-registered NBFC/Bank partners of the Borrower;
• Communication, coordination, and information exchange between Company and the Borrowers;
• Data privacy, security, and usage of personal information shared with the Company;
• Accuracy of information provided by the Company; and
• Any perceived deficiency in services offered or promised by the Company.

Further, in the event of any conflict between the provisions of this Policy and the Directions, as amended from time to time, the Directions shall prevail over this Policy and the part(s) so repugnant shall be deemed to be severed from the Policy and the rest of the Policy shall remain in force and the parts added/amended to the Directions from time to time which are not a part of this Policy shall be deemed to be adopted on the date on which the Directions became effective until this Policy is formally amended.

The terms that have not been defined in this Policy shall have the same meaning assigned to them in the Directions.

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PURPOSE OF THE POLICY

Digital lending is defined as the remote and automated lending process, largely by use of seamless digital technologies for customer acquisition, credit assessment, loan approval, disbursement, recovery, and associated customer service.

This Policy outlines the Company’s structured approach to addressing inquiries, Complaints, and Grievances of the Borrowers promptly, efficiently, and with utmost impartiality and educate the Borrowers about the processes to be followed to lodge inquiries, Complaints, and Grievances with the Company and/or the RBI. Our objective is to ensure that all customer Grievances are handled courteously and resolved within defined timelines, adhering to Directions and other regulatory guidelines and promoting continuous improvement in our services. This policy reflects our commitment to fair practices and customer satisfaction.

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CORE PRINCIPLES OF GRIEVANCE REDRESSAL

Our Grievance redressal mechanism is built upon the following core principles:

• Fairness and Impartiality: Every Complaint is treated with objectivity and without bias.
• Customer Focus: Understanding the Borrower’s concerns effectively.
• Accessibility: Multiple convenient channels for lodging complaints.
• Transparency: Clear communication of timelines and escalation points.
• Timeliness: Adherence to strict timelines.
• Confidentiality: Protection of Borrower data.
• Accountability: Defined roles and responsibilities.
• Continuous Improvement: Ongoing service enhancement.

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PROCEDURE FOR LODGING A COMPLAINT OR GRIEVANCE

Channels for Lodging a Complaint or Grievance

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Information Required for Lodging a Complaint

• Full Name and Registered Mobile Number
• Registered Email ID
• Loan Application ID or Loan Account Number
• Date of the incident
• Detailed description of the issue
• Supporting documents (if any)

Upon submission, complaints will be acknowledged within 24–48 business hours with a unique reference number.

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GRIEVANCE REDRESSAL PROCESS AND TIMELINES

Every complaint is logged and tracked through a centralized system ensuring:

• Unique identification
• Proper assignment
• Timeline monitoring
• Complete audit trail
• Root cause analysis

Nodal Officer Details

• Name: Bhakti Aher
• Address: 12th Floor, 1205, Gera Imperium Rise, Hinjewadi Phase 2, Pune, Maharashtra – 411057
• Email: grievance@swipeloan.in
• Contact: 9117113999
• Working Days: Monday to Saturday

A response will be provided within 10 working days.

If unresolved within 30 days, Borrowers can escalate to RBI Ombudsman.

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RBI Complaint Process

• Online: https://cms.rbi.org.in
• Address:
  Centralised Receipt and Processing Centre
  Reserve Bank of India
  4th Floor, Sector 17
  Chandigarh – 160017

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CONFIDENTIALITY AND DATA PROTECTION

All customer data is handled with strict confidentiality and stored securely for 5 years as per regulations.

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CUSTOMER AWARENESS AND COMMUNICATION

The Policy is available on the website and mobile application along with FAQs and support content.

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REDRESSAL OF SYSTEMIC ISSUES

Complaint data is analyzed regularly to improve services, processes, and customer experience.

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POLICY REVIEW AND AMENDMENT

The Policy may be updated periodically to reflect regulatory or operational changes.