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FAIR PRACTICES

KGIL Fintech Solutions Private Limited

Fair Practices Code Version 1.0

Issue Date:

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.

A&A Comment: Kindly note that the compliances stipulated under the Reserve Bank of India (Digital Lending) Directions, 2025, dated May 8, 2025, have been duly incorporated in relation to the conduct and fairness-related provisions under this policy. We request you to review the policy in light of your specific business practices and let us know if any additional provisions need to be included or if any of the existing requirements require modification. Based on your feedback, we will make the necessary revisions accordingly

1. INTRODUCTION

KGIL Fintech Solutions Private Limited (hereinafter referred to as “KGIL” or “Company”) is a lending service provider (“LSP”) engaged in facilitating credit to customers through its partner financial institutions,  non-banking financial companies and/or banks (hereinafter collectively referred to as the “Lending Partners”), in compliance with Reserve Bank of India (Digital Lending) Directions, 2025, dated May 08, 2025 (“Digital Lending Guidelines”) issued by the Reserve Bank of India (“RBI”). The Company provides a technology-enabled platform with the name ‘SwipeLoan’, accessible via its website and mobile application (“Platform”) to connect customers (“Customer(s)”) with the Lending Partners and supports various aspects of the lending lifecycle, including loan sourcing, credit assessment, disbursal facilitation, and Customer support.

KGIL is committed to ensuring that its practices are fair and transparent. In line with this commitment, the Company has adopted this Fair Practice Code (“Code”), which outlines the principles to be followed while interacting with Customers and delivering its services. This Code has been formulated in alignment with the Digital Lending Guidelines.

2 SCOPE AND PURPOSE OF THE CODE

The purpose of this Code is to establish minimum standards for fair and transparent practices in the delivery of lending-related services by the Company. The Code is intended to ensure that all activities undertaken by the Company, while acting as an LSP and during its course of business, upholds the highest standards of integrity, transparency, and Customer protection.

This Code is applicable to all employees, directors, officers, representatives, and agents of KGIL who are involved in the activities, sourcing, onboarding, servicing, or collection of loans facilitated through the Company’s Platform. It also governs the Company’s interaction with its Customers, Lending Partners, and third-party service providers.

The objectives of this Code include the following:

  • To promote fair, honest, and ethical practices in the conduct of digital lending services;
  • To ensure transparency in the loan facilitation process, including clear communication of terms and conditions to Customers;
  • To safeguard the interests of the Customers by ensuring that Customer data and rights are respected and protected; and
  • To promote a culture of responsible lending, grievance redressal, and accountability across all Customer-facing processes.

This Code forms an integral part of KGIL’s governance and compliance framework and is subject to periodic review and updates to reflect changes in regulatory expectations, industry best practices, and Customer needs.

3. KEY COMMITMENTS

The Company makes the following key commitments:

  • Fair Dealings: All Customer interactions will be honest, respectful, and free from coercion or misrepresentation.
  • Transparency: Clear and complete information on loan terms, charges, and repayment conditions will be provided upfront through Key Fact Statements (“KFS”) and other disclosures.
  • Data Privacy: Customer data will be handled securely and used only for authorized purposes. No data will be shared without consent, unless required by law.
  • Grievance Redressal: A transparent and accessible grievance mechanism will be maintained to address Customer complaints promptly and fairly.
  • Non-Discrimination: No Customer will be discriminated against based on gender, religion, caste, economic status, or any other unlawful ground.
  • Regulatory Compliance: The Company will comply with all applicable RBI guidelines and work closely with its Lending Partners to ensure responsible lending practices.

    4. DISCLOSURE OF INFORMATION

    The Company shall ensure that the Customers are provided with clear, accurate, and timely information to help them make informed decisions regarding credit facilities facilitated through its Platform. The Company will uphold transparency in all stages of the loan process. Key aspects include:

    • Disclosure of Terms: Customers will receive detailed information regarding the loan, including:
      1. Interest rate and method of calculation;
      2. Processing fees and other charges;
      3. Repayment schedule and tenure;
      4. Annual Percentage Rate (“APR”);
      5. Penal charges (if any);
      6. Cooling-off/look-up period, where applicable.
    • KFS: A KFS, i.e., a Key Fact Statement, in the prescribed format under the RBI Circular dated April 15, 2024 [RBI/2024-25/18 DOR.STR.REC.13/13.03.00/2024-25 – Key Facts Statement (KFS) for Loans & Advances will be shared digitally with the Customer before loan execution, ensuring full disclosure in accordance with RBI’s Digital Lending Guidelines.
    • Loan Documentation: All relevant loan documents, including the KFS, sanction letter, terms and conditions, and account statements, shall be accessible to the Customer on the registered and verified email/ SMS upon execution of the loan contract/ transactions at any time.
    • Language and Clarity: All communications and documents will be presented in a language understood by the Customer and in a manner that is clear, concise, and unambiguous.
    • Partnership Disclosures: The name and contact details of the Lending Partner originating the loan will be clearly disclosed to the Customer, in accordance with applicable laws and regulatory requirements.

      5. TARIFF (FEE / CHARGES / INTEREST)

      KGIL ensures full transparency in disclosing all fees, charges, and interest associated with loans facilitated through its Platform.

      • Upfront Disclosure: All applicable charges, including interest rate, processing fees, penal charges, and any other applicable costs, will be clearly stated in the KFS and loan agreement, prior to disbursal.
      • APR: The APR, reflecting the total cost of the loan on an annualized basis, will be disclosed to enable informed Customer decisions.
      • No Hidden Charges: No charge shall be levied without prior disclosure and Customer consent.
      • Lender-Determined Tariffs: Fees and interest will be set and duly communicated by the Lending Partner. Further, KGIL will communicate these as provided, without modification or misrepresentation.

      Customers can find the schedule of common fees and charges (including interest rates) by referring to the service guide/member booklet, calling the customer service numbers, visiting KGIL’s website, and/or asking the Company’s designated staff. Any changes in fees, charges, or interest rates will be communicated to the Customers in advance. Such changes will be applied prospectively and will be made available on the website and the official website and mobile application of the Company. [A&A Comment: Please confirm whether KGIL has any service guide or member booklet in place, which provides for the common fees and applicable charges. Basis your confirmation, we will accordingly revise the understanding captured herein.]

      6. APPLICATIONS FOR LOAN AND THEIR PROCESSING

      The Company aims to make the loan application process simple, transparent, and Customer-friendly. As an LSP, the Company facilitates digital loan applications on behalf of its Lending Partner and ensures fair handling at every stage, thereby ensuring the following:

      • Application Support: Customers will be provided with clear guidance regarding loan eligibility, documentation, and product features. The application process will be technology-enabled, secure, and accessible via the Company’s Platform.

       

      • Acknowledgement and Status Updates: Upon submission of a loan application, an acknowledgement will be issued through electronic means (email/SMS/in-app). Customers will have access to timely updates regarding the status of their application.

       

      • Fair and Timely Processing: All applications for loans by the Customers will be processed in an unbiased and efficient manner. In cases where additional information is required or the application is delayed, Customers will be appropriately informed.

       

      • Rejection Communication: If an application is rejected, the applicant will be notified of the decision along with a brief reason, to the extent possible under regulatory and Lending Partner policies.

       

      • Non-Discrimination: Loan applications will be assessed on merit, based on defined criteria of the Lending Partners. The Company will not reject or disapprove any loan application of a Customer on the basis of gender, religion, caste, or age.

        7. LOAN APPRAISAL AND TERMS & CONDITIONS

        The Company ensures that loan appraisal and approval processes are conducted in a fair, transparent, and responsible manner, in coordination with its regulated Lending Partners.

        • Loan Appraisal:

          1. Every loan application is assessed objectively based on the creditworthiness of the applicant and the eligibility criteria prescribed by the Lending Partners.
          2. Credit evaluation may include analysis of income, repayment capacity, credit history, and other relevant factors, either manually or through automated underwriting systems approved by Lending Partners.
          3. The Company may use automated decisioning systems, credit scoring models, and alternative data sources to assess loan applications, where such models are approved by the Lending Partners and are in compliance with applicable laws.
          4. Standardized fraud detection and risk mitigation protocols, such as data validation, may be used during the loan appraisal stage to ensure the authenticity of the Customer data and prevent misuse.
          5. The Company coordinates with its Lending Partners to ensure the appraisal standards are adhered to, and no loan is sanctioned without due credit evaluation in accordance with the policies of the Lending Partner.
          6. Loans shall not be sanctioned without the explicit application or request from the Customer. Pre-approved offers (if any) will also be based on pre-defined credit criteria and require express consent from the Customer prior to disbursal.

        • Communication of Terms:

          1. Upon approval, a sanction letter or a loan agreement will be shared with the Customer, indicating the amount sanctioned, annualized interest rate, tenure, EMI structure, and other key terms.
          2. A KFS will also be provided before loan execution, outlining all essential terms, including fees, charges, and repayment obligations.

        • Acceptance of Terms:

          1. The Customer will be required to provide explicit consent to the terms and conditions before the disbursal of loan.
          2. The loan agreement, KFS, and other related documents will remain accessible to the Customer throughout the loan tenure.
        • Language and Clarity: All terms and conditions will be communicated in a simple and clear manner, in a language understood by the Customer.
        •  
        • Right to Understand Before Acceptance: Customers will be given an adequate opportunity to review and understand the terms before entering into the loan agreement with the Lending Partners through the Company’s Platform.

          8. MARKETING ETHICS

          The Company is committed to conducting all marketing and promotional activities in a fair, transparent, and ethical manner. All advertisements and communications will present accurate and non-misleading information about the services offered, including the nature of the loan products and the role of the Lending Partner(s). The Company will clearly disclose to the Customers that it acts as an LSP and not as a lender. Any third-party representatives engaged for marketing purposes will be required to adhere strictly to these ethical standards.

          9. ACCOUNT OPERATIONS

          KGIL will ensure that the Customers have easy and secure access to their loan-related account information at all times. Customers will be provided with regular updates on their loan status, repayment schedules, outstanding balances, and transaction history through digital channels such as email, the Company’s Platform, including the mobile application, and website. Any request for account statements or loan documents will be addressed promptly and without undue delay. The Company will also assist the Customers in resolving operational queries related to repayments, prepayments, or changes in contact details. All account operations will be carried out in a transparent and Customer-friendly manner, in coordination with the Lending Partner.

          10. GENERAL

          The Company shall ensure that all policies and procedures related to its lending facilitation services are implemented with a strong emphasis on Customer trust, ethical conduct, and operational integrity. The Company will monitor compliance with this Code and take corrective actions in case of deviations or contraventions.

          All staff and authorized representatives shall undergo periodic training to remain updated on regulatory changes, Customer service protocols, and technology-related safeguards. . In the event of any conflict or inconsistency between the provisions of this Code and any applicable law, rule, regulation, or direction issued by the RBI or any other competent authority, such regulatory provisions shall prevail to the extent of the conflict. This Code shall be deemed to be automatically amended or interpreted, as necessary, to comply with such prevailing regulatory directions, without affecting the validity or enforceability of the remaining provisions herein.

          KGIL reserves the right to amend this Code, in whole or in part, based on regulatory developments, business needs, or Customer feedback. Therefore, the revised and updated Code will be made available on the Company’s Platform.