ANAND PROPERTY FINANCE LIMITED

FAIR PRACTICES CODE V1.2

Policy Name Fair Practice Code Issue and Effective date April 19, 2023 Date of next review Apr 19, 2024 Periodicity of review Annual Owner / Contact Compliance Department Approver Board of Directors

Introduction The Fair Practices Code is aimed to provide to the customers effective overview of practices, which will be followed by the Company in respect of the financial facilities and services offered by the Company to its customers. The Code will facilitate the customers to take informed decisions in respect of the financial facilities and services to be availed by them and will apply to any loan that the Company may sanction and disburse. The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Financial Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers. Master Direction – Non-Banking Financial Company – Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (“the Directions”) issued by RBI provides that all the applicable NBFCs shall put in place Fair Practices Code based on the guidelines outlined in the said directions. In terms of the RBI Directions and considering the nature of the business, it is proposed to adopt the following Fair Practice Code (Code) for AFPL lending activities under all categories of products. The FPC will be applicable to all the offices of the Company including the Head Office, the Regional Offices located in various centres and the Branches located across India. The FPC shall be binding on all the employees and officers of the Company. 1. Objective of the Code This Code has been developed: • To promote good, fair and trustworthy practices by setting minimum standards in dealing with the customers; • To increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services. • To encourage market forces, through competition, to achieve higher operating standards; • To promote a fair and cordial relationship between the customers and the Company.

2. Our Key Commitments and Declarations 1) The Company undertakes to abide by all applicable laws, regulations and guidelines passed / issued by the Regulators (Reserve Bank of India, Ministry of corporate Affairs etc.) and other competent authorities. 2) The Company commits itself to full customer satisfaction through efficient, professional and courteous services across all its offices. 3) The Company shall consistently strive to meet with and improve upon the internally set benchmarks and practices and be ahead of the standards prevalent in the industry. 4) The Company undertakes not to discriminate customers on grounds of religion, caste, gender or language. 5) The Company will provide clear and full information about its products and services to its customers / prospective customers and will not resort to any misleading or potentially misguiding advertisement or publicity. 6) The Company undertakes to desist from introducing any products / services having elements of ‘hidden charges’ or lack of transparency. 7) The Company will communicate in the local language with the customer and in English at the request of the customer 8) The Company undertakes to take all possible and reasonable measures to secure the safe custody of the security pledged by the customer and to compensate the customer for any accidental, inadvertent or fraudulent loss of the security whilst in the custody of the Company. 9) The Company undertakes not to take advantage of any unintentional or clerical error made by the customer while transacting business. 10) The Company is committed to put in place a system for promptly addressing complaints and suggestions of the customers supplemented with a structured Grievance Redressal Mechanism having an escalation matrix. 11) The Company shall display the FPC on all the places of its operation and also make available to the Customer, on request, a copy of the FPC on demand

3. Applications for loans and their processing: 1) All communications to the borrowers shall be made in vernacular language or a language as understood by the borrower. 2) Loan application forms issued by the Company shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the borrower. The loan application form shall indicate the documents required to be submitted along with the application form. 3) The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 90 days, from the date of receipt of application form complete in all respects. In any case the Customer will be kept informed by the sales person with regards to the status of his application from time-to-time. The Customer may also contact APFL’s customer service team at the prescribed number or email id to obtain an update on the status of application. 4) If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.

4. Loan appraisal and terms/conditions: 1) The Company shall conduct a due diligence on the credit worthiness of the borrower, which will be an important parameter for taking decision on the application. The assessment would be in line with the Company’s credit policies, norms and procedures in respect thereof. 2) The borrower would be informed by means of a written sanction letter in vernacular language as understood by the borrower, of the amount of loan sanctioned or otherwise. The said letter shall contain the terms and conditions including the annualized rate of interest and the method of application thereof. 3) The Company shall obtain an acceptance from the borrower on the said sanction letter with the borrowers’ signature under the caption “I/WE ACCEPT ALL THE TERMS AND CONDITIONS WHICH HAVE BEEN READ AND UNDERSTOOD BY ME/US”. The Company shall maintain a record of such acceptance. 4) The Company shall invariably be bound to furnish a copy of the loan agreement, preferably in the vernacular language as understood by the borrower, along with a copy of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction/ disbursement of loans. The Company shall ensure that the loan agreement and all enclosures furnished to all borrowers contains the terms and conditions and the rate of interest in the form of a Term Sheet, which shall be annexed to the Loan Agreement. Further, the Company shall mention the penal interest charged for late payment in bold in the loan agreement 5) The Company shall have a built-in repossession clause in the contract/loan agreement so as to have legal enforceability.

5. Disbursement of loans including changes in terms and conditions: 1) The Company shall frame appropriate internal principles and procedures for determining and ensuring that the interest rates and processing and other charges are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and processing and other charges on loan and advances are in strict adherence to above referred internal principles and procedures. 2) The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower. 3) The Company shall give a notice to the borrower in the vernacular language as understood by the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. A condition to this effect shall be incorporated in the loan agreement.

6. Post Disbursal Supervision: 1) Any decision to recall/accelerate payment or performance under the loan agreement shall be in consonance with the Loan Agreement. 2) All securities offered by the borrower shall be released on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against the borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.

7. Recovery or Dues, Exercise of Lien & Delivery of Security 1) The Company will not, as a matter of fair dealing, normally recall the loan before the initially agreed tenure except in unanticipated or abnormal circumstances where the Company’s interests are adversely affected e.g. when the security value diminishes substantially, when the quality of security is not found to be acceptable, due to any regulatory / government directives etc. In all such cases proper and reasonable notice shall be given to the customer recalling the loan before expiry of the normal tenure. 2) The Company will make all possible soft or persuasive efforts to get the customer to repay the dues without resorting to disposal of the security. The Company does not accept nor will it encourage the use any coercive or hard measures to recover its dues from the customer. 3) The Company will deliver the security to the customer immediately upon settlement of the loan in the same condition as was at the time of sanction of the loan. In case of any damage caused to the security due to mishandling by its employees, the Company shall at its cost get the damage repaired or alternately pay reasonable compensation to the customer on a case to case basis. If the security has signs of damage thereon, before being taken custody of by the Company at the time of sanction of loan, the fact will be briefly incorporated in the sanction letter. 4) The Company will exercise only legitimate right of lien over the pledged security or such cash surplus as may arise upon settlement of existing loans at any time. Such right of lien shall arise only if the customer has any other dues, either directly or as guarantor, and will be subject to proper intimation of such right of lien being given to the customer by the Company. 5) The Company shall issue a signed and, normally, a system generated receipt for all cash payments made by the customer immediately. The Company shall also accept payments vide cheques, demand drafts, electronic transfers etc. subject to the condition that return of the security will be made only after confirmation of realization. 6) Even though the loan sanction letter contains all applicable terms and conditions of the loan the Company shall, nevertheless, endeavour, on a best effort basis, to send advices, reminders etc. regarding due date for payment of interest, principal etc. by letter, courier service, telephone , SMS etc. 7) The Company shall, on demand, provide the customer or his duly authorized representative with a statement of the loan account at any time during the currency of the loan or immediately upon closure. However, the Company may, at its discretion, require payment of reasonable processing charges by the customer for providing statement of account if such demand is made 30 calendar days after closure of the account. 8) The Company will resort to disposal of security only as a last resort and that too after adequate and proper notice is served on the customer to repay the dues. Such notice will be as per the terms contained in the sanction letter and also in compliance with applicable laws and regulatory guidelines. The disposal of the security will be taken up through public auction when the customer does not positively respond to the communications sent by the Company to close the loan account along with interest and other charges. 9) Where the Company proposes to dispose of the security even before the normal tenure of the loan based on the rights conferred on the Company vide loan application and loan sanction letter adequate and proper notice will be served on the customer before such action is initiated for recovery of dues. 10) The Company prefers and encourages customers to take back delivery of the security immediately upon full settlement of all dues. However, should there be exceptional instance of the Customer being unable to take delivery of the security, not attributable to the inability of the Company, after closure of the loan account reasonable safe custody charges may be payable which will be duly advised to the customer or displayed in the branch premises and the Company’s website. 11) The Company will not interfere in the affairs of the customers except for the purposes mentioned in the terms & conditions of the loan or when constrained to do so due to inadequate or false disclosures made by the borrower at the time of putting through the transactions. 12) The Company shall ensure that the entire process of enforcing its security, valuation and realisation thereof be fair and transparent

8. Complaint Redressal Mechanism 1) The Company will implement all possible steps to prevent and minimize customer complaints / grievances. 2) The Company will facilitate the customer to pay the whole or part of the dues at any of the branches of the Company subject to the condition that delivery of the pledged security shall be made only at the branch where loan was originally disbursed. 3) The customer can register grievances through email id and toll free number provided at our branches /Head Office/website. 4) After examining the matter, the Company will endeavour to send the customer its response expeditiously and intimate the customer how to escalate the complaint to higher level, if he is not satisfied with the response. The Company has set up product wise turnaround time (“TAT”) for resolution of customer grievances and shall ensure to resolve the grievances within such defined TATs. 5) The customer has to confirm whether the grievance has been resolved to his/her satisfaction or not. The grievance will be deemed to be closed, if the customer does not respond via toll free number or email. 6) At all branches/Head Office and official website of the Company, Notice will be put up informing the customers about the Customer Care Executives, Escalation Mechanism and the Grievance Redressal Officer (including the name and contact details of persons responsible for logging and resolving the grievances). If the grievance is not redressed within four weeks from the date of receipt of the grievances, the customer may appeal to: The Officer In Charge Department of Non-Banking Supervision Reserve Bank of India 3 rd Floor, Opposite Mumbai Central Railway Station, Byculla, Mumbai – 400 008 Email id: dnbsmro@rbi.org.in 7) The Company shall also request the customer to provide feedback on the services rendered. This can be done through direct contact by staff or through specific customer satisfaction surveys that may be conducted from time to time. 8) A periodical review of the Fair Practices Code and the functioning of the Grievances Redressal Mechanism at various levels of management would be undertaken by the Company and a consolidated report of such reviews shall be submitted to the Board of Directors of the Company, at regular intervals. 9) The Company will put in place an effective training system to ensure that employees of the Company are customer friendly and do not resort to rude, inappropriate or unethical behavior. 10) The Company will endeavour to work out and display the time norms for putting through and completing the various transactions. 11) The Company will have a sympathetic approach to the problems faced by the customer especially the poor and underprivileged sections.

9. Policy for Determining Interest Rates, Processing and Other Charges To ensure that there the Customers are not charged excessive interest rate and charges on loans and advances by the Company, the Board of the Company has adopted a Policy for Determining Interest Rates, Processing and Other Charges (“Interest Rate Policy”) and the same has been put up on the Company’s website www.tatacapital.com. The changes in the interest rates are also displayed on the website on a regular basis. Further the Board of the Company also undertakes periodical review of the Interest Rate Policy.

10. General 1) The Company shall display the normal business hours at the respective branches, the list of holidays and notify the changes, if any, by way of a notice displayed in the premises of the branch or through press notification. 2) Personal information of the customer will not be shared with unauthorized persons or agencies or third parties by the Company. However, the Company will be bound to honour and comply with legal or regulatory requirements, if any, in this matter obligating it to part with such information even without notice to the customer

The Company shall abide by this Fair Practices Code following the spirit of the Code and in the manner it may be applicable to its business.