Fair Practice Code

1. Introduction

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Kuvik Solutions Private Limited (CIN: U66190RJ2026PTC111957, PAN: AAMCK6374Q, GST: 08AAMCK6374Q1ZI), having its registered office at Office No. 103 & 203, 2nd Floor, Ram Bharat Villa, Siddharth Colony, Ajmer Road, Jaipur – 302006, Rajasthan, India ("Company" or "Kuvik"), operating under the brand Kuvik Loans, is a Lending Service Provider (LSP), Lead Generator, Loan Aggregator / Marketplace, and Technology Platform. The Company facilitates credit access for customers ("Customers") through its digital platform at www.kuvikloans.com ("Platform"), connecting them with partner RBI-registered Banks and Non-Banking Financial Companies ("Lending Partners").

The Company is NOT a bank, NBFC, or lending institution. It does not directly sanction, disburse, or fund any loan. All credit products available through the Platform are exclusively provided by the relevant Lending Partners, who are responsible for all decisions regarding loan approval, pricing, disbursal, and recovery.

The Board of Directors of the Company has reviewed and adopted this Fair Practices Code with effect from 23 March 2026. The Code is reviewed at least annually and upon any material regulatory change. It is published at www.kuvikloans.com/fair-practice-code and available to any Customer upon request.

2. Scope and Purpose

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Purpose: This Code establishes mandatory minimum standards for fair and transparent conduct in the delivery of digital lending facilitation services by the Company. It is designed to: (a) protect the rights and interests of Customers; (b) promote transparency, integrity, and ethical conduct in all Customer-facing activities; (c) ensure full compliance with RBI (Digital Lending) Directions, 2025 and all other Applicable Laws; and (d) foster a culture of accountability, responsible facilitation, and Customer-first service delivery.

Applicability: This Code applies to all employees, directors, officers, agents, representatives, and third-party vendors of the Company engaged in any activity relating to Customer acquisition, onboarding, loan facilitation, servicing support, or collections support. It governs all Company interactions with Customers, Lending Partners, and third-party service providers.

Hierarchy: In the event of any conflict between this Code and Applicable Law, RBI directions, or regulatory guidelines, the regulatory provisions shall prevail. This Code shall be deemed automatically amended to comply with any subsequent regulatory direction without affecting the validity of its remaining provisions.

3. Key Commitments

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The Company makes the following binding commitments to all Customers:

4. Disclosure of Information

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4.1 Key Fact Statement (KFS) — Mandatory Pre-Disbursement Disclosure

The Company shall ensure that a Key Fact Statement (KFS) in the format prescribed under RBI Circular DOR.STR.REC.13/13.03.00/2024-25 dated April 15, 2024 is provided digitally to every Customer before execution of the Loan Agreement. The KFS shall contain, at minimum:

• Interest rate and method of calculation (flat or reducing balance basis)
• All processing fees and other applicable charges
• Annual Percentage Rate (APR) expressed on an annualised basis — reflecting the total cost of credit to the Customer
• Repayment schedule, loan tenure, and EMI structure
• Penal charges for late payment or default (if any)
• Prepayment and foreclosure charges (if any)
• Duration of the Cooling-Off / Look-Up Period
• Name, RBI registration number, and contact details of the Lending Partner

4.2 APR — Annual Percentage Rate

The APR, reflecting the total annualised cost of credit to the Customer, shall be prominently disclosed in the KFS before loan execution. APR disclosure is a mandatory requirement under RBI (Digital Lending) Directions, 2025 and enables informed Customer decision-making.

4.3 Loan Documentation Access

All loan-related documents — including the KFS, sanction letter, Loan Agreement, account statements, and repayment schedule — shall be made accessible to the Customer on their registered email address and/or through the Platform at any time during the loan tenure.

4.4 LSP and Lender Identity Disclosure

The Company shall clearly disclose to every Customer: (a) that it acts as an LSP and NOT as a lender; and (b) the name, RBI registration number, and contact details of the Lending Partner from whom the loan is being availed. This disclosure shall appear prominently on the Platform, in all Customer communications, and in all marketing materials.

4.5 Language and Accessibility

All communications, disclosures, and documents shall be in a language understood by the Customer and presented in a clear, simple, concise, and unambiguous manner. Where required, the Company shall make reasonable efforts to provide communications in vernacular languages.

4.6 No Hidden Charges

The Company shall not impose any charge, fee, or levy on a Customer without prior written disclosure and the Customer's explicit consent. All charges shall be disclosed in the KFS before execution of the Loan Agreement. Any change in fees or charges shall be communicated to Customers prospectively with adequate advance notice and shall not be applied retrospectively.

5. Tariff — Fees, Charges, and Interest Rates

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The Company shall ensure full transparency in disclosing all fees, charges, and interest rates associated with loans facilitated through the Platform.

All applicable charges — including but not limited to interest rate, processing fees, penal charges, and prepayment/foreclosure charges — shall be clearly stated in the KFS and Loan Agreement prior to disbursement. No charge shall be levied without prior disclosure.

The APR, reflecting the total annualised cost of credit, shall be prominently disclosed in the KFS to enable informed Customer decisions.

Fees and interest rates are determined by the Lending Partner. The Company shall communicate these to Customers without modification or misrepresentation.

Any changes in fees, charges, or interest rates shall: (a) be communicated to Customers in advance; (b) apply only to new loan agreements executed after the change takes effect; and (c) not be applied retrospectively to subsisting loan arrangements.

Customers may access the schedule of fees and charges at www.kuvikloans.com, by reviewing the KFS, or by contacting support@kuvikloans.com.

6. Loan Applications and Processing

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6.1 Application Support and Accessibility

The Company shall provide Customers with clear, accurate guidance regarding loan eligibility criteria, documentation requirements, and product features. The application process shall be digitally enabled, secure, accessible, and user-friendly.

6.2 Acknowledgement and Status Updates

Upon submission of a loan application, the Company shall promptly issue an electronic acknowledgement (via email, SMS, or in-app notification). The Company shall provide timely status updates to Customers at each stage of processing.

6.3 Fair and Timely Processing

All loan applications shall be processed in an objective, unbiased, and efficient manner. Where additional documentation is required or processing is delayed, the Customer shall be promptly informed with the reason.

6.4 Rejection Communication

Where a loan application is rejected, the Customer shall be notified of the decision along with such reasons as are permissible to communicate under the Lending Partner's policies and Applicable Law.

6.5 Non-Discrimination

Loan applications shall be assessed on merit based on defined creditworthiness criteria. The Company shall not reject or apply different standards to any application on the basis of gender, religion, caste, race, age, economic status, or any other unlawful ground.

7. Loan Appraisal and Terms and Conditions

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7.1 Objective Credit Assessment

Every loan application shall be assessed based on the Customer's creditworthiness and the Lending Partner's eligibility criteria, including income, repayment capacity, and credit history. The Company may use automated decisioning systems and credit scoring models approved by Lending Partners, in compliance with Applicable Law.

7.2 No Unsolicited Disbursement

The Company shall ensure that no loan is disbursed without an explicit application or request from the Customer. Pre-approved offers, if any, shall be based on predefined credit criteria and shall require the Customer's express written consent before disbursement.

7.3 Cooling-Off / Look-Up Period

In compliance with RBI (Digital Lending) Directions, 2025, every Customer shall be provided a Cooling-Off / Look-Up Period of the duration specified in the KFS. During this period, the Customer may exit the loan by repaying the principal disbursed and interest for the period of actual use, without any prepayment penalty whatsoever. The Cooling-Off Period is a mandatory legal right that cannot be waived or contracted out of.

7.4 Informed Acceptance

The Customer shall be given adequate time and opportunity to review all loan terms — including the KFS and Loan Agreement — before providing consent to proceed. Consent shall be obtained through an explicit, affirmative act. It shall not be inferred from inaction or silence.

7.5 Communication of Approved Terms

Upon approval, the Customer shall receive: (a) a sanction letter specifying the sanctioned amount, annualised interest rate, APR, tenure, EMI, and other material terms; and (b) the KFS as prescribed by the RBI. Both documents shall be accessible at any time during the loan tenure.

8. Marketing Ethics

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The Company shall ensure that all marketing and promotional activities meet the following mandatory standards:

• All marketing and promotional materials shall present information that is accurate, factual, and not misleading regarding the nature, terms, APR, and conditions of loan products and the Company's role as an LSP
• The Company shall clearly disclose in all marketing materials that it acts as an LSP / facilitator and NOT as a lender, and that loans are provided by RBI-regulated Lending Partners
• The Company shall not make exaggerated, false, or deceptive claims about interest rates, APR, loan amounts, approval rates, or eligibility criteria
• The Company shall not guarantee loan approval in any marketing material or sales script
• Marketing materials shall not target Minors (persons below 18 years of age) or financially vulnerable individuals in a predatory manner
• All marketing activities shall comply with the Consumer Protection (E-Commerce) Rules, 2020; ASCI guidelines; TRAI regulations; and Applicable Law
• Third-party marketing representatives shall be contractually required to adhere to these standards
• Unsolicited, bulk, or spam marketing communications shall not be deployed

9. Customer Data and Privacy

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The Company shall handle Customer Personal Information and SPDI in strict accordance with the Privacy Policy (www.kuvikloans.com/privacy-policy), the DPDP Act, 2023, the SPDI Rules, 2011, and all applicable RBI data protection directions.

The Company shall adhere to the following mandatory data protection standards:

• Personal Information and SPDI shall be collected only with the Customer's prior, explicit, granular, and independently revocable consent
• Data shall be used only for the purposes stated in the Privacy Policy and as specifically authorised by the Customer
• Data shall not be shared with unaffiliated third parties for commercial purposes without explicit consent, except as required by Applicable Law
• All data shall be stored on servers located within India, in compliance with RBI data localisation norms and the DPDP Act, 2023
• Appropriate technical (SSL/TLS encryption, AES-256 storage encryption, RBAC, VAPT) and organisational (training, confidentiality agreements) security measures shall be maintained at all times
• Customers have the right to access, correct, and request erasure of their Personal Information in accordance with the DPDP Act, 2023
• In the event of a data breach, affected Customers shall be notified and the incident reported to competent authorities as required by Applicable Law

Customers exercising data rights may contact the Grievance Officer at support@kuvikloans.com.

10. Recovery and Collections Conduct

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Where the Company provides reminder or servicing support to Lending Partners, the following mandatory standards shall apply without exception:

• Recovery activities shall be conducted only through trained and authorised personnel
• All recovery communications shall be made only between 8:00 AM and 7:00 PM local time. No contact of any kind shall be made outside this window, irrespective of the extent or duration of default — this is an absolute RBI-prescribed restriction
• The identity of the representative and their relationship to the Lending Partner and/or the Company shall be disclosed at the commencement of every call or communication
• No harassment, intimidation, coercion, public humiliation, threat of violence, or any form of abusive conduct shall be used in any recovery communication
• Personal information of the Customer (including contact details obtained via device permissions) shall not be used to contact the Customer's family members, employer, or associates for recovery purposes without the Customer's prior specific consent
• All communications shall be made via officially registered and disclosed communication channels only
• Customers have the right to raise disputes regarding recovery communications through the Grievance Officer
• The Company and its Lending Partners shall comply with the RBI's Fair Practices Code for NBFCs and the RBI's Recovery Agent Guidelines

Violations of any recovery conduct standard shall be treated as a serious disciplinary matter and reported to the relevant Lending Partner.

11. Account Operations and Service Standards

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The Company shall ensure the following service standards in Customer account operations:

• Customers shall have secure and reliable access to their loan account information — including outstanding balance, repayment schedule, and transaction history — through the Platform at all times
• Requests for account statements or loan-related documents shall be addressed promptly and without undue delay, at no additional charge
• Customer queries regarding repayments, prepayments, contact detail changes, or account-related matters shall be resolved efficiently through support@kuvikloans.com or the in-Platform support function
• All account operations shall be conducted in a transparent, accurate, and Customer-friendly manner in coordination with the relevant Lending Partner
• Any incorrect account information shall be corrected promptly upon Customer notification

12. General Provisions

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Training: All employees, officers, and authorised representatives involved in Customer-facing activities shall undergo periodic mandatory training covering regulatory requirements, this Code, Customer rights, data privacy standards, and ethical conduct.

Compliance Monitoring: The Company shall periodically monitor adherence to this Code and shall take prompt corrective action upon identifying any deviation or contravention.

Board Oversight: The Board of Directors shall review and reapprove this Code at least annually, or upon any material regulatory change, whichever is earlier.

Amendments: The Company shall amend this Code promptly as required by regulatory developments, RBI directions, or material business changes. The revised Code shall be published on the Platform with the updated effective date and Board approval date.

Conflict Resolution: In the event of any inconsistency between this Code and any RBI direction, guideline, or Applicable Law, the regulatory provision shall prevail. This Code shall be deemed automatically amended to the extent necessary to comply.

13. Grievance Redressal

The Company shall maintain a comprehensive, accessible, and effective grievance redressal mechanism to address Customer complaints within prescribed timelines.

Customers may raise a grievance regarding any of the following:

• Unfair, misleading, or unethical practices by the Company or its representatives
• Mis-selling of loan products or non-disclosure of material terms, including APR or the Cooling-Off Period
• Incorrect, undisclosed, or arbitrary charges or fees
• Recovery communications outside RBI-prescribed hours (8:00 AM to 7:00 PM) or any coercive or abusive conduct
• Breach of data privacy, unauthorised data sharing, or misuse of personal information
• Non-issuance of the KFS before loan execution
• Any other violation of this Code or Applicable Law

Grievance Officer Contact:

All grievances shall be acknowledged within 24 (twenty-four) hours of receipt and resolved within 30 (thirty) days, in compliance with the IT Act, 2000 and applicable Rules. The Grievance Officer may request additional information during investigation. Customers shall receive written communication of the outcome.

14. Governing Law and Jurisdiction

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This Code is governed by the laws of the Republic of India. All disputes arising out of or in connection with this Code shall be subject to the exclusive jurisdiction of the courts of Jaipur, Rajasthan, India.