Collection and Recovery Policy

• aReserve Bank of India (Digital Lending) Directions, 2025 and all subsequent amendments.
• bReserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025, updated directions and fair practices requirements applicable to NBFCs.
• cRBI directions on Key Facts Statement, Annual Percentage Rate, penal charges, grievance redressal, outsourcing, recovery agents, credit information reporting, KYC/AML, cyber security and customer protection.
• dCompanies Act, 2013, Information Technology Act, Digital Personal Data Protection framework, Contract Act, consumer protection laws and any other applicable law.

The purpose of this Policy is to establish a comprehensive, transparent, borrower-protective and regulator-ready framework for collection and recovery of Crestmont Capital Pvt. Ltd. The Policy is designed for digital lending through Askrupee, website publication, internal governance, LSP/DLA control, audit review and Board oversight.

This Policy is deliberately detailed so that business, compliance, technology, recovery, customer service, legal and audit teams can operate from a common control framework and avoid informal practices that may create regulatory, conduct, data, customer protection or reputational risk.

• aAll directors, KMPs, employees and officers of the Company.
• bAll digital lending journeys, including Askrupee and any web/app/API channel.
• cAll outsourced service providers, LSPs, DLAs, collection agencies, technology vendors, call centres, API partners and processors.
• dAll borrowers, applicants, co-applicants, references and customer data subjects to the extent applicable.
• eAll loan lifecycle stages: marketing, application, KYC, underwriting, sanction, KFS, disbursement, servicing, repayment, collection, closure and complaint handling.

This section establishes detailed operating expectations for recovery philosophy under the Crestmont Capital Pvt. Ltd. policy framework. It shall be implemented through SOPs, system controls, employee training, LSP contractual obligations and periodic compliance testing.

• aRecovery shall be lawful, dignified, evidence-based and proportionate.
• bRecovery targets shall not justify unethical behaviour.
• cAgents shall not humiliate borrowers or contact relatives/employers except in legally permissible and consented/contractual circumstances.
• dBorrowers in hardship may be offered structured communication, settlement or restructuring as per policy.

This section establishes detailed operating expectations for permitted and prohibited conduct under the Crestmont Capital Pvt. Ltd. policy framework.

• aCalls shall be made only within permitted hours (8:00 AM – 7:00 PM) and within approved frequency limits.
• bThreats, abusive language, fake legal notices, police impersonation, social media shaming and coercion are strictly prohibited.
• cScripts suggesting that borrowers should take another app loan to repay existing dues are prohibited.
• dField visits and cash collection shall only be permitted as per Board-approved SOP with documented authorisation.

This section establishes detailed operating expectations for recovery agency management under the Crestmont Capital Pvt. Ltd. policy framework.

• aAll recovery agencies engaged by the Company shall be maintained in a Board-approved list with due diligence records, contract terms, and performance history.
• bAgents must be trained, identity-card enabled and actively monitored for compliance with this Policy.
• cComplaints against agents shall be investigated by Company compliance within 7 working days; substantiated complaints shall result in disciplinary action or termination.
• dLegal recovery proceedings shall proceed only after proper legal notice and adequate documentation of default and communication attempts.

8.1 Board Ownership

The Board shall own this Policy, approve material changes, monitor management implementation and ensure that the Company does not operate any product, channel or partner arrangement in a manner inconsistent with RBI directions. The Board may delegate day-to-day monitoring to a committee or senior management; however, regulatory accountability remains with the Company.

8.2 Management Responsibility

Senior management shall convert this Policy into SOPs, process notes, system controls, maker-checker workflows, vendor obligations, employee training, audit programmes and exception reporting. Each business owner shall ensure that operational teams and LSPs follow the approved policy without informal deviations.

8.3 Three Lines of Defence

The first line shall operate the process, the second line comprising compliance/risk/legal shall independently review design and exceptions, and the third line comprising internal audit shall test adequacy and effectiveness. Material gaps shall be escalated with corrective action timelines.

8.4 Policy Review

This Policy shall be reviewed at least yearly and earlier upon any RBI circular, product change, technology change, LSP onboarding, adverse audit observation, material complaint trend, data incident or Board direction.

9.1 Customer-first Standards

All borrower communication shall be transparent, fair, non-misleading and in a language understood by the borrower. The customer shall not be pressurised through dark patterns, hidden charges, pre-selected options, forced consent or difficult exit flows.

9.2 Disclosure Standards

The Company shall disclose lender identity, NBFC status, non-deposit taking nature, product terms, interest, APR, fees, taxes, penal charges, cooling-off rights, grievance contacts, LSP/DLA involvement and repayment schedule before loan acceptance.

9.3 Consent Standards

Consent must be specific, informed, purpose-linked, revocable where permissible, separately recorded and preserved in a retrievable audit trail. Bundled consent or silence shall not be treated as valid consent for sensitive actions.

9.4 Vulnerable Borrowers

Teams shall exercise additional care for borrowers who appear distressed, financially vulnerable, digitally inexperienced, elderly or otherwise unable to understand consequences. Such borrowers shall not be pushed into repeat loans or refinancing merely for collection targets.

10.1 Digital Lending App Governance

Askrupee and any other DLA shall be governed as a regulated digital lending interface of the Company. The app journey shall not misrepresent approval status, conceal charges, access prohibited device data or allow LSPs to control loan decisions outside Company-approved rules.

10.2 Fund-flow Control

Loan disbursement and repayment must flow directly between the Company and borrower/end-beneficiary except as expressly permitted. LSP pool accounts, pass-through accounts or informal collections are not permitted.

10.3 LSP Accountability

The Company remains responsible for outsourced activities. Every LSP shall be subject to due diligence, contract controls, customer conduct obligations, data processing restrictions, audit rights, complaint reporting, termination rights and periodic performance review.

10.4 Prohibited Data Access

The app shall not access contact list, call logs, file/media, telephony functions or other intrusive device resources. Any camera, microphone or location access shall be one-time or need-based, disclosed clearly and supported by consent.

11.1 Record Keeping

The Company shall maintain records of applications, KYC, bureau pulls, underwriting outputs, KFS, consent logs, sanction terms, disbursement, repayment, complaints, recovery actions, notices, settlement, closure and audit trails for the prescribed retention period.

11.2 Evidence Quality

Every important customer action shall be evidenced through timestamp, user identifier, IP/device metadata where lawful, document hash/version, OTP/e-sign trail, communication log and maker-checker approval as applicable.

11.3 MIS and Exception Reporting

Monthly MIS shall include loan volumes, pricing, complaints, TAT, recovery exceptions, LSP breaches, data incidents, cooling-off cancellations, NPA movement, write-offs, fraud alerts and regulatory exceptions.

11.4 Audit Readiness

Policies, SOPs, logs, Board approvals, contracts, training records, system screenshots and exception closures shall be maintained in a form suitable for statutory audit, internal audit, RBI inspection and management review.

Policy Code: ATFPL/CRP/2026-27/04 | Version 1.0 | © 2026 Crestmont Capital Pvt. Ltd. All rights reserved.