Grievance Redressal Policy

• aRBI Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016.
• bRBI (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023.
• cRBI (Digital Lending) Directions, 2025.
• dRBI (NBFC – Responsible Business Conduct) Directions, 2025.
• eRBI Integrated Ombudsman Scheme, 2021.
• fConsumer Protection Act, 2019.
• gInformation Technology Act, 2000 (as amended).

This Policy establishes a structured, transparent, and time-bound grievance redressal mechanism for all customers of Crestmont Capital Pvt. Ltd. accessing financial services through its digital lending platform Askrupee.

The Policy aims to:

• aEnsure every customer complaint is acknowledged, investigated, and resolved within defined timelines.
• bProtect customer rights and promote fair treatment in all lending interactions.
• cMaintain a robust escalation framework including Grievance Redressal Officer (GRO), Internal Ombudsman (where applicable), and RBI Ombudsman.
• dFulfill the Company's regulatory obligations under applicable RBI Directions and Schemes.
• eBuild customer trust through accountability, transparency, and continuous improvement.

This Policy applies to:

• aAll individual and retail borrowers who have applied for or availed personal loans through the Askrupee platform.
• bAll employees, agents, recovery agents, DSAs, and third-party service providers acting on behalf of the Company.
• cAll complaints received via email, phone, app, website, written correspondence, or walk-in.
• dAll stages of the loan lifecycle — application, disbursement, repayment, closure, and post-closure.

This Policy does not cover disputes related to third-party products or services not offered directly by the Company, or matters sub-judice before any court or tribunal.

Customers may register their complaints through any of the following channels:

In compliance with RBI (NBFC – Responsible Business Conduct) Directions, 2025, the Company shall prominently display the following on its website and Askrupee app:

• aName, designation, and contact details of the Grievance Redressal Officer (GRO).
• bComplaint registration process and channels.
• cExpected turnaround time (TAT) for resolution.
• dEscalation path including RBI Ombudsman details.
• eLink to the RBI Sachet Portal: sachet.rbi.org.in.

The GRO shall be a senior officer not below the rank of Deputy Manager / equivalent, appointed by the Board. The GRO's details shall be updated on the RBI portal as required.

8.1 Board Oversight

• aThe Board of Directors approves this Policy and any amendments thereto.
• bThe Board receives a quarterly grievance redressal report including complaint volume, TAT compliance, root cause analysis, and systemic issues identified.
• cThe Audit Committee reviews the effectiveness of the grievance mechanism annually.

8.2 Grievance Redressal Officer (GRO)

• aThe GRO is responsible for overseeing the complaint management system, ensuring TAT compliance, and reporting to senior management.
• bThe GRO coordinates with relevant departments (credit, operations, collections, technology) to investigate and resolve complaints.
• cThe GRO maintains a Complaint Register with complete details of each complaint, actions taken, and final resolution.

8.3 Management Review

• aMonthly review of complaint data by the Compliance Officer to identify trends, recurring issues, and process gaps.
• bCorrective action plans for systemic issues to be implemented within 30 days of identification.
• cAnnual policy review by the Board or whenever triggered by regulatory change, significant complaints volume, or customer feedback.

8.4 Third-Party Accountability

• aAll LSPs, DSAs, and recovery agents are contractually bound to comply with this Policy.
• bComplaints arising from the conduct of third parties shall be treated as complaints against the Company and resolved within the same TAT framework.
• cThe Company retains primary accountability for all customer interactions regardless of which entity executed them.

9.1 Customer Rights

• aEvery customer has the right to register a complaint without fear of retaliation or adverse treatment on their loan account.
• bCustomers shall be informed of the status of their complaint at every stage of escalation.
• cCustomers shall receive a written final resolution with reasons, and information about further escalation options if unsatisfied.

9.2 Non-Retaliation

• aNo action shall be taken against a borrower solely on account of a complaint filed against the Company or its agents.
• bLoan decisions, collection activities, or account management shall not be negatively influenced by the pendency of a grievance.

9.3 Communication Standards

• aAll communication with customers regarding their complaints shall be in plain language, free of jargon.
• bResolution letters shall clearly state: the outcome, reason for decision, and next escalation steps if applicable.
• cThe Company shall not use threatening, misleading, or coercive language in any complaint-related communication.

9.4 Special Categories

• aComplaints from senior citizens, differently-abled customers, or customers in financial distress shall be treated with additional sensitivity and priority.
• bRegional language support shall be provided where operationally feasible.

10.1 In-App Complaint Mechanism

• aThe Askrupee app shall maintain a dedicated, easy-to-access complaint registration flow accessible from the main menu.
• bAutomated acknowledgement with CRN shall be generated immediately upon complaint submission.
• cComplaint status tracking shall be available within the app in real time.

10.2 Cooling-Off Period Complaints

• aComplaints related to loan cancellation within the cooling-off period shall be treated with highest priority (Level 2 TAT: 3 working days).
• bNo penalty shall apply for cancellations within the 3-day cooling-off window as required by RBI Digital Lending Directions, 2025.

10.3 Data and Privacy Complaints

• aComplaints related to unauthorized data access, data sharing, or privacy violations shall be escalated immediately to the Compliance Officer and Data Protection Officer.
• bSuch complaints shall be resolved within 7 calendar days and reported to the Board.

10.4 LSP-Related Complaints

• aComplaints against Lending Service Providers (LSPs) shall be registered, investigated, and resolved by the Company as if they were direct complaints.
• bThe Company retains full accountability for LSP conduct under RBI Digital Lending Directions, 2025.

11.1 Complaint Register

• aA centralized Complaint Register shall be maintained in digital format capturing: CRN, date of receipt, customer details, nature of complaint, channel, TAT, status, final resolution, and root cause.
• bRecords shall be retained for a minimum of 5 years from complaint closure.

11.2 MIS Reporting

• aMonthly MIS report to be prepared by GRO covering: total complaints received, resolved within TAT, pending, escalated, root cause categories, and repeat complaints.
• bQuarterly grievance report to be placed before the Board.
• cAnnual summary to be filed with RBI as per applicable reporting requirements.

11.3 Trend Analysis

• aComplaint data shall be analysed for recurring themes, seasonal spikes, or product-specific issues.
• bInsights from trend analysis shall feed into product improvement, training programs, and policy updates.

11.4 Audit Trail

• aAll complaint-related communications, escalations, and resolutions shall be logged with timestamps and officer identifiers.
• bThe audit trail shall be available for internal audit, regulatory inspection, and ombudsman review.

The following matters are outside the scope of this Policy's grievance mechanism:

Policy Code: ATFPL/GRM/2026-27/02 | Version 1.0 | © 2026 Crestmont Capital Pvt. Ltd. All rights reserved.