I. PREAMBLE

Sehgal Televisions Private Limited (“the Company”), operating its digital lending business under the brand “Just Rupee”, is a Non-Banking Financial Company registered with the Reserve Bank of India. The Company extends personal loans and other credit facilities to eligible individuals and entities through the Just Rupee digital lending platform.

This Fair Practices Code (“Code”) has been framed with reference to:

1. Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, as amended from time to time;
2. RBI Master Circular / Guidelines on Fair Practices Code for Non-Banking Financial Companies;
3. Guidelines on Digital Lending issued by the Reserve Bank of India, as amended from time to time;
4. The Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023;
5. Any other applicable circular, direction or notification issued by the Reserve Bank of India from time to time.

Any subsequent amendment or clarification issued by the RBI is deemed to form part of this Code to the extent applicable. Where this Code conflicts with law or a regulatory direction, the law or direction prevails.

II.  OBJECTIVES

This Code is intended to:

1. Ethical and Transparent Practices: Build fair, professional and responsible conduct into every stage of the lending relationship, from sourcing and processing through to disbursement, servicing and recovery;
2. Transparency in Disclosure: Give customers clear and adequate information on loan terms, charges, interest rates, repayment obligations and grievance redressal, so they can make an informed choice;
3. Fair and Respectful Customer Relationships: Maintain a respectful, non-discriminatory and trust-based relationship with every borrower;
4. Financial Literacy and Borrower Awareness: Help existing and prospective borrowers understand what borrowing involves, their rights and duties, and how to raise a grievance;
5. Regulatory Compliance: Stay compliant, on an ongoing basis, with all applicable law and RBI direction.

III. SCOPE AND APPLICABILITY

This Code applies uniformly to every product and service offered by Sehgal Televisions Private Limited through the Just Rupee Platform, whether existing today or introduced later, and governs every customer interaction conducted:

1. Through the Just Rupee website and mobile application;
2. By telephone, email, SMS or any other electronic or digital channel;
3. Through any authorised representative or customer service personnel of the Company.

This Code applies to every category of borrower, including a prospective borrower enquiring about Just Rupee’s products, an applicant whose loan is under process or has been declined, and every existing borrower at any stage of the loan.

IV. COMMITMENTS

1. Fairness and Integrity

All business is conducted fairly, honestly and with integrity. Every customer interaction, whether digital, telephonic or otherwise, is professional, non-discriminatory and transparent.

1. Regulatory Compliance

The Company complies fully with applicable law and every direction issued by the RBI and other competent authorities. Every product and service meets the standard set by this Code and by applicable regulatory guidance.

1. Truthful and Responsible Advertising

All advertising and promotional material issued by, or for, the Company is factual, clear and free of misleading or exaggerated claims about loan amount, processing time, or certainty of approval.

1. Transparent Disclosure of Loan Terms

The Company discloses the following clearly in loan documentation and on the Platform:

–    Annualised Rate of Interest (ROI) and Annual Percentage Rate (APR);

–    Whether the interest rate is fixed or floating;

–    Loan tenure and repayment schedule;

–    Frequency, due dates and number of instalments, with the split between principal and interest;

–    Processing fee, documentation charge, insurance charge and any other applicable fee;

–    Penal charge for late repayment or default, shown in bold in the loan agreement;

–    Foreclosure and prepayment terms and any related charge;

–    Any other incidental or service charge.

1. Data Privacy and Confidentiality

Every borrower’s personal, financial and transaction data is collected, stored, processed and shared strictly in line with applicable law, including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and the RBI’s digital lending guidelines, and as set out in the Just Rupee Privacy Policy. Customer data is not shared with a third party without the customer’s consent, except where the law or a regulator requires it. For this clause, “third party” excludes law enforcement agencies, credit information companies, the RBI, and other regulatory or statutory bodies.

1. Staff Training

Employees who deal with customers, including those in sales, collections and support, receive periodic training so that their conduct with borrowers matches the standards set out in this Code.

1. Availability of this Code

This Code is published on the Just Rupee Platform and the Company’s website, and a copy is given to any customer who asks for one, free of cost, electronically or in print.

V.  LOAN APPLICATION AND PROCESSING

1. Language of Communication: Loan application forms, sanction letters, the Key Fact Statement (KFS) and the loan agreement are given in English or Hindi, as applicable under RBI norms. Where a borrower asks for communication in another language, the Company accommodates that request for later communication with that borrower.
2. Loan Application Form Disclosures: The application form discloses every material fact affecting the borrower’s interest, including the indicative range of annualised interest for the loan product, how interest is computed, prepayment options, and all applicable fees, so the borrower can compare Just Rupee’s offer with other lenders before deciding.
3. Document Requirements: The application is accompanied by a clear list of documents needed for verification, underwriting, and KYC / AML compliance, including proof of identity, address and income, and any other document required by regulation.
4. Acknowledgement of Applications: Every loan application is acknowledged, along with an indicative timeframe for disposal. Applications are ordinarily disposed of within 60 (sixty) days of receipt.
5. Communication of Application Status: The borrower is kept informed of the application’s status. At the time an application is accepted, the Company explains the loan process end to end, from origination to sanction and disbursement, with expected timelines for each stage.
   
   VI.  LOAN APPRAISAL, TERMS AND CONDITIONS
   

Credit Evaluation

The Company examines all information and documents submitted by the applicant, and promptly asks for anything further it needs for credit evaluation or risk assessment. Every application is assessed on the applicant’s creditworthiness, credit history, income, repayment capacity and other relevant factors under the Company’s internal credit policy.

Sanction Letter and Key Fact Statement

On sanctioning a loan, and before the loan agreement is signed, the Company communicates the following in writing through a sanction letter and KFS:

–    The sanctioned loan amount;

–    The annualised rate of interest and Annual Percentage Rate (APR);

–    The loan tenure and repayment amount;

–    How interest is computed and applied;

–    Repayment due dates and the split between principal and interest;

–    Whether the rate is fixed or floating, and, for floating rates, the benchmark and reset mechanism;

–    All applicable fees, charges and taxes;

–    Penal charge for late payment or default, expressed per month or per year and shown in bold;

–    Foreclosure and prepayment terms;

–    The cooling-off period available under the digital lending framework.

The borrower’s written or digitally recorded acceptance of the sanction terms is obtained and kept on record.

Copy of Loan Agreement

A copy of the executed loan agreement, with all enclosures and referenced documents, is given to every borrower at sanction or disbursement, by email or other electronic mode, or in physical form, as the borrower prefers and regulation permits.

Rejection of Loan Applications

Where the Company cannot sanction a loan, it will, so far as law and its credit policy allow, try to explain why.

VII. PENAL CHARGES

Any charge for a borrower’s non-compliance with a material loan term is levied strictly as a “penal charge”, never as “penal interest”, and is not added to the principal outstanding or to the effective interest rate. Penal charges are not compounded, so no further interest accrues on an unpaid penal charge.

The amount of a penal charge is reasonable and matched to the seriousness of the non-compliance, applied consistently within a loan or product category. A penal charge on an individual borrower, for a non-business purpose, does not exceed what a non-individual borrower would be charged for the same non-compliance.

The basis and quantum of every penal charge is disclosed in the loan agreement, the KFS, and on the Company’s website. Any reminder sent for non-compliance also states the applicable penal charge, and any actual levy of a penal charge, with reasons, is communicated to the borrower.

VIII. DISBURSEMENT AND CHANGES IN TERMS

Disbursement follows the schedule and terms agreed with the borrower under the loan agreement and sanction letter.

The Company gives the borrower prior written notice, in English, of any change proposed to loan terms, including the disbursement schedule, interest rate, service charge or prepayment terms. Every change to interest rates or charges applies only prospectively, and the loan agreement carries a suitable clause to this effect.

Any decision to recall a loan, accelerate repayment, or demand early performance is taken strictly as the loan documents permit, with adequate prior notice to the borrower.

IX.  DIGITAL LENDING NORMS

Since Just Rupee operates only as a digital lending platform, the Company follows these norms at all times:

Key Fact Statement

A KFS is given to every borrower on execution of the loan agreement, in the standardised format the RBI prescribes, covering at least:

–    The Annual Percentage Rate (APR);

–    Loan amount, tenure and repayment schedule;

–    All fees, charges and taxes;

–    Details of the Grievance Redressal Officer for digital lending complaints;

–    The cooling-off or look-up period available;

–    The applicable recovery mechanism.

Cooling-Off Period

Every borrower may exit the digital loan, without any prepayment penalty, by repaying the principal and proportionate interest within the cooling-off period, which is not less than 1 (one) day. Beyond the cooling-off period, prepayment continues to be allowed as per RBI norms.

Loan Agreement and Communications

The sanction letter is issued on the Company’s letterhead promptly after sanction and before the loan agreement is signed. An executed copy of the loan agreement is sent to the borrower with the welcome communication, or promptly after disbursement.

Disclosure on the Platform

The Just Rupee Platform prominently displays, at onboarding and through the application process:

–    Product features, loan limits and cost structure;

–    The identity of Sehgal Televisions Private Limited as the lender;

–    The KFS applicable to the loan product;

–    Details of the Grievance Redressal Officer and grievance mechanism;

–    This Fair Practices Code.

Reporting Fraud and Suspicious Activity

If a customer notices fraud or suspicious activity using the Just Rupee or Sehgal Televisions name or platform, they are advised to contact the Grievance Redressal Officer at once and report the matter to the RBI through the Sachet portal at https://sachet.rbi.org.in.

X.  POLICY FOR DETERMINING INTEREST AND OTHER CHARGES

The Company’s Board has approved an interest rate model that takes into account:

–    Cost of funds;

–    Margin and target return;

–    Risk premium based on the borrower category’s credit profile;

–    Regulatory requirements and market benchmarks.

The rate of interest, the basis for risk gradation, and the reasoning for charging different borrower categories different rates are disclosed in the loan application form and communicated in the sanction letter and KFS. All rates are expressed on an annualised basis so borrowers know exactly what applies to their account, and the rates and risk-gradation approach are also published on the Company’s website and updated whenever they change.

The Company does not levy any hidden charge, or any unapproved fee disguised as interest or a service charge. Every charge is consistent with the Board-approved interest rate policy.

The Company does not charge foreclosure or prepayment penalties on floating-rate term loans given to individual borrowers for non-business purposes.

XI.  COLLECTION OF DUES

At the time of sanction, the Company explains the repayment process to the borrower, including instalment amount, tenure, due dates, bounce charges and penal charges for late payment.

Where a borrower falls behind on the agreed schedule, recovery follows applicable law and accepted industry practice, and may include:

–    Written or electronic reminders and notices;

–    Follow-up by phone or personal visit from an authorised representative;

–    Enforcement of any security interest, as the loan agreement provides.

Where security is involved, the loan agreement sets out:

–    The notice period before possession is taken;

–    Any circumstance in which that notice period may be waived;

–    The process for taking possession of the secured asset;

–    The borrower’s right to repay all dues before the asset is sold or auctioned;

–    The process for returning a repossessed asset to the borrower, where applicable;

–    The process for sale or auction of the secured property.

The Company, and anyone acting for it in recovery, follows these standards:

–    Contact with borrowers only between 8:00 a.m. and 7:00 p.m., unless the borrower’s circumstances need otherwise;

–    Contact at the place of the borrower’s choice; failing a stated preference, at the borrower’s residence or, if unavailable, place of business;

–    Disclosure of the representative’s identity and authority at first contact;

–    No intimidation, coercion, harassment or abusive language, spoken or written;

–    No threatening, anonymous or repeated calls, and no contact with family, referees or associates in a way that causes embarrassment or distress;

–    No inappropriate message by phone, email or social media;

–    No false or misleading claim, including posing as police, a court official or a government authority;

–    Honouring, so far as reasonably possible, a borrower’s request to avoid calls at certain times or places;

–    No visit on an inappropriate occasion, such as a bereavement or other difficult event in the borrower’s household;

–    Confidentiality of borrower information at all times.

Every recovery representative, whether an employee or an outsourced agent, receives periodic training so that recovery stays dignified, civil and lawful, and the Company takes suitable disciplinary action against anyone who departs from these standards.

XII. NON-DISCRIMINATION

The Company does not discriminate against a borrower or applicant on the basis of gender, caste, religion, region, marital status, disability or any similar ground. Every applicant is assessed only on financial merit, creditworthiness and risk, under the Company’s Board-approved credit policy.

XIII. GENERAL PROVISIONS

1. The Company does not interfere in a borrower’s personal or business affairs, except to verify information given in the loan application, monitor repayment, meet a statutory duty, or look into material information the borrower had not earlier disclosed.
2. Where a borrower asks for the loan account to be transferred, the Company communicates its consent or objection within 21 (twenty-one) days of the request, and any transfer follows transparent, lawful terms.
3. All customer information is kept strictly confidential, and shared with a third party only as law, regulation or the customer’s written consent permits.
4. Every communication, acceptance and amendment concerning the loan is in writing, and preserved for at least 10 (ten) years.
5. The Company gives genuine cases of financial hardship fair consideration, and encourages borrowers facing repayment difficulty to reach out early.

XIV. GRIEVANCE REDRESSAL MECHANISM

Just Rupee maintains a Grievance Redressal Mechanism (“GRM”), approved by the Board of Directors, so that a dispute over any decision of the Company’s staff is heard, and if unresolved, escalated to the next level. The Company’s separate Grievance Redressal Policy sets out this mechanism in full; its key features are:

Level 1

For a service request or complaint, write to the customer engagement team at care@justrupee.com. An acknowledgement follows within 3 (three) working days, by email, letter, SMS, WhatsApp or another valid electronic mode, and the Company aims to resolve the matter within 7 (seven) working days, though a complaint needing detailed investigation, the customer’s help in identifying the person responsible, root-cause analysis, or one under litigation (including with the police) may reasonably take longer.

Level 2

If the complaint stays unresolved after 7 days, or the response is unsatisfactory, write to the Grievance Redressal Officer at gro@justrupee.com. The Company aims to resolve such matters within a further 7 working days. If dissatisfied with the GRO’s decision or its rejection of the complaint, the customer may appeal within 30 days to the Consumer Education and Protection Department, Reserve Bank of India, or lodge a complaint through the RBI’s CMS portal at https://cms.rbi.org.in, or, for fraud or unregulated entities, the Sachet portal at https://sachet.rbi.org.in.

The Company follows the Reserve Bank – Integrated Ombudsman Scheme, 2021, in full. A complaint under the Scheme may be filed:

–    Online, through the Integrated Ombudsman portal at https://cms.rbi.org.in;

–    By email, to CRPC@rbi.org.in;

–    In physical form, at the Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160017;

–    Through the toll-free helpline 14448 (9:30 a.m. to 5:15 p.m.), in Hindi, English and regional languages.

XV.  REVIEW OF THE FAIR PRACTICES CODE

This Code is reviewed, and revised where necessary, by the Board of Directors at least once a year, or whenever the law shows a regulatory direction, or the Company’s business changes. Any resulting change to RBI Master Directions or other applicable rules is built into this Code and approved by the Board at the earliest opportunity. Where this Code conflicts with law or a regulatory direction, the law or direction prevails.

ANNEXURE A – CODE OF CONDUCT FOR RECOVERY PERSONNEL

Every person authorised to collect or recover loan dues on the Company’s behalf, whether an employee or an outsourced agent, follows this Code of Conduct:

1. Every member of the collection team, and every authorised agent, follows this Code diligently.
2. Customer confidence, long-term relationships, and the customer’s dignity and respect are maintained at all times.

     3. Recovery relies on courtesy, fair treatment and persuasion; unduly coercive methods are never used.
     4. Fairness and transparency govern repossession, valuation and realisation of security.

     5. Customers are contacted at their preferred place; absent a stated preference, at their residence or, failing that, place of business or occupation. Every visit is conducted with decency and decorum.

     6. The recovery representative’s identity and authority are disclosed to the customer at the outset.

     7.  There is no interference in the customer’s personal affairs; every interaction is civil and free of force or coercion.

     8.  Representatives contact customers only between 8:00 a.m. and 7:00 p.m., unless the customer’s business or occupation requires otherwise.

     9. A customer’s request to avoid calls at a given time or place is honoured so far as reasonably possible.

     10. Customers are given full information about outstanding dues, with enough notice to enable payment.

     11. Reasonable notice is given before security is repossessed and before it is realised.

     12. Disputes over dues are resolved, so far as reasonably possible, in a fair and orderly way.

     13. Calls or visits are avoided on inappropriate occasions, such as a bereavement or similar event in the family.

    14. Customer information remains confidential at all times.

    15.  No inappropriate message is sent by phone, email or social media.

    16.  No false or misleading claim is made to a customer; no representative poses as a police officer, court official or government authority, or falsely claims legal or criminal proceedings have begun.

    17.  All communication about collection or recovery is through the contact details the customer has provided.