CORPORATE GOVERNANCE POLICY

Barwala Leasing and Finance Private Limited
(Brand: CASH BOXX)

1. Purpose

The purpose of this Corporate Governance Policy is to establish a framework for effective governance, accountability, transparency, and ethical business practices at Barwala Leasing and Finance Private Limited. The Policy aims to ensure responsible management, safeguard stakeholder interests, and promote compliance with applicable RBI guidelines, the Companies Act, 2013, and other applicable laws.

2. Scope

This Policy applies to the Board of Directors, management, employees, Board committees, and all persons acting on behalf of the Company. It covers all business activities including digital lending under the brand CASH BOXX.

3. Objectives

• Promote sound corporate governance.
• Ensure accountability and transparency.
• Protect stakeholder interests.
• Ensure compliance with laws and RBI regulations.
• Foster ethical conduct.
• Strengthen internal controls and risk management.

4. Governance Principles

The Company shall conduct its business with integrity, transparency, accountability, fairness, regulatory compliance, responsible decision-making, and protection of confidential information.

5. Board of Directors

The Board shall provide strategic direction, approve key policies, oversee financial performance, monitor risk management and internal controls, ensure regulatory compliance, and promote ethical business practices.

6. Management Responsibilities

Management shall implement Board-approved policies, ensure efficient operations, maintain internal controls, manage risks, ensure compliance, and report significant matters to the Board.

7. Compliance and Regulatory Framework

The Company shall comply with RBI guidelines, the Companies Act, 2013, PMLA where applicable, RBI Digital Lending Guidelines, and other applicable laws and regulations. Regular compliance reviews shall be conducted.

8. Risk Management and Internal Controls

The Company shall maintain an effective internal control system to manage credit, operational, compliance, technology, cyber, fraud, and reputational risks.

9. Ethical Conduct

Employees and representatives shall act honestly, avoid conflicts of interest, maintain confidentiality, comply with laws and Company policies, and report unethical or fraudulent activities.

10. Customer Protection

The Company shall ensure fair lending practices, transparent disclosure of loan terms and charges, protection of customer information, timely grievance redressal, and responsible recovery practices.

11. Record Keeping

The Company shall maintain accurate books, records, and documents in accordance with applicable legal and regulatory requirements.

12. Monitoring and Review

This Policy shall be monitored periodically by Management and reviewed annually or whenever required due to regulatory or business changes.

This Policy promotes responsible governance, ethical business conduct, transparency, accountability, and sustainable business practices within Barwala Leasing and Finance Private Limited.