FAIR PRACTICES CODE (FPC)

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

Barwala Leasing and Finance Private Limited (referred to below as the “Company”), operating under the brand name Cash Boxx, is a Non-Banking Financial Company registered with the Reserve Bank of India. It operates as a digital lender, extending personal loans and other credit facilities to eligible individuals through the Cash Boxx platform.

This Fair Practices Code (“FPC” or “Code”) has been drawn up in line with:

1. the Master Direction, Reserve Bank of India (Non-Banking Financial Company, Scale Based Regulation) Directions, 2023, as amended from time to time;
2. the RBI’s Master Circular on Fair Practices Code for NBFCs dated July 1, 2015;
3. the RBI’s Guidelines on Digital Lending dated September 2, 2022, as amended from time to time; and
4. every other applicable circular, direction, and notification the Reserve Bank of India issues from time to time.

Any later amendment, clarification, or direction the RBI issues is treated as forming part of this Code, to the extent it applies. Where this Code conflicts with applicable law or a regulatory direction, the law or direction will prevail.

2. Objectives

This Code has been drawn up with the following objectives:

1. Ethical and Transparent Practices: to build fair, professional, and responsible conduct into every customer interaction, across the entire lending lifecycle, from sourcing and processing through to disbursement, servicing, and recovery.
2. Transparency in Disclosure: to make sure customers get clear, understandable, and adequate information about loan terms, charges, interest rates, repayment obligations, and grievance redressal, so they can make informed financial decisions.
3. Fair and Respectful Customer Relationships: to build and hold on to a respectful, non-discriminatory, trust-based relationship with every borrower, grounded in equity, integrity, and dignity.
4. Financial Literacy and Borrower Awareness: to help existing and prospective borrowers understand what borrowing involves, what their rights and responsibilities are, and how they can seek redressal for a grievance.
5. Regulatory Compliance: to comply fully and continuously with every applicable law, regulation, and direction the Reserve Bank of India and other competent authority’s issue.

3. Scope and Applicability

This Code applies uniformly to every product and service Barwala Leasing and Finance Private Limited offers through the Cash Boxx platform, whether existing on the date of this Code or introduced afterwards. It governs every customer interaction carried out:

1. through the Cash Boxx digital lending platform and mobile application;
2. by telephone, email, SMS, or any other electronic or digital channel; and
3. through any authorized field representative or customer service staff of the Company.

This Code applies to every category of borrower: prospective borrowers enquiring about the Company’s products, applicants whose loan applications are being processed or have been declined, and existing borrowers at every stage of the loan lifecycle.

4. Commitments

The Company holds itself to high standards of integrity, fairness, and professionalism. The following principles govern all its dealings with customers.

1. Fairness and Integrity

Every business dealing is conducted fairly, honestly, and with integrity. Every customer interaction, whether digital, telephonic, or otherwise, is carried out professionally, without discrimination, and transparently.

1. Regulatory Compliance

The Company complies fully with every applicable law, rule, regulation, and direction the Reserve Bank of India and other competent authorities’ issue. Every product and service offered meets the standards set out in this Code and applicable regulatory guidance.

1. Truthful and Responsible Advertising

Every advertisement, marketing material, and promotional communication issued by or on behalf of the Company is factual, clear, and free of misleading claims or ambiguous terms. The Company does not exaggerate claims about loan amounts, processing times, or the certainty of approval.

1. Transparent Disclosure of Loan Terms

The Company maintains transparency in every communication about its products and services. The following are disclosed clearly in all loan documentation and on the Company’s official platform:

1. the annualized rate of interest (ROI) and Annual Percentage Rate (APR);
2. whether the interest rate is fixed or floating;
3. loan tenure and the repayment schedule;
4. the frequency, due dates, and number of instalments, with the split between principal and interest;
5. processing fees, documentation charges, insurance charges, and any other applicable fee;
6. penal charges for late repayment or default, highlighted clearly in bold in the loan agreement;
7. foreclosure and prepayment terms and any applicable charge; and
8. any other incidental or service-related fee.
9. Data Privacy and Confidentiality

Every borrower’s personal, financial, and transactional information is collected, stored, processed, and disclosed strictly in accordance with applicable law, including the Information Technology Act, 2000, and the RBI’s digital lending guidelines. Customer information is not shared with a third party without that customer’s express prior consent, except where the law or a regulatory direction requires it. For this purpose, “third party” does not include law enforcement agencies, credit information companies, the RBI, or other regulatory or statutory bodies.

1. Staff Training

Every customer-facing employee, including staff engaged in sales, collections, and customer support, receives periodic training so that their interactions with borrowers reflect the ethical standards, service expectations, and regulatory requirements this Code sets out.

1. Public Availability of This Code

This Fair Practices Code is available on the Company’s official website and on the Cash Boxx platform. A copy is provided to any customer who asks for one, free of charge, in electronic or physical form.

5. Loan Application and Processing

1. Language of Communication: every communication with a borrower, including the loan application form, sanction letter, Key Fact Statement (KFS), and loan agreement, is given in English or Hindi as RBI guidelines require. Where a borrower asks for communication in another language, the Company accommodates that preference for its later communications with that borrower.
2. Loan Application Form Disclosures: the loan application form discloses every material fact affecting the borrower’s interest, including the indicative range of the annualized interest rate for the relevant loan product, how interest is computed, prepayment options, and every applicable fee and charge, so the borrower can compare the Company’s offering with other lenders’ and make an informed choice.
3. Document Requirements: the loan application process comes with a clear checklist of the documents needed for verification, underwriting, and KYC/AML compliance, including proof of identity, address, income, and any other document a regulatory norm requires.
4. Acknowledgement of Applications: the Company acknowledges every loan application it receives and gives an indicative timeframe for disposing of it. Applications are ordinarily disposed of within 60 (sixty) days of receipt.
5. Communication of Application Status: the Company keeps the borrower informed of their application status as needed. When accepting an application, the Company explains the whole loan process, from origination through sanction to disbursement, including the expected timeline for each stage.

6. Loan Appraisal and Terms and Conditions

Credit Evaluation

The Company examines all information and documentation an applicant submits. Where it needs more information for credit evaluation or risk profiling, it promptly tells the applicant. Every application is assessed on the applicant’s creditworthiness, credit history, income, repayment capacity, and other relevant factors, in line with the Company’s internal credit policy.

Sanction Letter and Key Fact Statement

On sanctioning a loan, the Company, through a sanction letter and Key Fact Statement (KFS), tells the borrower in writing, before the loan agreement is executed:

1. the sanctioned loan amount;
2. the annualized rate of interest and the Annual Percentage Rate (APR);
3. the loan tenure and the repayment amount;
4. how interest is computed and applied;
5. the exact repayment due dates and the split between principal and interest;
6. whether the interest rate is fixed or floating, and, for a floating rate, the benchmark rate and reset mechanism;
7. every fee, charge, and tax applicable to the loan;
8. penal charges for late repayment or default, shown as a percentage per month or per annum and highlighted clearly in bold;
9. foreclosure and prepayment terms and any applicable condition; and
10. the cooling-off period available to the borrower under the digital lending framework.

The Company obtains and keeps on record the borrower’s written or digitally recorded acceptance of the sanction terms.

Copy of Loan Agreement

At the time of sanction or disbursement, the Company gives every borrower a copy of the executed loan agreement, along with every enclosure and document it refers to. These may be shared digitally, by email or another electronic format, or physically, according to the borrower’s preference and applicable regulatory requirements.

Rejection of Loan Applications

Where the Company cannot sanction a loan, it will try to explain why, to the extent applicable law and its internal credit policy allow.

7. Penal Charges

Any penalty levied because a borrower has not complied with a material term of the loan agreement is charged strictly as a “penal charge”, not as “penal interest”. Penal charges are never added to the outstanding principal or to the effective interest rate, and they are never capitalized, meaning no further interest is charged on unpaid penal charges.

The amount of any penal charge is reasonable and proportionate to how serious the non-compliance is and is applied without discrimination within a given loan or product category. Penal charges applied to individual borrowers, for purposes other than business, will not exceed those applied to non-individual borrowers for similar non-compliance.

The amount and basis of every penal charge is disclosed clearly in the loan agreement, the KFS, and on the Company’s official website. Whenever a reminder is sent to a borrower about non-compliance, the applicable penal charge is communicated along with it. Any instance where a penal charge is levied, and the reason for it, is communicated to the borrower.

8. Disbursement of Loans and Changes to Terms and Conditions

Loans are disbursed according to the disbursement 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 proposed change to the loan’s terms and conditions, including a change to the disbursement schedule, interest rate, service charges, or prepayment conditions. Every change to interest rates and charges takes effect only prospectively, and the loan agreement includes a suitable clause for this effect.

Any decision by the Company to recall a loan, accelerate repayment, or demand early performance under the loan agreement is taken strictly under the loan documentation, and the borrower is given adequate prior notice before any such step is taken.

9. Digital Lending Norms

The Company operates exclusively through the Cash Boxx digital lending platform and follows these digital lending norms at all times.

Key Fact Statement

Every borrower receives a Key Fact Statement (KFS) when the loan agreement is executed. The KFS follows the standardized format the RBI prescribes and includes, at a minimum:

1. the Annual Percentage Rate (APR);
2. the loan amount, tenure, and repayment schedule;
3. every fee, charge, and tax applicable to the loan;
4. details of the Grievance Redressal Officer designated to handle digital lending complaints;
5. the cooling-off or look-up period available to the borrower; and
6. the recovery mechanism applicable to the loan.

Cooling-Off Period

Every borrower has an explicit option to exit the digital loan, without any prepayment penalty, by repaying the principal and proportionate interest during the cooling-off period. Cash Boxx offers a cooling-off period of 3 (three) days from the date of disbursement. Borrowers who continue with the loan beyond the cooling-off period may prepay it in line with applicable RBI guidelines.

Loan Agreement and Communications

The sanction letter is issued on Barwala Leasing and Finance Private Limited’s letterhead immediately on sanction and before the loan agreement is executed. An executed copy of the loan agreement is sent to the borrower as an attachment to the welcome communication, or promptly after disbursement.

Disclosure on the Platform

The Cash Boxx platform prominently displays, at onboarding and throughout the application process:

1. product features, loan limits, and cost structure;
2. the identity of Barwala Leasing and Finance Private Limited as the lender;
3. the applicable KFS for the relevant loan product;
4. details of the Grievance Redressal Officer and the grievance redressal mechanism; and
5. the Company’s Fair Practices Code.

Reporting Fraud and Suspicious Activity

If a customer notices fraud or suspicious activity carried out using the Cash Boxx name, identity, or platform, they are advised to contact the Grievance Redressal Officer immediately and to report the platform or application to the RBI through the Sachet portal at https://sachet.rbi.org.in.

10. Policy for Determining Interest Rate and Other Charges

The Board of Directors has adopted a Board-approved interest rate model to determine the interest rate and other charges applicable to the Company’s loan products. The model factors in:

1. the cost of funds;
2. margin and target return;
3. a risk premium based on the borrower category’s credit risk profile; and
4. regulatory requirements and market benchmarks.

The interest rate, the approach to grading risk, and the reasoning behind charging different rates to different borrower categories are disclosed in the loan application form and communicated explicitly in the sanction letter and KFS.

Every interest rate is expressed as an annualized rate, so borrowers know exactly what applies to their loan account. The interest rates and the risk-grading approach are also published on the Company’s official website and updated whenever they change.

The Company does not levy any hidden charge or 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 charges or prepayment penalties on floating rate term loans given to individual borrowers for purposes other than business.

11. Collection of Dues

At the time a loan is originated, the Company clearly explains the repayment process to the borrower, including the instalment amount, repayment tenure, due dates, bounce charges, and penal charges for late payment.

Where a borrower does not keep to the agreed repayment schedule, the Company pursues recovery strictly in line with applicable law and industry best practice. Recovery methods may include:

1. written or electronic reminders and notices;
2. follow-up by phone or personal visit from an authorized representative; and
3. enforcement of any security interest, where applicable, under the loan agreement’s terms.

Where security is enforced or repossessed, the loan agreement clearly sets out:

1. the notice period required before possession is taken;
2. any circumstance in which that notice period may be waived;
3. the procedure for taking possession of secured assets;
4. the borrower’s right to repay all dues before the secured asset is sold or auctioned;
5. the procedure for returning a repossessed asset to the borrower, where applicable; and
6. the procedure for selling or auctioning the secured property.

The Company, and everyone authorized to act for it in recovery, strictly follows these standards of conduct:

1. recovery agents contact borrowers only between 8:00 a.m. and 7:00 p.m., unless a borrower’s specific circumstances call for otherwise;
2. customers are contacted at the place of their choice; where no preference is given, contact is made at the borrower’s residence or, failing that, their place of business;
3. a recovery representative’s identity and authority are made known to the borrower at first contact;
4. no recovery representative uses intimidation, coercion, harassment, or abusive language, verbal or written;
5. no recovery representative makes threatening, anonymous, or persistent calls, or contacts a borrower’s family, referees, or associates in a way that causes embarrassment or distress;
6. no recovery representative sends inappropriate messages by mobile, email, or social media;
7. no recovery representative makes a false or misleading representation, including posing as a police officer, court official, or government authority;
8. a borrower’s request to avoid calls at particular times or places is honoured wherever reasonably possible;
9. visits are not made on inappropriate occasions, such as a bereavement or other difficult event in the borrower’s household; and
10. borrower information is kept confidential at all times.

Every recovery employee or agent, whether in-house or outsourced, receives periodic training so recovery is carried out with dignity, civility, and lawfully. The Company takes appropriate disciplinary action against any representative who breaches these principles.

12. Non-Discrimination

The Company does not discriminate against any borrower or applicant on the basis of gender, caste, religion, region, marital status, physical ability, or any other ground. Every applicant is assessed purely on financial merit, creditworthiness, and risk factors, in line with the Company’s Board-approved credit policy.

13. 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 performance, meet a statutory obligation, or look into material information the borrower had not earlier disclosed;
2. where a borrower asks for their loan account to be transferred, the Company communicates its consent or objection within 21 (twenty-one) days of receiving that request, and any such transfer follows transparent contractual terms consistent with applicable law;
3. every piece of customer information is treated as strictly confidential and is not shared with a third party except as the law, a regulatory direction, or the customer’s prior written consent requires;
4. every communication, acceptance, and amendment relating to a loan facility is in writing and is kept for at least 10 (ten) years; and
5. the Company gives genuine cases of financial difficulty appropriate consideration, and encourages borrowers facing repayment trouble to reach out proactively at the earliest opportunity.

14. Grievance Redressal Mechanism

The Company has set up a Grievance Redressal Mechanism (“GRM”), approved by its Board of Directors, that makes sure any dispute arising from a decision of the Company’s staff is heard and disposed of at the next higher level. This mechanism operates over three levels.

Level 1: Customer Support

For any service request or complaint, contact the customer engagement team at care@cashboxx.in or call +91 8796466311. The Company acknowledges every request or complaint within 3 (three) working days and aims to resolve it within 7 (seven) working days, though a complaint that needs extensive investigation, the customer’s help identifying a wrongdoer, a root-cause analysis, or is under litigation may reasonably take longer.

Level 2: Grievance Redressal Officer

If your complaint stays unresolved 7 days after reaching Level 1, or you are dissatisfied with the response, approach the Grievance Redressal Officer at gro@cashboxx.in or call +91 8796466411. The Company aims to resolve complaints at this level within the next 7 working days.

Level 3: Principal Nodal Officer

If you remain dissatisfied, you may escalate to the Principal Nodal Officer at pno@cashboxx.in or call +91 8796466440. If you are still aggrieved after a decision or rejection at this level, you may appeal within 30 days to the Consumer Education and Protection Department, Reserve Bank of India, or lodge a complaint through the RBI’s Complaint Management System (CMS) portal or the Sachet portal at https://sachet.rbi.org.in, particularly to report fraud or an unregulated entity.

The Company follows the Reserve Bank, Integrated Ombudsman Scheme, 2021, as amended from time to time. A complaint under the Scheme may be filed:

1. online, through the Integrated Ombudsman portal at https://cms.rbi.org.in;
2. by email to CRPC@rbi.org.in;
3. in physical form, at the Centralized Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh 160017; or
4. through the toll-free Contact Centre at 14448 (9:30 a.m. to 5:15 p.m.), which offers assistance in Hindi, English, and regional languages.

15. Review of This Fair Practices Code

The Board of Directors reviews this Code, and revises it if needed, at least once a year, or whenever applicable, a regulatory direction, or the Company’s own operations change. Where the RBI’s Master Directions or another applicable regulatory framework is amended, the Board incorporates and approves the necessary changes to this Code at the earliest opportunity. Where this Code conflicts with applicable law or a regulatory direction, the law or direction will prevail.

Annexure A: Code of Conduct for Recovery Personnel

Every authorized person acting for the Company, whether an in-house employee or an outsourced agent, engaged in collecting or recovering loan dues from borrowers, follows this Code of Conduct:

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

iii.  courtesy, fair treatment, and persuasion form the basis of recovery; unduly coercive methods are never used;

1. fairness and transparency are maintained in every matter involving repossession, valuation, and realisation of security;
2. customers are contacted at the place of their choice; where no preference is given, contact is made at their place of residence or, failing that, their place of business or occupation, and decency and decorum are maintained during every visit;
3. a recovery representative’s identity and authority are disclosed to the customer at first contact;

vii. there is no interference in a customer’s personal affairs; every interaction stays civil and never involves force or coercion;

viii. authorised representatives contact customers only between 8:00 a.m. and 7:00 p.m., unless the customer’s specific business or occupation calls for otherwise;

1. a customer’s request to avoid calls at a particular time or place is honoured wherever reasonably possible;
2. customers are given full information about outstanding dues and reasonable notice to enable them to discharge those dues;
3. reasonable notice is given before security is repossessed and before it is realised;

xii. disputes about dues are, wherever reasonably possible, resolved in a mutually acceptable and orderly manner;

xiii.   calls or visits are avoided on inappropriate occasions, such as a bereavement or other difficult event in the family;

xiv. customer information is kept confidential at all times;

1. no inappropriate message is sent by mobile phone, email, or social media;

xvi. no false or misleading representation is made to a customer; recovery personnel never pose as a police officer, court official, or government authority, and never falsely claim that legal or criminal proceedings have begun unless they genuinely have; and

xvii.    every communication about collecting or recovering dues is made only through the contact details the customer has provided.

Disclaimer and Company Information Barwala Leasing and Finance Private Limited Operating under the brand name: Cash Boxx Registered NBFC with the Reserve Bank of India This Fair Practices Code is published for information and is subject to periodic revision. Where any provision of this Code conflicts with applicable law or a regulatory direction issued by the Reserve Bank of India, the applicable law or regulatory direction will prevail. Customers are encouraged to check the Cash Boxx platform and the Company’s official website regularly for the most current version of this Code. Approved by the Board of Directors of Barwala Leasing and Finance Private Limited.