RISK MANAGEMENT POLICY

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

1. Purpose

The purpose of this Risk Management Policy is to establish a framework for identifying, assessing, monitoring, mitigating, and reporting risks associated with the business operations of Barwala Leasing and Finance Private Limited.

2. Scope

This Policy applies to all employees, management, outsourced service providers, and third-party vendors involved in the Company’s operations.

3. Objectives

Identify and manage risks, protect financial and operational stability, ensure regulatory compliance, strengthen internal controls, and support sustainable growth.

4. Risk Management Framework

The Company shall adopt a structured framework comprising Risk Identification, Risk Assessment, Risk Monitoring, Risk Mitigation, and Periodic Review.

5. Credit Risk

Credit risk shall be managed through customer verification, credit assessment, bureau checks, fraud checks, and portfolio monitoring.

6. Operational Risk

Operational risks shall be minimized through SOPs, employee training, internal controls, and system monitoring.

7. Compliance Risk

The Company shall monitor compliance with RBI regulations, applicable laws, and internal policies.

8. Technology and Cyber Risk

The Company shall maintain secure IT infrastructure, access controls, encryption, vulnerability assessments, and disaster recovery arrangements.

9. Information Security Risk

Customer information shall be protected against unauthorized access, misuse, loss, or disclosure.

10. Fraud Risk

Appropriate controls shall be maintained to prevent and detect fraud by customers, employees, vendors, and third parties.

11. Reputational Risk

The Company shall maintain ethical business practices, transparent communication, and effective customer service.

12. Risk Monitoring

The Company shall periodically monitor portfolio performance, defaults, fraud incidents, operational losses, customer complaints, and compliance matters.

13. Business Continuity

Appropriate business continuity and disaster recovery arrangements shall be maintained.

14. Policy Review

This Policy shall be reviewed periodically and updated whenever required.