Grievance Redressal Policy

Barwala Leasing and Finance Private Limited (referred to below as the “Company”), which runs its digital lending business under the brand name Cash Boxx, is a Non-Banking Financial Company registered with the Reserve Bank of India and is in the business of extending EMI-based loan facilities through the Cash Boxx platform. The Company treats customer service and satisfaction as central to how it operates, and this Grievance Redressal Policy (“Policy”) sets out a structured, accessible, and time-bound way for customers to raise complaints, seek redressal, and give feedback about their dealings with the Company.

This Policy draws on the following regulatory frameworks:

1. the Master Direction, Non-Banking Financial Company, Non-Systemically Important Non-Deposit Taking Company (Reserve Bank) Directions, 2016, dated September 1, 2016;
2. the Master Direction, Reserve Bank of India (Non-Banking Financial Company, Scale Based Regulation) Directions, 2023; and
3. the Reserve Bank of India’s Guidelines on the Fair Practices Code for Non-Banking Financial Companies.

Any amendment, clarification, or direction that the RBI issues from time to time is treated as forming part of this Policy, to the extent it applies.

Objective of This Policy

The Company recognizes that prompt, effective grievance handling is central to earning and keeping customer trust. This Policy is built around the following objectives:

1. to treat every customer fairly, equally, and with dignity at all times;
2. to take up complaints promptly, courteously, and without unreasonable delay;
3. to give priority handling to grievances raised by senior citizens, pensioners, and persons with disabilities;
4. to keep customers informed about every escalation channel available within the Company, and their right to seek other remedies if still dissatisfied;
5. to handle complaints fairly and efficiently, protecting both the Company’s reputation and its customers’ interests; and
6. to make sure every employee carries out their responsibilities in good faith, without bias, and in customers’ best interest.

Any customer who is unhappy with a service the Company, or anyone acting on its behalf, has provided may register a complaint under this Policy.

Scope of This Policy

This Policy applies to:

1. every office and branch operating under the Cash Boxx brand;
2. every employee of the Company, whether permanent or engaged on a contract; and
3. every customer-facing activity the Company carries out through the Cash Boxx platform or otherwise.

For this Policy:

“Customer” means any individual or entity that has taken a loan facility from the Company through Cash Boxx or any other channel the Company operates.

“Complaint” means any written or electronic expression of dissatisfaction, grievance, or allegation a customer raises about a deficiency in:

1. the Company’s services, products, policies, or procedures;
2. how a Company employee has conducted or behaved themselves while dealing with customers; or
3. the confidentiality, protection, or security of a customer’s personal, sensitive personal, or financial information.

Core Commitments

The Company holds itself to high standards of customer satisfaction, built on the following principles.

Fair and Transparent Dealings

1. every product and service offered through Cash Boxx complies with applicable law and regulatory requirements;
2. every customer interaction is carried out honestly, transparently, and with integrity; and
3. the Company’s systems, procedures, and processes are designed and run in its customers’ best interests.

Customer Assistance and Information

1. customers receive relevant product and service information in English and/or a local language of their choice;
2. the financial implications of any product or service are explained clearly before a customer commits to it; and
3. customers are helped to identify and choose the product or service that best fits their needs.

Error Rectification

Where the Company makes an error, omission, or oversight, it will, on a priority basis:

1. correct the error promptly;
2. resolve the customer’s complaint;
3. guide the customer on escalation options where dissatisfaction continues; and
4. reverse any charge, including interest, that was wrongly applied to a customer’s account because of the Company’s error or lapse.

Grounds for Filing a Complaint

Customers may file a written complaint clearly describing the nature of grievance or deficiency. Grounds for a complaint include, without limitation, those listed under Clause 8 of the Ombudsman Scheme for Non-Banking Financial Companies, 2018:

1. failure to communicate, in writing, the sanctioned loan amount and applicable terms, including the annualized rate of interest and how it is applied;
2. failure or refusal to provide a sanction letter or the applicable terms and conditions;
3. failure or unreasonable delay in releasing security documents once a borrower has repaid all dues; levying charges without adequate prior notice; or failing to include a legally enforceable repossession clause in the loan agreement;
4. non-compliance with any direction the Reserve Bank of India has issued to non-banking financial companies; and
5. non-adherence to any other requirement of the RBI’s Fair Practices Code guidelines for Non-Banking Financial Companies.

How to File a Complaint

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. The 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.

On receiving a service request or complaint, the Company will send an acknowledgement within 3 (three) working days, by email, post, SMS, WhatsApp, or another legally valid form of electronic communication. The Company aims to resolve the matter within 7 (seven) working days. Where a complaint calls for extensive investigation, the customer’s help in identifying a wrongdoer, a root-cause analysis, or involves litigation (including a matter pending with the local police), resolving it may reasonably take longer than 7 (seven) working days.

If you are not satisfied with the response given at Level 1, you may escalate the matter to Level 2.

Level 2: Grievance Redressal Officer

If your request or complaint remains unresolved 7 days after you approached Level 1, or if you are dissatisfied with the resolution offered, you may approach the Grievance Redressal Officer (GRO) at gro@cashboxx.in or call +91 8796466411.

The Company will make its best effort to resolve complaints at this level within the next 7 working days.

Level 3: Principal Nodal Officer

If you remain dissatisfied with the GRO’s response or decision, you may escalate the matter to the Principal Nodal Officer at pno@cashboxx.in or call +91 8796466440.

If you remain aggrieved after the GRO’s or the Principal Nodal Officer’s decision, or your complaint is rejected, you may file an appeal within 30 days of receiving that decision, with the Consumer Education and Protection Department of the Reserve Bank of India.

You may also file a complaint through the RBI’s Complaint Management System (CMS) portal, or through the Sachet portal at https://sachet.rbi.org.in, particularly to report fraud or an unregulated entity.

The RBI Integrated Ombudsman Scheme

The Company follows the Reserve Bank, Integrated Ombudsman Scheme, 2021 (“Scheme”), as amended from time to time. For the benefit of the Company’s borrowers, its key features are set out below. 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.

Review of This Policy

The Board of Directors will review this Policy and revise it where necessary. The Company may amend this Policy at any time to reflect a change in applicable law, regulatory direction, or its own governance requirements. If this Policy ever conflicts with applicable law or an RBI direction, the law or direction will prevail.

Disclaimer This Policy is published for information and is subject to periodic revision. Where any provision of this Policy conflicts with applicable law or a regulatory direction, the applicable law or regulatory direction will prevail. Customers are encouraged to check the Cash Boxx website or platform from time to time for the most current version of this Policy. Approved by the Board of Directors of Barwala Leasing and Finance Private Limited