COMPENSATION POLICY

1. INTRODUCTION

Ayaan Finserve Private Limited is committed to providing fair, transparent, efficient, and customercentric financial services. The Company believes that customers should be treated fairly at all stages of the lending lifecycle and should not suffer financial loss or inconvenience due to deficiencies in service, operational lapses, or negligence attributable to the Company. This Compensation Policy has been framed in accordance with the guidelines issued by the Reserve Bank of India (RBI), including:

• RBI Fair Practices Code for NBFCs
• RBI Master Circular on Customer Service
• RBI Integrated Ombudsman Scheme
• RBI Digital Lending Guidelines
• Other applicable circulars, notifications, and regulatory directions issued from time to time

The Policy establishes a framework for compensating customers in cases involving service deficiencies, delayed services, operational errors, failed transactions, or any other acts attributable to the Company.

2. OBJECTIVES OF THE POLICY

The key objectives of this Policy are:

• To establish a transparent and fair compensation mechanism for customers.
• To strengthen customer confidence and trust in the Company.
• To ensure accountability for operational and service deficiencies.
• To provide timely and effective grievance resolution.
• To comply with RBI regulatory requirements and customer protection standards.
• To ensure consistency in handling compensation-related matters.

3. APPLICABILITY

This Policy shall apply to all customers and prospective customers of the Company in relation to all products and services offered by the Company, including but not limited to:

• Personal Loans
• Short-Term Loans
• Digital Lending Products
• Invoice Financing / Bill Discounting
• Collection and Recovery Services
• Customer Service Operations

This Policy shall be applicable across all branches, digital platforms, service channels, employees, outsourced agencies, recovery agents, and service providers acting on behalf of the Company.

4. DEFINITIONS

For the purpose of this Policy:

4.1 “Customer” Means any borrower, co-applicant, guarantor, applicant, or prospective customer dealing with the Company.

4.2 “Compensation” Means monetary reimbursement, waiver of charges, refund, or any corrective action provided to a customer for financial loss, inconvenience, hardship, or service deficiency attributable to the Company.

4.3 “Service Deficiency” Means any delay, error, omission, negligence, misconduct, system failure, or operational lapse attributable to the Company which adversely impacts the customer.

5. PRINCIPLES OF COMPENSATION

The Company shall follow the below principles while determining compensation:

• Compensation shall be fair, transparent, and reasonable.
• Compensation shall be based on actual financial loss, inconvenience, or hardship suffered by the customer.
• The Company may provide compensation Suo moto in deserving cases without waiting for a formal complaint.
• Compensation shall not be treated as admission of legal liability.
• Each complaint shall be assessed independently based on facts, supporting documents, and regulatory guidelines.
• The Company shall endeavour to resolve complaints within the prescribed timelines.

5.1. AWARD OF COMPENSATION

Compensation shall be payable only where:

• The deficiency is directly attributable to the Company;
• Actual financial loss has been suffered by the customer.

Compensation may include:

• Reversal of charges;
• Refund of excess recovery;
• Interest compensation;
• Monetary compensation prescribed under RBI guidelines.

The Company may also provide compensation suo moto in deserving cases without waiting for a formal complaint.

6. CIRCUMSTANCES UNDER WHICH COMPENSATION MAY BE PAID

The Company may compensate customers under the following circumstances:

6.1 Delay in Loan Processing or Disbursement

Where delay occurs after submission of complete documents and fulfilment of eligibility criteria due to internal operational reasons attributable to the Company, the Company may:

• Waive processing fees partially or fully;
• Prioritize immediate resolution;
• Compensate for direct financial loss suffered by the customer, if any.

6.2 Wrong Debit / Excess Recovery

In cases where:

• EMI is debited multiple times;
• Excess amount is recovered;
• Unauthorized debit occurs;
• Incorrect charges are levied;

the Company shall:

• Reverse the excess amount upon verification;
• Refund applicable penalties or bank charges borne by the customer;
• Compensate for delay in reversal, where applicable.

6.3 Delay in Refunds

Compensation may be applicable for delays in refund of:

• Excess repayment amount;
• Loan cancellation amount;
• Security deposit;
• Insurance premium refunds;
• Failed transaction reversals.

Where delay is attributable to the Company, compensation may include:

• Interest on delayed refunds;
• Refund of charges;
• Reimbursement of bank penalties incurred by the customer.
• Any wrongful/unauthorised/erroneous debit to customer account which is delayed for settlement beyond 48 hrs from the time of debit in customer account

6.4 Failed Digital Transactions

In cases involving:

• Amount debited but transaction failed;
• Repayment not updated;
• Duplicate repayment deduction;
• UPI/IMPS/NEFT transaction failure;

the Company shall investigate the matter promptly and take corrective action within reasonable timelines. Where financial loss occurs due to Company-related system or operational failure, compensation may be provided.

6.5 Incorrect Credit Bureau Reporting

Where incorrect information is reported due to Company error to credit information companies including:

• TransUnion CIBIL
• Experian
• CRIF High Mark
• Equifax

the Company shall:

• Rectify the records promptly;
• Notify the concerned bureau;
• Provide confirmation to the customer upon correction;
• Compensate direct financial losses, where established.

6.6 Staff Misconduct and Recovery Practices

The Company maintains zero tolerance towards:

• Harassment or abusive behaviour;
• Coercive recovery practices;
• Misrepresentation of loan terms;
• Unauthorized recovery methods;
• Mis-selling of products or services.

Appropriate disciplinary action shall be initiated against the concerned employee, recovery agent, or outsourced agency. Compensation may be provided depending upon the severity of the issue and actual hardship caused to the customer.

6.7 Data Privacy and Confidentiality Breach

The Company shall maintain confidentiality of customer information and comply with applicable data privacy and information security standards. In cases involving unauthorized disclosure or misuse of customer information attributable to the Company, appropriate corrective actions and compensation may be considered based on the severity and impact of the breach.

7. EXCLUSIONS

Compensation shall not be payable in the following circumstances:

• Delay or issue caused due to customer negligence;
• Incorrect or incomplete information/documents provided by the customer;
• Force majeure events including natural disasters, strikes, war, pandemic, or government restrictions;
• Failure of third-party banking/payment systems beyond the Company’s control;
• Legal or regulatory restrictions preventing timely action;
• Situations where no financial loss or hardship is established.

AWARD OF COMPENSATION

Compensation shall be payable only where:

• The deficiency is directly attributable to the Company;
• Actual financial loss has been suffered by the customer.

Compensation may include:

• Reversal of charges;
• Refund of excess recovery;
• Interest compensation;
• Monetary compensation prescribed under RBI guidelines.

The Company may also provide compensation suo moto in deserving cases without waiting for a formal complaint.

8. CUSTOMER GRIEVANCE REDRESSAL MECHANISM

The Company has established a robust grievance redressal mechanism to ensure timely resolution of customer complaints.

9. AWARD OF COMPENSATION

Compensation shall be payable only where:

• The deficiency is directly attributable to the Company;
• Actual financial loss has been suffered by the customer.

Compensation may include:

• Reversal of charges;
• Refund of excess recovery;
• Interest compensation;
• Monetary compensation prescribed under RBI guidelines.

The Company may also provide compensation suo moto in deserving cases without waiting for a formal complaint.

9.1. FORCE MAJEURE

The Company shall not be liable for compensation where delays or deficiencies arise due to circumstances beyond its reasonable control, including:

• Natural calamities;
• War;
• Civil disturbances;
• System failures;
• Network outages;
• Government restrictions;
• Technical disruptions.

10. CUSTOMER RESPONSIBILITIES

Customers are expected to:

• Keep loan account credentials and OTPs confidential;
• Promptly report unauthorized transactions;
• Verify repayment confirmations regularly;
• Maintain updated contact details with the Company;
• Exercise reasonable caution while conducting digital transactions.

Level 1 – Customer Support

Customers may register complaints through:

• Customer care support: Ashish Verma
• Contact Number: 0120-4832057
• Official email support: info@afiloans.co.in

The Company shall acknowledge customer complaints within 48 hours of receipt.

Level 2 – Grievance Redressal Officer

If the complaint is not resolved satisfactorily within the prescribed timelines, customers may escalate the complaint to the Grievance Redressal Officer.

Grievance Redressal Officer Details

• Name: Amit Khanna
• Designation: Grievance Redressal Officer
• Email: nodalofficer@afiloans.co.in
• Contact Number: 0120-4832057 / 0120-3229778

Level 3 – RBI Integrated Ombudsman Scheme

If the complaint remains unresolved within 90 days from the date of complaint or the customer is not satisfied with the response provided by the Company, the customer may approach the Reserve Bank of India under the RBI Integrated Ombudsman Scheme.

11. TIMELINES FOR RESOLUTION
12. CUSTOMER AWARENESS

The Company shall ensure that:

• This Policy is displayed on the official website of the Company;
• Customers are informed about grievance escalation channels;
• Employees and service providers are trained on customer service standards;
• The Policy is made available to customers upon request.

13. REVIEW AND AMENDMENT

This Policy shall be reviewed periodically or as required due to:

• Changes in RBI regulations;
• Changes in business operations;
• Regulatory observations;
• Internal policy revisions.

Any amendment to this Policy shall be approved by the Board of Directors of Ayaan Finserv Private Limited.

14. BOARD APPROVAL

This Compensation Policy has been approved by the Board of Directors of Ayaan Finserv Private Limited and shall come into force from the date of approval.

15. CONCLUSION

Ayaan Finserve India Private Limited remains committed to maintaining the highest standards of customer service, ethical business practices, transparency, and regulatory compliance while ensuring fair compensation and timely grievance redressal for all customers.