Applicability: Lending Service Provider (LSP) / Digital Lending Application (DLA) operations conducted on behalf of partner Regulated Entities (NBFCs/Banks).

Regulatory Framework: Prepared in accordance with Reserve Bank of India's (i) Guidelines on Digital Lending dated September 2, 2022 (as amended), (ii) Guidelines on Default Loss Guarantee (DLG) in Digital Lending, (iii) Fair Practices Code guidelines applicable to Regulated Entities and their outsourcing arrangements, and (iv) the Reserve Bank – Integrated Ombudsman Scheme, 2021.

1. Introduction

AFPL Fintech Private Limited (“AFPL”) is a technology-driven Lending Service Provider (LSP) that operates one or more Digital Lending Applications (DLAs) on behalf of its partner Regulated Entities (REs), including Arthashastra Epaylater Financial Private Limited and other partner Regulated Entities (“Partner NBFC”). AFPL is not itself an RBI-regulated lender; it provides origination, sourcing, technology, and customer-facing support services under outsourcing arrangements with its Partner NBFC(s), in accordance with the RBI's Guidelines on Digital Lending.

Although the credit decision, disbursement, and regulatory accountability for a loan rest with the Partner NBFC, AFPL recognises that it is the primary point of customer interaction and therefore bears a significant responsibility for prompt, fair, and transparent grievance redressal. This Policy sets out AFPL's grievance redressal framework and its interface with the Partner NBFC's grievance mechanism and the RBI's Ombudsman framework.

AFPL's approach to grievance redressal is guided by the following principles:

• Customers/borrowers shall always be treated fairly, transparently, and with courtesy.
• Complaints are dealt with promptly, without undue delay, and without any charge to the customer.
• Grievances of senior citizens, differently-abled persons, and other vulnerable customers are handled on a priority basis.
• Customers are clearly informed of the escalation matrix, including their right to approach the Partner NBFC's Grievance Redressal Officer and, thereafter, the RBI Ombudsman, if not satisfied with AFPL's response.
• No complaint shall be rejected without adequate examination, and reasons for rejection/closure shall be communicated in writing.
• Employees and outsourced personnel shall act in good faith and in the interest of the customer at all times.

2. Definitions

• Complaint: An expression of dissatisfaction made by a customer/borrower to AFPL, whether written, oral, or electronic, relating to a loan product sourced through AFPL's platform, its services, or the manner in which a prior complaint was handled, where a response or resolution is explicitly or implicitly expected.
• Digital Lending Application (DLA) / Platform: The mobile application/website operated by AFPL through which loan products of the Partner NBFC are sourced, serviced, and supported.
• Lending Service Provider (LSP): An agent engaged by a Regulated Entity to carry out one or more of the lender's functions in customer acquisition, underwriting support, pricing support, servicing, monitoring, or recovery, in accordance with RBI's outsourcing and digital lending guidelines.
• Regulated Entity (RE) / Partner NBFC: The RBI-regulated Non-Banking Financial Company on whose behalf AFPL sources and services digital loans, and which bears ultimate responsibility for compliance with RBI regulations, including grievance redressal, under the Fair Practices Code.
• Grievance Redressal Officer (GRO): The designated officer of AFPL/Partner NBFC responsible for the resolution of escalated customer complaints.

3. Internal Machinery to Handle Customer Complaints

3.1 Complaint Registration

A customer may lodge a complaint through any of the following channels. Every complaint, irrespective of the channel, is logged in AFPL's centralised grievance register/ticketing system with a unique complaint reference number, which is shared with the customer at the time of registration.

3.2 In-App / Website Grievance Redressal

The AFPL DLA and website prominently display a “Help”/“Grievance Redressal” section enabling customers to raise a complaint directly, track its status, and view the applicable escalation matrix, in line with RBI's requirement that DLAs prominently publish the grievance redressal mechanism, including the name, designation, and contact details of the GRO.

3.3 Call Centre

Complaints can be lodged at AFPL's customer support helpline at 8100050505, available between 10:00 AM to 7:00 PM (Monday to Saturday). A confirmation of registration is shared with the customer at the time of the call, and by SMS/email/in-app notification shortly thereafter.

3.4 Complaints through E-mail / Post

Customers may also submit complaints by e-mail or post. Complaints received by e-mail are acknowledged by e-mail.

4. Resolution of Grievances

4.1 Grievances Relating to Loan Origination, Disbursement, or Servicing

The AFPL support team is the first point of resolution for complaints relating to on-boarding, KYC, disbursement delays, app functionality, data privacy, unauthorised/excess collection calls, or other LSP-side service issues. Where the complaint pertains to matters within the Partner NBFC's exclusive domain (e.g., interest rate, sanction terms, foreclosure charges), AFPL forwards the complaint to the Partner NBFC's designated grievance team within one (1) working day and keeps the customer informed of the reference number and expected timeline.

4.2 Role of the Partner NBFC

AFPL and its Partner NBFC(s) maintain a documented service-level arrangement under which unresolved or NBFC-specific complaints are escalated to the Partner NBFC's Grievance Redressal Officer. The Partner NBFC retains oversight of AFPL's grievance redressal performance as part of its outsourcing/LSP due diligence obligations under RBI's digital lending framework, and reviews complaint data periodically as detailed in Section 6.

4.3 Alternative Remedy

Where the customer remains unsatisfied after exhausting AFPL's and the Partner NBFC's internal grievance redressal mechanism, or where the complaint is not resolved within thirty (30) days, the customer may approach the Reserve Bank – Integrated Ombudsman Scheme, 2021, against Arthashastra Epaylater Financial Private Limited as the Regulated Entity, since LSPs are not themselves directly covered under the Ombudsman Scheme.

5. Time Frame

• Acknowledgement: Within three (3) working days of receipt, with a unique reference/ticket number.
• First-Level Resolution (AFPL): Within seven (7) working days of receipt, wherever the matter is within AFPL's control.
• GRO Escalation Resolution: Within fifteen (15) days of escalation to AFPL's Grievance Redressal Officer.
• Overall Resolution: Within thirty (30) days from the date of original receipt (including matters escalated to Partner NBFC), in line with RBI Guidelines.
• Credit Bureau Disputes: Within seven (7) working days, in accordance with applicable RBI/CIC guidelines.

The escalation matrix and indicative time-frame for each level are set out in the Annexure (Escalation Grid). Departments and outsourced personnel handling customer complaints are required to strictly adhere to these timelines.

6. Review Mechanism

6.1 Internal Review

AFPL's management periodically reviews complaint volumes, turnaround times, root causes, and repeat/systemic issues, and reports this data to the Partner NBFC and, where applicable, to AFPL's own Board/Management Committee, to identify shortcomings in product design, app functionality, or service delivery and to drive corrective action.

6.2 Grievance Redressal Officer

Aggrieved customers can write directly to AFPL's Grievance Redressal Officer at the details below:

7. Mandatory Display Requirements

• The name, designation, and contact details (phone/email) of AFPL's Grievance Redressal Officer.
• The name of the Partner NBFC(s) on whose behalf loans are being sourced/serviced through the AFPL platform.
• The applicable escalation matrix, including the Partner NBFC's Grievance Redressal Officer details and the RBI Ombudsman details.
• A key facts statement / product summary for each loan, including all-in cost, recovery mechanism, and grievance redressal contacts, prior to loan execution.
• AFPL's Privacy Policy and data-sharing practices, including the list of third parties with whom borrower data is shared.

8. Interaction with Customers and Staff Sensitisation

• Ensures front-line and collections staff (including outsourced recovery agents) are trained in fair, courteous, and non-coercive customer interaction, consistent with RBI's guidelines on recovery practices for digital lending.
• Sensitises staff on the prohibition of unauthorised data access, harassment, or contact with persons other than the borrower, except as permitted under RBI guidelines.
• Ensures the Grievance Redressal Officer monitors that the internal grievance machinery operates efficiently across all levels and channels.

ANNEXURE – Escalation Grid

Customers can escalate their grievances through the multi-level hierarchy outlined below: