FAIR PRACTICES CODE

Pursuant to the Notification issued by the Reserve Bank of India by its Circular No.RBI/2006-07/138 DNBS (PD) CC No.80/03.10.042/2005-06 dated 28th September 2006, Kalpathi Investments Private Limited (referred to as the “Company”) has formulated this Fair Practices Code to lay down the following procedures/practices in dealing with the lending business transactions. At present the company is in the business of investment and not dealing with lending business, this Code shall come into effect upon commencement of the lending business by the Company.

i) Applications for loans and their processing:

(a) Loan Application Forms include necessary information, which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form indicates the documents required to be submitted with the application form.

(b) The Company would give acknowledgement for receipt of all loan applications. The time frame within which loan applications shall be disposed of is also indicated in the acknowledgement.

(ii) Loan appraisal and terms/conditions:

The Company shall convey in writing to the borrower by means of sanction letter, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof. The Company shall keep the acceptance of these terms and conditions by the borrower on its record. The Company shall also communicate to the borrower if the loan is rejected.

A copy of the loan agreement along with the copies of each of the enclosures quoted in the loan agreement will be furnished to all the borrowers at the time of sanction/ disbursement of loans.

(iii) Disbursement of loans including changes in terms and conditions:

(a) The Company shall give notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company shall ensure that changes in interest rates and charges are effected only prospectively. The Loan Agreement contains necessary provisions to this effect.

(b) Decision to recall / accelerate payment or performance under the agreement shall be in consonance with the loan agreement.

(c) The Company shall release all securities on repayment of all dues or on realisation of the outstanding amount of loan, subject to any legitimate right or lien for any other claim the Company may have against the borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/paid.

(iv) General:

(a) The Company shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company.).

(b) In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. the Company’s objection, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.

(c) In the matter of recovery of loans, consistent with its policy over the years, the company shall not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc.

(v) Grievances, if any:

in connection with the loan shall be addressed to Shri.R.Rangarajan, Chief Financial Officer, Kalpathi Investments Private Limited, No.34, Thirumalai Road, T.Nagar, Chennai-600 017 by letter with copy marked to Shri.Praveen Kumar, Sr Vice President, Kalpathi Investments Private Limited, No.34, Thirumalai Road, T.Nagar, Chennai-600 017.

All disputes arising out of the decisions of the above functionaries will be heard and disposed of by the Grievances redressal committee comprising the above officials and a member of the board.