Fair Practices Code

Orin Financial Advisory Private Limited ("OFAPL" or the "Company"), operating under the brand name DhanLY, is committed to conducting its business in a fair, transparent, ethical, and customer-centric manner.

As a Lending Service Provider (LSP), the Company provides technology-enabled services to regulated Banks and Non-Banking Financial Companies ("Lending Partners") for facilitating digital lending. The Company does not undertake lending in its own name unless separately authorized under applicable law.

This Fair Practices Code ("FPC") sets out the principles that guide the Company's interaction with customers throughout the loan lifecycle and reflects its commitment to responsible business conduct.

This Policy applies to:

• Directors
• Employees
• Customer Support Teams
• Sales & Marketing Teams
• Collection Personnel
• Recovery Agencies (where engaged)
• Third-party Service Providers acting on behalf of the Company

Every employee and representative of the Company shall adhere to this Code while interacting with customers.

The Company shall conduct its business based on the following principles:

• Fairness
• Transparency
• Customer Respect
• Ethical Conduct
• Regulatory Compliance
• Responsible Lending Support
• Data Privacy
• Prompt Grievance Resolution

The Company aims to build long-term customer trust through honest and professional conduct.

The Company shall ensure that all customer communications are clear, accurate, and easy to understand. Customers shall be provided with relevant information regarding:

• Loan products offered by Lending Partners.
• Eligibility criteria.
• Applicable charges.
• Interest rates as communicated by the Lending Partner.
• Processing fees.
• Repayment schedule.
• Consequences of delayed repayment.
• Customer obligations under the loan agreement.

The Company shall avoid misleading, deceptive, or exaggerated marketing claims.

The Company believes that customer consent is fundamental to digital lending. Accordingly:

• Customer consent shall be obtained before collecting personal information.
• Separate consent shall be obtained wherever required for accessing financial information or personal data.
• Customer information shall be collected only for legitimate business purposes.
• Customers may withdraw consent wherever permitted under applicable law, subject to contractual or regulatory requirements.

The Company supports Lending Partners by facilitating a digital onboarding journey. The Company shall ensure that:

• Customers are informed that the loan is sanctioned by the respective regulated Lending Partner.
• Required disclosures are made before execution of loan documents.
• Customers are provided access to the applicable Key Fact Statement (KFS), sanction terms, and loan agreement issued by the Lending Partner.
• Loan disbursement and repayment are processed through authorized banking channels.

The Company is committed to ensuring that all recovery-related activities are carried out professionally, respectfully, and in compliance with applicable laws and regulatory guidelines. Accordingly:

• Customers shall be treated with dignity and respect at all times.
• Recovery personnel shall identify themselves during interactions.
• Intimidation, harassment, coercion, abusive language, or threats shall not be used under any circumstances.
• Communication shall generally be limited to reasonable hours unless otherwise agreed with the customer or permitted by applicable law.
• The Company does not encourage or permit disclosure of a customer's loan obligations to unrelated third parties, except where required by law or expressly authorized by the customer.
• Where collection activities are undertaken through authorized service providers, the Company shall require such providers to adhere to standards consistent with this Fair Practices Code.

The Company respects the privacy of every customer. Customer information shall:

• Be collected only for lawful purposes.
• Be processed only to the extent necessary for providing services.
• Be stored securely.
• Not be disclosed to unauthorized parties.
• Be protected through appropriate administrative, technical, and organizational safeguards.

The Company shall comply with applicable data protection and privacy laws.

The Company shall ensure that customers are treated fairly irrespective of:

• Gender
• Religion
• Caste
• Language
• Region
• Disability
• Occupation
• Socio-economic background

Customer interactions shall always remain courteous, respectful, and professional.

The Company maintains a structured grievance redressal mechanism to ensure timely resolution of customer complaints. Customers may raise concerns through the contact details published on the Company's website or other official communication channels.

Upon receipt of a complaint, the Company shall:

• Acknowledge the complaint within a reasonable period.
• Investigate the matter objectively.
• Communicate the outcome to the customer.
• Maintain records of complaints and their resolution.

Where a complaint pertains to the Lending Partner or another service provider, the Company shall coordinate with the relevant party to facilitate an appropriate resolution.

Employees shall:

• Behave professionally with customers.
• Avoid making false commitments.
• Provide accurate information.
• Protect customer confidentiality.
• Escalate customer concerns promptly.
• Comply with internal policies and applicable laws.

Any employee found violating this Code may be subject to disciplinary action.

The Company shall periodically review compliance with this Fair Practices Code. Management may conduct internal reviews to evaluate:

• Customer complaints.
• Recovery practices.
• Employee conduct.
• Customer communication standards.
• Vendor compliance.

Corrective actions shall be implemented wherever necessary.

This Policy shall be reviewed annually or earlier if required due to:

• Regulatory changes.
• Changes in business operations.
• Directions issued by the Reserve Bank of India or other competent authorities.
• Internal governance requirements.

Any amendments shall be approved by the Board of Directors or an authorized committee.

This Fair Practices Code represents the Company's commitment to ethical business conduct and customer protection.

The provisions of this Policy shall be read in conjunction with applicable laws, RBI guidelines, and the contractual arrangements between the Company and its Lending Partners. In the event of any inconsistency, applicable law or regulatory direction shall prevail.