Interest Rate Policy

Orin Financial Advisory Private Limited ("OFAPL" or the "Company"), operating under the brand name DhanLY, is committed to promoting transparency and responsible lending practices in accordance with applicable laws and the Reserve Bank of India's Digital Lending Guidelines.

As a Lending Service Provider (LSP), the Company facilitates digital lending services on behalf of regulated Banks and Non-Banking Financial Companies ("Lending Partners"). The Company does not independently determine interest rates or lending terms unless specifically authorized under applicable law.

This Policy outlines the principles governing the disclosure of interest rates and other charges applicable to loan products facilitated through the Company's platform.

This Policy applies to:

• Employees
• Customer Support Teams
• Sales & Marketing Teams
• Technology Teams
• Third-party representatives acting on behalf of the Company

It governs all customer interactions relating to loan pricing, fees, and repayment disclosures.

The Company acts solely as a Lending Service Provider (LSP) and facilitates customer onboarding, loan application processing, technology services, and customer support on behalf of regulated Lending Partners.

Accordingly:

• Loan sanction is undertaken by the Lending Partner.
• Interest rates are determined by the Lending Partner.
• Processing fees and other loan-related charges are determined by the Lending Partner.
• Final credit decisions remain solely with the Lending Partner.

The Company shall ensure that customers receive clear and transparent disclosures regarding applicable charges before accepting a loan.

The Company shall adhere to the following principles:

• Transparency
• Fairness
• Simplicity
• Responsible customer communication
• Compliance with applicable laws
• No hidden charges
• Accurate disclosures

Customers shall be provided sufficient information to make informed borrowing decisions.

Interest rates applicable to loans facilitated through the Company's platform shall be determined by the respective Lending Partner based on factors including, but not limited to:

• Customer credit profile
• Credit bureau information
• Income assessment
• Employment profile
• Existing indebtedness
• Repayment capacity
• Internal underwriting policies of the Lending Partner
• Applicable regulatory requirements

The Company shall not independently alter or modify the interest rate approved by the Lending Partner.

Before execution of the loan agreement, customers shall be provided with details relating to:

• Loan amount
• Applicable interest rate
• Annual Percentage Rate (APR), wherever applicable
• Loan tenure
• Processing fees
• Applicable taxes
• Repayment schedule
• Penal charges, if applicable
• Other charges disclosed by the Lending Partner

These disclosures shall be made through the Key Fact Statement (KFS), sanction communication, loan agreement, or other applicable documents issued by the Lending Partner.

Any applicable fees, including but not limited to:

• Processing Fee
• Platform Fee (where applicable)
• Convenience Charges
• Documentation Charges
• Taxes
• Penal Charges
• Bounce Charges
• Other regulatory charges

shall be disclosed to the customer before loan acceptance in form of KFS and Sanction Letter.

The Company shall not encourage or permit the recovery of undisclosed charges.

In the event of delayed repayment, customers may be liable to pay penal charges or additional interest, as specified by the Lending Partner in the applicable loan documents.

The Company shall ensure that:

• Customers are informed of such charges before loan acceptance.
• Penal charges remain transparent.
• Recovery communications accurately reflect the applicable dues.

The Company is committed to ensuring complete transparency. Accordingly:

• No undisclosed charges shall be levied through the Company's platform.
• Customers shall receive complete pricing information before accepting the loan.
• Any revisions in pricing by the Lending Partner shall be communicated wherever applicable.

Employees and representatives shall:

• Explain loan pricing accurately.
• Avoid making misleading statements.
• Refrain from promising preferential pricing unless authorized.
• Ensure customers understand repayment obligations before proceeding.

Marketing material shall not misrepresent interest rates or other financial obligations.

Where permitted by the Lending Partner, customers may prepay or foreclose their loans subject to the applicable loan terms.

Any applicable foreclosure charges or prepayment conditions shall be disclosed by the Lending Partner before execution of the loan agreement.

The Company shall assist customers in obtaining such information whenever requested.

Customers seeking clarification regarding:

• Interest calculation
• Loan pricing
• Processing fees
• Repayment schedule
• Outstanding balance
• Penal charges

may contact the Company's customer support team through the communication channels published on the Company's website. Where necessary, the Company shall coordinate with the relevant Lending Partner to provide an appropriate response.

The Company shall periodically review its processes to ensure that:

• Interest-related disclosures remain transparent.
• Customer communications remain accurate.
• Regulatory requirements are complied with.
• Lending Partner pricing information is correctly reflected on the platform.

Any identified deficiencies shall be addressed promptly.

This Policy shall be reviewed annually or earlier in the event of:

• Amendments to applicable laws.
• RBI directions.
• Changes in Lending Partner arrangements.
• Introduction of new products.
• Material business changes.

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

This Policy governs the Company's approach to interest rate transparency and customer communication.

The Company does not independently determine interest rates or lending terms unless otherwise permitted under applicable law. Interest rates, fees, and loan conditions are determined by the respective regulated Lending Partner and are communicated to customers through the applicable loan documentation.

In the event of any inconsistency between this Policy and applicable law or regulatory direction, the latter shall prevail.