Fair Practice Code

1. Introduction and Philosophy

CopperHive Technologies Private Limited ("the Company") acts as a Lending Service Provider (LSP) and is committed to the highest standards of integrity and transparency in its operations. We facilitate digital lending services in partnership with SONU MARKETING PVT LTD, a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI), which acts as the actual lender.

While financial contracts can be complex, we are committed to ensuring that customers interacting through our digital platform are treated fairly, provided with clear and transparent information, and supported by robust grievance redressal mechanisms.

This Fair Practices framework aligns with the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025, and the RBI Digital Lending Guidelines. The applicable Fair Practices Code is issued by SONU MARKETING PVT LTD (NBFC), and we operate strictly in compliance with such Code in our capacity as a Lending Service Provider.

2. Applicability

This Code applies to all services facilitated by the Company through the AlphaRupee platform, specifically including the Digital Lending Application (DLA) owned and operated by the Company. It applies to all employees, directors, agents, and third-party vendors authorised to represent the Company.

3. Customer Empowerment: Applications and Processing

3.1 Transparency in Product Offerings

The Company ensures that all loan products, interest rates, and fees offered by our Partner Lender are clearly listed on our website and Digital Lending Application (DLA). We use plain and simple language (vernacular/regional language where applicable) to explain these products. Our goal is to empower you to compare our offerings with other market participants before making a commitment. We will provide a comprehensive checklist of required documents upfront to ensure a seamless and predictable application process.

3.2 Formal Acknowledgement and Timeline

Upon submission of a digital loan application, the Company will issue an immediate electronic acknowledgement through the AlphaRupee platform, or through other communication channels where such channels are used. This receipt serves as a formal record of your application and includes a unique tracking ID. We are committed to a time-bound process; the acknowledgement will clearly state the expected timeframe within which your application will be reviewed by the Partner Lender and a final decision (sanction or rejection) will be communicated to you.

3.3 Responsible Credit Assessment

The Partner Lender performs a diligent credit appraisal to ensure that the loan amount is within your repayment capacity, thereby preventing over-indebtedness. The Company provides credit-assessment support to the Partner Lender for this purpose. This assessment is based on the data you provide and information obtained from Credit Information Companies (CICs). Any enhancement in your credit limit will occur only following a fresh credit assessment by the Partner Lender and your explicit, recorded consent.

4. The Sanction Process and "No Hidden Costs"

4.1 The Key Fact Statement (KFS) — Your Absolute Reference

Before you execute any loan agreement, you will be provided with a Key Fact Statement (KFS). This is a standardised, easy-to-read document that acts as the single source of truth for your loan.

Annual Percentage Rate (APR): The KFS will prominently display the APR, which represents the total cost of the loan (interest + processing fees + any other charges) expressed as an annual percentage.

Binding Nature: The Partner Lender is bound by the KFS. No fee, cost, or interest that is not explicitly mentioned in the KFS will be charged to you at any stage.

Validity Period: You will have a validity period, as stated on the KFS and prescribed under the RBI Responsible Business Conduct Directions, 2025, to review the KFS and decide whether to proceed.

4.2 Clear Documentation

Upon approval of the loan, you will be provided with a copy of the Sanction Letter and the Loan Agreement, along with copies of all relevant enclosures referred to therein. The loan documentation shall clearly set out the terms and conditions of the loan, including the repayment schedule and the method of interest calculation. Copies of the executed loan documents shall be furnished to you at the time of sanction and/or disbursement of the loan.

5. Disbursement and Changes in Terms

5.1 Disbursement

All disbursement of loans shall be made directly into the bank account of the borrower.

There shall be no disbursal to a third-party account, including accounts of Lending Service Providers, except as provided under statutory mandates or co-lending guidelines.

5.2 Changes in Terms

Notice will be provided to the borrower in the vernacular language, or a language understood by the borrower, of any change in terms and conditions, including disbursement schedule, interest rates, service charges, and prepayment charges.

Any change in interest rates and charges takes effect only prospectively.

6. Specific Provisions for Digital Lending

6.1 The Cooling-Off / Look-up Period

We recognise that a borrower may have second thoughts after a loan is disbursed. A mandatory Cooling-Off Period is provided in accordance with the Partner Lender's Board-approved policy. During this window, you may exit the loan by repaying the principal amount and the proportionate Annual Percentage Rate without paying any foreclosure or pre-payment penalty. This ensures you are never trapped in a financial commitment you regret.

6.2 Ethical Data Practices and Privacy

In the digital lending ecosystem, your data privacy is paramount.

Explicit Consent: We collect only data that is necessary for loan processing, and only after obtaining your opt-in consent at each stage.

Restricted Access: Our application does not access your private mobile resources such as contacts, media files, call logs, or telephony functions.

Data Locality: All customer data is stored on secure servers located within India. You also have the right to request the deletion of your data once the loan is fully repaid, subject to statutory record-keeping requirements.

7. Interest Rates, Penal Charges, and Repayment

7.1 Fair Interest Pricing

The Partner Lender's Board has approved an Interest Rate Model that considers the cost of funds, operational expenses, and the risk profile of the borrower. Interest is calculated on a daily/monthly reducing balance basis, ensuring you pay interest only on the outstanding principal.

7.2 Penal Charges (Not Penal Interest)

In the event of a payment delay, the Partner Lender may levy Penal Charges. In accordance with the RBI Responsible Business Conduct Directions, 2025, these are "charges" and not "interest".

No Compounding: These charges are not added to the principal balance to calculate further interest. This prevents a debt spiral where interest is charged on top of penalties.

Transparency: The exact amount and reason for any penal charge will be clearly highlighted in bold in your KFS and Loan Agreement.

8. Responsible Collections and Recovery

8.1 Conduct of Recovery Agents

If you face difficulties in repayment, our first approach is always dialogue and persuasion. Where a recovery agent is engaged, we ensure they are professionally trained to deal with customers in an appropriate manner.

No Harassment: Agents do not resort to intimidation or harassment of any kind, either verbal or physical, against any person in debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the borrower's family members, referees and friends, sending inappropriate messages on mobile or through social media, or making threatening and/or anonymous calls.

Restricted Timing: Calls or visits for recovery will only take place between 08:00 AM and 07:00 PM.

9. Grievance Redressal

9.1 Tiered Redressal Mechanism

We value your feedback and take complaints seriously.

Level 1 (Grievance Redressal Officer): You may contact our Grievance Redressal Officer via the email provided on our Grievance page. We commit to resolving all issues within 30 days.

Level 2 (Partner Lender Escalation): If your complaint is rejected, or resolved only in part, you may escalate it to the Nodal Grievance Redressal Officer of our Partner Lender, whose details are provided in your Key Fact Statement. Where applicable, complaints will be reviewed by the Partner Lender's Internal Ombudsman in accordance with the RBI (Internal Ombudsman) Directions.

Level 3 (RBI Ombudsman): If you remain unsatisfied after 30 days, you have the right to approach the Reserve Bank – Integrated Ombudsman Scheme via the CMS portal at https://cms.rbi.org.in.

10. Outsourcing

Outsourcing arrangements do not diminish the obligations owed to customers or to the RBI.

• The Company is responsible for the actions of the service providers and recovery agents it engages.
• The Company ensures confidentiality and security of customer information possessed by its service providers.
• Core management functions, and decision-making functions such as loan sanctioning, are not performed or outsourced by the Company; these remain with the Partner Lender.

11. Policy Review

This Code is reviewed annually to incorporate any new regulatory changes or technological advancements. We are committed to following not just the letter of the law, but the spirit of fairness it represents.

CopperHive Technologies Private Limited (CIN: U66190KA2026PTC221909)

Registered address: 02A-116, WeWork Vista Earth Centre, EPIP Zone, Whitefield Road, Bengaluru 560048, Karnataka, India.

You may contact us at any time via email at [email protected] or call 6206802020.