KYC & AML Policy

Approved by the Board of Directors · Last reviewed: 2 April 2026

1. Objective and Statutory Basis

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy is framed pursuant to the Prevention of Money-Laundering Act, 2002, the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, and the RBI's Master Direction — Know Your Customer (KYC) Direction, 2016, as amended. Its objective is to prevent the Company from being used, intentionally or unintentionally, for money laundering or terrorist financing, and to enable the Company to know and understand its customers.

2. Key Elements

The Policy comprises four key elements: (a) Customer Acceptance Policy; (b) Risk Management; (c) Customer Identification Procedures (CIP); and (d) Monitoring of Transactions.

3. Customer Acceptance Policy

• No account or loan shall be opened in anonymous, fictitious or benami names.
• No relationship shall be established or transaction undertaken where the Company is unable to apply appropriate customer due diligence (CDD) measures.
• No transaction or account-based relationship shall be undertaken without following the CDD procedure, and the mandatory information required for KYC shall be obtained at onboarding.
• Customers shall be screened against applicable sanctions lists and the lists of designated individuals / entities circulated under the Unlawful Activities (Prevention) Act, 1967.

4. Customer Identification and Due Diligence

Identity and address shall be verified through Officially Valid Documents (OVDs) — the passport, driving licence, proof of possession of Aadhaar number, Voter's Identity Card, NREGA job card, or letter issued by the National Population Register — or through such equivalent e-documents and digital processes (including the Video-based Customer Identification Process, where implemented) as permitted under the KYC Direction. For legal entities, constitution documents, registered address proof, and identification of beneficial owners shall be obtained in accordance with the PML Rules.

5. Risk Categorisation

Customers shall be categorised as low, medium or high risk based on parameters such as identity, social / financial status, nature of business activity, geography, mode of payments and information about the customer's business and location. Enhanced due diligence shall apply to high-risk customers, including politically exposed persons; simplified measures may apply to low-risk customers as permitted.

6. Ongoing Monitoring and Reporting

• Transactions shall be monitored on an ongoing basis with attention to complex, unusually large, or unusual patterns of transactions with no apparent economic purpose.
• Cash Transaction Reports (CTRs), Suspicious Transaction Reports (STRs) and other prescribed reports shall be filed with the Financial Intelligence Unit — India (FIU-IND) within the prescribed timelines. There shall be no tipping-off of the customer in relation to an STR.
• KYC records shall be updated periodically as per the customer's risk category, and records of identity and transactions shall be preserved for at least five years as prescribed.

7. Governance, Training and Outsourcing

The Board shall designate a “Designated Director” and appoint a “Principal Officer” responsible for compliance and reporting to FIU-IND. Employees and agents shall receive periodic KYC / AML training. Where any activity is outsourced, the Company shall remain responsible for KYC / AML compliance. Customer information shall be kept confidential and used only as permitted by law.

Review of this Policy

This Policy shall be reviewed by the Board of Directors at least once a year, and earlier whenever changes in applicable law or Reserve Bank of India directions so require. Any amendment shall take effect upon approval by the Board.