CODE OF CONDUCT

1Purpose of the Code

This Code of Conduct is intended to promote a culture of integrity, responsibility, accountability, and mutual respect within Rupyaa.

It applies to all employees, directors, contractors, vendors, and partners who interact with our organization, operations, or customers.

The Code is designed to support compliance with applicable laws, regulations, and ethical standards, including relevant requirements and guidelines issued by the Reserve Bank of India (RBI) and other regulatory authorities in India.

2Scope

This Policy applies to all individuals and entities associated with Rupyaa, including:

• Full-time employees.
• Part-time employees.
• Consultants.
• Contractors.
• Vendors.
• Third-party partners.

It applies across all areas of our operations, including:

• Customer interactions.
• Financial dealings.
• Marketing activities.
• Internal workplace conduct.
• Business relationships.

3Core Principles

We follow the principles below in all our activities:

• Integrity: Conduct all dealings honestly, ethically, responsibly, and fairly.
• Transparency: Maintain clear, open, and truthful communication with customers, employees, partners, and other stakeholders.
• Respect: Treat every individual with dignity, courtesy, and respect, irrespective of gender, background, role, or position.
• Confidentiality: Protect the privacy, personal information, and sensitive information of customers and employees in accordance with our Privacy Policy and applicable laws.
• Compliance: Follow all applicable laws, regulations, regulatory requirements, and internal policies, including applicable anti-corruption and anti-money laundering requirements.

4Employee Responsibilities

Employees are expected to:

• Maintain high standards of professional and ethical behaviour in all interactions.
• Avoid actual or potential conflicts of interest and disclose any such conflicts promptly.
• Refrain from engaging in bribery, corruption, fraud, or other unethical practices.
• Protect company assets, including intellectual property, confidential information, systems, and customer data.
• Report any suspected or actual violation of this Code to the Compliance Officer or Grievance Redressal Officer.

5Customer Interactions

We are committed to providing customers with fair, transparent, professional, and respectful service.

This includes:

• Providing accurate, complete, and clear information regarding loan products, applicable fees, charges, and terms.
• Responding to customer queries, concerns, and complaints within reasonable timelines.
• Complying with applicable data protection requirements and safeguarding customer information.
• Avoiding false, misleading, deceptive, or aggressive marketing practices.

6Partner and Vendor Conduct

All partners, vendors, contractors, and third-party service providers associated with Rupyaa are expected to follow ethical and professional standards consistent with those applicable to our employees.

We may conduct appropriate due diligence to assess whether our partners and vendors are aligned with our Code of Conduct, legal requirements, and regulatory expectations.

Where a violation is identified, appropriate action may be taken, including suspension or termination of the applicable business relationship.

7Reporting Violations

Any suspected, observed, or known violation of this Code should be reported promptly to our Compliance Officer or Grievance Redressal Officer, Prashant Kabra.

Where permitted, reports may be submitted anonymously.

Individuals who report genuine concerns in good faith will be protected from retaliation or unfair treatment in accordance with applicable policies and laws.

8Consequences of Non-Compliance

Failure to comply with this Code may result in appropriate disciplinary or corrective action depending on the nature and seriousness of the violation.

Such action may include:

• Disciplinary proceedings.
• Termination of employment.
• Legal action.
• Suspension or termination of vendor, contractor, or partnership arrangements.

Where required, we will cooperate with applicable law enforcement agencies, regulatory bodies, and other competent authorities.

9Policy Updates

Rupyaa reserves the right to revise, modify, or update this Code of Conduct from time to time.

Any changes will become effective upon publication on our website, mobile application, or other official platform, unless otherwise specified.

Employees, partners, vendors, and other relevant stakeholders are encouraged to review this Policy periodically for any updates.

10Contact Us

For any questions regarding this Code of Conduct or to report a concern, please contact our customer support team at:

Email: care@rupyaa.com

We remain committed to maintaining high standards of ethical conduct, professionalism, accountability, and responsible business practices, and to addressing genuine concerns in a timely and appropriate manner.