Weekline Investment and Trading Company Limited ("WITCL" or the "Company"), a Non-Banking Financial Company ("NBFC"), is committed to conducting its lending business in a fair, transparent, responsible and customer-centric manner.

This Interest Rate and Penal Charges Policy ("Policy") has been formulated in accordance with the applicable provisions of the Reserve Bank of India ("RBI") Master Direction – Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025, the Fair Practices Code adopted by the Company, and other applicable laws, regulations, circulars and guidelines issued by RBI from time to time.

The Policy establishes the framework governing:

• determination of interest rates for various loan products;
• adoption of a risk-based pricing methodology;
• levy of penal charges for non-compliance with material terms of the loan agreement;
• disclosure of interest rates, fees and charges to borrowers; and
• governance mechanisms for ensuring transparency, consistency and regulatory compliance.

The Company recognises that pricing of credit is a commercial decision requiring an appropriate balance between business sustainability, customer affordability, portfolio quality and regulatory expectations. Accordingly, interest rates and applicable charges shall be determined through an objective, risk-based and non-discriminatory framework.

This Policy shall apply to all credit facilities offered by the Company, including but not limited to:

• Digital Consumer Loans;
• Payday Loans;
• Business Loans;
• Loan Against Property (LAP) and
• any other lending products introduced by the Company from time to time.
• The Policy shall be applicable to all borrowers unless otherwise specified under any product-specific guidelines approved by the Company.

This Policy has been framed considering, inter alia, the following regulatory framework:

• Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025;
• RBI guidelines on Fair Practices Code;
• RBI Digital Lending Guidelines, wherever applicable;
• RBI guidelines relating to Key Fact Statement (KFS);
• applicable provisions of the Reserve Bank of India Act, 1934;
• other circulars, notifications, directions or instructions issued by RBI from time to time.
• In case of any inconsistency between this Policy and any applicable law or regulatory direction, the applicable law or regulatory instruction shall prevail.

• Unless the context otherwise requires:
• Board means the Board of Directors of Weekline Investment and Trading Company Limited.
• Borrower means any individual or entity to whom the Company has sanctioned or disbursed a loan.
• Interest Rate means the contractual rate charged by the Company on the outstanding principal amount of a loan.
• Penal Charges mean charges levied by the Company for non-compliance with the material terms and conditions of the loan agreement and shall not form part of the interest rate.
• Key Fact Statement (KFS) means the statement prescribed by RBI containing the details of the loan, including Annual Percentage Rate (APR), fees, charges and other material terms.
• Risk-Based Pricing means the methodology adopted by the Company for determining the applicable interest rate based upon the borrower's risk profile and other commercial factors.
• Words and expressions used but not defined herein shall have the meaning assigned to them under applicable laws and RBI regulations.

The primary objectives of this Policy are to:

• establish a transparent, fair and consistent framework for determination of lending rates;
• ensure that pricing appropriately reflects the Company's cost of funds, operating expenses, credit risk, business strategy and desired return on capital;
• adopt a structured risk-based pricing methodology for different customer segments and loan products;
• ensure that interest rates, fees and penal charges are reasonable, transparent and adequately disclosed to borrowers;
• promote responsible lending practices while protecting the interests of borrowers;
• comply with applicable RBI regulations governing interest rates, penal charges and customer disclosures.

• This Policy shall be approved by the Board of Directors of the Company.

• The Board shall periodically review this Policy to ensure that it remains aligned with:
• regulatory developments;
• prevailing market conditions;
• business requirements;
• changes in cost of funds;
• portfolio performance; and
• the Company's overall risk management framework.

The Board may delegate operational responsibilities relating to implementation of this Policy to the appropriate management committee(s) or authorised officials.

The Compliance Department shall monitor adherence to this Policy and recommend revisions whenever necessitated by regulatory or business changes.

Unless required earlier, this Policy shall be reviewed at least once every year.

• The Company believes that transparency in pricing enables borrowers to make informed borrowing decisions.
• Accordingly, the Company shall ensure that:

Interest Rate Disclosure

• The applicable interest rate, together with the rationale for charging different rates based on risk assessment, shall be disclosed to the borrower at the time of sanction through:
• Sanction Letter;
• Loan Agreement;
• Key Fact Statement (KFS); and
• any other communication prescribed by RBI.

Website Disclosure

• The Company shall publish on its official website:
• the Interest Rate and Penal Charges Policy;
• the methodology adopted for risk-based pricing;
• applicable interest rate ranges;
• penal charges;
• other material fees and charges, wherever applicable.
• The website shall be updated whenever there is any material revision in the pricing framework.

Annual Percentage Rate (APR)

• The Company shall disclose the Annual Percentage Rate (APR), along with all applicable charges, in accordance with RBI guidelines to ensure that borrowers have a clear understanding of the total cost of borrowing.

Changes in Pricing

• Any revision in interest rates or applicable charges shall operate prospectively unless otherwise permitted under applicable laws.
• Such revisions shall be communicated through appropriate channels including:
• Company's website;
• digital lending platform;
• SMS;
• email;
• customer portal; or
• any other legally permissible mode of communication.

Penal Charges Disclosure

• The quantum, nature and reason for levy of penal charges shall be clearly disclosed:
• in the Loan Agreement;
• in the Key Fact Statement (KFS);
• on the Company's website; and
• through communications issued to borrowers whenever penal charges are levied.

• The Company follows a structured and risk-based pricing framework while determining interest rates for various loan products.

• The objective of the framework is to ensure that pricing remains commercially viable, competitive, transparent and commensurate with the level of credit risk assumed by the Company.

• Interest rates shall not be uniform across all borrowers and may vary depending upon several commercial and risk-related factors.

• The Company shall periodically review its pricing framework considering changes in market conditions, cost of funds, regulatory requirements and portfolio performance.

• While determining the applicable interest rate for any lending product, the Company may consider one or more of the following factors:

Cost of Funds

• The Company's overall cost of funds, including equity capital, borrowings from banks, financial institutions and other funding sources, constitutes the primary component of lending rates.
• The pricing framework seeks to ensure adequate recovery of such funding costs while maintaining business sustainability.

Cost of Borrowings

• Interest rates payable on external borrowings, together with incidental borrowing costs such as processing fees, legal expenses, documentation charges, guarantee fees and other funding-related expenses, may be considered while determining lending rates.
• Variations in market borrowing costs may result in corresponding revisions in product pricing.

Operating Costs

• The Company incurs operational expenses towards sourcing, underwriting, customer onboarding, technology infrastructure, servicing, collections, compliance, customer support and portfolio management.
• Such costs may form part of the pricing framework.

Credit Risk

• Interest rates may vary depending upon the level of credit risk associated with a borrower.
• While assessing credit risk, the Company may consider factors including:
• repayment capacity;
• credit bureau history;
• credit score;
• income profile;
• occupation;
• business stability;
• repayment behaviour;
• indebtedness;
• internal credit assessment;
• fraud risk indicators;
• digital verification results; and
• any other risk parameters considered relevant.
• Borrowers presenting relatively higher credit risk may attract higher pricing consistent with the Company's risk appetite.

Product Characteristics

• Pricing may also differ based upon:
• nature of loan product;
• loan amount;
• repayment tenure;
• repayment structure;
• secured or unsecured nature of the facility;
• expected portfolio behaviour.

• The Company adopts a risk-based pricing model for determining the applicable interest rate for each loan product and borrower. The pricing framework is designed to ensure that lending rates appropriately reflect the level of credit risk, operating costs, funding costs and the Company's commercial objectives while remaining fair, transparent and compliant with applicable regulatory requirements.

• Interest rates may therefore vary across borrowers, products and market segments and shall not be construed as discriminatory, provided that such variations are based on objective and commercially justifiable parameters.

• The Company may consider one or more of the following factors while determining the applicable pricing:

• The above factors are indicative and not exhaustive. The Company may consider additional commercial or risk-related factors depending upon the nature of the lending product and prevailing market conditions.

• Interest rates offered by the Company shall be determined in accordance with this Policy and approved internal pricing framework.
• The applicable rate of interest for a borrower shall be communicated through the:
• Sanction Letter;
• Loan Agreement;
• Key Fact Statement (KFS); and
• any other disclosure prescribed under applicable regulations.

• The Company shall ensure that all interest rates are:
• transparent;
• reasonable;
• risk-based;
• commercially sustainable;
• non-discriminatory; and
• compliant with applicable RBI guidelines.

Interest Rate Structure

• The Board of Directors shall approve the range of interest rates applicable to various lending products. Based on the prevailing business model, the indicative interest rate structure is as follows:

• The above ranges represent the maximum permissible pricing framework approved by the Board and may be revised from time to time depending upon business requirements, cost of funds, market conditions and applicable regulatory guidelines.

• The actual rate applicable to an individual borrower shall depend upon the Company's internal credit assessment and risk evaluation.

Loan Amount and Repayment Tenure

• The Company presently offers the following categories of loan products:

• The Board or authorised management may revise the above limits from time to time depending upon business requirements.

• Depending upon the nature of the lending product, the Company may offer loans carrying either fixed or floating rates of interest.

Fixed Interest Rate

• Under a fixed-rate facility, the applicable rate of interest remains unchanged throughout the agreed tenure of the loan unless otherwise permitted under the loan agreement or applicable law.
• This provides certainty regarding repayment obligations.

Floating Interest Rate

• Under floating-rate facilities, the applicable interest rate may vary during the loan tenure based upon changes in benchmark rates or other reference rates adopted by the Company.

• Any revision shall be carried out strictly in accordance with the terms of the loan agreement and applicable RBI guidelines.

Existing Product Offering

• Presently, all retail loan products offered by the Company carry Fixed Interest Rates.

• The Company may introduce floating-rate products in future after obtaining all necessary internal approvals and ensuring compliance with applicable regulatory requirements.

• Interest shall accrue and become payable in accordance with the repayment schedule agreed with the borrower.

• The Company may compute interest on such basis as specified in the loan agreement including monthly, daily or any other permissible basis depending upon the nature of the product.

• Interest shall be payable on the due dates specified in the repayment schedule communicated to the borrower.

• Unless specifically agreed otherwise, no grace period shall be available for payment of instalments or interest.

• Any revision in interest rates applicable to future transactions shall take effect prospectively.

• The Company recognises that penal charges are intended to encourage repayment discipline and compliance with the terms of the loan agreement and shall not constitute an additional source of revenue or enhancement of interest income.

• Accordingly, penal charges shall be governed by the following principles:
• Penal charges shall be levied only for non-compliance with material terms and conditions of the loan agreement.
• Penal charges shall not be levied in the form of penal interest.
• Penal charges shall not be capitalised.
• No further interest shall be charged on unpaid penal charges.
• Penal charges shall be reasonable and proportionate to the nature of default.
• The Company shall ensure that similarly placed borrowers are treated consistently and fairly.
• Penal charges applicable to loans sanctioned to individual borrowers for purposes other than business shall not exceed the penal charges applicable to non-individual borrowers for similar defaults.

Events Triggering Penal Charges

• Penal charges may be levied upon occurrence of any material event of default, including but not limited to:
• failure to pay any instalment or other amount on the scheduled due date;
• dishonour of repayment instruments including ECS, NACH, Auto Debit or similar payment mandates;
• breach of any material covenant contained in the loan agreement;
• submission of false, inaccurate or misleading information affecting the loan;
• misuse of loan proceeds where usage restrictions are applicable;
• any other material breach identified under the loan agreement.
• The above list is illustrative and not exhaustive.

Quantum of Penal Charges

• Unless otherwise approved for a specific product, the Company may levy penal charges as under:

• The Company may revise the above charges from time to time with appropriate approvals and disclosures.

Disclosure of Penal Charges

• The Company shall ensure that:
• penal charges are clearly disclosed in the Loan Agreement and the Key Fact Statement (KFS);
• the applicable Schedule of Charges is made available on the Company's website;
• borrowers are informed whenever penal charges are levied;
• the reason for levy of penal charges is communicated through appropriate customer communication channels.

• In addition to interest, the Company may recover such fees and charges as are applicable to the relevant loan product.

• These charges are intended to recover the cost of services provided by the Company and shall be reasonable, transparent and disclosed upfront.

• Depending upon the nature of the loan product, the Company may levy one or more of the following charges:
• Processing Fee;
• Documentation Charges;
• Credit Assessment Charges;
• Loan Origination Charges;
• Payment Gateway Charges;
• ECS/NACH Registration Charges;
• ECS/NACH Bounce Charges;
• Cheque Bounce Charges;
• Collection Charges;
• Recovery Expenses;
• Statement of Account Charges;
• Duplicate Document Charges;
• Security Swap Charges (where applicable);
• Loan Restructuring Charges;
• Customer Service Charges;
• Portfolio Monitoring Charges;
• Legal Expenses incurred for recovery;
• Taxes and statutory levies, including GST, as applicable;
• any other charges specifically disclosed in the Schedule of Charges.

• The nature and amount of applicable charges may vary depending upon the loan product, customer category, operational requirements and applicable law.
• All applicable charges shall be disclosed to the borrower through the:
• Key Fact Statement (KFS);
• Sanction Letter;
• Loan Agreement; and
• Schedule of Charges published by the Company.

Any revision in fees or charges shall operate prospectively and shall be communicated in accordance with applicable regulatory requirements

• The Company shall provide borrowers with a cooling-off or look-up period wherever mandated under applicable RBI guidelines or as approved for a particular loan product.

• During such period, a borrower may exit the loan by repaying:
• the principal amount disbursed; and
• the proportionate Annual Percentage Rate (APR) and other permissible charges for the period during which the loan remained outstanding.

• No penal charge shall be levied if the borrower exercises the exit option within the applicable cooling-off period.

• The duration of the cooling-off period shall be disclosed in the Key Fact Statement (KFS) and the Loan Agreement.

• The Company may permit foreclosure or prepayment of loans in accordance with the terms of the respective loan product and applicable RBI guidelines.

• Where foreclosure is permitted:
• the borrower shall remain liable to pay interest accrued up to the date of actual repayment;
• foreclosure charges, if any, shall be levied only in accordance with applicable regulatory directions and the Schedule of Charges.

• Presently, the Company does not permit part-prepayment of its loan products unless specifically approved under any product programme or mandated by applicable law.

• The Company is committed to ensuring that borrowers are provided with complete, accurate and timely information regarding the cost of borrowing and all applicable financial obligations.

• Accordingly, the Company shall ensure that:
• The applicable rate of interest, Annual Percentage Rate (APR), processing fee, penal charges, and all other applicable fees and charges are clearly disclosed to the borrower before execution of the loan agreement.
• The borrower is provided with a Key Fact Statement (KFS) containing all material financial terms and conditions of the loan in accordance with applicable RBI guidelines.
• All loan-related documents, including the Sanction Letter, Loan Agreement and KFS, clearly specify the applicable interest rate, repayment schedule, tenure, applicable charges and penal charges.
• The Company shall maintain complete transparency regarding the pricing of its loan products and shall not levy any charge that has not been disclosed to the borrower in advance, except where such levy is mandated under applicable law.
• Any revision in interest rates or charges applicable to future transactions shall be communicated through one or more of the following channels, as applicable:
• Company's website;
• mobile application;
• borrower dashboard/customer portal;
• e-mail;
• SMS;
• other digital communication channels recognised by the Company.

• The Company believes that informed borrowers make better financial decisions. Accordingly, the Company shall adopt fair and transparent practices throughout the lending lifecycle.

• The Company shall ensure that:
• borrowers are adequately informed about the pricing methodology and applicable charges before availing the loan;
• all communications are clear, simple and capable of being understood by borrowers;
• no hidden charges are levied;
• recovery-related charges and penal charges are separately disclosed and are not included within the contractual rate of interest;
• customer queries relating to interest computation, fees or penal charges are addressed promptly through the Company's customer service and grievance redressal mechanism.

• The Company recognises that exceptional business circumstances may occasionally require deviations from the standard pricing framework.

• Accordingly:
• Any deviation from the interest rate ranges, fee structure or penal charges prescribed under this Policy shall be permitted only with the approval of the authority authorised under the Company's Delegation of Authority (DOA) or other internal approval framework.

• Such deviations shall be based on documented commercial or risk considerations and shall not result in violation of any applicable RBI guideline or law.

• Appropriate records of all approved deviations shall be maintained by the concerned business unit for audit and regulatory review.

• Board of Directors
• The Board of Directors shall:
• approve this Policy and any subsequent amendments;
• oversee implementation of the Company's pricing framework;
• periodically review the effectiveness of the Policy;
• ensure compliance with applicable RBI regulations.

• Management
• The Management shall be responsible for:
• implementing the Policy across all lending operations;
• ensuring that pricing decisions are consistent with the approved framework;
• monitoring changes in market conditions and recommending revisions where necessary;
• ensuring appropriate disclosures are made to borrowers.

• Risk Management Function
• The Risk Management function shall:
• periodically review the appropriateness of the risk-based pricing framework;
• monitor portfolio behaviour and credit risk trends;
• recommend suitable changes in pricing where necessary.

• Compliance Function
• The Compliance Department shall:
• monitor compliance with this Policy;
• assess regulatory developments affecting pricing or penal charges;
• recommend amendments whenever required;
• facilitate regulatory inspections relating to implementation of this Policy.

• Internal Audit
• The Internal Audit function shall periodically examine compliance with this Policy and report any material observations to the Audit Committee and the Board, wherever applicable.

• The Company shall maintain appropriate records relating to:
• pricing approvals;
• interest rate revisions;
• Board approvals;
• Schedule of Charges;
• deviations approved under this Policy;
• disclosures made to borrowers;
• customer acknowledgements, wherever applicable.
• Such records shall be maintained for the period prescribed under applicable laws and the Company's Record Retention Policy.

• This Policy shall always be read together with:
• the Reserve Bank of India Act, 1934;
• the RBI (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025;
• RBI Digital Lending Guidelines;
• RBI guidelines relating to Key Fact Statement (KFS);
• Fair Practices Code adopted by the Company;
• any circular, notification, clarification or direction issued by RBI from time to time.
• Where any provision of this Policy is inconsistent with any applicable law or RBI direction, the applicable regulatory requirement shall prevail, and this Policy shall be deemed to stand modified to the extent of such inconsistency.

• This Policy shall be reviewed at least annually or earlier if required due to:
• amendments in applicable laws or RBI regulations;
• significant changes in the Company's business model;
• changes in funding costs;
• changes in the Company's risk appetite;
• recommendations made by the Board, Audit Committee, Compliance Department or Internal Audit.
• Any amendment to this Policy shall become effective only after approval by the Board of Directors or such authority as may be authorised by the Board.

• Any question relating to interpretation of this Policy shall be referred to the Compliance Department, whose recommendation shall be placed before the competent authority wherever necessary.

• The interpretation adopted by the Company shall always be consistent with applicable laws and RBI directions.

Indicative Interest Rate Matrix

*Floating-rate products may be introduced in future subject to Board approval and applicable regulatory requirements.

Indicative Schedule of Penal Charges

All penal charges shall be separately disclosed in the Loan Agreement, Key Fact Statement (KFS), Schedule of Charges and the Company's website.

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