Code of Conduct

Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Finance Companies (NBFCs) defining the standards for fair business and corporate practices while dealing with customers, vide Circular number RBI/2006-07/138 DNBS (PD) CC 80/03.10.042/2005-06 dated 28th Sept 2006, and Master Circular RBI/2014-15/34 DNBS (PD) CC No.388/03.10.042/2014-15 dated 1st July, 2014. Nitstone Finserv Pvt Ltd. (herein after referred to as “the Company”) is committed to abide by the said guidelines and has published the Fair Practices Code - FPC in line with the RBI guidelines, aimed to provide effective overview of practices followed by the Company in respect of the facilities and services offered by the Company to its customers. Further, the Company notes to effect appropriate modifications in the FPC as per the directives issued by RBI from time to time. The Fair Practices Code shall apply to all lending activities of the Company. The commitments made in the FPC are applicable under normal operating environment.

Details of Nitstone Finserv’s compliance with the Fair Practice Code can be found in our Fair Practice Code Policy

Obligations of senior financial officers

In addition to Nitstone’s purpose, values and vision and the Fair Practice Code Policy ,the Chief Executive, Chief Financial Officer and Chief Accounting Officer or persons performing similar functions (the ‘Senior Financial Officers’) are subject to and must comply with the following principles:

• Each Senior Financial Officer shall engage in honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
• Each Senior Financial Officer shall avoid conflicts of interest and shall disclose to the Chairman of the Audit Committee any material transaction or relationship of which they are aware that reasonably could be expected to give rise to such conflict
• Each Senior Financial Officer shall take such measures as appropriate to ensure that Nitstone complies with all applicable governmental laws, rules and regulations and provides full, fair, accurate, timely and understandable disclosure in reports and documents that it files with, or submits to, any securities regulatory authority including the Reserve Bank of India (RBI), and in other public communications it makes

Board responsibilities

The Board aims to promote Nitstone’s long-term success, deliver sustainable value to our shareholders, and promote a culture of openness and debate. Led by the Chairman, the Board sets the Nitstone’s strategy and risk appetite.

The Board of Directors either through itself or by through any Committee thereof shall also provide for periodical review of the compliance of the FPC of the Company and the functioning of the grievances redressal mechanism at various levels of management. This is described in page 26-27 of the Fair Practice Code Policy

As described in page 7 of the RBI Resolution Policy , the Board is to carry out the following activities with regard to resolution plan arrangements:

• To approve the Resolution Policy in order to implement the measures for the customers.
• To ensure that the above instructions are properly communicated down the line in their respective organizations, and clear instructions are issued to their staff regarding their implementation.