Outsourcing Policy
MoneyCloud
MoneyCloud — STARLINE UTILITY SERVICES PRIVATE LIMITED
NBFC-ICC | Non-Deposit Taking | Non-Systemically Important (ND-NSI)
RBI Reg No.: B12.00466
CIN: U65921UP1995PTC086551
INTRODUCTION
MoneyCloud ("the Company"), having Corporate Office at Flat No.: 1001, 10th Floor, Wave Silver Tower, Captain Vijayant Thapar Marg, Sector 18, Noida, Gautam Buddha Nagar, Uttar Pradesh - 201301 and Registered Office at Flat No.: 1001, 10th Floor, Wave Silver Tower, Captain Vijayant Thapar Marg, Sector 18, Noida, Gautam Buddha Nagar, Uttar Pradesh - 201301 adopts this Outsourcing Policy in alignment with the RBI (Non-Banking Financial Companies – Managing Risks in Outsourcing) Directions, 2025, RBI/DOR/2025-26/363DOR.ORG.REC.No.282/21-04-158/2025-26 dated November 28, 2025.
PURPOSE
This Policy sets out guiding principles and governance framework for outsourcing arrangements, ensuring they enhance operational efficiency while safeguarding interests of customers. It establishes clear roles, responsibilities, and oversight mechanisms so the Company retains ultimate accountability over all outsourced functions.
KEY RESPONSIBILITIES OF THE COMPANY
The outsourcing of any activity does not diminish the Company's obligations. The Board shall be responsible for: approving a framework to evaluate risks and materiality, laying down appropriate approval authorities, setting up suitable administrative framework, undertaking regular review, deciding on business activities of material nature to be outsourced, approving policy for outsourcing to a group entity, and reviewing records of material outsourcing on half yearly basis.
The Audit Committee shall monitor internal audit of all outsourced activities and review ageing analysis of entries pending reconciliation.
For IT services, the Board shall put in place a framework for approval, approve policies to evaluate risks, ensure no conflict of interest.
The Company shall NOT outsource core management functions including Internal Audit, strategic and compliance functions, and decision-making functions such as KYC norms, giving sanction for loans and management of investment portfolio.
AUTHORISATION, ACCOUNTABILITY, AND OVERSIGHT
The Company shall ensure all relevant laws have been considered in due diligence, outsourcing does not impede RBI supervisory functions, does not interfere with Company's ability to manage activities, does not compromise internal control, service provider employs same high standard of care, and service provider is not owned by any director of the Company.
The Company shall be responsible for CTRs and STRs to FIU.
OUTSOURCING POLICY FRAMEWORK - CRITERIA FOR SELECTION
The Company shall outsource only appropriate activities. Prior to outsourcing, conduct due diligence to assess competence, financial soundness, reputation, experience, and compliance of service provider.
DELEGATION OF AUTHORITY
Outsourcing arrangements shall be approved based on a defined delegation framework. Material outsourcing shall require Board approval.
SYSTEMS TO MONITOR AND REVIEW
The Company shall use appropriate mechanisms to monitor and periodically review performance of service providers, including audits.
ROLE OF SENIOR MANAGEMENT
Senior Management shall be responsible for evaluating risks, developing sound outsourcing policies, reviewing effectiveness of policies, communicating material outsourcing risks to the Board, ensuring contingency plans are in place, ensuring independent review and audit, and undertaking periodic review.
CONFIDENTIALITY AND SECURITY
The Company shall ensure confidentiality, security, preservation and protection of customer information. Access to customer information shall be on a ‘need to know’ basis.
The Company shall require service provider to disclose security breaches. Must immediately notify RBI of breach of security and leakage of confidential information.
OUTSOURCING AGREEMENT
Terms shall be defined in written agreements vetted by legal counsel. The agreement shall be flexible enough to allow the Company to retain control and right to intervene.
MONITORING AND CONTROL
The Company shall maintain central record of all material outsourcing for review by Board and Senior Management. Regular audits shall assess adequacy of risk management.
Annual review of financial and operational condition of service providers.
On termination, publicise by displaying at branch, posting on website, and informing customers.
REDRESSAL OF GRIEVANCES
The Company's Grievance Redressal Machinery will deal with issues relating to outsourced services. Time limit of 30 days for preferring complaints.
If rejected wholly or partly and not satisfied, complainant can proceed towards CEPC of Regional Office of RBI.
MoneyCloud
STARLINE UTILITY SERVICES PRIVATE LIMITED | Flat No.: 1001, 10th Floor, Wave Silver Tower, Captain Vijayant Thapar Marg, Sector 18, Noida, Gautam Buddha Nagar, Uttar Pradesh - 201301
Email: info@moneycloud.in | Toll Free: 9899900468