Code of Conduct for Recovery Agents (Recovery Policy)

MoneyCloud is a brand of STARLINE UTILITY SERVICES PRIVATE LIMITED. All loans on the MoneyCloud platform are provided by AASRA FINCORP PRIVATE LIMITED (“the Company”), CIN U65921UP1995PTC086551, incorporated on April 17, 1995, RBI-registered NBFC (Reg. No. B12.00466), with registered office at Flat No.: 1001, 10th Floor, Wave Silver Tower, Captain Vijayant Thapar Marg, Sector 18, Noida, Gautam Buddha Nagar, Uttar Pradesh - 201301. This Code of Conduct for Recovery Agents is based on RBI guidelines on Fair Practice Code for NBFCs. The Company is engaged exclusively in digital lending activities. The Code reflects the Company's commitment to the highest standards of good corporate governance, ethical conduct, transparency, fairness and accountability.

This code applies to all persons involved in collection/recovery of any loan or financial product of the company. Any employee/collection agent found violating this code may be terminated permanently. This Policy applies to all loan accounts where any instalment or repayment falls due on or after 01st December, 2025.

The company conducts once in every week, a training program for all its Collection-Recovery Agents.

Prohibited Harsh Methods in Recovery:

The agents are strictly prohibited from engaging in any harsh methods towards recovery. Following practices are deemed harsh:

• Use of threatening or abusive language
• Persistently calling the borrower and/or calling before 9:00 AM and after 6:00 PM
• Harassing relatives, friends, or co-workers
• Publishing the name of borrowers
• Use or threat of use of violence or similar means to harm the borrower or borrower's family/assets/reputation
• Misleading the borrower about extent of debt or consequences of non-repayment

Pre-Default Communication:

The Company may send 2 reminders to the Borrower, first by SMS and second at least five days before the due date.

Post-Default Communication:

Upon Event of Default, the Company may use contact details provided by the Borrower to communicate. Any such communication shall be conducted in a civilized and lawful manner, without harassment, intimidation, coercion, physical or verbal abuse. No anonymous calls. All communications only between 08:00 AM and 07:00 PM.

Reference Contact:

If Borrower fails to respond, the Company may contact the references provided by the Borrower for obtaining updated contact information.

Recovery Location:

Recovery shall ordinarily be conducted at a mutually agreed designated place. However, if repayment remains unpaid after 30 days from due date, the recovery agent may visit the Borrower at their place of residence or work.

The company carries out verification of antecedents of its employees/Recovery Agents periodically, which includes police verification.

The company issues identity cards to its recovery agents. They must carry notice and appropriate authorization to initiate recovery. If recovery agency is changed, the new agent shall carry the notice, authorization letter and identity card. Details of recovery agents are hosted on the company website.

The company shall refrain from interference in affairs of borrower except for purposes in the loan agreement. The company has put in place a Grievance cell at info@moneycloud.in, Customer Care: 9899900468, Complaint Helpline: 9899900468 to report inappropriate behavior of recovery agents.

Repayment / Collection Account Details:

The Company shall recognise incipient stress by classifying accounts as Special Mention Accounts (SMA). The following table outlines the SMA classification criteria:

This code is placed on the website. The Board will periodically review compliance of this Code and the functioning of the grievance redressal mechanism.