Grievance Redressal Mechanism (Policy) of Aureus Finvest Private Limited (Formerly known as "Shivdurga Trading Private Limited")

1. INTRODUCTION

Aureus Finvest Private Limited(“the Company”/“Aureus”) (formerly known as Shivdurga Trading Private Limited)has adopted this Grievance Redressal Policy (“Policy”) in compliance withapplicable regulatory requirements prescribed by the Reserve Bank of India(“RBI”), including but not limited to the Fair Practices Code, the DigitalLending Guidelines 2022 and the RBI Integrated Ombudsman Scheme 2021.
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The Policy establishes a structured,system-driven, and time-bound grievance redressal framework for receiving,recording, tracking, and resolving customer complaints arising out of theCompany’s products, services, and digital lending operations.
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The scope of this Policyexpressly includes complaints originating from services provided throughthird-party service providers, digital lending applications (DLAs), lendingservice providers (LSPs), agents, and business facilitators. The Companyacknowledges that outsourcing of activities does not dilute itsresponsibility, and it shall remain fully accountable for grievanceredressal in all such cases.
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This Policy is designed notmerely as a statement of intent but as an operational control framework,ensuring transparency, accountability, auditability, and regulatory compliancein grievance handling. It also aims to ensure that customers are adequatelyinformed of escalation mechanisms, including recourse available under the RBIOmbudsman framework.

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2. PURPOSE

This Policy aims to establish a time-bound,transparent, and system-driven grievance redressal mechanism to ensureprompt and effective resolution of customer complaints in compliance withapplicable RBI regulations.The Policy seeks to achieve the followingobjectives:Customer complaints shall betreated as a critical input for improving operational efficiency, riskmanagement, and customer service standards, and shall be periodicallyreviewed by senior management and the Board.
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• Ensure time-bound resolution of complaints  within defined Turnaround Times (TATs), with clear accountability at each level
• Provide a structured and auditable framework for receipt, classification, tracking, escalation, and  closure of complaints
• Enable root cause analysis and corrective action, with a view to preventing recurrence of similar complaints
• Ensure seamless integration of grievance handling across physical and digital channels, including complaints arising from DLAs and LSPs
• Strengthen customer confidence and  protection, by ensuring transparency in communication and access to escalation mechanisms, including those under the RBI Integrated Ombudsman     Scheme 2021

3. Scope Of POLICY

This Policy shall be applicable across alloperations of the Company, including all branches, offices, employees, andrepresentatives, and shall cover all customer interactions across thelifecycle, including prospective, existing, and former customers, in respect ofall products and services offered by the Company.

The scope of this Policy explicitly extends to all digitaland physical customer touchpoints, including the Company’s digital lendingapplication “Klinq”, website, call centres, and any other technology-enabledplatforms.

Further, this Policy shall apply to all activitiescarried out through third-party service providers, lending service providers(LSPs), agents, and business facilitators, engaged by the Company. TheCompany shall ensure that:

• All complaints arising through such outsourced or digital channels  are captured within the Company’s grievance redressal system
• There is no dilution of responsibility and the Company  remains fully accountable for grievance redressal
• Adequate oversight, monitoring, and control mechanisms are in place over such entities in line with applicable RBI outsourcing and     digital lending guidelines
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This Policy shall also cover complaints receivedthrough regulatory and external platforms, including but not limited tothe Complaint Management System (CMS) of RBI, CPGRAMS, and other statutory orjudicial forums.

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4. Key PRINCIPLES

The Company adopts the principles of the RBI’s Charter of Customer Rights as the foundational framework for customerprotection. These principles are operationalised through defined processes,systems, and controls within the grievance redressal mechanism, as detailedbelow:

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4.1. Right to Equitableand Fair Treatment

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The Company shall ensure that allcustomer interactions, including complaint handling, are conducted in a fair,unbiased, and non-discriminatory manner. Any complaint alleging discriminationon grounds such as gender, age, religion, caste, or physical ability shall beclassified as a high-priority complaint and escalated for immediatereview. Periodic monitoring shall be undertaken to identify patterns ofdiscriminatory practices, if any.

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4.2. Right to Transparency

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The Company shall ensure that allcustomer grievances relating to product terms, charges, or disclosures areaddressed with complete transparency. Complaints relating to non-disclosure,hidden charges, or misleading communication shall be specifically tracked andsubjected to root cause analysis, including review of Key FactStatements (KFS), loan agreements, and customer communication practices.

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4.3 Right to Suitability

The Company shall ensure thatcomplaints arising from inappropriate product offerings, mis-selling, orunsuitable credit decisions are identified, monitored, and reviewed. Suchcomplaints shall be analysed to assess deficiencies in credit underwriting, customerprofiling, or sales practices, and corrective actions shall be implemented.
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4.4 Right to Privacy and Customer Confidentiality

All complaints involvingunauthorized use, breach, or misuse of customer data shall be treated as criticalincidents and escalated on priority. The Company shall ensure that suchcomplaints are investigated with defined timelines and reported to appropriateinternal authorities, with necessary corrective and preventive actions.
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4.5 Right to Grievance Redressal and Compensation

The Company shall maintain anaccessible, system-driven grievance redressal mechanism with clearly definedTurnaround Times (TATs), escalation matrix, and audit trails. Wheredeficiencies in service result in financial or non-financial loss to the customer,the Company shall evaluate the need for appropriate compensation or remedialaction, in line with regulatory expectations and internal policies.

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5.  Definitions

a. “Competent Authority”means the Managing Director / Chief Executive Officer or such other seniorofficial(s) as may be authorized by the Board to exercise oversight anddecision-making in respect of grievance redressal matters.
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b. “Complaint” means anywritten, oral, or electronic communication from a customer or on behalf of acustomer, alleging deficiency in service, unfair practice, mis-selling,unauthorized charges, data breach, or any other grievance relating to theCompany’s products or services, and seeking resolution or relief.
For the purpose of this Policy, the definition of “Complaint” shall be alignedwith that prescribed under the RBI Integrated Ombudsman Scheme 2021.
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c. “Customer” means aperson who has availed, is availing, or has expressed intent to avail anyfinancial product or service offered by the Company, including users of digitalplatforms operated by or on behalf of the Company.

d. “Deficiency in Service”means any act of omission, negligence, or inadequacy in the quality, nature, ormanner of performance of services, whether statutory or contractual, which mayresult in financial or non-financial impact on the customer.
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e. “Query” / “Request”

• Query     means a customer communication seeking information, clarification, or  status, which does not involve a complaint or deficiency in service.
• Request means a customer-initiated instruction or service requirement, such as account modification, document issuance, or transaction-related  processing.
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f. “Ombudsman” means anOmbudsman appointed by the Reserve Bank of India under the Integrated OmbudsmanScheme, 2021, as amended from time to time.
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g. “Grievance RedressalCommittee” means a committee constituted by the Company with clearlydefined roles and responsibilities, including review of complaint trends, rootcause analysis, escalation handling, and oversight of the grievance redressalframework.
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h. “High-Risk Complaint”means complaints involving allegations of fraud, mis-selling, harassment, databreach, regulatory non-compliance, or any matter having potential legal orreputational impact on the Company.

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6. Responsibilities of Grievance Redressal Committee

 I    The Grievance Redressal Committee (“the  Committee”) shall function as the central oversight body for  monitoring the effectiveness, adequacy, and regulatory compliance of the  Company’s grievance redressal framework.

 II    The Committee shall, inter alia, be responsible  for the following:

III   Oversight  of Grievance Redressal Framework:
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To ensure that a system-driven,  auditable, and time-bound grievance redressal mechanism is implemented  across the Company, including all digital platforms, DLAs, and LSPs.

IV  Monitoring  of Complaint Trends and Risks:

To review periodic MIS reports capturing volume,  nature, category, ageing, and status of complaints, including identification  of high-risk complaints and emerging risk areas.
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 V   Root Cause Analysis and Corrective Action:
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To ensure that complaints are subjected to  structured root cause analysis, and that corrective and preventive actions  (CAPA) are identified, tracked, and closed within defined timelines.
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VI  TAT and  Escalation Monitoring:
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To monitor adherence to prescribed Turnaround  Times (TATs), including review of TAT breaches, reasons thereof, and  implementation of accountability measures.
All unresolved complaints beyond defined timelines shall be escalated  automatically and reviewed by the Committee.
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VII  Oversight  of Rejected and Escalated Complaints:
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To review cases where complaints are partially or  fully rejected, ensuring that such decisions are reasoned, documented, and  communicated transparently to customers.

VIII  Regulatory  Compliance Oversight:
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To ensure compliance with applicable RBI  guidelines, including those relating to digital lending, outsourcing, and  customer protection.
 Any complaints received through regulatory channels (e.g., CMS, CPGRAMS)  shall be specifically tracked and monitored.
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IX   LSP and  Outsourcing Oversight:
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To monitor complaints arising from services  provided through LSPs, agents, and third-party service providers, and ensure  that accountability is not diluted and appropriate corrective actions  are taken.
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 X    Reporting to the Board:
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To submit periodic reports to the Board, including:

a.  Complaint statistics and trends  

b.  Root cause analysis findings

c.  Status of corrective actions

d.  Significant complaints and  regulatory issues

XI  Data  Integrity and Classification Review:
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To ensure that all customer communications are  correctly classified as Query, Request, or Complaint, based on defined  criteria, and that such classification is system-driven and auditable.
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XII  Customer  Protection Focus:
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To ensure that grievances relating to vulnerable  categories, including persons with disabilities, are addressed in a fair,  equitable, and non-discriminatory manner.
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XIII  The Committee shall meet at  least once every quarter, and more frequently, if warranted, based on  volume or severity of complaints.

XIV Review the MIS on a quarterly  basis and directing the department for corrective measures. The Company shall  ensure that grievances raised by persons with disabilities are addressed in a  fair, equitable, and non-discriminatory manner.
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7. Role of the board

 I   The Board of Directors shall  exercise overall oversight and strategic supervision over the  grievance redressal framework of the Company and shall ensure that the  mechanism is effective, responsive, and aligned with regulatory expectations.

II     The Board shall, inter alia,  undertake the following:
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a)    Quarterly Review of Grievance Redressal  Framework:

Review the effectiveness of the grievance  redressal mechanism, including adherence to the Fair Practices Code and  applicable RBI guidelines.

b)    Review of Complaint Metrics and Trends:

Examine periodic reports on the volume, nature,  classification, and ageing of complaints, including identification of high-risk  and recurring complaint categories.

c)    Root Cause Analysis and Corrective Action:

Review key findings arising from root cause  analysis of complaints and ensure that corrective and preventive actions  (CAPA) are implemented and monitored.

d)    Oversight of TAT and Customer Outcomes:

Evaluate adherence to prescribed Turnaround Times  (TATs), including analysis of delays, customer impact, and remedial measures  undertaken.

e)     Review  of Rejected and Escalated Complaints:

Examine cases of complaint rejection, partial  resolution, and escalation, including assessment of adequacy, fairness, and  transparency in resolution.

f)     Regulatory and Audit Observations:

Review findings from internal audit, statutory  audit, and regulatory inspections relating to grievance redressal, and ensure  timely remediation of identified gaps.

g)    Oversight of Digital and Outsourced Ecosystem:

Specifically review complaints arising from  digital lending platforms, DLAs, LSPs, and outsourced arrangements, and  ensure that accountability remains with the Company at all times.

h)    Strategic Direction and Policy Review:

Provide guidance on process improvements,  customer protection measures, and technological enhancements to strengthen  the grievance redressal mechanism.

i)      External and Environmental Factors:

Consider the impact of changes in regulatory  requirements, technology, business models, and organizational structure on  the grievance redressal framework.

III     The Board shall ensure that adequate  MIS, dashboards, and analytics are placed before it to enable informed  decision-making and effective oversight.

8. Channels – Lodgement of a  Query/Request/Complaint

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I  Customers may register queries,requests, or complaints through multiple channels provided by the Company, asdetailed below:
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a.Inbound calls through the Customer Service Helpline (+91 99091 08215)‍

b.E-mails through the designated grievance redressal email ID (grievance@myklinq.com)
c. Physical channels, including written communication, complaint registers, andcomplaint boxes at Company offices

d.Digital platforms, including the Company’s Digital Lending Application “Klinq”and its official website

e.External and regulatory platforms, including but not limited to RBI’s ComplaintManagement System (CMS), CPGRAMS, RBI DAKSH, consumer forums, and courts of law
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II   The Company shall ensure that allcomplaints received through the above channels are mandatorily:

a)  Captured in a centralized Complaint ManagementSystem (CRM) with a unique identificationnumber

b)   Time-stamped at the point of receipt, irrespective of the channel through which thecomplaint is received

c)   Acknowledged to the customer within a definedtimeline, through SMS, email, or otherappropriate means

d)   Tracked end-to-end until resolution and closure, with complete audit trail of actions taken

e)   Integrated across channels, ensuring that complaints received through LSPs,DLAs, or third-party platforms are not handled outside the Company’s system
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II  The Company shall ensure that nocomplaint remains unrecorded, untracked, or handled outside the centralizedsystem, irrespective of the channel of receipt.

III   Further, complaints receivedthrough regulatory platforms (such as CMS or CPGRAMS) shall be taggedseparately, monitored on priority, and responded to strictly withinprescribed regulatory timelines.

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9. Classification ofcustomer Queries, Requests and Complaints

All  customer communications received by the Company shall be systematically  classified into Queries, Requests, and Complaints through a standardized  and system-driven classification framework, to ensure consistency,  auditability, and appropriate handling.

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9.1 Classification Categories

 
• Query:
        Any customer communication seeking information, clarification, or  status, which can be resolved without further processing or  investigation and does not indicate dissatisfaction or deficiency in  service.
 
• Request:
        Any customer-initiated instruction requiring processing, action, or fulfilment, such as account modification, issuance of documents, transaction-related services, or service activation/deactivation.
 
• Complaint:
        Any expression of dissatisfaction, whether explicit or implicit, relating to products, services, processes, charges, employee conduct, digital platforms, or third-party service providers, including cases involving alleged deficiency in service.
 

9.2 Risk-Based Classification  of Complaints

In addition to the above categorization, all complaints shall be further classified based on risk  and severity, as under:

 
• High-Risk Complaints:
 
• Complaints involving fraud, mis-selling,data breach, unauthorized transactions, harassment by recovery agents, regulatory violations, discrimination, or reputational risk.
        Such complaints shall be escalated within 24 hours and monitored at senior management level.
 
• Medium-Risk Complaints:
        Complaints involving service deficiencies, delays, operational issues, or recurring complaints requiring investigation.
 
• Low-Risk Complaints:
        Minor service-related issues with limited customer impact and capable of  resolution within standard timelines.
 

9.3 System-Based Classification  and Controls

The Company shall ensure that:

 
• Classification of all communications is system-driven and rule-based, minimizing manual subjectivity
 
• Each complaint is assigned appropriate category, sub-category, and risk level within the CRM system
 
• Complaints arising from DLAs, LSPs, agents, or outsourced entities are tagged and tracked separately
 
• Misclassification, if any, is subject to periodic review and correction
 

9.4 Monitoring and Analytics

The classification framework  shall be used to:

 
• Identify emerging trends and recurring  issues
 
• Enable root cause analysis
 
• Support regulatory reporting and  Board-level MIS
 
• Detect systemic issues, mis-selling  patterns, and operational gaps
 

Indicative  lists of Queries, Requests, and Complaints, as provided in this Policy, shall  serve as guidance; however, classification shall be based on substance of  the communication rather than form.

10. Internal Machinery & TAT

The  Company shall operate a centralized, system-driven Customer Relationship  Management (CRM) platform as the core engine for grievance redressal,  ensuring end-to-end tracking, monitoring, and resolution of all customer  communications.

The CRM system shall  mandatorily:

 
• Capture all complaints,  queries, and requests with unique identification number and   time-stamp at the point of receipt
 
• Record key parameters  including customer ID, complaint category, sub-category, risk classification, channel of receipt, and priority level
 
• Enable automated  allocation of complaints to appropriate teams based on predefined rules and expertise
 
• Maintain a complete  audit trail of all actions taken, including communication with the customer and internal notes
 
• Trigger automated  alerts and escalations in case of delays or breach of defined  Turnaround Times (TATs)
 
• Provide real-time  dashboards and MIS for monitoring at management and Board levels
 

The  Company shall adopt a risk-based Turnaround Time (TAT) framework, as  under:

 
• High-Risk Complaints: To be acknowledged immediately and resolved       on priority, with escalation within 24 hours
 
• Other Complaints and  Requests: To be resolved within a  maximum period of 14 working days, unless a shorter timeline is  prescribed
 
• Regulatory Complaints: To be responded to strictly within  timelines prescribed by the regulator, and in any case, within 30 days from the date of receipt
 

In all  cases, customers shall be acknowledged promptly, informed of expected  timelines, and kept updated in case of delays, with reasons recorded in the  system.

The CRM  framework shall ensure that complaints originating from Digital Lending  Applications (DLAs), Lending Service Providers (LSPs), and other outsourced  entities are fully integrated into the Company’s system, and are not  handled outside the centralized framework.

Notwithstanding  any outsourcing arrangements, the Company shall retain full responsibility  and accountability for grievance redressal, and shall ensure that  adequate controls and monitoring mechanisms are in place to oversee such  activities.

11. ALLOCATION

Upon classification, eachcustomer communication shall be systematically allocated through the CRMplatform to the appropriate team or individual, based on predefined rulesensuring efficiency, accountability, and timely resolution.

Allocation shall be governed by the followingprinciples:

• Expertise-Based Allocation:

Complaintsshall be routed to specialized teams based on the nature and complexity of theissue, including customer service, operations, technical support, collections,compliance, or risk management functions.

• Risk-Based Allocation:

High-riskcomplaints (including fraud, mis-selling, data breach, harassment, orregulatory complaints) shall be immediately escalated and assigned to seniorpersonnel or designated escalation teams, with appropriate oversight.

• Regulatory and Statutory Complaints:

Complaintsreceived from regulatory, statutory, or judicial authorities (including CMS,CPGRAMS, or courts) shall be directly routed to compliance or seniormanagement, and monitored on priority.

• Workload and Timeliness Considerations:

Allocationshall take into account team capacity and workload; however, suchconsiderations shall not override risk classification or regulatory priority.

• Defined Ownership and Accountability:

Eachcomplaint shall have a clearly identified owner responsible forresolution, with accountability for adherence to TAT and quality of response.
Reassignment, if any, shall be recorded in the system with reasons.

• System Controls and Auditability:

Allocation,reassignment, and closure actions shall be system-driven and fully auditable,ensuring traceability of responsibility at all stages.

The Company shall ensure thatgrievances raised by vulnerable categories, including persons withdisabilities, are identified, prioritized, and handled in a fair, equitable,and non-discriminatory manner, with appropriate sensitivity and support.

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12. TIME FRAME

The Company shall adhere to a clearlydefined, risk-based, and time-bound Turnaround Time (TAT) framework forhandling all customer communications, ensuring prompt resolution and minimizingcustomer inconvenience.
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12.1 Acknowledgement of Complaints

All complaints shall be acknowledgedwithin 24 hours of receipt (excluding non-working days), throughappropriate channels such as SMS, email, or system-generated communication.
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12.2 Resolution Timelines

• Queries: To be responded to within 3 working days
• Requests: To be processed and resolved within 7 to 14 working days, depending on the nature and complexity
• Complaints:
   
  • Standard complaints to be resolved within 14 working days
   
  • High-risk complaints (including fraud, mis-selling, data breach, harassment, regulatory complaints) to be prioritized and escalated within 24 hours, and resolved on priority basis

12.3 Regulatory Complaints

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Complaints received throughregulatory platforms (including RBI CMS, CPGRAMS, or other statutoryauthorities) shall be:

• Immediately escalated to compliance function
• Responded to strictly within prescribed regulatory timelines
• In all cases, final response shall be     provided within 30 days from the date of receipt of complaint by the  Company
  
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12.4 Delay Handling and Customer Communication

In cases where resolution is likely to exceeddefined timelines:

• The customer shall be informed of the delay along with reasons thereof
• Revised timelines shall be communicated and recorded in the system
• Such cases shall be automatically escalated within the CRM system
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12.5 Ombudsman Escalation

If a complaint is not resolvedwithin 30 days from the date of receipt, or if the customer is notsatisfied with the resolution provided, the customer may approach the Ombudsmanunder the RBI Integrated Ombudsman Scheme 2021 through the RBI ComplaintManagement System (CMS) or other prescribed channels.

The Company shall ensure that customers are adequatelyinformed of such escalation options at the time of final response

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13. Review and Monitoring

13.1 The Company shall establisha structured and data-driven review and monitoring framework to ensurecontinuous improvement in grievance redressal, identification of systemicissues, and strengthening of customer protection mechanisms.

13.2 The review and monitoring framework shallinclude:

1. Periodic MIS and Dashboard Review:

Regularreview of detailed MIS reports capturing complaint volumes, categories, riskclassification, ageing, resolution timelines, and channel-wise distribution,supported by system-generated dashboards.

2. Trend Analysis and Early Warning Signals:

Identificationof recurring complaints, emerging risk areas, and abnormal spikes in complaintcategories, enabling early detection of systemic issues.

3. Root Cause Analysis (RCA):

Allsignificant and recurring complaints shall be subjected to structured rootcause analysis, with documentation of findings and linkage to corrective andpreventive actions.

4. Corrective and Preventive Action (CAPA):

Implementationand tracking of corrective measures arising out of complaint analysis, withdefined timelines and accountability for closure.

5. TAT and Escalation Monitoring:

Continuousmonitoring of adherence to Turnaround Times (TATs), including identificationand review of delays, escalation handling, and customer impact.

6. LSP and Outsourcing Monitoring:

Specificmonitoring of complaints arising from Digital Lending Applications (DLAs),Lending Service Providers (LSPs), and other outsourced arrangements, ensuringthat service deficiencies and risks are identified and addressed.

7. Regulatory and Audit Feedback Integration:

Incorporationof observations from internal audit, regulatory inspections, and supervisorycommunications into the grievance redressal framework, with appropriate actiontaken.

8. Customer-Centric Monitoring:

Assessmentof customer satisfaction indicators, complaint closure quality, andeffectiveness of communication with customers.

13.3 The Grievance RedressalCommittee shall periodically review the above parameters and ensure that identifiedgaps, risks, and process deficiencies are addressed in a time-bound manner.

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14. Review and Monitoring

14.1 The Company shall maintain aclearly defined, transparent, and time-bound escalation mechanism toensure that customers have access to higher levels of authority in case ofnon-resolution or dissatisfaction.
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Level 1 – Grievance RedressalOfficer (GRO)
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Customers shall, in the firstinstance, lodge their complaints with the Grievance Redressal Officer (GRO)through any of the designated channels.

Details of GRO:

Name: Ms. Sujata Sunchiuri
Designation: Grievance Redressal Officer
Address: Office No. 4I, 4th Floor, Dwarika R N Agarwala Signature Complex, Opp.Brahma Kumaris, Burdawan Road, Siliguri, Darjeeling, West Bengal – 734005
Contact: +91 99091 08215
Email: grievance@myklinq.com

The GRO shall:

• Acknowledge complaints within 24 hours
• Ensure resolution within defined Turnaround Times (TATs)
• Provide a reasoned response to the customer
• Inform the customer about escalation options in case of     dissatisfaction
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Level 2 – Nodal Officer
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In case the customer does notreceive a response within the stipulated timelines or is not satisfied with theresponse provided by the GRO, the complaint may be escalated to the NodalOfficer.

Details of Nodal Officer:

Name: Mr. Ankit Sanghvi
Designation: Nodal Officer
Address: Office No. 4I, 4th Floor, Dwarika R N Agarwala Signature Complex, Opp.Brahma Kumaris, Burdawan Road, Siliguri, Darjeeling, West Bengal – 734005
Contact: +91 99091 08215
Email: nodalofficer@myklinq.com
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The Nodal Officer shall:

• Review escalated complaints independently
• Ensure fair, unbiased, and transparent resolution
• Monitor cases involving delays, rejections, or customer dissatisfaction
• Ensure that responses are provided within regulatory timelines    
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System-Driven Escalation Controls

The Company shall ensure that:

• Escalation is not solely dependent on customer  action, but is also system-triggered in case of TAT breaches
• All escalations are tracked within the CRM  system with clear audit trail
• Repeated escalations or unresolved complaints  are flagged for senior management and Committee review
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Customer Awareness

Customers shall be clearly informed, at the time ofcomplaint acknowledgment and closure, about:

• The escalation matrix
• Contact details of the GRO and Nodal Officer
• Their right to approach the Ombudsman in case of non-resolution

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15. Complaints to Ombudsman

In case a customer does notreceive a response from the Company within a period of 30 days from thedate of lodging a complaint, or is not satisfied with the response provided,the customer may approach the Ombudsman under the RBI Integrated OmbudsmanScheme 2021.

Complaints may be filed through the followingmodes:

• Online through the Complaint Management System  (CMS) portal: https://cms.rbi.org.in
• Through electronic or physical submission to  the Centralised Receipt and Processing Centre (CRPC), Reserve Bank     of India, Chandigarh
• Through the Contact Centre (Toll-free number:     14448), during prescribed working hours

·      Forsalient features of the Ombudsman Scheme, please refer to our website https://www.myklinq.com/. A copy of the Ombudsman Scheme is available onthe website of the Reserve Bank of India at www.rbi.org.in and also with our Nodal Officer.

The Company shall ensure that:

• Customers are clearly informed of their  right to approach the Ombudsman at the time of final response or  rejection of complaint
• Details of the Ombudsman Scheme, including  process and contact details, are displayed prominently on the Company’s website and digital platforms
• A copy/link of the Ombudsman Scheme is  made available to customers upon request
  

The Company shall ensure thatresponses provided to customers are reasoned, documented, and compliant,so as to facilitate fair resolution and minimize escalation to the Ombudsman.

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16. Complaints to Ombudsman

Grievances relating to digital applications, data processing, data privacy, and customer information securityshall be treated with high priority and sensitivity, given theirpotential impact on customer trust and regulatory compliance.

Customers may raise suchgrievances through any of the channels specified in this Policy, includingwebsite, mobile application, email, phone, or other digital interfaces.

The Company shall ensure that:

• All complaints relating to unauthorized  access, data breach, misuse of personal information, or privacy concerns  are classified as high-risk complaints and escalated on priority
• Such complaints are acknowledged  immediately and investigated within defined timelines, with  involvement of appropriate internal functions such as IT, information  security, compliance, and risk management
• A complete audit trail of   investigation, actions taken, and resolution is maintained within the     system
• Customers are informed of the status and  outcome of investigation, including any corrective actions taken

The Company shall also ensurethat grievances arising from Digital Lending Applications (DLAs), LendingService Providers (LSPs), or third-party service providers involving customerdata are fully captured within the Company’s grievance redressal system,and that accountability for resolution remains with the Company.

Where any complaint indicates a systemicissue or potential data security vulnerability, the same shall be escalatedto senior management and reviewed for corrective and preventive action,including strengthening of controls and processes."
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17. Display – Grievance Redressal Policy

The Company shall ensure that theGrievance Redressal Policy is prominently displayed and easily accessibleto customers across all customer touchpoints, including:

• The Company’s official website (https://www.myklinq.com/)
• Digital Lending Applications (DLAs) and mobile applications
• Customer portals and login interfaces
• Physical offices and branches, where applicable
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The display shall include, at a minimum:

• Contact details of the Grievance Redressal  Officer (GRO) and Nodal Officer
• The escalation matrix, including  timelines and levels of escalation
• Details of the RBI Integrated Ombudsman  Scheme 2021, including customer rights and complaint filing process
• Links to RBI portals such as Sachet (https://sachet.rbi.org.in) for reporting unauthorized     schemes

The Company shall ensure that such information is:

• Clear, simple, and customer-friendly, avoiding technical complexity
• Regularly updated, ensuring accuracy of contact details and  processes
• Displayed in a manner that enables customers to easily access grievance redressal channels and escalation options

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18. Sensitizing Operating Staff on Handling Complaints

The Company recognizes that effectivegrievance redressal is critically dependent on the competence, sensitivity, andaccountability of its staff and associated personnel.
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Accordingly, the Company shallestablish a structured training and sensitization framework for allemployees, agents, and personnel involved in customer interaction and complainthandling, including those associated with Digital Lending Applications (DLAs),Lending Service Providers (LSPs), and outsourced functions.

The framework shall include:

• Periodic Training Programs:

Regulartraining on grievance handling procedures, regulatory requirements, customerprotection principles, and communication standards

• Behavioral and Sensitivity Training:

Trainingfocused on courtesy, empathy, non-discrimination, and fair treatment,particularly in handling vulnerable customers and sensitive complaints

• Regulatory Awareness:

Ensuringstaff are adequately aware of applicable RBI guidelines, including customerrights, grievance redressal timelines, and escalation mechanisms

• Complaint Handling Standards:

Trainingon classification, documentation, response quality, and adherence to definedTurnaround Times (TATs)

• Accountability and Performance Linkage:

Incorporationof grievance handling performance, including complaint resolution quality andadherence to timelines, into employee performance evaluation frameworks,wherever applicable

• Monitoring and Feedback:

Periodicassessment of staff performance through review of complaint handling, customerfeedback, and audit observations

The Company shall ensure thatstaff and associated personnel do not engage in any conduct that may resultin customer grievance, including mis-selling, harassment, or unfairpractices, and any deviations shall be subject to appropriate correctiveaction.

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19. Customer Education

The Company shall undertake continuousand structured customer education initiatives to enhance customerawareness, promote informed decision-making, and strengthen access to grievanceredressal mechanisms.

The Company shall ensure thatcustomers are adequately informed about:

• Key features of products and services, including terms, conditions, charges, and   risks
• Key Fact Statements (KFS) and their importance in understanding loan terms
• Customer rights, including the right to fair treatment, transparency, privacy, and grievance redressal
• Grievance redressal process, including channels for lodging complaints, escalation matrix, and timelines
• Availability of recourse under the RBI Integrated Ombudsman Scheme 2021
• Risks associated with digital lending, unauthorized transactions, and fraudulent schemes, and preventive     measures

Customer education shall becarried out through multiple channels, including:

• Website and mobile applications
• Digital communication (SMS, email, in-app notifications)
• Customer onboarding and communication materials
• Awareness campaigns and informational content

The Company shall ensure thatsuch communication is clear, simple, and easily understandable, enablingcustomers to make informed decisions and effectively exercise their rights.

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20. Modifications/Amendments/Revisionto the Policy

This Policy shall be subject to periodic review and revision to ensure continued alignment with applicableregulatory requirements, evolving business practices, and emerging risks.
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Any modification, amendment, orrevision issued by the Reserve Bank of India (RBI) or any other applicableregulatory authority shall be promptly incorporated into this Policy,and such changes shall be deemed to form an integral part of the Policy.

The Policy shall be:

• Reviewed at least once in every financial year, or more frequently, if required, based on:
   
  • Changes in regulatory framework
   
  • Observations from internal audit, regulatory inspection, or supervisory communication
   
  • Significant changes in business model, products, or technology

o   Emerging risks, including those relating to digitallending and outsourcing

• Approved by the Board of Directors or   appropriate Committee thereof, With documented review and approval process
• Updated versions of the Policy shall be communicated   internally to relevant stakeholders and made available to customers   through appropriate channels, including the Company’s website

The Company shall ensure that allrevisions are tracked, version-controlled, and documented, maintainingan audit trail of changes made over time.

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