INTEREST RATE POLICY

1. Preface

Finlix Capital Private Limited (“Finlix” or the “Company“) is a Non-Banking Financial Company (NBFC) incorporated under the Companies Act, 2013 and operates in accordance with the applicable guidelines, directions, circulars, and regulations issued by the Reserve Bank of India (RBI), together with all other applicable laws governing financial institutions in India.

This Interest Rate Policy reflects the Company’s commitment to conducting its lending business in a fair, transparent, responsible, and customer-centric manner. It has been formulated in accordance with the RBI Guidelines on Fair Practices Code for NBFCs, including the directions requiring NBFCs to publicly disclose their approach to interest rate determination and risk-based pricing.

The Board of Directors has approved this Interest Rate Policy, which establishes the guiding principles and internal framework for determining interest rates, fees, and other charges applicable to the Company’s lending products.

Finlix is committed to ensuring that all lending decisions are made fairly, consistently, and transparently while balancing customer affordability, business sustainability, and prudent risk management.

This Policy shall be read together with all applicable RBI circulars, notifications, and regulatory directions. In the event of any inconsistency between this Policy and any applicable law or RBI regulation, the applicable law or regulatory direction shall prevail.

Any clarification relating to the interpretation or implementation of this Policy shall be referred to the Compliance Officer.

The Company primarily provides financing solutions including business loans, working capital loans, loan against property, purchase financing, and other credit facilities. Accordingly, the applicable interest rate shall vary depending upon the product category, customer profile, risk assessment, and market conditions.

2. Interest Rate Determination Framework

The interest rate applicable to each loan shall be determined individually based on a comprehensive evaluation of various commercial, financial, operational, and risk-related parameters.

The key factors considered while determining the applicable interest rate include:

a) Loan Tenure

Interest rates may vary depending upon the repayment tenure of the loan. Longer tenures generally involve relatively higher credit and market risks.

b) Nature and Purpose of the Loan

The pricing of each loan shall depend upon:

• Type of loan product

• Purpose of financing

• Secured or unsecured nature of the facility

• Industry segment

• Borrower’s business profile

• Expected repayment structure

c) Cost of Funds

Interest rates shall consider both:

• External borrowing costs

• Internal cost of capital

• Expected return on shareholders’ equity

The Company may offer loans at fixed or floating interest rates, depending upon the product and prevailing market conditions.

d) Operating and Administrative Costs

The pricing model also factors in:

• Credit assessment expenses

• Loan processing costs

• Technology costs

• Operational expenses

• Compliance and servicing costs

• Geographic and transaction-specific costs

e) Customer Risk Profile

Each customer’s pricing shall be determined after evaluating:

• Creditworthiness

• Financial strength

• Income and cash flow

• Business performance

• Credit history

• Existing indebtedness

• Banking behaviour

• Repayment capacity

• Relationship history with the Company

The Company may also consider information obtained from Credit Information Companies (CICs), external databases, market intelligence, and other legally permissible sources.

f) Credit Risk Assessment

Interest rates shall reflect the overall credit risk associated with each borrower.

The risk premium may vary depending upon:

• Probability of default

• Industry risk

• Business stability

• Historical repayment behaviour

• Financial leverage

• Security coverage

g) Security and Transaction Structure

Pricing may also depend upon:

• Type and value of collateral

• Loan-to-Value (LTV) ratio

• Nature of security

• Transaction complexity

• Special structuring requirements

h) Business Margin

Interest rates shall also include a reasonable commercial margin after considering:

• Cost of funds

• Operational costs

• Credit risk

• Regulatory costs

• Sustainable profitability

3. Customer Disclosure

Finlix shall ensure complete transparency by communicating the following information to customers before loan disbursement:

• Loan amount sanctioned

• Interest rate (including annualized rate)

• Repayment schedule

• Loan tenure

• Processing fees

• Applicable charges

• Penal charges for delayed payment

• Foreclosure or prepayment charges (where applicable)

• Other terms and conditions governing the loan

All penal charges applicable for delayed repayment shall be prominently disclosed in the loan agreement.

Whenever any material modification is made to the terms of the loan—including changes in interest rate, repayment schedule, fees, or other commercial terms—the customer shall be informed through appropriate written or electronic communication.

Any change in interest rates or charges not specifically provided for under the original loan agreement shall take effect prospectively.

Foreclosure or prepayment charges shall be levied strictly in accordance with:

• Loan Agreement

• Applicable RBI Directions

• Internal Board-approved policies

4. Risk-Based Pricing Framework

Finlix follows a risk-based pricing model whereby the applicable interest rate may differ from one customer to another based on the assessed level of risk.

The risk assessment may include, among other factors:

• Customer profile and reputation

• Credit history and repayment behaviour

• Business stability

• Industry risk

• Cash flow analysis

• Existing financial obligations

• Banking relationship

• Credit bureau reports

• Type of lending product

• Loan amount

• Loan tenure

• Loan-to-Value ratio

• Nature and value of collateral

• Purpose and end-use of funds

• Regulatory requirements

• Market conditions

• Any other relevant commercial or credit considerations

The final pricing shall reflect the overall credit risk associated with the borrower.

5. Disclosure on Company’s Website

In accordance with RBI guidelines, Finlix shall publish the following information on its official website:

• Interest Rate Policy

• Broad range of applicable interest rates

• Risk-based pricing methodology

• Applicable fees and charges

• Customer disclosures required under RBI regulations

Such information shall be updated periodically whenever material changes occur.

6. Public Disclosure

The Company shall make this Interest Rate Policy publicly available on its website to promote transparency and enable customers to make informed borrowing decisions.

7. Review and Amendment

This Policy shall be reviewed periodically by the Board of Directors or whenever required due to:

• Changes in RBI regulations

• Amendments in applicable laws

• Changes in market conditions

• Business strategy

• Risk management framework

• Operational requirements

The Board reserves the right to modify, amend, or update this Policy at any time to ensure continued regulatory compliance and alignment with industry best practices.