Fair Practices Code: Viva Money Loan App

Fair Practices Code – VIVA Money

INTRODUCTION

Vivamoney is a Lending Service Provider (‘LSP’) and have a Digital Lending Application (‘DLA’) that offers a personal loan in partnership with NBFC FincFriends Private Limited which is registered in accordance with applicable laws as a non-deposit taking Non Banking Financial Company (‘NBFC’) with the Reserve Bank of India (RBI).

As working with NBFCs is a very crucial part of the operations, Viva endeavours to review and follow the policy guidelines laid down by RBI to set up fair business practices while dealing with its customers. This Code considers regulatory documents published by regulatory bodies (referred as ‘Applicable Laws’), in particular: The Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 (the ‘RBC Directions’), which govern responsible business conduct, the Fair Practices Code, Key Facts Statement, penal charges, reset of floating interest rates, pre-payment charges, release of security documents, conduct of recovery agents for NBFCs, and which have repealed and superseded the erstwhile ‘Fair Practice Code (Chapter VII)’ under the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, the RBI notification on Key Facts Statement (KFS) for Loans & Advances dated April 15, 2024 the RBI notification on Fair Practices Code for Lenders – Charging of Interest dated April 29, 2025, each of which now stands repealed; (b) the Reserve Bank of India (Digital Lending) Directions, 2025 [RBI/2025-26/36, DOR.STR.REC.19/21.07.001/2025-26, dated May 8, 2025], as amended from time to time; and (c) the Reserve Bank – Integrated Ombudsman Scheme, 2021 dated November 12, 2021.

The Company shall always adopt best business and customer service practices from time to time and make appropriate modifications, as necessary to this Code. The management of the Company will ensure that the implementation of this FPC becomes the responsibility of the entire organization and its employees. The fair lending practices shall apply to its entire business operations including marketing, loan origination, processing, servicing and collection activities. Its commitment to FPC will be demonstrated in terms of employee accountability, training, counselling, monitoring, auditing programs, internal controls, optimal use of technology and empathy to service the needs of its customers. At the same time, we will remain cognizant of our customer’s need for privacy and confidentiality for their personal data lending practices shall apply to its entire business operations including marketing, loan origination, processing, servicing and collection activities.

OBJECTIVES OF CODE

Promote good and fair practices by setting minimum service standards in dealing with the customer;
Increase transparency so that the customer can have a better understanding of what they can reasonably expect from the services of the Company;
Encourage market forces, through competition, to achieve higher operating service standards;
Promote a fair and cordial relationship with the customer.

APPLICATION OF CODE

This Code shall apply to all the products and services provided by the Company across the counter, over the phone, by post, through interactive electronic devices, on the internet, or by any other method.
This code will be applicable to all our customers (which as the context permits it shall include prospective customers, customers who have applied for loan/credit limit increase with us but loan not sanctioned/ disbursed/credit limit not increased in addition to the customers who are in receipt of loan amount from the Non-Banking Financial Companies [NBFCs]).

COMPANY’S KEY COMMITMENTS

The Company shall always act fair and reasonable in dealings with its customer(s) by adhering to the principles of integrity and transparency at all times.
The Company shall meet all the legal and regulatory requirements and fulfil standards provided in this Code while soliciting any products and services.
The Company shall ensure that all advertising and promotional material is clear, and not misleading.
The Company shall ensure transparency in communication and provide information on interest rates, fees and charges in the loan document or on its website.
The Company may, from time to time, communicate to customer about various features of products/services availed by them including information about third party products/services or promotional offers after obtaining prior consent from the customer.
The Company shall implement transparent Code of Conduct for its Direct Selling Teams (DST’s)/Tele callers/Collection Agencies in line with the FPC.
The Company shall always preserve the privacy and confidentiality of personal information provided by Customer as per the laws of the country.

APPLICATIONS FOR LOANS & THEIR PROCESSING

At the time of sourcing a Loan, Viva will provide Information about the indicative range of annualized Rate of Interest (RoI) for the loan product availed, pre-payment options, fees, financial charges and other charges, if any, and any other matter which affects the interest of the customer, so that a meaningful comparison with those of other lenders can be made and informed decision is taken by the customer.
The loan application shall contain the list of documents required to be submitted with the application form.
Every loan application completed in all respects shall be duly acknowledged by the Company and authorized personnel. The time frame for disposing loan applications shall be indicated to the customer.
All Communications to the customer will be in the English, or in a vernacular/regional language as understood by the customer.

LOAN APPRAISAL AND TERMS & CONDITIONS

As a standard process, all information required for processing the application shall be collected at the time of loan application itself. In case any additional information is required for credit and risk assessment, the customer shall be again contacted on an immediate basis.
The Company shall conduct a due diligence on the credit worthiness of the customer, which will be an important parameter for taking decision on the application. The assessment would be in line with the partner NBFCs credit policies, norms and procedures in respect thereof.
The Company shall convey in writing to the customer in English, or in a vernacular/regional language as understood by the customer, the Loan Sanctioned along with the Terms & Conditions and Key Fact Statement (KFS) thereof including annualized RoI, method of application, EMI Schedule, and any other charges if any.
The Company shall keep the written acceptance of all these terms and conditions by the customer in its records. Penal interest and late payment charges shall be highlighted in bold to sensitize and clearly convey to the Customers about consequences of delay in payment of periodic instalments and/or any breach of the terms of the loan agreement and sanction letter.
The Company shall provide copies of all the loan documents executed by the customer along with a copy of each of its enclosures as per the Loan Documentation to every customer, after loan disbursement.

KEY FACTS STATEMENT (KFS)

Prior to execution of the loan contract, the Company shall ensure every prospective borrower is provided a Key Facts Statement (KFS) in the standardised format prescribed under Annex I of the RBC Directions, in a language understood by the borrower; its contents shall be explained to the borrower and the borrower’s acknowledgement of having understood the same shall be obtained.
The KFS shall bear a unique proposal number and remain valid for a minimum of three working days where loan tenor is seven days or more, and for one working day where tenor is less than seven days. The Company shall be bound by the terms indicated in the KFS if the borrower agrees within this validity period.
The KFS shall include a computation sheet of the Annual Percentage Rate (APR) being the annualised cost of credit inclusive of interest and all other charges and an amortisation schedule of the loan over its tenor.
Charges recovered by the Company on behalf of third-party service providers (e.g., insurance, legal charges) on an actual basis shall form part of the APR, be separately disclosed, and be supported by receipts furnished to the borrower within a reasonable time.
No fee or charge not disclosed in the KFS shall be levied on the borrower at any stage of the loan without the borrower’s explicit consent. The KFS shall also be exhibited as a summary box forming part of the loan agreement.

PENAL CHARGES ON LOAN ACCOUNTS

Any penalty charged for non-compliance of material terms and conditions of the loan contract, including default in repayment, shall be levied only as ‘penal charges’ and not as ‘penal interest’ added to the rate of interest. There shall be no capitalisation of penal charges, and no further interest shall be computed on such charges (although normal compounding of interest on the loan account, including on unpaid EMI, at the contracted rate shall continue until remediation).
Penal charges shall be reasonable and commensurate with the non-compliance, levied only on the amount in default, applied in a non-discriminatory manner within a loan/product category pursuant to the Company’s Board-approved policy, and shall not be used as a revenue enhancement tool. No fresh penal charge shall be levied on an already outstanding amount of penal charges.
Penal charges applicable to individual borrowers availing loans for purposes other than business shall not be higher than those applicable to non-individual borrowers for similar non-compliance.
The quantum and reason for penal charges shall be disclosed upfront in the loan agreement and KFS, and displayed on the Company’s/partner NBFC’s website under interest rates and service charges; a mere reference to the website schedule in the sanction letter/loan agreement shall not suffice. Applicable GST, if any, shall follow instructions issued by the Central Board of Indirect Taxes & Customs.
Whenever a reminder for non-compliance is sent, the applicable penal charges shall be communicated; any actual levy of penal charges, together with the reason, shall likewise be communicated to the borrower.

PRE-PAYMENT CHARGES ON LOANS

No pre-payment charges shall be levied on floating rate loans sanctioned for purposes other than business to individual borrowers (with or without co-obligant(s)), irrespective of the source of funds used for pre-payment (in part or full) and without any minimum lock-in period.
The applicability, or otherwise, of pre-payment charges shall be clearly disclosed in the sanction letter, loan agreement and KFS. No pre-payment charge that has not been so disclosed shall be levied, and no charge earlier waived shall be levied retrospectively at the time of pre-payment.
No pre-payment charge shall be levied where pre-payment is effected at the instance of the Company or its partner NBFC.

LOAN FACILITIES TO PERSONS WITH DISABILITIES

The Company shall not discriminate in extending its products and facilities, including loan facilities, to physically or visually challenged applicants on grounds of disability, and shall render all possible assistance to such persons in availing its services.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

Disbursement shall be made in accordance with the disbursement schedule and/or terms agreed with the customer as per the Loan Agreement/Sanction Letter.
The Company shall give notice to the customer in English or a language as understood by the customer of any change in the terms and conditions including disbursement schedule, RoI, service charges, pre-payment charges, other applicable fee/charges etc. The Company shall also ensure that changes in RoI and charges are affected only prospectively with prior intimation to the customer. A suitable condition in this regard shall be incorporated in the loan agreement.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

Disbursement shall be made in accordance with the disbursement schedule and/or terms agreed with the customer as per the Loan Agreement/Sanction Letter.
The Company shall give notice to the customer in English or a language as understood by the customer of any change in the terms and conditions including disbursement schedule, RoI, service charges, pre-payment charges, other applicable fee/charges etc. The Company shall also ensure that changes in RoI and charges are affected only prospectively with prior intimation to the customer. A suitable condition in this regard shall be incorporated in the loan agreement.

COLLECTION OF DUES

At the time of giving a loan to the customer, Viva shall convey to the customer the repayment process including instalment amount, tenure, bounce charges, penal interest and periodicity of repayment. However, if the customer does not adhere to the repayment schedule, a defined process in accordance with the laws of the land under but not limited to The Payment and Settlement Systems Act, 2007 and Negotiable Instruments Act, 1881 shall be followed for recovery of loan dues. The process will involve reminding the customer by sending him / her notice or by making personal visits.
In line with the aforesaid, a Code of Conduct which shall be adhered during collections/recovery of dues from the customers by Company’s authorized personnel is provided in Annexure A.

GRIEVANCE REDRESSAL MECHANISM

Viva believes in providing utmost importance to customer services which includes addressing the customer’s grievances on a priority level. In case of any service request/complaints, the customer may contact the customer engagement team on any of the below mentioned contact points:

Grievance Redressal Officer

Mr. Syamprasad Reddy
Grievance Officer gro@vivamoney.in; chat@vivamoney.in
+91-8884000361
Vivamoney Solutions Private Limited
BHIVE Workspace, No.467/468, Shri Krishna Temple Road,
Indiranagar 1st Stage, Bengaluru, Karnataka

Additionally, the Company informs the customer about the Grievance Redressal Mechanism which is provided on our partner NBFCs website. On receipt of service request / complaint, an acknowledgement shall be given within 5 (five) working days by us to the customer via email/ letter by post/ SMS/any other form of legally valid electronic communication including WhatsApp. The Company shall endeavour to respond to the same within a period of 10 (ten) working days.

However, in case where a complaint warrants extensive investigation and/or support of the customer to identify the perpetrator, root cause analysis, or under litigation (including pending with local Police authorities), the Turn Around Time (TAT) for responding and resolving such complaints may be more than 10 (ten) working days.

GENERAL

The Company shall not discriminate on grounds of sex, caste & religion in the matters of lending.
All personal information of customer and information related to the transactions with the Company shall be treated confidential, shall not be revealed to anyone, except with customer’s prior written consent and/or required by laws and regulations.
The Company shall publicize the Code as under:
•    Provide existing and new customers with a copy of this Code, whenever requested;
•    Disclose this Code on the website of the Company; and
•    Periodic trainings to all the customer facing staff about the fair business practices as mentioned in this Code.
The Company shall periodically review this Code basis its business and regulatory requirements.
Periodic reports on the customer complaints (entailing the number and nature of the complaints received, ageing of complaints, adherence to TATs, root cause details of the complaints in which service deficiencies are found) shall be submitted to the Board of Directors / Audit Committee at regular intervals.

ANNEXURE A

Following Code of Conduct shall be adhered by all authorized personnel of the Company while engaging in any manner with the customer(s) for Collections of loan dues:

The code of conduct for collections shall be followed diligently by all staff members of the Collection team.
Foster customer confidence, long term relationship and ensure dignity and respect to customers is maintained.
Courtesy, fair treatment and persuasion shall be the basis of recovery. Unduly coercive methods in collection of dues shall not be adopted.
Fairness and transparency in repossession, valuation and realization of securities shall be made.
Customers would be contacted ordinarily at the place of their choice. In the absence of any specified place, at their place of residence and if unavailable there, then at the place of business/ occupation. During visits to customer(s) place for dues collection, decency & decorum shall be maintained.
Identity and authority to represent Viva shall be made known to the customer(s) at the first instance.
No interference in the affairs of the customer (s). Interaction with them shall be in a civil manner without use of muscle power for recovery.
Authorized Representatives shall only contact the customer between 08:00 a.m. and 7:00 p.m.
Customer’s request to avoid calls at a particular time / particular place shall be honoured to the extent possible.
Customer would be provided with all the information regarding dues and necessary notice would be given for enabling discharge of dues.
At all times, as far reasonably possible, endeavour to resolve disputes / differences regarding dues in a mutually acceptable and orderly manner.
Inappropriate occasions such as bereavement in the family or such other calamitous occasions would be avoided for making calls/visits.
Confidentiality of customer information shall be always maintained.
Demeanour that suggests criminal intimidation or resorting to harassment (verbal or physical) including acts intended to publicly humiliate or intrude the privacy of debtors/family members/friends is strictly prohibited.
Not send inappropriate messages either on mobile or social media.
The Company Shall not make any kind of false and misleading representations to the
customer.
Necessary caution shall be taken to ensure that minors are not contacted for financial transactions. More importantly communications related to collections/recovery of dues shall be with the customers/loan applicants (i.e. person attaining majority).
The Company shall not publish, or threaten to publish, the names of any customer/borrower as a means of recovery and shall not resort to intimidation or harassment of any kind verbal or physical including acts intended to publicly humiliate or intrude upon the privacy of the borrower’s family members, referees or friends.
The Company shall carry out a due diligence process, including verification of antecedents (which shall include police verification) of personnel of any recovery agency engaged by it, and shall decide the periodicity of re-verification of such antecedents.
Before initiating recovery, the Company shall furnish details of the recovery agent/agency to the borrower. The agent shall carry a copy of the notice and authorisation letter issued by the Company, together with the identity card issued to the agent by the Company or the agency; the notice and authorisation letter shall also include the contact details of the recovery agency and the Company. Where the recovery agency is changed during the recovery process, the new agent shall similarly carry the notice, authorisation letter and identity card, and the borrower shall be notified of the change.
Up-to-date details of all recovery agencies engaged by the Company shall be hosted on the Company’s/partner NBFC’s website.
The Company shall not engage any Direct Sales Agent (DSA)/Direct Marketing Agent (DMA) as a telemarketer unless such person holds a valid registration certificate from the Department of Telecommunications (DoT), Government of India, and is registered in terms of the guidelines issued by the Telecom Regulatory Authority of India (TRAI) for promotional/telemarketing activities. The Company shall furnish the list of such telemarketers, along with the registered telephone numbers used by them, to TRAI, and shall ensure that all agents presently engaged register themselves with DoT as telemarketers.

Last Updated: 31.08.2026