The Reserve Bank of India (“RBI”) vide the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 (RBI/DOR/2025-26/362, DOR.MCS.REC.No.281/01-01-039/2025-26 dated November 28, 2025), Chapter III, and subsequently amended, updated from time to time, advises that the Non-Banking Financial Companies (NBFCs) and their Board of Directors undertake a comprehensive review of their internal principles and procedures and implement an interest rate model that factors in critical elements and relevant factors such as the cost of funds, margin, and risk premium in order to determine the rate of interest to be charged for loans and advances. This model aims to serve as the basis for determining the interest rates applicable to loans and advances, ensuring alignment with RBI guidelines and promoting financial stability and responsible lending practices in the NBFC sector.
Unicap Investments Private Limited (hereinafter referred to as “The Company” or “Unicap”) shall adopt all such guidelines prescribed from time to time and shall make appropriate modifications if necessary, to this policy to conform to the standards so prescribed. The Company shall comply with all applicable regulatory requirements governing interest rates, pricing of loans, charges, penal charges, Key Fact Statement (KFS), disclosure and fair lending practices, including the RBI (NBFCs – Miscellaneous) Supervisory Directions, 2026, and any subsequent amendments, directions or instructions issued by RBI from time to time.
The Company shall periodically review this Policy and make such modifications as may be necessary to ensure continued compliance with applicable regulatory requirements. In compliance with these regulatory requirements and the Fair Practices Code adopted by the Company, the Company has adopted this Interest Rate Policy broadly outlining the Interest Rate Policy broadly outlining the Interest Rate model and the Company’s approach of risk gradation in this regard for its lending business.
Determine Internal Benchmark rates for the borrower to finalise the rate of Interest to be charged from the borrower.
The Company shall maintain a documented methodology for determining the applicable rate of interest for different categories of borrowers and loan products. The methodology shall take into account, as appropriate, cost of funds, operating and administrative costs, credit and default risk, tenor, product characteristics, borrower risk profile, margin and other relevant factors.
The Company shall maintain appropriate parameters for gradation of risk and the rationale for charging different rates of interest to different categories of borrowers. The methodology and its material changes shall be approved by the Board of Directors or an authority duly authorised by the Board.
Publish the interest rates on the company's website to ensure accessibility and transparency, and keep the published rates updated whenever they are revised.
Board of Directors: The Board of Directors of the Company shall oversee this Interest Rate Policy and ensure its effective implementation, including its annual review (or earlier, upon any change in the RBC Directions). the Board may delegate the responsibility of implementation of this Policy and other functioning aspects to the Chief Compliance Officer/Executive Director /or Committee as it deems fit.
The Company applies a per-day interest rate on its loan products. The applicable interest rate is determined after considering the following factors:
Interest shall accrue only from the date on which the loan amount or relevant part thereof is actually disbursed to the borrower. The Company shall not charge interest from the date of sanction, execution of the Loan Agreement or any earlier date where the funds have not actually been disbursed to the borrower. In case of part-disbursement, interest shall be charged only on the amount actually disbursed and outstanding from the respective date of disbursement. The Company's systems and processes shall be configured to ensure that the date and amount of actual disbursement are appropriately captured for the purpose of interest computation.
Where a loan is disbursed, partly disbursed, prepaid or otherwise repaid during a month, interest shall be calculated only for the period during which the relevant amount remains outstanding, in accordance with the agreed interest calculation methodology disclosed to the borrower. The Company shall not charge interest for any period during which the relevant loan amount was not outstanding with the borrower. The Company shall ensure that interest, instalments and repayment obligations are calculated with reference to the actual amount disbursed to the borrower, unless otherwise expressly agreed with the borrower and permitted under applicable regulatory requirements.
The Company shall not calculate interest or repayment obligations on the undisbursed portion of a sanctioned loan amount. Where any instalment or repayment amount is collected in advance, the Company shall ensure that such advance collection does not result in charging of interest on an amount or for a period during which the corresponding loan amount is not outstanding, except to the extent expressly permitted under applicable regulatory requirements and the contractual terms disclosed to the borrower.
The interest rate for credit facilities extended by the Company is driven by Internal Benchmark rate of the Company plus the risk premium associated with the borrower/facility.
The Credit Risk Premium for the loan product offered by our Company is determined for the customers to account for potential credit loss risks. It is evaluated based on the following factors:
The Rate of Interest that shall be charged to the customers for availing its loan product shall be mentioned in the Key Fact Statement and the Loan Agreement
The approach and rationale for the gradation of risk resulting in different interest rates for different categories of borrowers shall be disclosed to the customer in the application form, communicated explicitly in the sanction letter, and shall also be published on the Company’s website, in accordance with the RBC Directions.
Interest rates would be intimated to the customers, in the vernacular language or a language as understood by the borrower, at the time of sanction / availing of the loan. Repayment Amount will be made available to customer in the sanction letter as well as the Loan Agreement.
The Company will mention penal charges charged for late repayment in bold in the loan agreement. The Interest rate shall not be discriminatory and shall be determined in a non-arbitrary manner for borrowers falling under similar risk categories, in compliance with applicable RBI regulations
All processing, documentation, and other charges levied are explicitly stated in the loan documents. They generally reflect the costs incurred in providing services to customers. Market practices, including those of competitors, are also considered when determining these charges. No fee, charge, or cost that is not disclosed in the Key Facts Statement shall be levied on the borrower at any stage of the loan, without the borrower's explicit consent.
Penal charges are applicable in cases of making default by the borrower. The amount and rationale for penal charges shall be clearly communicated to customers through the loan agreement and sanction letter.
The Company shall compute and disclose the APR for all loan products in the KFS, representing the total annualised cost of credit including all applicable charges.The calculation methodology shall comply with RBI guidelines and be clearly communicated to the borrower before execution of the loan agreement. The KFS shall be issued in the standardised format prescribed by RBI, shall carry a unique proposal number, and shall remain valid for a minimum of three working days (where loan tenor is seven days or more) or one working day (where loan tenor is less than seven days), during which the borrower may agree to the disclosed terms.
The Company shall adopt a fair and non-discriminatory approach in determining interest rates based on objective criteria such as credit risk, cost of funds, and business considerations.No borrower shall be discriminated against on grounds such as gender, religion, caste, region, or any other prohibited basis, ensuring equitable treatment within similar risk categories.
Where a loan is sourced through a digital lending platform or application, The Company shall provide a KFS to borrowers before loan execution, including details of APR, total borrowing cost, repayment schedule, penal charges, and recovery mechanisms, in accordance with RBI's guidelines/directions on Digital Lending, as amended from time to time. The KFS shall be provided in a language understood by the borrower. The contents of the KFS shall be explained to the borrower, wherever required, and an acknowledgement of receipt and understanding shall be obtained in accordance with applicable regulatory requirements.
The KFS shall be consistent with the sanction letter and Loan Agreement. Any fee, charge or other amount which is required to be disclosed in the KFS and is not disclosed therein shall not be subsequently charged to the borrower, except where such charge is subsequently permitted and expressly consented to by the borrower in accordance with applicable RBI requirements.
Where the Company undertakes digital lending activities, the Company shall comply with the applicable RBI Digital Lending Directions, including requirements relating to KFS, cooling-off period, disclosures, customer consent, data protection and grievance redressal. A cooling-off/look-up period shall be offered, allowing borrowers to exit the loan by paying principal and proportionate charges without penalty, as per regulatory guidelines.
The Company shall maintain an effective grievance redressal mechanism for complaints related to interest rates, charges, and lending practices, with defined escalation channels, consistent with the Grievance Redressal Mechanism set out in the Company's Fair Practices Code. If unresolved within the stipulated time, borrowers may approach the RBI under the applicable RBI Complaint Management System/RBI Ombudsman, and all grievance details shall be available on the Company’s website and loan documents.
The Company shall ensure that its loan management, accounting and other relevant systems are configured to give effect to the interest rate methodology and charging practices prescribed under this Policy.
The Company shall periodically review its systems and processes to ensure that interest is calculated on the actual amount disbursed and outstanding for the relevant period and that the system does not result in charging of interest or other amounts contrary to applicable RBI requirements.
Any identified deviation shall be promptly rectified and, where necessary, appropriate corrective and preventive measures shall be implemented.
This Policy shall be reviewed at least annually and also whenever there is a material change in applicable RBI regulations, the Company's business model, loan products, interest rate methodology, technology systems or market conditions.
Any material amendment to this Policy shall be placed before the Board of Directors for consideration and approval. The Company shall also ensure that corresponding changes, wherever required, are implemented in its loan documentation, customer disclosures, systems and operating procedures.