Responsible Collection Policy

1. Why this policy exists

Our clients' names are on every conversation we have. A debtor business is a counterparty that owes money, not an adversary. We recover commercial dues by verifying the claim, stating the position accurately, making the consequence of non-payment clear as a process, and following through — lawfully and on the record. This policy sets out what that means and what happens when someone falls short of it.

2. Principles

1. We act for a client, and we say so. Every contact identifies Kenstone, the client, the amount and the reference. We are not the creditor, and we never imply we are a court, a government body, the police, a bank, a bureau or a law firm.
2. We contact the business, not the private lives of the people in it.
3. We state facts and process, never threats. What will happen, when, and on whose decision — never a consequence that is not actually available or intended.
4. We record everything and will show the record.
5. A dispute stops the pressure until it is looked at.
6. Money goes to the client, through official channels, with a record.
7. Nothing is filed and nothing is conceded without the client's written decision.

3. Conduct we prohibit

No Kenstone practitioner, field collector, contractor or agent may, in relation to any debtor or any person connected to a debtor:

4. Standards we follow

4.1 Identification

Every call opens with the collector's name, "Kenstone Capital", the client's name and the reference. Every email and message carries the same. Every field collector carries a photo identity card issued by Kenstone and a case-specific authorisation letter naming the client and the matter, and produces both on request. A debtor may verify a collector by calling +91 80 6824 8827.

4.2 Authorisation

A collector acts on a matter only after it is allocated on Kenstone's collection platform. The Authority for that matter (what may be discussed, proposed or conceded) is recorded on the file before first contact. Anything outside it is referred to the client.

4.3 Permitted contact times and channels

Monday to Saturday, 9 AM to 6 PM IST, excluding notified public holidays, through the business's telephone, business email, business WhatsApp number, registered office, and premises. If the debtor nominates a contact person or channel in writing, we use it.

4.4 Commercial-premises visits

Visits are to business premises only, during business hours, by identified staff, with the file on hand. The collector asks for the person responsible for payables, states the purpose, does not discuss the debt with reception staff or bystanders beyond asking for the right person, does not disrupt operations, leaves when asked, and records the visit (time, place, persons met, outcome) on the platform the same day. Two collectors attend where a prior visit was hostile. No visit is made to a residence except under a written authorisation supported by an independent advocate's confirmation of a lawful basis.

4.5 Call recording

We do not record calls at present. When call recording is introduced, the collector will say so at the start of every recorded call, and the Electronic Communications and Call-Recording Notice will be updated before recording begins to explain how recordings are used and kept.

4.6 Debtor verification before contact

Before first contact we confirm from the client's documents and public registries that the entity, the representative and the contact details belong to the debtor. If a contact says they are not connected to the debtor, contact stops and the file is re-verified.

4.7 Professional language

Calm, specific, in the language the contact prefers where we can. We describe the claim, the documents, what the client has asked for, the options, and what the next step will be and when. We do not raise our voice, mock, moralise or speculate about the debtor's finances or character.

4.8 Disputed debts

A dispute — about quantity, quality, price, delivery, credit notes, set-off or the amount — is recorded in the debtor's words, acknowledged in writing, and referred to the client. Collection of the disputed part pauses until the client responds. We do not tell a debtor that a dispute is "not our concern".

4.9 Vulnerable persons

Debtors are businesses, but the people we speak to are individuals. If a contact tells us of serious illness, bereavement, or another circumstance that makes contact inappropriate at that time, we note it, stop for a reasonable period, and ask for an alternative contact at the business.

4.10 Third parties and advisers

If a debtor appoints an advocate, insolvency professional or other adviser and tells us so in writing, we deal with the adviser on that matter.

4.11 Insolvency

If a debtor is under a moratorium or in liquidation, all collection contact stops and the matter is referred to the client and an independent advocate.

5. Complaints and escalation

Any person — a debtor, its staff, a client, a member of the public or a Kenstone employee — may report conduct under this policy to info@kenstonecapital.in (subject: "Grievance Officer"), by post to the Bengaluru office, or through the Debtor Complaint form at https://www.kenstonecapital.in/debtor-complaint. The Grievance Redressal Policy sets out acknowledgement (two working days), reference numbers, investigation and closure. Where a complaint alleges intimidation, unauthorised disclosure, a fake notice or a money irregularity, contact on that matter is paused while it is investigated.

6. Monitoring, investigation and consequences

• Monitoring: every contact is logged; call notes and messages (and, once introduced, call recordings) are sampled monthly by a supervisor who did not handle the account; field reports are reviewed weekly; debtor complaints are reviewed by the Grievance Officer.
• Investigation: by a person not involved in the matter, against the record (logs, recordings, messages, visit reports), with the complainant and the staff member both heard.
• Corrective action: apology and correction to the affected person; retraining; withdrawal of the matter from the collector; process change.
• Discipline: under the Employee and Agent Disciplinary Matrix — from warning to summary termination and, where the conduct may be criminal, referral to the police. Contractors in breach are removed from all matters.
• Audit: an annual audit of this policy's operation is reported to the directors.

7. Whistleblowing

Employees and contractors who report a breach in good faith are protected from retaliation. Reports may be made to any director in person or in writing marked "Confidential — for the Directors" to the Bengaluru office, and anonymously by post.

8. Regulated-entity work

Kenstone Capital is empanelled with more than 30 banks and financial institutions, each through the lender's own empanelment and due-diligence process under the Reserve Bank of India's guidelines on outsourcing and recovery agents. On those mandates — including enforcement of security interest under the SARFAESI Act — the lender's code of conduct, its written instructions and the Reserve Bank's requirements for recovery agents apply in addition to this policy, and the stricter rule prevails. Possession and sale under the SARFAESI Act are acts of the lender's authorised officer; Kenstone supports that process and does not act in its own name. Concerns about work done on a lender's behalf may be raised with us under the Grievance Redressal Policy and with the lender through its own grievance mechanism.

9. Review

This policy is reviewed annually and after any upheld complaint that reveals a gap. Earlier versions are available on request.

10. Contact

Kenstone Capital Debt Consulting Private Limited · Sabari Complex, Field Marshal Cariappa Road, Shanthala Nagar, Ashok Nagar, Bengaluru 560025 · +91 80 6824 8827 · info@kenstonecapital.in · Grievance Officer Shraddha Rathod, Head of B2B Collections, info@kenstonecapital.in (subject: "Grievance Officer").

Earlier versions of this document are available on request from info@kenstonecapital.in. Questions or complaints: Grievance Redressal Policy.