Investment Policy

Introduction:

M/s Aurum Instafinance India Private Limited (Formerly Dico Transport corporation private Limited) was incorporated on 21/04/1987 under the Companies Act, 2013, having CIN U63090WB1987PTC042227 and situated at 33/1, N. S. Road, Room No. 247 2ND FLOOR, Kolkata, West Bengal-700001.

The Company is a registered NBFC in terms of Section 45-IA of the RBI Act, 1934 vide registration number B.-05-05595 under the classification as NBFC-Non-Systemically Important Non-Deposit taking Company, now called as NBFC- Base Layer and regulated by the RBI

The objective of investments by the company is to manage liquidity and to get reasonable

returns while ensuring safety of the Investments, which can be in any of the following manners:

i) Return on investments in the form of Dividend and/or interest, or

ii) For capital appreciation or

iii) For other benefits.

Investment Objective is also to optimize return on surplus / idle fund with adequate liquidity

and safety and to adhere to RBI’s prudential norms as applicable.

Objectives:

The Board of Directors have established the Policy parameters with regard to investment of the

funds of the Company into the instruments, products, securities etc. within the regulatory/

statutory requirements.

This policy lays out the general terms and conditions for Investments made by the Company.

This policy covers all operational guidelines for the investments.

The broad objectives of the Policy are as under:

i) Effectively manage and invest the funds in permitted investments for the duration

available.

ii) Effectively manage and invest surplus funds which may be available relatively for a longer

period or shorter period

iii) Effectively manage interest rate risk by adopting appropriate maturity pattern, particularly

when the funds are invested in Government Securities.

iv) Effectively implement Internal Control on the operations/execution of Investment

Transactions.

v) Proper recording/accounting of the investment transactions.

vi) Timely reporting of the Investment transaction to Management

1.2 Applicable Regulations:

i) Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based

Regulation) Directions, 2023, as applicable.

ii) Guidelines for investments in unencumbered securities.

iii) Clarifications as may be issued from time to time by Reserve Bank of India.

iv) The Company will adhere to the provisions of the Companies Act, 2013.

v) Pursuant to any subsequent amendments or any statutory modifications or re-enactments

in the above stated guidelines / norms / clarifications or in any other applicable acts /

regulations, if there is any change in any of the parameter(s) framed by the Board, then the

act / regulation will have overriding effect on the parameter(s).

1.3 Delegation of Power, Approval and Review

The Board of Directors of the Company will approve this Policy and authorities under the Policy.

Further, the Board, by way of a resolution, may delegate the said power to any of its

Committees, the Managing Director, the Manager or the Principal Officer (hereinafter

collectively referred to as the "delegate") of the Company. The said resolution should specify

the total amount up to which the funds may be invested and the nature of the investments

which may be made by the delegate.

The said powers are subject to review from time to time as per respective Board resolution.

1.4 Exception to the Policy

Any exception to the Policy will need approval from the Board of Directors or Finance

Committee.

1.5 Recordkeeping

The Company will maintain appropriate records in accordance with the regulatory/ statutory

requirements from time to time.

1.6 Applicability

The Policy will be applicable from the date of approval by the Board of Directors of the Company.

1.7 Policy Review

The Board of Directors of the Company or the Risk Management Committee may review the

policy to ensure that it remains consistent with the overall objectives of the Company and it

complies with the regulatory/ statutory requirements from time to time.

POLICY STANDARDS

2.1 Classification of Investments

The Investments of the Company will be treated as assets of the Company held with the motive

of earning income by way of dividends, interest, and / or for capital appreciation and / or for

other benefits.

As per Ind AS, the investments are financial assets.

At Initial recognition, Company will classify financial assets in any one of the following

categories:

(a) Amortised Cost

(b) Fair value through Other Comprehensive Income (FVOCI)

(c) Fair value through Profit or Loss (FVTPL)

(a) Amortised Cost:

A financial asset shall be measured at amortised cost if both of the following conditions are met:

(i) the financial asset is held within a business model whose objective is to hold financial assets

in order to collect contractual cash flows; and

(ii) the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount outstanding.

(b) Fair value through Other Comprehensive Income (FVOCI):

A financial asset shall be measured at fair value through other comprehensive income if both of the following conditions are met:

(i) the financial asset is held within a business model whose objective is achieved by both

collecting contractual cash flows and selling financial assets; and

(ii) the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount outstanding.

(c) Fair value through Profit or Loss (FVTPL):

A financial asset shall be measured at fair value through profit or loss unless it is measured at

amortised cost or at fair value through other comprehensive income. However, the Company

may make an irrevocable election at initial recognition for particular investments in equity

instruments that would otherwise be measured at fair value through profit or loss to present

subsequent changes in fair value in other comprehensive income.

2.2 Type of Investment:

The Company may invest the surplus fund of the Company up to a maximum of INR 500 crores

(Rupees Five Hundred Crore Only), at any point in time, in any of the following:

a) Debt Instruments / Treasury Bills / Securities / issued and or guaranteed by the Government of India

b) Corporate Debt / Short Term Deposits / Commercial Papers / Inter corporate Deposits of any scheduled Commercial bank, Small Finance Bank, Financial Institution or any other borrowers which are rated minimum A1 or A1+ Short term.

c) Quoted equity shares for investment purpose.

d) Money market / Liquid funds/ Fixed Maturity Plans / Bond Funds / Gilt Funds and in the units of Mutual Fund registered with the Security and Exchange Board of India (SEBI).

e) Bonds / Certificate of Deposits / Fixed Deposits with /of any scheduled Commercial or Cooperative Bank and or financial Institution.

2.3 Recognition of Income from Investments

a) Income from dividend on units of mutual funds shall be taken into account when right to

receive dividend is established;

b) Interest income from bonds and debentures of corporate bodies and from Government

securities/bonds are classified at amortise cost or FVOCI and shall be recognised at effective

interest rate method. For investments classified at FVTPL, interest income shall be

recognised at coupon rate;

c) Interest Income on Fixed Deposits with Banks/ Financial Institutions may be taken into

account on accrual basis;

d) Financial assets that are classified at FVOCI or FVTPL shall be remeasured at fair value at

each balance sheet date and the gain / loss shall be recognised in statement of profit & loss

or in OCI as the case may be.

e) Gain / loss on derecognition of financial assets shall be booked as difference between

carrying amount and realised value.

2.4 Transaction in Government Securities

The Company may undertake transactions in Government securities (Debt Instruments) through its CSGL account or it’s demat account; provided that Company shall not undertake any transaction in government security in physical form through any broker.

2.5 Concentration of Investment/ Exposure limits

The Company will ensure that all its investments comply with the concentration norms

prescribed in the RBI Directions as applicable.

2.6 Investment Authorisation Matrix

The Board may delegate powers to the Finance Committee, Chief Executive Office, Chief

Financial Officer and Head Treasury to sell, purchase, transfer, endorse, negotiate and or/

otherwise deal in Securities/ Mutual Funds and sign letter of indemnity, execute bond of

indemnity, guarantee, sign declaration and also authorised to receive interest & principal

thereof on behalf of Company.

The Said powers are subject review from time to time as per respective Board resolution issued.

Annexure- A

Individuals Limits Prescribed for Investment in various Products)

Investment Criteria for Investment in Liquid Fund

Investment Criteria for Investment in Ultra Short-Term Fund

Investment Criteria for Investment in Short Term Debt Fund

Investment in Commercial Paper/Debentures/Corporate Bonds/

Investment in Fixed Deposit