Agent Onboarding Policy

1. INTRODUCTION

This Agent Onboarding Policy ("Policy") has been formulated and adopted by SAFALPAY INDIA PRIVATE LIMITED ("SAFALPAY", "Company", "We", "Us", or "Our"), a B2B financial technology company incorporated under the Companies Act, 2013, and engaged in providing digital financial services, payment solutions, banking correspondent services, and financial inclusion services through its network of authorized agents, distributors, retailers, merchants, and business correspondents across India.

SAFALPAY operates as a technology-enabled financial services platform facilitating various digital payment and banking services through regulated partner banks, payment service providers, NBFCs, and licensed financial institutions. The Company is committed to maintaining the highest standards of compliance, transparency, security, and integrity in the onboarding and management of its agents and business partners.

This Policy establishes the framework, procedures, eligibility criteria, due diligence requirements, regulatory obligations, and operational guidelines governing the onboarding, verification, approval, activation, monitoring, suspension, and termination of SAFALPAY agents and distributors.

This Policy shall be binding upon all employees, agents, distributors, merchants, business correspondents, channel partners, and other stakeholders involved in the agent onboarding process.

2. OBJECTIVES OF THE POLICY

The objectives of this Policy are to:

• Establish a standardized onboarding process for agents and distributors;
• Ensure compliance with applicable RBI, NPCI, FIU-IND, and government regulations;
• Prevent fraud, money laundering, terrorist financing, and financial crimes;
• Verify the identity and legitimacy of prospective agents;
• Protect customer interests and financial data;
• Promote transparency and accountability;
• Strengthen financial inclusion initiatives;
• Ensure ethical and lawful conduct of business operations;
• Maintain operational efficiency and service quality.

3. SCOPE OF THE POLICY

This Policy shall apply to all individuals, proprietorship firms, partnerships, LLPs, companies, retailers, merchants, business correspondents, agents, distributors, and channel partners seeking authorization to provide services through SAFALPAY.

The Policy covers onboarding for services including but not limited to:

• Bharat Bill Payment System (BBPS)
• Aadhaar Enabled Payment System (AEPS)
• Micro ATM Services
• Domestic Money Transfer (DMT)
• UPI Payment Services
• Merchant Payment Collection Services
• Prepaid Card Services
• Business Correspondent (BC) Services
• Bank Account Opening Services
• Cash Deposit and Withdrawal Services
• Insurance Facilitation Services
• Loan Facilitation Services
• Financial Inclusion Services
• Other value-added financial services.

4. DEFINITIONS

For the purpose of this Policy:

5. ELIGIBILITY CRITERIA

Applicants seeking onboarding as SAFALPAY agents must satisfy the following eligibility conditions:

6. DOCUMENT REQUIREMENTS

Applicants shall submit the following documents:

7. AGENT APPLICATION PROCESS

The onboarding process shall consist of the following stages:

8. KNOW YOUR AGENT (KYA) PROCESS

SAFALPAY shall conduct Know Your Agent (KYA) procedures including:

• Aadhaar verification;
• PAN verification;
• Mobile OTP verification;
• Email verification;
• Bank account validation;
• Address verification;
• Video verification (where applicable);
• Business verification.

9. DUE DILIGENCE AND RISK ASSESSMENT

All agents shall undergo risk assessment based on:

• Business profile;
• Geographical location;
• Transaction profile;
• Source of funds;
• Regulatory history;
• Customer base;
• Operational risk.

Agents shall be categorized as:

• Low Risk;
• Medium Risk;
• High Risk.

Enhanced Due Diligence (EDD) shall be conducted for high-risk applicants.

10. AML/CFT SCREENING

SAFALPAY shall conduct:

• Sanctions screening;
• PEP screening;
• Adverse media checks;
• Fraud database checks;
• Regulatory watchlist screening;
• Internal blacklist verification.

Suspicious applicants shall be rejected.

11. AGENT TRAINING AND CERTIFICATION

Before activation, agents shall complete mandatory training covering:

• Product knowledge;
• Customer service;
• RBI guidelines;
• NPCI regulations;
• AML/CFT compliance;
• Fraud prevention;
• Data privacy;
• Cybersecurity;
• Transaction processing;
• Grievance handling.

Agents may be required to pass certification assessments.

12. AGENT AGREEMENT

Every approved agent shall execute an Agent Agreement containing:

• Rights and obligations;
• Commission structure;
• Confidentiality obligations;
• Data protection obligations;
• AML compliance obligations;
• Audit rights;
• Suspension provisions;
• Termination provisions.

13. AGENT ACTIVATION

Following approval, SAFALPAY shall:

• Generate a unique Agent ID;
• Create secure login credentials;
• Enable approved services;
• Configure transaction limits;
• Register devices;
• Activate digital channels.

14. CUSTOMER DATA PROTECTION

Agents shall:

• Maintain customer confidentiality;
• Protect customer information;
• Avoid unauthorized disclosure;
• Comply with DPDP Act, 2023;
• Follow SAFALPAY Privacy Policy.

Unauthorized disclosure shall result in disciplinary action.

15. TRANSACTION MONITORING

SAFALPAY shall continuously monitor:

• Transaction volumes;
• Customer complaints;
• Suspicious activities;
• Fraud indicators;
• AML risks;
• Operational anomalies.

The Company may impose transaction limits or restrictions where necessary.

16. PERIODIC REVIEW AND RE-KYC

SAFALPAY reserves the right to:

• Conduct periodic KYC reviews;
• Request updated documents;
• Perform field verification;
• Conduct compliance audits;
• Review transaction behavior.

Failure to comply may result in suspension.

17. SUSPENSION AND TERMINATION

SAFALPAY may suspend or terminate agents for:

• Fraudulent activities;
• Fake documentation;
• AML violations;
• Regulatory non-compliance;
• Customer complaints;
• Unauthorized charges;
• Security breaches;
• Misrepresentation;
• Criminal activities.

18. AUDIT AND INSPECTION

SAFALPAY reserves the right to conduct:

• Internal audits;
• External audits;
• Compliance inspections;
• Regulatory reviews;
• Site visits;
• Financial investigations.

Agents shall fully cooperate.

19. GRIEVANCE REDRESSAL

For onboarding-related grievances:

Complaints shall be acknowledged within 48 hours and resolved within 15 working days.

20. LEGAL AND REGULATORY FRAMEWORK

This Policy is governed by:

• Companies Act, 2013;
• Reserve Bank of India Act, 1934;
• Payment and Settlement Systems Act, 2007;
• Prevention of Money Laundering Act, 2002;
• Information Technology Act, 2000;
• Digital Personal Data Protection Act, 2023;
• RBI KYC Master Directions;
• RBI Payment Aggregator Guidelines;
• NPCI Guidelines;
• FIU-IND Guidelines;
• Applicable Indian laws.

21. POLICY REVIEW

This Policy shall be reviewed:

• Annually;
• Upon regulatory changes;
• Upon introduction of new products;
• Upon identification of material risks.

22. EFFECTIVE DATE

This Policy shall come into effect from 01 July 2026 and remain valid until modified, replaced, or withdrawn by SAFALPAY INDIA PRIVATE LIMITED.

23. DECLARATION

This Agent Onboarding Policy has been approved by the management of SAFALPAY INDIA PRIVATE LIMITED and shall be binding upon all employees, agents, distributors, business correspondents, merchants, retailers, and channel partners.