Customer Acceptance Policy (CAP)

Effective Date: 01.12.2025

Introduction

Swaraaj Ecosystem Private Limited (“Swaraaj”, “the Company”) recognizes the importance of conducting business with customers who meet high standards of integrity, transparency, and legal compliance. This Customer Acceptance Policy (“Policy”) establishes the framework for identifying, assessing, onboarding, monitoring, and, where necessary, exiting customers in a manner consistent with applicable laws, regulatory expectations, and the Company’s ethical standards.

This Policy forms a key part of the Company’s overall governance, risk management, and compliance framework.

This Policy is an internal governance and compliance document and does not create any rights, obligations, or entitlements in favor of any customer or third party.

Objectives of the Policy

• Ensure that the Company conducts business only with legitimate and identifiable customers
• Prevent the Company’s products, services, or platforms from being used for illegal, fraudulent, or unethical purposes
• Mitigate operational, legal, reputational, and financial risks
• Establish a standardized, risk-based customer onboarding and monitoring process
• Ensure compliance with applicable laws, regulations, and contractual obligations

Applicability and Scope

This Policy applies to:

• All customers, users, clients, subscribers, members, partners, vendors-as-customers, and counterparties
• Individual customers, proprietorships, partnerships, LLPs, companies, trusts, societies, NGOs, and other legal entities
• All business lines, platforms, applications, products, services, and ecosystem offerings of the Company
• All employees, directors, officers, consultants, and third parties involved in customer onboarding or management

Regulatory and Legal Framework

The Company shall comply with all applicable laws and regulations in India, including but not limited to:

• Companies Act, 2013
• Prevention of Money Laundering Act, 2002 and related rules, to the extent applicable
• Information Technology Act, 2000
• Applicable data protection and privacy laws and rules
• Industry-specific or sectoral regulations applicable to the Company’s business
• Guidelines, advisories, or directions issued by government or regulatory authorities from time to time

Customer Identification (Customer Due Diligence)

1. General Principles

The Company shall identify and verify the identity of customers prior to onboarding. The extent of verification shall depend on the customer’s risk profile and nature of engagement.

2. Individual Customers

Information that may be collected includes:

• Full name
• Date of birth
• Residential address
• Contact details
• Government-issued identity documents (as applicable)

3. Non-Individual Customers (Entities)

For entities such as companies, LLPs, partnerships, trusts, or societies, the Company may collect:

• Legal name and registered address
• Certificate of incorporation or registration
• Constitutional documents (MOA/AOA, partnership deed, trust deed, etc.)
• Details of directors, partners, trustees, or authorized signatories
• Ownership and control structure, including beneficial owners

4. Beneficial Ownership

Where applicable, the Company shall identify and verify the beneficial owners who ultimately own or control the customer.

Risk-Based Customer Assessment

1. Risk Parameters

Customers shall be assessed based on factors including:

• Nature of business or activity
• Source of funds or revenue model (where relevant)
• Geographic location and jurisdictional exposure
• Transaction patterns, size, and volume
• Complexity of ownership or control structure
• Reputation and public information

2. Risk Categorization

• Low Risk: Minimal compliance concerns
• Medium Risk: Moderate level of monitoring required
• High Risk: Enhanced due diligence and senior management approval required

Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be conducted for:

• High-risk customers
• Customers with complex ownership structures
• Customers operating in high-risk sectors or geographies
• Politically Exposed Persons (PEPs), where relevant

EDD may include:

• Additional documentation
• Independent verification of information
• Management approval prior to onboarding

Prohibited and Restricted Customers

The Company shall not accept or shall discontinue relationships with customers who:

• Are involved in illegal, criminal, fraudulent, or money-laundering activities
• Appear on sanctions lists, blacklists, or watchlists issued by competent authorities
• Provide false, misleading, or incomplete information
• Refuse or fail to comply with reasonable due diligence requirements
• Use or intend to use the Company’s services for unlawful or unethical activities

Ongoing Monitoring and Review

1. Continuous Monitoring

• Ensure consistency with stated purpose and risk profile
• Identify unusual, suspicious, or high-risk behavior

2. Periodic Review

• Periodic review based on risk category
• Review upon material changes in ownership, business model, or geography

Suspicious Activity and Reporting

Where suspicious or unusual activity is identified:

• The matter shall be escalated internally to designated personnel
• Appropriate action may include enhanced monitoring, suspension, or termination
• Reporting to authorities shall be made where legally required

The Company shall not be liable to any customer for actions taken in good faith under this Policy.

Data Protection and Confidentiality

• Customer information shall be collected solely for legitimate business and compliance purposes
• Data shall be stored securely and accessed only by authorized personnel
• Confidentiality and privacy shall be ensured in accordance with applicable laws and internal policies

Customer Rejection, Suspension, and Exit

The Company reserves the right to:

• Reject a customer at the onboarding stage
• Suspend services temporarily
• Terminate the customer relationship

Such decisions may be taken where risk exceeds the Company’s risk appetite, legal or regulatory concerns arise, or continued association may harm the Company’s interests.

Nothing in this Policy obligates the Company to onboard or continue any customer relationship.

Roles and Responsibilities

1. Board of Directors

Approve and oversee implementation of this Policy.

2. Management

Ensure effective execution and compliance, allocate resources, and assign responsibilities.

3. Compliance / Operations Team

Conduct customer due diligence and monitoring, and maintain records and documentation.

4. Employees

Adhere to the Policy during customer interactions and report concerns or deviations.

Record Keeping

The Company shall maintain records of:

• Customer identification documents
• Risk assessments and approvals
• Monitoring and review activities

Records shall be retained for the period required under applicable law or internal policy and may be retained longer for audit, risk management, or legal purposes.

Training and Awareness

Employees involved in customer onboarding and management shall receive periodic training on this Policy and awareness on compliance, ethics, and risk indicators.

Policy Review and Amendment

This Policy shall be reviewed periodically and updated to reflect changes in laws, regulations, or business operations.

Any amendments shall be approved by the Board of Directors or an authorized committee.