Policy ID: PCI/POL/23/2026-27 • Version 1.0 Owner: Company Secretary / Credit / Legal • Approver: Board of Directors Sources: CRM, GOV, COA • Review: Annual / regulatory change
Purpose and application
Connected lending, employee loans, guarantees and transactions involving interested persons.
1. Legal gate:- Before processing, identify the director/officer, relatives and connected entities. Legal shall test Companies Act sections 185/186, exemptions and applicable RBI restrictions. If prohibited or legality is unresolved, no commitment or disbursement shall be made.
2. Independent underwriting: Apply normal credit standards, repayment capacity, pricing, security and documentation; no hidden concession. The beneficiary shall not influence appraisal or verification. Staff welfare loans shall follow a separate approved scheme and legal eligibility.
3. Approval and recusal: Apply the amended related-party framework: Board-approved aggregate/group limits and materiality thresholds no higher than ₹1 crore (BL), ₹5 crore (ML) or ₹10 crore (UL/ TL). Above-threshold loans need Board or permitted non-Audit Board committee sanction. Company control: every director-related proposal goes to the Board. Interested persons shall recuse, including on later waivers/settlements.
4. Monitoring and disclosure:- Maintain a connected-lending register and aggregate group exposures. Monitor repayment independently; concessions, extensions and waivers require the same legal/ approval scrutiny. CFO shall make prescribed financial statement disclosures.
5. Audit and escalation:- Conduct quarterly or more frequent internal audit of related-party lending, report specified-employee/relative facilities annually to the Board and report deviations to Audit Committee/Board. Reciprocal or disguised lending shall not circumvent rules. Maintain updated related-person and entity lists.
Source codes are linked to the Reference Register. Read with the common implementation controls and relevant annexes. Applicable law and RBI Directions prevail.