POLICY ON MANNER OF SOLICITING INSURANCE BUSINESS

(Approved by Board on: 31 / 10 / 2025)

1. Objective

This Policy on the Manner of Soliciting Insurance Business ("Policy") is framed in compliance with the IRDAI (Insurance Brokers) Regulations, 2018, to ensure that all insurance solicitation activities undertaken by Recapita Insurance Brokers Private Limited ("the Company") are conducted in a transparent, ethical, professional, and regulatory-compliant manner, safeguarding the interests of policyholders at all times.

2. Regulatory Framework

This Policy is formulated pursuant to, inter alia:

Regulation 21 and Regulation 22 of the IRDAI (Insurance Brokers) Regulations, 2018

IRDAI (Protection of Policyholders' Interests) Regulations, 2017

Code of Conduct specified under Schedule V of the IRDAI (Insurance Brokers) Regulations, 2018

Circulars, guidelines, advisories and directions issued by IRDAI from time to time

3. Applicability

This Policy shall apply to:

All Directors

Key Management Personnel

Designated Persons

Employees

Insurance Sales Persons (ISPs)

Authorized Representatives

Outsourced service providers engaged in solicitation or servicing of insurance business.

4. Guiding Principles for Solicitation

The Company shall ensure that:

Insurance solicitation is carried out in a fair, transparent and professional manner

Products are recommended only after assessing the needs and suitability of the prospect

No misrepresentation, coercion, inducement or unfair practice is adopted

The interests of policyholders are placed above commercial considerations

5. Manner of Soliciting Insurance Business

5.1 Authorization to Solicit

Only duly authorized and trained personnel holding valid ISP certification and appointment letters shall solicit insurance business.

No person shall solicit insurance business without being empanelled and authorized by the Company.

5.2 Needs Analysis and Suitability

A comprehensive need analysis shall be conducted prior to recommending any insurance product.

The recommended product shall be suitable to the customer's risk profile, financial position, and stated objectives.

5.3 Disclosure Requirements

The Company shall disclose its identity, IRDAI registration details, and nature of services at the time of solicitation.

All material information including benefits, exclusions, terms, conditions, premium, tenure, surrender value and claim procedure shall be clearly explained.

The Company shall disclose the insurer(s) with whom it has arrangements.

5.4 Prohibited Practices

The Company and its representatives shall not:

Make any misleading, false or exaggerated statements

Promise assured returns unless explicitly provided in the policy

Induce prospects through rebates, gifts or incentives not permitted by law

Withhold material information relevant to the policy

5.5 Mode of Solicitation

Solicitation may be undertaken through physical meetings, telephonic interaction, digital platforms or other permitted channels.

All digital solicitation shall comply with IRDAI guidelines on electronic modes and data privacy norms.

6. Documentation and Record Keeping

Records of solicitation, need analysis, proposal forms, disclosures and communications shall be maintained as per regulatory requirements.

The Company shall ensure confidentiality and secure handling of customer information.

7. Training and Competency

All personnel involved in solicitation shall undergo mandatory training and certification as prescribed by IRDAI.

Periodic refresher training shall be conducted to ensure regulatory awareness and ethical conduct.

8. Grievance Redressal

Customers shall be informed of the Company's grievance redressal mechanism at the time of solicitation.

Any complaint arising out of solicitation shall be addressed promptly and in accordance with the Board-approved Grievance Redressal Policy.

9. Monitoring and Compliance

The Compliance Officer shall periodically review solicitation activities for adherence to this Policy and IRDAI regulations.

Any deviation or violation shall be reported to the management and corrective action shall be initiated.

10. Review and Amendment

This Policy shall be reviewed annually or earlier, if required, pursuant to any change in regulatory framework. Any amendment shall be subject to approval of the Board of Directors.

11. Board Approval

This Policy was reviewed and approved by the Board of Directors of Recapita Insurance Brokers Private Limited at its meeting held on October 31, 2025.

For Recapita Insurance Brokers Private Limited

AMIT JAIN (DIN-07632009)

Director