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Suryoday Small Finance Bank Ltd. Notes to Accounts
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You can view the entire text of Notes to accounts of the company for the latest year
Market Cap. (Rs.) 1442.35 Cr. P/BV 0.75 Book Value (Rs.) 181.12
52 Week High/Low (Rs.) 161/98 FV/ML 10/1 P/E(X) 12.55
Bookclosure 12/09/2024 EPS (Rs.) 10.82 Div Yield (%) 0.00
Year End :2025-03 

M. Provisions, contingent liabilities and contingent assets

In accordance with AS 29, Provision, Contingent liabilities
and Contingent Assets, the provision is recognised when
the Bank has a present obligation as a result of past
event, where it is probable that an outflow of resources
embodying economic benefits will be required to settle
the obligation, in respect of which a reliable estimate can
be made. Provisions are not discounted to its present
value and are determined based on best estimate
required to settle the obligation at the Balance Sheet
date. These are reviewed at each Balance Sheet date
and adjusted to reflect the current best estimates.

A disclosure of contingent liability is made
when there is:

• a possible obligation arising from a past event, the
existence of which will be confirmed by occurrence
or non-occurrence of one or more uncertain future
events not within the control of the Bank; or

• a present obligation arising from a past event
which is not recognised as it is not probable
that an outflow of resources will be required to
settle the obligation or a reliable estimate of the
amount of the obligation cannot be made.

When there is a possible obligation or a present
obligation in respect of which the likelihood of
outflow of resources is remote, no provision or
disclosure is made.

Contingent assets are not recognised in the
financial statements.

N. Cash and cash equivalents

Cash and cash equivalents include cash in hand,
balances with RBI, balances with other banks and
money at call and short notice. Cash and Cash
Equivalents for the purpose of Cash Flow Statement
comprises Cash at Bank and in hand and short term
Investments with an original maturity of less than
three months and without any charge.

O. Borrowing cost

Borrowing cost includes arranger fees, processing
fees, stamp duty on issuance of debenture certificates
and other associated transaction cost related to
borrowing from banks and other financial institutions.
Borrowing costs are recognised upfront.

P. Retirement and other employee benefits

Employee benefits include Provident Fund,
Employee state insurance schemes, Gratuity and
Compensated Absences.

(i) Defined Contribution Plans

Retirement benefits in the form of provident fund
and employee state insurance schemes are defined
contribution schemes and the contributions are
charged to the Profit and Loss Account for the year
when the contributions to the respective funds are
due. There are no other obligations other than the
contribution payable to the respective funds.

(ii) Defined Benefit Plan
Gratuity:

The Bank operates a defined benefit scheme
for its employees, viz., gratuity scheme. The
costs of providing benefits under this plan is
determined on the basis of actuarial valuation
at each year-end.

Separate actuarial valuation is carried out for each
plan using the projected unit credit method. In
accordance with the gratuity fund’s rules, actuarial
valuation of gratuity liabilities is calculated based
on certain assumptions regarding rate of interest,
salary growth, mortality and staff alteration as
per projected unit credit method.

Actuarial gains/losses are immediately taken to
profit and loss account and are not deferred.

Other Employee Benefits

Compensated Absences:

The Bank accrues the liability for compensated
absences based on the actuarial valuation as on the
Balance Sheet date conducted by an independent
actuary which includes assumptions about
demographics, early retirement, salary increases,
interest rates and leave utilisation. The net present
value of the Banks’ obligation is determined using
the Projected Unit Credit Method as on the Balance
Sheet date. Actuarial gains / losses are recognised
in the Profit and Loss Account in the period in
which they arise.

Q. Employee Stock Compensation Cost

Employees (including senior executives) of the Bank
receive remuneration in the form of share-based
payment transactions, whereby employees render
services as consideration for equity instruments
(equity-settled transactions).

In accordance with the Guidance Note on Accounting
for Employee Share-based Payments, issued by the
ICAI, the cost of equity-settled transaction is measured
using the fair value method and recognized, together
with a corresponding increase in the "Employees
Stock options outstanding account” in reserves. The
cumulative expense recognized for equity-settled
transactions at each reporting date until the vesting
date reflects the extent to which the vesting period has
expired and the Bank’s best estimate of the number of
equity instruments that will ultimately vest. The expense
or credit recognized in the Profit and Loss Account for a
period represents the movement in cumulative expense
recognized as at the beginning and end of that period
and is recognized in employee benefits expense.

R. Share issue expenses

Share issue expenses are adjusted from Share Premium
Account in terms of Section 52 of the Companies Act,
2013 and RBI approval in accordance with RBI/2006-
07/132 DBOD.BP. BC No. 31 / 21.04.018/ 2006-07.

S. Segment information

In accordance with guidelines issued by RBI vide DBOD.
No.BRBC.81 /21.01.018/2006-07 dated April 18, 2007 and
Accounting Standard 17 (AS-17) on "Segment Reporting”,
the Banks’ business has been segregated into Treasury,
Retail Banking and Corporate/ Wholesale Segments.

Segment revenues consist of earnings from external
customers and inter-segment revenues based on
a transfer pricing mechanism. Segment expenses
consist of interest expenses including allocated
operating expenses and provisions. Segment results
are net of segment revenues and segment expenses.

Segment assets include assets related to segments
and exclude tax related assets. Segment liabilities
include liabilities related to the segment excluding net
worth and dividend liability, if any.

Since the business operations of the Bank are
primarily concentrated in India, the Bank is considered
to operate only in the domestic segment.

T. Corporate Social Responsibility (CSR)

Expenditure towards CSR, in accordance with
Companies Act, 2013, is recognised in the Profit
and Loss Account.

U. Proposed Dividend

Proposed dividend / declared after the balance sheet
date is accrued in the books of the Bank in the year in
which the dividend is declared.

b) Draw Down from Reserves
Share Premium

There has been no draw down from share premium during the year ended March 31,2025 (March 31, 2024: H Nil).

c) Appropriation to Reserves

i) Statutory Reserve

The Bank has made an appropriation of H 28.74 crores (March 31, 2024: H 53.99 crores) out of profits for the year ended
March 31, 2025 to Statutory Reserve pursuant to the requirements of section 17(1) and section 11(2)(b)(ii) of Banking
Regulation Act, 1949 and RBI guidelines dated September 23, 2000.

ii) Capital Reserve

During the year ended March 31, 2025, the Bank has been required to appropriate (net of taxes and statutory reserves)
H 4.24 crores (March 31,2024: H Nil) from profit and loss account to capital reserves being the profit from sale of investments
under HTM category as per the RBI guidelines.

iii) Investment Fluctuation Reserve

During the year ended March 31, 2025, the Bank has transferred H 7.05 crores (March 31, 2024: H 4.56 crores) from
Investment Fluctuation Reserve to Profit & Loss Account as per RBI guidelines.

d) Proposed dividend

The Board of Directors of the Bank has not proposed any dividend for the year ended March 31, 2025 (March 31,2024: H Nil).

ii) Qualitative information on Liquidity Coverage Ratio (LCR) is given below:

The objective of LCR is to ensure that the Bank maintains an adequate stock of unencumbered High Quality Liquid Assets
(HQLA) that can be converted into cash to meet its liquidity needs for a 30-day period under a significantly severe liquidity
stress scenario. At a minimum, the stock of liquid assets should enable the Bank to survive until day 30 of the stress
scenario, by which time it is assumed that appropriate corrective actions can be taken.

The LCR is calculated by dividing the amount of High Quality Liquid unencumbered Assets (HQLA) by the expected net cash
outflows over a stressed 30 day period as per the RBI Guidelines. Minimum LCR requirement for small finance banks is 100%.

HQLA comprises of cash in hand, excess CRR, excess SLR/Non SLR securities, maximum liquidity facility allowed by RBI
under marginal standing facility (MSF) and Facility to Avail Liquidity for Liquidity Coverage Ratio (FALLCR).

The Asset Liability Committee (ALCO) governs the Liquidity Risk management of the Bank. The liquidity profile of the
Bank is monitored and measured by the Risk Management Department, which reviews liquidity under different business
conditions and places the same before the ALCO.

The net cash outflows are calculated by applying RBI prescribed outflow factors to the various categories of liabilities
(deposits, borrowings), as well as to undrawn commitments and other miscellaneous liabilities, partially offset by expected
inflows from assets maturing within 30 days.

The average LCR for the quarter ended March 31, 2025 was at 141.20% as against 144.89% for the quarter ended March
31, 2024, and well above the present prescribed minimum requirement of 100%. The average HQLA for the quarter ended
March 31, 2025 was H 2,793.35 crores, as against was H 1,735.93 crores for the quarter ended March 31, 2024.

C) Net stable funding Ratio (NSFR)

As per the RBI guideline vide circular RBI circular RBI/2017-18/178 DBR.BRBC.No.106/21.04.098/2017-18 dated May
17,2018 , RBI/2020-21/95 DOR.No.LRG.BC.40/21.04.098/2020-21 dated February 06,2021 and RBI/2020-21 DOR.BRBC
No.16/21.04.098/2020-21 dated Septemebr 06, 2021 is required to maintain the NSFR on an ongoing basis. The objective of
NSFR is to ensure that banks maintain a stable funding profile in relation to the composition of their assets and off-balance
sheet activities. A sustainable funding structure is intended to reduce the probability of erosion of a bank’s liquidity position due
to disruptions in a bank’s regular sources of funding that would increase the risk of its failure and potentially lead to broader
systemic stress. The NSFR limits overreliance on short-term wholesale funding, encourages better assessment of funding risk
across all on- and off-balance sheet items, and promotes funding stability.

The NSFR is defined as the amount of available stable funding relative to the amount of required stable funding. "Available
stable funding” (ASF) is defined as the portion of capital and liabilities expected to be reliable over the time horizon considered
by the NSFR, which extends to one year. The amount of stable funding required (""Required stable funding"") (RSF) of a specific
institution is a function of the liquidity characteristics and residual maturities of the various assets held by that institution as well
as those of its off-balance sheet (OBS) exposures. The above ratio should be equal to at least 100% on an ongoing basis. The
NSFR as on March 31,2025 was at 159.15% (March 31, 2024: 151.70%).

e) Divergence in asset classification and provisioning

RBI vide its circular DBR.BP.BC.No.63/21.04.018/2016-17 dated April 18, 2017 and Notification dated April 1,2019, has directed
banks shall make suitable disclosures, if either or both of the following conditions are satisfied:

(a) the additional provisioning for non-performing assets (NPAs) assessed by the RBI exceeds 5% of the reported profit before
provisions and contingencies for the reference period, and/ or

(b) the additional Gross NPAs identified by the RBI exceed 5% of the reported incremental Gross NPAs for the reference period.

There has been no divergence observed by the RBI for the Financial year 2024-25 in respect of the Bank’s asset classification
and provisioning as per the extant prudential norms on income recognition asset classification and provisioning (IRACP) which
require such disclosures.

f) Disclosure of transfer of loan exposures

Details of loans transferred/acquired during the year ended March 31,2025 under the RBI Master Direction on Transfer of Loan
Exposures dated September 24, 2021 are given below:

e) Factoring exposures

The factoring exposure of the Bank as at March 31, 2025 is H 259.37 Crores (March 31, 2024 : H Nil)

f) Intra Group Exposure

The Bank does not have any intra group exposure as at March 31, 2025 (March 31,2024 : H Nil).

g) Unhedged Foreign Currency Exposure

In accordance with the RBI guidelines on Banks’ exposures to entities with Unhedged Foreign Currency Exposure ('UFCE’), the
Bank has put in place a mechanism to seek information from its borrowers and to evaluate the currency induced credit risk. In
the case of listed entities, the Bank obtains information relating to unhedged positions based on the latest available audited /
reviewed financial statements; whilst in the case of unlisted / private companies, the Bank obtains the aforesaid information
based on the latest available audited financial statements (not exceeding a financial year) so as to estimate the extent of likely
loss and to provide for incremental capital or to recognise incremental provision in accordance with the aforesaid guidelines.
Further, as per the above-mentioned guidelines, the Bank obtains audited and certified UFCE information from the statutory
auditors of the borrowers, wherever feasible, on an annual basis. In the case of smaller entities i.e. entities with exposure to
banking industry up to H 50 crore, the Bank recognises an incremental provision at 10 basis points on all such exposures.

In accordance with RBI guidelines, as at March 31,2025 the Bank holds UFCE provisions of H 4.21 crores (March 31,2024: H 2.14
crores) maintains capital of H 85.32 crore (March 31,2024: H 39.53 crore) in respect of the unhedged foreign currency exposure
of its customers

12. Disclosure of penalties imposed by the Reserve Bank of India

During the year ended March 31,2025, no penalties were imposed on Suryoday Small Finance Bank Limited by the Reserve Bank
of India. (March 31,2024: H 0.001 crore).

13. Disclosures on remuneration
A) Qualitative Disclosures

(a) Information relating to the composition and mandate of the Nomination and Remuneration Committee:

The Nomination and Remuneration Committee of the Board ("NRC”) is the main body overseeing remuneration of the
Directors, Key Managerial Personnel ("KMPs”), and Senior Management Personnel ("SMPs”) of the Bank. As on March 31,
2025, the NRC had four (4) members of which three (3) are Independent Directors. The functions of the Committee include
formulating criteria to determine independence of Directors, identifying persons for appointment as Directors on the Board
of the Bank, devising a Policy on Board Diversity, formulating criteria for evaluation of the performance of the Board, its
Committees and individual Directors, recommending remuneration of KMPs and SMPs, administering, monitoring and
formulating detailed terms and conditions of the Employees' Stock Option Scheme of the Bank, recommending to the
Board Policy on Succession Planning for the Board and senior management and overseeing and reviewing the succession
plans from time to time.

The Composition of NRC committee as on March 31, 2025 is as follows:

1. Mr. Mrutunjay Sahoo, Independent Director (Chairman upto September 21, 2024)

2. Mrs. Swati Datye, Independent Director (member upto September 29, 2024; and thereafter Chairperson w.e.f.
September 30, 2024)

3. Mr. Arun Diaz, Independent Director

4. Mr. Krishana Prasad Nair, Independent Director

5. Mr. Ranjit Shah, Investor Director

6. Mr. Jyotin Mehta, Independent Director (w.e.f. September 30, 2024 upto February 12, 2025)

External consultants whose advice has been sought, the body by which they were commissioned, and in what areas of the
remuneration process

Not Applicable

Scope of the Bank's remuneration policy (e.g. by regions, business lines), including the extent to which it is applicable to
foreign subsidiaries and branches

(a) The Policy on appointment and remuneration of Directors, Key Managerial personnel and senior management
employees was approved by the Board on January 23, 2017 and reviewed periodically. It was modified in October 2020
to exclude the remuneration aspects in view of new Compensation Policy being formulated and approved by the Board.

(b) The Bank's new Compensation Policy (formulated in accordance with RBI Guidelines on Compensation of Whole Time
Directors, Chief Executive Officers, Material Risk Takers and Risk Control & Compliance Staff), was approved by the
Board in October 2020 and is annually reviewed.

(c) The Employee Policies Manual of the Bank was approved by the Board on January 23, 2017 and is reviewed
periodically. It covers compensation policy for all other employees of the Bank.

Type of employees covered and number of such employees by the Compensation Policy and the Employee Policies Manual.

All permanent employees of the Bank are covered. The total number of permanent employees of the Bank at March 31,
2025 was 8,649.

(b) Information relating to the design and structure of remuneration processes of remuneration processes and the key
features and objectives of remuneration policy:

Key features and objectives of Compensation policy: The Bank, under the guidance of the NRC and the Board, follows
remuneration practices that are intended to drive meritocracy and performance based on a prudent risk management
framework and in line with the RBI guidelines.The NRC has oversight over compensation to senior management personnel
and also provides overall guidance to the compensation paid to other employees.While the Bank seeks to achieve a mix
of fixed and variable (cash and non-cash) remuneration for employees covered under the new Compensation Policy,
for all other employees, it has predominantly a fixed remuneration structure with no guaranteed bonuses. Also, the
remuneration of employees in financial and risk control functions is not linked to business outcomes and solely depends
on their performance. Further, the Bank has an Employee Stock Option Scheme for eligible employees aimed at aligning
compensation to long term performance through stock options that vest over a period of time.

Effective governance of compensation: The NRC has oversight over compensation to senior management personnel and
also provides overall guidance to the compensation paid to other employees.

Alignment of compensation philosophy with prudent risk taking: While the Bank seeks to achieve a mix of fixed and variable
(cash and non-cash) remuneration for employees covered under the new Compensation Policy, for all other employees,
it has predominantly a fixed remuneration structure with no guaranteed bonuses. Also, the remuneration of employees in
financial and risk control functions is not linked to business outcomes and solely depends on their performance. Further,
the Bank has an Employee Stock Option Scheme for eligible employees aimed at aligning compensation to long term
performance through stock options that vest over a period of time.

Whether the remuneration committee reviewed the firm's remuneration policy during the past year, and if so, an overview
of any changes that were made: Yes; the Compensation Policy was modified and approved during the period . The
keys changes included roles identified for Material Risk Takers and Risk Control Staff and change in deferment period
for cash variable.

Discussion of how the Bank ensures that risk and compliance employees are remunerated independently of the
businesses they oversee: The remuneration of employees in control functions such as Risk and Compliance depends
solely on their performance and is not linked to any business outcomes.

(c) Description of the ways in which current and future risks are taken into account in the remuneration processes including
the nature and type of the key measures used to take account of these risks:

Overview of the key risks that the Bank takes into account when implementing remuneration measures: The Board
approves the overall risk management policy including risk framework, limits, etc. The Bank conducts all its business

activities within this framework. The NRC while assessing the performance of the Bank and senior management, shall
consider adherence to the policies and accordingly make its recommendations to the Board.The evaluation process shall
incorporate both qualitative and quantitative aspects including asset quality, provisioning, increase in stable funding
sources, refinement/improvement of the risk management framework, effective management of stakeholder relationships
and mentoring key members of the top and senior management.In order to ensure alignment of remuneration with prudent
practices, the NRC takes into account adherence to the risk framework in addition to business performance.

Overview of the nature and type of key measures used to take account of these risks, including risk difficult to measure:

The evaluation process shall incorporate both qualitative and quantitative aspects including asset quality, provisioning,
increase in stable funding sources, refinement/improvement of the risk management framework, effective management
of stakeholder relationships and mentoring key members of the top and senior management.

Discussion of the ways in which these measures affect remuneration: In order to ensure alignment of remuneration with
prudent practices, the NRC takes into account adherence to the risk framework in addition to business performance.

Discussion of how the nature and type of these measures have changed over the past year and reasons for the changes, as
well as the impact of changes on remuneration: With the introduction of the new Compensation Policy, the compensation
structure of employees covered therein has undergone a change resulting in an increase in overall remuneration.

(d) Description of the ways in which the bank seeks to link performance during a performance measurement period
with levels of remuneration:

Overview of main performance metrics for the Bank, top level business lines and individuals: The main performance metrics
include profitability, business growth, asset quality, compliance, and customer service.The assessment of employees shall
be based on their performance with respect to their result areas and shall include the metrics mentioned above.

Discussion of how amounts of individual remuneration are linked to the Bank-wide and individual performance: The

assessment of employees shall be based on their performance with respect to their result areas and shall include the
metrics mentioned above.

Discussion of the measures the Bank will in general implement to adjust remuneration in the event that performance
metrics are weak, including the Bank's criteria for determining ‘weak' performance metrics: In case such an event should
occur, the Board/NRC shall review and provide overall guidance on the corrective measures to be taken.

(e) A discussion of the bank's policy on deferral and vesting of variable remuneration and a discussion of the bank's policy
and criteria for adjusting deferred remuneration before vesting and after vesting:

Discussion of the Bank's policy on deferral and vesting of variable remuneration and, if the fraction of variable remuneration
that is deferred differs across employees or groups of employees, a description of the factors that determine the fraction
and their relative importance: Under the new Compensation Policy, the cash variable component will be deferred over 2-3
years and the non-cash variable component (employee stock options) will be deferred over the vesting period as per the
extant ESOP Scheme. In case of other employees, where cash variable is not applicable and in case of employees being
granted ESOPs, they will be deferred over the vesting period as per the extant ESOP Scheme. In the case of employees
covered under the Compensation Policy, all deferred variable compensation would be subjected to malus/clawback
arrangements as provided in the RBI guidelines and this would be administered by the NRC.

Discussion of the Bank's policy and criteria for adjusting deferred remuneration before vesting and (if permitted by
national law) after vesting through claw back arrangements: In the case of employees covered under the Compensation
Policy, all deferred variable compensation would be subjected to malus/clawback arrangements as provided in the RBI
guidelines and this would be administered by the NRC.

(f) Description of the different forms of variable remuneration that the Bank utilises and the rationale for using these different
forms: As per the Compensation Policy, the variable remuneration will comprise of cash and non-cash components.

Overview of the forms of variable remuneration offered. A discussion of the use of different forms of variable remuneration
and, if the mix of different forms of variable remuneration differs across employees or group of employees, a description
of the factors that determine the mix and their relative importance: As per the new Compensation Policy, only the
employees falling under the categories of Material Risk Takers (MRTs), Risk Control & Compliance Staff (RCS) and All Other
Employees (AOEs) and who donot earn performance linked incentives, are eligible for variable remuneration which could be
in cash and/or non- cash forms. The Policy also determines the category-wise mix of the variable compensation payable.

f). Implementation of IFRS converged Indian Accounting Standards (Ind AS)

As per the RBI circular RBI/2015-16/315 DBR.BRBC. No.76/21.07.001/2015-16 dated February 11, 2016 Implementation of
Indian Accounting Standards (Ind AS), The banks are advised to follow the Indian Accounting Standards as notified under the
Companies (Indian Accounting Standards) Rules, 2015, subject to any guideline or direction issued by the the Reserve Bank in
this regard. The Banks in India currently prepare their financial statements as per the guidelines issued by the RBI, the Accounting
Standards notified under section 133 of the Companies Act, 2013 and generally accepted accounting principles in India (Indian
GAAR). In January 2016, the Ministry of Corporate Affairs issued the roadmap for implementation of new Indian Accounting
Standards (Ind AS), which were based on convergence with the International Financial Reporting Standards (IFRS), for scheduled
commercial banks, insurance companies and non-banking financial companies (NBFCs). In March 2019, RBI deferred the
implementation of Ind AS for banks till further notice as the recommended legislative amendments were under consideration of
Government of India. The Bank had undertaken preliminary diagnostic analysis of the GAAR differences between Indian GAAR
vis-a-vis Ind AS and shall proceed for ensuring the compliance as per applicable requirements and directions in this regard.

The Expected life of the stock option is based on historical data and current expectation and is not necessarily indicative of the
pattern that may occur.

The expected volatility reflects the assumption that the historical volatility of a comparable listed entity for 6 years period ended
on the date of the grant is indication of future trends which may not necessarily be the actual outcome.

16. Segment Reporting

Business segments have been identified and reported taking into account, the customer profile, the nature of products and
services, the differing risks and returns, the organisation structure and the guidelines prescribed by the RBI. The Bank operates
in the following segments:

a) Treasury

Treasury performs liquidity management activities for various business segments. Transfer pricing is based on internally
approved yield curve or at an agreed transfer rate on the funding provided by treasury to another business segment.

b) Retail banking

The retail banking segment serves retail customers through a branch network. Exposures are classified under retail banking
taking into account the status of the borrower (orientation criterion), the nature of product, granularity of the exposure and the
quantum thereof.

Revenues of the retail banking segment are primarily derived from interest and fees earned on retail loans, interest on deposits
placed as collateral with the Bank. Expenses of this segment primarily comprise interest expense on borrowings, deposits,
infrastructure and premises expenses for operating the branch network, personnel costs and other direct overheads.

c) Corporate banking

Wholesale banking includes all advances to borrowers, which are not included under Retail banking. Revenues of the wholesale
banking segment consist of interest and fees on loans made to customers.

d) Other Banking Operation

Other Banking includes other items not attributable to any particular business segment. This segment includes income from
para banking activities such as distribution of third party product and the associated costs.

e) Unallocated

All items which are reckoned at an enterprise level are classified under this segment. This includes other unallocable assets and
liabilities such as deferred tax etc.

Geographical segments

The business operations of the Bank are concentrated in India hence the Bank is considered to operate only in domestic segment.

g) There are no such items in other assets and in other liabilities exceeding 1% of total assets to be disclosed as per Reserve Bank
of India (Financial Statements - Presentation and Disclosures) Directions, 2021, updated as on February 20, 2023.

h) Micro, Small and Medium Enterprises (MSME) sector - Restructuring of Advances

The Bank has restructured accounts in accordance with RBI circular on Micro, Small and Medium enterprise (MSME) sector) -
Restructuring of advances

1. Resolution Framework 2.0 - Resolution of Covid-19 related stress of Micro, Small and Medium Enterprises (MSMEs)_
RBI/2021-22/32/DOR.STR.REC.12/21.04.048/2021-22.

2. Micro, Small and Medium Enterprises (MSME) sector -Restructuring of Advances circular DOR.No.BP.BC.34/21.04.048/2019-
20 dated February 11,2020.

o) Disclosure on the scheme for sustainable structuring of stressed assets

The Bank does not have any account under the Scheme for Sustainable Structuring of Stressed Assets (S4A) as on March 31,
2025 (March 31,2024: H Nil).

p) Disclosure on flexible structuring of existing loans

The Bank does not have any account under the Scheme Flexible Structuring of Existing Loans as on March 31, 2025 (March
31,2024: H Nil).

q) Disclosure on strategic debt restructuring (SDR) scheme

The Bank does not have any account under the strategic debt restructuring (SDR) scheme as on March 31, 2025 (March
31,2024: H Nil).

r) Disclosure on change in ownership of project under implementation

The Bank does not have any account which are currently under the scheme of Change in Ownership of Projects Under
Implementation as on March 31, 2025 (March 31, 2024: H Nil).

s) Disclosure on change in ownership outside SDR scheme

The Bank does not have any account which are currently under the scheme of Change in Ownership Outside SDR as on March
31,2025 (March 31, 2024: H Nil).

t) The Code on Social Security, 2020

The Code on Social Security, 2020 ('Code') relating to employee benefits during employment and post-employment benefits
received Presidential assent in September 2020. The Code has been published in the Gazette of India. However, the date on
which the Code will come into effect has not been notified and the final rules/interpretation have not yet been issued. The
Company will assess the impact of the Code when it comes into effect and will record any related impact in the period the Code
becomes effective.

u) No proceedings have been initiated on or are pending against the Bank for holding benami property under the Benami
Transactions (Prohibition) Act, 1988 (45 of 1988) and Rules made thereunder.

v) The Bank has no transactions with the companies struck off under Companies Act, 2013 or Companies Act, 1956.

w) The Bank, as part of its normal banking business, that is conducted ensuring adherence to all regulatory requirements, grants
loans and advances, makes investments and accepts deposits and borrowings from its customer, other entities and persons.

(i) Other than the transactions described above which are carried out in the normal course of business, the Bank has not
advanced or loaned or invested funds to any other person(s) or entity(ies), including foreign entities (Intermediaries) with
the understanding that the Intermediary shall directly or indirectly lend or invest in other persons or entities identified in any
manner whatsoever by or on behalf of the Bank (Ultimate Beneficiaries) or provide any guarantee, security or the like to or
on behalf of the ultimate beneficiaries.

(ii) The Bank has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) with the
understanding (whether recorded in writing or otherwise) that the Bank shall directly or indirectly lend or invest in other
persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (Ultimate Beneficiaries) or
provide any guarantee, security or the like on behalf of the ultimate beneficiaries.

x) There is no income surrendered or disclosed as income during the current or previous year in the tax assessments under the
Income Tax Act, 1961, that has not been recorded in the books of account.

y) Disclosure on Green Deposits

During the year 2024-25, the Bank has not raised Green deposits and hence the Portfolio level information on use of funds and
reporting on allocation of proceeds of Green deposits to green activities/projects as mentioned in circular RBI/2023-24/14 DOR.
SFG.REC.10/30.01.021/2023-24 dated April 11, 2023 is not applicable.

z) The Bank has covered its unsecured loan portfolio under the Credit Guarantee Fund for Micro Units (CGFMU) Scheme,
administered by the National Credit Guarantee Trustee Company Limited (NCGTC), since FY 2022-23. As of FY 2024-25,
approximately 95% of the Bank’s unsecured loan portfolio is covered under the scheme.

Till FY 2023-24, the Bank maintained NPA, provisions on the full value of loans, including those covered under the CGFMU
Scheme, in line with its internal policy. From FY 2024-25, the Bank has decided to avail the benefit in accordance with Paragraph
5.9.4 of the RBI Master Circular - "Prudential Norms on Income Recognition, Asset Classification and Provisioning pertaining
to Advances” (DOR.STR.REC.8/21.04.048/2024-25) dated April 2, 2024, applicable to loans covered under the CGFMU Scheme.
Consequently, NPA provisions during FY 2024-25 were made only on the portion of such loans not guaranteed under the
scheme. Accordingly, the NPA provision for the year has been adjusted by H2.57 crore in respect of loans classified as NPA
as on March 2024.

Similarly, the Bank used to maintain Risk Weight as per New Capital Adequacy Framework (NCAF) guidelines issued by RBI,
on all the loans including those covered under the Scheme even though the same were eligible for claim under the Scheme
to the extent of the guaranteed portion. Henceforth, the Bank has decided to avail the benefit as per the provisions of the RBI
Circular DOR.STR.REC.67/21.06.201/2022-23 dated September 07, 2022, titled "Review of Prudential Norms - Risk Weights for
Exposures guaranteed by Credit Guarantee Schemes (CGS)”. Consequently, the Risk Weight is applied only on the portion to the
extent it is not guaranteed under the CGFMU Scheme, in respect of these loans. Accordingly, the capital to risk weighted asset
ratio (CRAR) as at March 31,2025 is 25.83%. Had the Bank not taken the benefit of the guarantee cover under the CGFMU Scheme
both in respect of NPA provisioning and CRAR computation, the CRAR as per the NCAF guidelines would have been 22.03%.

aa) Comparatives

Figures for the previous year have been regrouped wherever necessary to conform with the current year presentation.

As per our report of even date

For Mukund M. Chitale & Co. For and on behalf of the Board of Directors

Chartered Accountants Suryoday Small Finance Bank Limited

Firm Registration No: 106655W

Nilesh RS Joshi Krishna Prasad Nair Baskar Babu Ramachandran Vivek Karve

Partner Chairperson Managing Director and Director

Membership No: 114749 DIN-02611496 Chief Executive Officer DIN - 06840707

DIN-02303132

Place: Navi Mumbai Krishna Kant Chaturvedi Kanishka Chaudhary

Date: May 08, 2025 Company Secretary Chief Financial Officer


 
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