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Responsible Lending Policy

Pakimu Investment Limited T/A WanPaus Microfinance
Effective 16 June 2026 · Version v1.0 · Governed by the laws of Papua New Guinea

Draft — pending formal legal review. This document is effective as of 16 June 2026.

1. Purpose and Commitment

Pakimu Investment Limited T/A WanPaus Microfinance ("Pakimu", "we") is committed to responsible lending. We recognise that credit, if extended irresponsibly, can harm borrowers. This policy sets out the principles and controls we apply to ensure that every loan we make is affordable, transparently disclosed, and consistent with the borrower's ability to repay.

This policy applies to all lending decisions, products, and processes on the WanPaus Microfinance platform ("the Platform"). It is informed by the principles of responsible microfinance and the regulatory environment governing financial services in Papua New Guinea.

2. Defined Terms

Cooling-off period: The 5-business-day window after loan disbursement during which a borrower may cancel a loan without penalty, provided the full disbursed amount is returned. Distinct from the grace period.

Grace period (late fee threshold): The 5-calendar-day window after the loan due date before a late fee is applied. During the grace period, no late fee is charged and the repayment streak is maintained if the loan is repaid. This is a late-payment tolerance window, not a borrower right.

Default declaration period: If a loan remains unpaid for 14 calendar days past the due date (after the grace period has elapsed and the late fee has been applied), the loan is declared DEFAULTED and the default process is initiated. The default declaration period is separate from and longer than the late-fee grace period.

Overdue: A loan status indicating the loan has passed the grace period and the late fee has been applied, but the loan has not yet been declared DEFAULTED. An overdue loan can still be recovered without default consequences if repaid before the end of the default declaration period.

Default: A loan status indicating the loan has not been repaid within 14 calendar days of the due date. Default triggers credit bureau reporting (where applicable), tier reset to BRONZE, and commencement of the collections process.

3. Affordability Assessment

Before approving any loan, Pakimu evaluates affordability through the following controls:

(a) Tier-based borrowing limits. New borrowers start at BRONZE tier (K50 limit). The limit increases only as the borrower demonstrates consistent on-time repayment through a progressive 6-tier ladder: BRONZE (K50) → SILVER (K100) → GOLD (K200) → PLATINUM (K500) → EMERALD (K800) → DIAMOND (K1,000). Each tier requires a minimum of 3 additional consecutive on-time repayments.
(b) One active loan per borrower per lender. A borrower may not apply for a new loan while an existing loan with the same lender remains active. This prevents the accumulation of concurrent loan obligations.
(c) Credit bureau profile. Where available, the borrower's credit bureau profile is considered in the loan approval decision, including prior defaults and repayment history.
(d) Rule engine checks. Every loan application is assessed against a configurable rule set that may include: KYC verification status, outstanding balance thresholds, tier eligibility, and any tenant-specific credit criteria.

4. Transparent Pricing and Pre-Commitment Disclosure

No loan is issued without the borrower's informed consent to the full terms. Before any loan is approved, the Platform discloses:

(a) the principal amount;
(b) the applicable interest rate (APR and flat rate equivalent);
(c) the total amount repayable, calculated at approval;
(d) the loan due date and term;
(e) all fees (including any late fee that applies if the grace period is exceeded);
(f) the consequences of late payment, overdue status, and default;
(g) the borrower's right to a 5-business-day cooling-off period.

Consent is recorded with an OTP-confirmed digital signature before any funds are disbursed. This consent record is immutable and forms the audit basis for the loan agreement.

5. No Predatory Practices

Pakimu does not engage in predatory lending. The following practices are expressly prohibited:

(a) approving a loan where the total repayable amount is not disclosed in advance;
(b) charging any fee not disclosed before consent;
(c) structuring loan rollovers or refinancing in a manner that conceals the accumulating cost of credit;
(d) applying pressure, urgency, or misleading statements to obtain consent;
(e) approving a loan where there is a reasonable basis to believe the borrower cannot repay.

Refinancing (where enabled by the lender) extends the due date and recalculates the outstanding balance with additional interest. The additional cost is calculated and disclosed before the refinancing is confirmed.

6. Cooling-Off Right

Every borrower has the right to cancel a newly approved loan within 5 business days of disbursement, provided:

(a) no funds have been drawn down, or the full disbursed amount is returned in a single payment; and
(b) the borrower contacts Pakimu at hi@wantekpng.com within the cooling-off window.

The cooling-off period is a pre-disbursement cancellation right. It is distinct from the 5-day grace period that applies after a loan's due date.

7. Late Payment, Overdue, and Default — Escalation Process

Pakimu applies a structured escalation process that distinguishes three states:

Due date passes: The loan enters a 5-calendar-day grace period. No late fee applies. Repayment streak is maintained if paid within this window.
Day 6 (grace period exceeded): A late fee of 10% of the original principal is applied. The loan status moves to OVERDUE. The consecutive repayment streak resets to zero and tier returns to BRONZE.
Day 14 (default declaration): If the loan remains unpaid, it is declared DEFAULTED. Credit bureau reporting (where applicable), suspension of access to new loans, and commencement of the collections process follow.

At each stage, Pakimu will attempt to contact the borrower. Borrowers experiencing hardship should contact hi@wantekpng.com before their loan becomes overdue or defaults.

8. Hardship and Flexibility

We recognise that circumstances can change. Borrowers experiencing financial hardship are encouraged to contact us before their loan becomes overdue. While we do not guarantee hardship arrangements, we will consider each case individually. Early communication is the most effective way to avoid late fees, tier reset, and default consequences.

9. Responsible Marketing

All marketing and promotional materials for WanPaus loan products must:

(a) state the APR prominently;
(b) not present borrowing as a solution to long-term financial difficulty;
(c) not target individuals who show signs of financial distress or addiction;
(d) include a reference to this Responsible Lending Policy.

10. Amendments and Review

This policy will be reviewed at least annually. Material amendments will be communicated to borrowers by email at least 14 days before taking effect and will be reflected in an updated version of this document on the Platform.

11. Contact

Pakimu Investment Limited T/A WanPaus Microfinance
Email: hi@wantekpng.com
Papua New Guinea