1. Background 1.1

PayU Payments Private Limited (“PayU Payments”) acts as an intermediary between its business customers (“Merchants”) and the end users (“Consumer”) by aggregating various payment instruments to facilitate online transactions. The Reserve Bank of India (“RBI”) vide notification dated 17 March 2020 bearing reference number RBI/DPSS/2019-20/174 DPSS.CO.PD.No.1810/02.14.008/2019-20 as amended, restated, clarified and modified from time to time (“PA Guidelines”) has laid out regulations for PayU Payments’ payment aggregation business.