Product & Distributor Compliance Policy
This Product & Distributor Compliance Policy (“Policy”) sets out the minimum compliance requirements that Distributors and the products listed, offered or supplied by them through SutraFin (“Platform”) are required to meet. The Policy covers requirements relating to Distributor verification, product authenticity, lawful sourcing, product information, safety and compliance with Applicable Law.
This Policy shall be read together with the applicable terms and conditions and other policies of the Platform. The requirements under this Policy are in addition to the obligations applicable to Distributors under the applicable terms and conditions, agreements, policies and Applicable Law. Compliance with this Policy does not relieve a Distributor of any responsibility or obligation imposed under Applicable Law.
Distributor Verification and Regulatory Compliance
The Platform may verify the legal or trade name, constitution, contact details, GSTIN, PAN, business address, authorised person details, applicable FSSAI licence or registration, category-specific licences, registrations, certificates and manufacturer or brand authorisations of a Distributor.
Distributors are required to provide complete, accurate and current information and documents requested by the Platform for onboarding, verification or compliance purposes. The Platform may conduct verification through government databases, regulatory sources, authorised third-party service providers or other lawful sources.
Distributors are responsible for obtaining and maintaining all licences, registrations, approvals and authorisations required for their business and products and for complying with Applicable Law relating to the manufacture, sourcing, storage, packaging, labelling, pricing, taxation, sale, distribution, transportation, safety, quality and recall of products, as applicable.
Distributors must promptly notify the Platform of any suspension, cancellation, expiry, modification or other material change to any licence, registration, approval or authorisation relevant to the Distributor or a product listed or supplied through the Platform.
Product Authenticity and Lawful Sourcing
Only genuine, authentic and lawfully sourced products may be listed, offered or supplied through the Platform. Counterfeit, pirated, stolen, adulterated, tampered, unlawfully sourced or fraudulently represented products are prohibited.
Distributors must ensure that products listed or supplied through the Platform are sourced through lawful and legitimate channels and must maintain appropriate records or documents evidencing the source and authenticity of such products. The Platform may request such records or documents where reasonably required for verification or compliance purposes.
Product Information, Packaging and Labelling
Distributors are responsible for ensuring that product information provided to the Platform is accurate, complete, current and not misleading. Product listings must, where applicable, accurately state the product identity, brand, manufacturer, pack size, weight or volume, quantity, MRP, selling price, applicable taxes, images, ingredients, warnings, expiry or best-before date, shelf-life and statutory declarations.
Distributors must ensure that products comply with Applicable Law relating to packaging, labelling, mandatory declarations and Legal Metrology, including requirements concerning the name and address of the manufacturer, packer or importer, net quantity, MRP, date-related declarations and other information required to be displayed on packaged products.
Distributors must promptly update product information where any change affects the accuracy or regulatory compliance of a listing and must provide the Platform with information and declarations required for lawful display of products on the Platform.
Food Products
Food products listed or supplied through the Platform must comply with Applicable Law, including applicable requirements relating to FSSAI licensing or registration, food standards, product composition, labelling and display, storage, transportation, shelf-life, food safety and recall.
Distributors dealing in food products must maintain valid and applicable FSSAI licences or registrations and provide the same to the Platform when requested.
Product Expiry, Shelf-Life and Storage
Distributors must ensure that products listed, offered, supplied or delivered through the Platform are within their applicable shelf-life and are not expired, damaged or otherwise unfit for sale or consumption.
Products must be stored and handled in accordance with the storage conditions prescribed under Applicable Law, applicable product specifications and manufacturer instructions. Distributors must also comply with any minimum residual shelf-life requirement prescribed by Applicable Law, the Platform or applicable product-category requirements.
For food products delivered through the Platform, Distributors must ensure compliance with the minimum residual shelf-life requirements prescribed by FSSAI and Applicable Law, including the requirement that the food article delivered to the consumer has a shelf life of at least 30% or 45 days before expiry, as applicable.
For other product categories, the minimum residual shelf-life requirements shall be as prescribed under Applicable Law, applicable product-category requirements, manufacturer specifications, or such additional requirements as may be communicated by the Platform from time to time.
Product Recall and Safety
Distributors must promptly notify the Platform of any product recall, safety warning, contamination, regulatory restriction or prohibition, material product defect, adverse regulatory action or other circumstance that may affect the legality, safety or suitability of a product listed or supplied through the Platform.
The Platform may, based on such information or any other credible information available to it, restrict or remove an affected listing, block or cancel affected orders, require withdrawal of products or take other measures reasonably necessary to address the risk or comply with Applicable Law.
Records and Compliance Cooperation
Distributors must maintain records and documents reasonably necessary to demonstrate compliance with this Policy and Applicable Law, including sourcing invoices, licences, registrations, certificates, manufacturer or brand authorisations, product specifications, batch or lot information and recall-related records, as applicable.
The Platform may request information or documents for verification, investigation, compliance or audit purposes. Distributors must provide the requested information within the timeframe specified by the Platform and cooperate with reasonable requests relating to regulatory investigations, product recalls, safety matters, complaints or other compliance requirements.
Compliance Measures
The Platform may monitor product listings and Distributor information and may conduct compliance checks based on available information, complaints, regulatory notifications, verification results or other compliance concerns.
Where the Platform identifies non-compliance with this Policy or Applicable Law, it may require corrective action, remove or delist a product, restrict or block orders, suspend or restrict the Distributor’s access to the Platform, terminate the Distributor’s participation or make disclosures to competent authorities where required or permitted by Applicable Law.
Where there is credible information indicating counterfeit goods, unsafe or expired products, recalled products, fraud, falsified or invalid licences or documents, serious regulatory non-compliance or a material risk to public health or safety, the Platform may immediately restrict or suspend the relevant listing, order or Distributor account pending further review. Such action may be taken without prior notice where reasonably necessary to protect users, comply with Applicable Law or prevent further sale or distribution of the affected product.