1. Objective

• This Code of Conduct establishes a fair, transparent, and legally compliant framework for collection of dues and repossession of assets.
• It aims to ensure that all recovery activities are conducted in a manner that protects customer dignity, maintains trust, and avoids reputational risk to the Company.
• The policy is aligned with the Fair Practices principles prescribed by the Reserve Bank of India and reflects industry standards followed by leading NBFCs.

2. Scope & Applicability

• This Code shall apply to:
  • All employees engaged in collection and recovery
  • Field executives and telecalling staff
  • Third-party recovery agents appointed by the Company
• It governs:
  • Customer interactions
  • Recovery practices
  • Repossession procedures
  • Communication standards

3. Core Principles of Customer Engagement

3.1 Respect, Dignity & Professional Conduct

• All interactions with customers shall be conducted in a courteous, respectful, and professional manner, irrespective of the customer’s repayment status.
• Employees shall ensure that customer privacy is respected at all times, and no action should result in embarrassment or reputational harm.

3.2 Transparency & Fair Dealing

• Customers shall be provided with clear, accurate, and complete information regarding outstanding dues, charges, and recovery actions.
• Misleading statements, false commitments, or concealment of facts shall be strictly prohibited.

3.3 Non-Coercive Recovery Approach

• The Company shall adopt a non-coercive and customer-centric recovery approach, encouraging voluntary repayment.
• Any form of harassment, intimidation, or undue pressure shall be strictly prohibited.

4. Customer Contact & Communication Framework

4.1 Timing of Contact

• Customers shall be contacted only during permissible hours (08:00 AM to 07:00 PM), unless exceptional circumstances justify otherwise.
• Requests from customers to avoid specific times or locations shall be honored wherever feasible.

4.2 Place of Contact

• Customers shall ordinarily be contacted at their preferred location, and in absence of such preference:
  • At their residence
  • Or place of business/occupation

4.3 Modes of Communication

• Communication shall be carried out through:
  • Phone calls
  • Written notices
  • Personal visits
• All communication must:
  • Use clear and understandable language
  • Avoid aggressive tone or pressure tactics

4.4 Documentation of Communication

• All interactions shall be properly recorded, including:
  • Time and number of calls
  • Summary of discussions
  • Commitments made by customer
• This ensures audit trail and accountability.

5. Identification & Authorization

• All representatives must:
  • Carry valid Company-issued identity cards
  • Present authorization letters when required
• Customers must be clearly informed about:
  • Name of representative
  • Company affiliation
  • Purpose of visit

6. Prohibited Practices (Strict Compliance)

• The following practices are strictly prohibited:

6.1 Harassment & Intimidation

• Use of abusive language, threats, or coercion
• Physical or psychological intimidation
• Repeated unnecessary calls or visits

6.2 Public Humiliation

• Discussing customer dues in public or with unauthorized persons
• Visiting workplace in a manner that harms customer reputation

6.3 Intrusion into Personal Life

• Interfering with family matters
• Contacting relatives without consent

6.4 Sensitive Situations

• Recovery efforts shall not be conducted during:
  • Bereavement
  • Medical emergencies
  • Natural calamities

7. Pre-Recovery & Collection Procedures

7.1 Issuance of Notices

• Adequate written notice shall be provided before initiating recovery action.
• The notice shall clearly specify:
  • Outstanding dues
  • Due date for payment
  • Consequences of non-payment

7.2 Customer Assistance & Resolution

• Customers facing genuine financial difficulty shall be:
  • Guided on available options
  • Offered restructuring or rescheduling (as per policy)
• The Company shall adopt a solution-oriented approach rather than enforcement-first approach

8. Field Visit & Collection Conduct

8.1 Professional Behaviour

• Field executives shall:
  • Maintain decency and decorum during visits
  • Communicate politely and professionally

8.2 Physical Boundaries

• Executives shall:
  • Maintain appropriate distance from customer
  • Avoid any physical contact or obstruction

8.3 Visit Preparedness

• Executives shall carry:
  • Identity card
  • Collection records
  • Receipt book
• Visits shall be planned and purposeful to ensure maximum effectiveness.

9. Repossession of Assets

9.1 Conditions for Repossession

• Repossession shall be initiated only after:
  • Adequate notice to borrower
  • Exhaustion of reasonable recovery efforts

9.2 Fair & Lawful Process

• Repossession must be:
  • Conducted peacefully
  • Free from force or coercion
  • In compliance with legal requirements

9.3 Post-Repossession Handling

• The Company shall ensure:
  • Proper documentation of repossession
  • Safe custody of asset
  • Transparent valuation and sale

9.4 Borrower Rights

• Borrower shall be provided opportunity to:
  • Settle dues before sale
  • Receive surplus amount after adjustment

10. Engagement Of Recovery Agents

10.1 Appointment & Disclosure

• Recovery agents shall be appointed in line with regulatory guidelines.
• Their identity and role shall be clearly disclosed to customers.

10.2 Agent Conduct

• Agents shall strictly follow this Code of Conduct.
• Any violation shall result in:
  • Immediate action
  • Termination of engagement

11. Ethics, Confidentiality & Discipline

11.1 Ethical Conduct

• Employees shall not make:
  • Unauthorized commitments
  • Misleading statements

11.2 Confidentiality

• Customer information shall not be disclosed to:
  • Unauthorized individuals
  • Competitors or third parties

11.3 Process Discipline

• All actions shall be performed strictly within:
  • Defined policies
  • Approved procedures

12. Monitoring, Audit & Record-Keeping

• The Company shall maintain:
  • Records of all communications
  • Recovery actions and visits
  • Repossession details
• Regular audits shall be conducted to ensure:
  • Compliance with this Code
  • Adherence to RBI guidelines

13. Do’s & Don’ts (Behavioural Standards)

13.1 DO’s

• Maintain professional appearance and conduct
• Use polite and firm communication
• Be well-prepared before customer visits
• Focus on resolution and customer engagement

13.2 DON’Ts

• Do not use abusive or aggressive language
• Do not threaten or harass customers
• Do not disclose confidential information
• Do not make unauthorized commitments

14. Policy Enforcement & Consequences

• Any violation of this Code shall result in:
  • Disciplinary action against employees
  • Termination of recovery agents (if applicable)
• Serious violations may also lead to:
  • Regulatory reporting
  • Legal consequences

15. Policy Review & Approval

• This Code shall be approved by the Board of Directors.
• It shall be reviewed periodically or upon regulatory updates.