Code of Conduct - Sampathi

As per extant guidelines Reserve Bank of India (RBI), all NBFCs should follow strict guidelines under the Fair Practices Code (FPC) and ensure that a suitable mechanism exists for monitoring the collection process and adherence there to, teams deployed to do collections and Debt Recovery Agents (Agencies) with specific emphasis on resolving such complaints fairly and expeditiously regardless of the source of the complaints.

Where relevant and pertinent, applicability and provisions of the Reserve Bank of India (Digital Lending) Directions, 2025 and the Reserve Bank of India (Non-Banking Financial Company– Scale Based Regulation) Directions, 2023 are enshrined in this policy document (relevant extract placed in Annexure)

All Regulated entities remain strictly accountable for their outsourced agents and authorised representatives and must ensure that they uphold borrower dignity, maintain privacy, and act only during permitted hours etc.

Accordingly, the Company proposes to adopt an exclusive and comprehensive policy on this topic effective 1^st July 2026.

1. Introduction:

Sampathi Credits Private Limited is a technology-driven financial services company committed to advancing digital financial inclusion by bridging traditional lending practices with innovative fintech solutions.

Our mission is to transform the way loans are processed in India by leveraging advanced credit assessment systems and modern technology to deliver fast, secure, and seamless digital lending experiences and our vision is to become a premier fintech lending platform that empowers individuals and small businesses by providing accessible, collateral-free, and customer-centric credit solutions.

At Sampathi, customer trust and satisfaction are fundamental to our business. We strive to provide transparent, fair, and efficient services at every stage of the customer journey. However, despite our commitment to operational excellence, there may be occasions when our services do not fully meet customer expectations.

This Policy has been framed in accordance with applicable regulatory requirements and industry best practices, reinforcing our commitment to customer protection, responsible lending, and ethical business conduct and all aspects revolving around collections and debt recovery methods being adopted and followed by the Company.

This Policy applies to all products, services, digital lending platforms, business correspondents, lending service providers (where applicable) and customer interactions of the Company.

With an emerging collection-tech industry, recovery increasingly involves AI-powered interactions and layered processes. Regardless of this fact, it is noted that, NBFCs do have clear-cut fiduciary responsibility for compliance in the recovery process, including the right behaviour and communication with borrowers and data privacy and protection as per the borrower’s consent.

The policy seeks to cover and include all channels of the Company that are engaged in collections and debt recovery and provided by employees, agents, Business Correspondents (BCs), Lending Service Providers (LSPs), in whatever form and manner in which they called, described and referred to as.

The Code of Conduct for Collection Staff and Collection Agents of the Company (hereinafter referred to as the “Code”) is built around maintaining the dignity and respect to all its borrowers.

The Company believes that, all borrowers (including those who are late in paying or in default) must be treated with respect, dignity, courtesy, and fairness, persuasion and respect for the borrowers/ customers in debt collection efforts. The Company believes in following fair practices as laid down in its Policy on Collection of Dues and thereby instilling necessary borrower confidence and long-term relationship.

It is imperative that all Collection Staff and Collection/ Recovery Agents abide by this Code of Conduct in letter and spirit.

This Code applies to all employees of Company and/ or other affiliates and employees/ agents of companies that may be retained/ engaged to collect/ recover borrower debts/ dues on behalf of the Company.

All the practices adopted by the Company for follow up and recovery of dues and repossession of security will be in consonance with the law. Any Collection Agent found violating the tenets of the Governing law or this code may be blacklisted.

The debt collection (through Staff/ Recovery Agents) policy of the Company is built around dignity and respect to customers. It is mandatory for the Company to follow fair practices with regards to collection of dues and repossession of security and thereby cultivate customer confidence and long-term relationships. The repayment schedule for any loan sanction will be fixed taking into account, the repayment capacity and the actual cash flow pattern of the borrower.

The Company will explain to the borrower upfront the method of calculation of interest and how the Equated Daily Instalment (EDI)/ Equated Weekly (EWI)/ Equated Monthly Instalment (EMI) or any other mode of repayment will be appropriated against interest and principal due from the borrowers.

The method of collection of the instalment dues (say UPI mandate, ACH, direct debit, post-dated cheque etc.) would be fixed taking into consideration the convenience of the borrower. The Company would expect the borrower to adhere to the repayment schedule agreed to and approach the company for assistance and guidance in case of genuine difficulty in meeting repayment obligations. The aim of this policy is to facilitate recovery of dues in the event of default and not for whimsical deprivation of any nature impacting the borrower.

The Company would adhere to the extant regulatory guidelines on Fair Practices Code for Lenders, Outsourcing of Financial Services, Code of Company’s Commitment to Customers and Recovery Agents engaged by NBFCs and other best practices as are prevalent and practised in the market to ensure best possible customer service and service standards.

The word “borrower(s)” or “customer(s)”, whenever used in this policy collectively refers to borrower, co-borrowers and guarantors, loan applicants etc. as the context requires.

Collection Waterfall mechanism – for follow-up and recovery:

Primary banking: The Company aims to realize more than 95% its loan dues and demands through primary banking i.e. by presenting UPI Pulls, Debit ACH mandates, Account to Account Transfer Instructions, Post Dated Cheques etc. This layer would include intelligent banking of UPI and ACH mandates basis borrower’s specific cash flow pattern and its timing etc. and thus the Company would ensure to present the debit mandate at an appropriate time where the probability of realisation is high.

Customer-induced remittances: In the event of any loan getting into overdue/ delinquency, for any reason whatsoever, Borrowers (on their own) are expected to pay their dues immediately and through digital means i.e. by initiating funds transfer (of all dues) to Company’s designated Bank account.

Tele-calling (soft follow-up): Where such collections are not forthcoming, the Company may use its Tele-calling set-up to nudge the borrowers concerned, to remind about the dues in the concerned loan accounts and seek payment of dues/ overdue. Such remittances are sought through digital means only.

Field Visit and Collection follow-ups: For residual base of borrowers, collection follow-ups are initiated by Company’s Direct Team or through empanelled Collection & Recovery agencies.

Skip/ Absconding and Refusal to pay: Where the borrower has “skipped/ is absconding” or remains uncontactable or refuses to pay the dues citing some reason or the other, the Company may initiate legal proceedings for recovery of its dues.

The Company has a well-documented hierarchy and escalation protocols across buckets (e.g: loan amount, days past due, non-contactability, borrower behaviour/ past experience etc.) and loaded with specifics for physical and digital/ AI-enabled recovery as applicable.

The Company would use all information available at its disposal including borrower repayment history as well as behavioural scorecards to differentiate the borrowers based product, tenure, OD and DPD buckets, trend analysis, credit score movement, predefined categories to segment recovery process and accordingly strategize the recovery methods/ channels and severity etc.

The policy document covers aspects of due diligence, contract, disclosure, grievance and oversight of recovery functions and provisions for data privacy and security protocols (e.g. retention, purging, handover, destruction, reporting and mitigation for breach, log of processes where personal data is used) in contract with external agents. The policy also prescribes periodic review of the policy annually and in the event of any regulatory change.

Collection follow-up – General Guidelines:

Each borrower is duly informed of all details relating to the loan including the due amount, due date, interest payable in case of delayed payment, impact of delinquency on credit history etc.
In right earnest, it is expected that, the borrower would repay all his EDI/ EWI/ EMI on time every time and without any reminders or follow-up
The Company would give pre-presentation intimation to the borrower concerned, over his registered mobile number and the Borrower would keep adequate funds in his designated bank account to honour the EDI/ EWI/ EMI, as the case may be (such that, the loan is always current and without any delinquency strings). The Company thus would on “best efforts basis” endeavour to give sufficient prior notice for payment of dues.
The Company would do the collection follow-up and recovery of dues using its own collection team or by engaging Collection Agencies/ Agents
The Company has a system of doing multiple checks before passing on a default case to Field Team/ Collection Agencies so that borrowers are not harassed on account of lapses on Company’s part.
The details of all such Agencies engaged by the Company would be hosted on the Company’s website and the listing is duly refreshed periodically to reflect the current and active list of such Agencies deployed by the Company
The Company would formally communicate the Recovery-agent particulars to the Borrower by way of email/SMS before first contact is done
The Company would insist on the Collection Agencies to confirm and ensure that, each of the Agent deployed by the said Agency conforms with the selection/ qualification criteria prescribed and further that, he has qualified himself as an authorized “Debt Recovery Agent (DRA)” by clearing the relevant DRA Examination.
The Company staff or any person authorized to represent the Company for collection of dues would identify himself as such to the Borrower concerned (each time, at the beginning of interaction) and upon request also display to the Borrower (or his family or his appointed representative), his identity card issued by the Company or under Authority of the Company by his Agency.
The borrower will be contacted ordinarily at his Shop/ Office/ Workplace/ place of occupation/ business establishment (as the Company is more into the business of extending unsecured business loans) i.e. the address registered with the Company and in the absence of any specified place/ his non-availability in his shop/ office, at the place of his residence and if he is unavailable at his residence (too), at any other address obtained/ known during interaction with the borrower or from interaction with his friends/relatives or where the borrower is actually present/ available or can be traced to.
The Collection staff/ Agent should always carry a copy of the relevant notice(s) sent by the Company and the authorization letter from the Company and his Employee identity card, while on a field visit.
The notice and the authorization letter should, amongst other relevant details, also include the telephone numbers of the relevant Collection Agency/Agent to whom the loan recovery has been allocated/ assigned

Commitment to imbibe, adhere and follow:

All Collection Staff/ Recovery Agencies (Agents)/ Tele-callers note and understand that, he would:

Treat all Borrowers with due respect and dignity always.
always maintain professionalism during his telephonic conversations and physical visits or while doing neighbour checks in case of non-traceable addresses, “door locked” & “borrower vacated/ shifted/ not traceable/ absconding” instances etc.
Refrain from making telephone calls without meaningful disclosure of the his (Caller’s) identity.
be appropriately dressed, well-groomed and maintain decorum and decency always, avoiding misdemeanour of any sort or nature
ensure to adopt civil manners for interaction with borrowers.
always use acceptable business language, even if the other party does not.
as far as possible, use the vernacular/ common language with which the Borrower is comfortable.
ensure privacy of all Borrowers and their family members, referees and friends and shall respect this right always.
always ensure Borrower’s secrecy. However, he may choose to discuss the matter with the Borrower’s family members (*), especially if the Borrower does not respond to “Loan Recall Notices (LRNs)” and/ or to the repeated calls made by Collection staff / Agent.
(*) Family for this purpose will only be close and adult family members and includes borrower’s spouse, son (including legally adopted son), unmarried daughter (including legally adopted daughter), unmarried sister, father, mother, daughter-in-law, grandson and grand-daughter.
make best possible efforts to document the time and number of calls/ physical visits and contents of the conversation with the borrower for the recovery of dues.
communicate with the Company and ensure that all necessary assistance is given to resolve disputes or differences regarding dues, on time, in a mutually acceptable and in an orderly manner. The Company will be ready to provide any assistance which the borrower may seek in this regard.
furnish a formal undertaking to the Company (through the Collection and Recovery Agency) confirming that all content of this policy has been noted and understood and further that, he would totally adhere to the same
resort to only legally permissible activities/ methods during the course of recovery
appropriately sensitize the borrowers concerned about the Impact on their credit history, possible inclusion in the negative list of Credit Reference Agencies/ Card Issuers / Indian Banks Association etc. and also about possible legal action and its impact on social standing, cost of defending legal action, if such action is contemplated.

Don’ts:

Collection staff / agent should:

not make any written or verbal threats and avoid abuse, rudeness, boorishness, or mishandling at any time.
make threatening or anonymous calls or make persistent calls
not threaten with imprisonment or even mention imprisonment unless the planned or current legal action could result in imprisonment. Threaten with arrest/detention by the police unless, prima facie, the Borrower’s actions indicate criminal intent that could lead the police to arrest/ detention.
not resort to intimidation or harassment of any kind, either verbal or physical, against the Borrower or their family members or friends during debt collection efforts.
not react emotionally, even if the situation warrants
not make any false/ misleading representations.
not mislead the Borrower regarding the proposed action and its consequences.
not resort to any acts intended to publicly humiliate or intrude upon the privacy of the customer’s family members/ referrals/ friends
not use of agents’ personal phone numbers, devices, or emails for recovery purposes (unless duly permitted by the Company)
not mislead the Borrower about their true business or organization name, or falsely represent or imply that the Collection staff/ Agent is an attorney (lawyer), government official, officer of any court etc.
not accept Gifts or bribes from Borrowers or take any monetary inducement of any kind. Any Collection staff/ Agent offered a bribe or payment of any kind by a Borrower must report the incidence immediately to his Superior.
not enter the Borrower’s residence against his wishes or when they are told the Borrower is not at home.
not enter the house unless invited.
not remain in the Borrower’s house if he were to leave for any reason including to collect money from a bank/ elsewhere.
not restrict the Borrower’s movement or restrain the borrower from entering or leaving his house/ room
not embarrass the Borrower in the presence of neighbours/ relatives/ general public/ co-shop owners etc.
not continue with collection follow-up, if the Borrower is not present at his residence and only minors/ elderly/ infirm are present. He should end the visit with a proper Call Log/ Visit Report detailing the circumstances and inform Borrower’s family to request the Borrower to call back
not accept recovery payments from the borrower to his personal Bank A/c or in the form of Cash (anytime)
not put his own monies to make the loan current (for any reason whatsoever) and trying to make recoveries from the borrower concerned, on his own stead. Collection management and window dressing in any form and manner should never be practised.
not send inappropriate messages either on mobile or through social media or make threatening and/ or anonymous calls to the Borrower, its family members, referees and friends.
not make any promises to the borrowers on the settlement amount, change in the credit information bureau status or issuance of “No Dues Certificate” without prior approval from the authorized approver.
not use non-recorded lines/ personal mobile numbers to converse with the borrowers.
not use any unacceptable methods to reach out to the borrowers.
not approach/ use any Social Media partner to reach out to the borrowers.

Collection Calling & field visits:

Tele-callers/ Collection staff/ Agent should note that:

all borrowers are contacted on their registered mobile numbers and bureau numbers only.
all interactions with the borrowers are updated on the Company’s “Collection System”
always only recorded lines are used while interacting with the borrowers.
borrowers may be contacted only between 08:00 a.m. and 07.00 p.m. unless special circumstance of Borrower’s business or occupation or other engagements requires the Collection staff/ Agent to contact the Borrower at a different time.
Borrower requests to avoid calls at a particular time or at a particular place should be honoured as far as possible. And, it may be ensured that a Borrower is contacted when the call is not expected to inconvenience him.
Calls must first be placed to the Borrower. If the Borrower is not available, a message should be left for the Borrower to return the call or check for a convenient time to call again.
A formal message may be left with their business associate or person(s) representing them indicating that:
“Mr. XXX (Collection Staff / Agent representing Sampathi Credits Private Limited called up/ personally visited and he has requested to call him back at xxxxx-xxxxx (Mobile No) and the purpose of the call/ visit was for recovery of loan dues”.

Calls earlier or later than the prescribed hours may be placed under the following conditions:
When the Borrower has specifically authorized to do so in writing or orally.
Due notice of recall of the loan has been served by the Company on the borrower, and appointment of Collection Staff/ Agent has been intimated to him, and the borrower is intentionally avoiding calls of the Collection Staff/ Agent.
Time and number of calls and contents of conversations have been duly documented.
Collection Staff / Agents should endeavour to answer borrower’s queries and render assistance to resolve issues. Collection staff / Agent will document the efforts made for the recovery of dues and the copies of communication, if any, sent to the borrowers will be kept on record. All such records will be collated and maintained as per Record Retention Policy of the Company.
Inappropriate occasions such as bereavement in the family or serious illness/ accident or such other calamitous occasions are avoided for making calls / visits to collect dues.
If a borrower is repeatedly and purposely avoiding contacts during the permitted time window, then he may be contacted at hours which are beyond the generally prescribed time frame with due approval and ensuring all other covenants of this policy are adhered to. In such cases, the borrowers concerned would be contacted before or after the prescribed calling/ contact hours, especially where the borrower is refusing to pay or continuously remaining not contactable, is non-cooperative, disputing earlier commitments.

It is always the borrower’s responsibility to update his contact details/ provide alternate contact nos. with the Company. In case the Company is unable to contact the borrower at the details/ address provided, the Company will access information as available from public sources and approach friends/ relatives to locate the borrower/ customer concerned.

The Company would respect privacy of its borrowers. It shall however be noted that contacting the borrower on phone or personal visits for recovery of dues (in line with this model policy) will not be construed as an intrusion of the privacy of the borrower.

Policy & Process Assurance:

All Collection staff / Agents are to be treated with dignity.
They may refer the Borrower to management, or end calls when a Borrower becomes abusive or threatening. The said Borrowers should be formally informed about their inappropriate/ abusive usage of language or threatening tone etc. is not “acceptable” prior to termination of such calls. All calls where the borrower becomes abusive or threatening should be appropriately documented.
In such cases, Company would try to sensitize the Borrower concerned and ensure that repetitive instance of such nature is avoided and incorrigible borrowers are legally served with notice mentioning intimidation, threatening, abuse etc. warning of commensurate legal action.
The Company would:
provide all requisite training (covering soft skills, respectful behaviour, protection of borrower and lender information, and sensitive handling of agitated borrowers) during induction and repeat the reiterative training periodically to update to changes in internal policies/ regulations.
establish standard text messages/ WhatsApp templates that can be sent to the borrowers (and all such templates would be checked and validated by Legal and Compliance/ Risk Teams, per specific situations and scenarios
establish necessary access controls and safeguards to prevent the misuse of borrower data and share only the relevant data about the borrower necessary for debt recovery efforts.
ensure that recovery staff communicate effectively with different borrower profiles based on gender, age, and literacy. When using AI agents, ensure that agents understand AI escalation protocols.
all outgoing and incoming calls with borrowers and audit them for tone of voice and language, including mystery audits by seeding borrowers to audit the efficacy of the collection process.
share only minimal borrower data for collection-specific purposes with recovery agents and align with data and information security policy for security controls, isolation of data, encryption, data localisation, retention period, handover, certified destruction of data and reporting, response and mitigation for data breach.
prohibit Data scraping, especially sensitive personal data or information of borrowers, unless consent is provided for the same.
avoid “creepy AI” behaviour and borrower data to be used for AI / ML model training with explicit borrower consent for the purpose.
monitor the AI communication with the human-in-the-loop (HITL) principle for escalations and critical decisions
regularly review AI-enabled “collection recovery models and processes” for validation/ logical reasoning and traceability/ repeatability, accuracy, bias, data privacy, exception/ error handling process, back-up plans, and potential legal liabilities.

Engagement of Collection and Recovery Agencies:

The Company:

may use the services of collection and recovery agents for follow-up and collection of dues (including tele-calling set-ups).
shall formally evaluate and appoint such agents and this process shall be carried with proper antecedent verification, due diligence checks, market reference checks, reputation feedback, police clearance etc.
shall make available the name and address of all such agencies approved and engaged, on its website for information.
would develop a Standard Operating Procedure (SOP) to advise debt recovery agents on steps to approach a borrower for recovery including internal limits for the number of calls and messages per day through calls/ auto-dialers and SMS/WhatsApp for non-connect.
would ensure that the employees engaged in collection & recovery of its lawful dues are deployed only after completing the mandatory Debt Recovery Agent (DRA) training (certification from the Indian Institute of Banking and Finance (IIBF)).
would disclose the identity of the agency to the borrower.
would ensure that all the Collection Staff/ Agents deployed follow a code of conduct which will govern their dealings with the borrowers.
would ensure that the engagement agreements would clearly define the parties’ responsibilities and actions for failure to perform and breach of obligations.
would define an appropriate penalty grid for agencies/ staff (including financial penalties) based on the nature/severity of breaches and would blacklist the erring agents including permanently terminating the recovery agency, informing the public at large, by displaying the termination status on the website; report breaches to relevant regulatory authorities (e.g., the RBI) or law enforcement, where legally required or deemed appropriate, within a reasonable timeframe.
would ensure that all such engagements are for finite period and are subjected to review before renewals and the Company would ensure to periodically review the conduct of Recovery Agencies.

Grievance Redressal:

The company would investigate any complaint from the borrower about unfair practices by collection agents. The grievance redressal policy for complaints as hosted on Company’s website will be applicable. The Company may provide assistance to the borrower/s to resolve disputes/ differences regarding dues in a mutually acceptable and orderly manner. The matters may also be referred to the Arbitral Tribunal, Lok Adalat etc. for speedy justice. In respect of MSME borrowers, grievances will be governed as per the extant MSME policy in place.

Governance Oversight:

Top management would periodically review the debt recovery performance, as below and present a consolidated summary to the Board (along with Action Taken Report (ATR)) during the quarterly meetings:

Trend analysis and movement in nos./ nature or type of major category of complaints
root cause analysis of complaints
complaints related to recoveries across internal teams/external personnel/ agencies
criminal complaints against recovery agents
code of conduct breaches by recovery agents
complaints raised by borrowers about service deficiency resulting in non-payment.
Bench-marking statistics with other peers in the industry
Complaints against borrowers for unruly behaviour
daily average and maximum contact made with the borrower
Incident where the borrower defaults on the first EMI or non-starters, DPD 90+ or peak DPD review etc. for patterns involving multiple accounts sourced by the same Sourcing Channel or Geography or Borrower profile etc., as these may indicate potential fraud.
information shared during the collection process during exceptional circumstances, such as the death or hospitalisation of the borrower or absconding or skip of the borrower, major illness in the family etc.
incidents of data leaks, unauthorised data access, incorrect system behaviour in identifying trends and strategizing collection models
incidents of escalation requiring human intervention for AI-enabled interaction
Regulatory changes and impact on company’s operations especially relating to Collection and Recovery

Review of Policy:

This policy will be reviewed annually by 31^st March or earlier if there are changes in regulatory guidelines impacting collection and recovery processes. The review shall be spearheaded by Head-Collections and other stakeholders concerned and placed before the Board of Directors for approval.

Target audience, Circulation & Confidentiality:

This policy document constitutes the property of Sampathi Credits Private Limited, and no part of this document may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying or recording or in any manner whatsoever without explicit consent of the Company.

This is an internal document intended for circulation and usage amongst its management, employees, other stakeholders and empanelled vendors engaged by the Company for collection related services.

Any misuse of the document or its contents or any other violation shall be viewed seriously as an infringement of its property and appropriate and commensurate action shall be taken accordingly.

Annexure

Relevant extract from regulations on recoveries Reserve Bank of India (Digital Lending) Directions, 2025

▪ RE shall impart necessary guidance to LSP acting as a recovery agent, to discharge their duties responsibly and ensure that LSP complies with the applicable instructions in this regard. (para 5v)

▪ In case of a loan default, when a recovery agent is assigned for recovery or there is a change in the recovery agent already assigned, the particulars of such recovery agent authorised to approach the borrower for recovery shall be communicated to the borrower through email/ SMS before the recovery agent contacts the borrower for recovery. (para 8v)

▪ At the time of sanction of loan, the borrower may be conveyed the name of empanelled agents authorized to contact the borrower in case of loan default. However, if the loan turns delinquent and the recovery agent has been assigned to the borrower, the particulars of such recovery agent assigned must be communicated to the borrower through email/ SMS before the recovery agent contacts the borrower for recovery (FAQ on DLG, Q17)

Master Direction – Reserve Bank of India (Non-Banking Financial Company– Scale Based Regulation) Directions, 2023 & NBFC Responsible Business Conduct Directions, 2025 (November 2025) and its 2026 amendments, with further reference to draft recovery-conduct amendments in May 2026 (which expected to be effective October 2026).

▪ In the matter of recovery of loans, an NBFC shall not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc. As complaints from borrowers also include rude behaviour from the staff of the companies, NBFCs shall ensure that the staff are adequately trained to deal with the borrowers in an appropriate manner. (para 5.7.3).

▪ NBFCs shall ensure that the DSA/DMA/Recovery Agents are properly trained to handle their responsibilities with care and sensitivity, particularly aspects such as soliciting borrowers, hours of calling, privacy of borrower information and conveying the correct terms and conditions of the products on offer, etc. (para 5.7.1)

▪ NBFCs shall put in place a board approved Code of conduct for DSA/DMA/ Recovery Agents and obtain their undertaking to abide by the code. In addition, Recovery Agents shall adhere to extant instructions on Fair Practices Code for NBFCs as also their own Circular DOR.ORG.REC.65/21.04.158/2022-23 on ‘Outsourcing of Financial Services – Responsibilities of regulated entities employing Recovery Agents’ dated August 12, 2022, and other relevant instructions as issued from time to time.

These guidelines support these requirements of RBI by outlining specific expectations.

Code for collection of dues and repossession of security.

It is essential that the Recovery Agents refrain from action that could damage the integrity and reputation of the NBFC and that they observe strict customer confidentiality. (para 5.7.2)

▪ The NBFC and their agents shall not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors’ family members, referees and friends, sending inappropriate messages either on mobile or through social media, making threatening and/or anonymous calls persistently calling the borrower and/or calling the borrower before 8:00 a.m. and after 7:00 p.m. for recovery of overdue loans or making false and misleading representations. Any violation in this regard will be viewed seriously. (para 5.7.3)

▪ KFS to contain the information on the clause of the Loan agreement relating to the engagement of recovery agents and details of the LSP acting as the recovery agent and authorised to approach the borrower. (Annex XXVII).