Policy 07

Recovery Agent Code of Conduct

The standards of conduct binding everyone who performs recovery activity for the Company.

Policy ownerCollections / Compliance
Version[INSERT VERSION]
Effective date[INSERT DATE]
Next review[INSERT DATE]
1

Applicability and responsibility

This Code binds the Company's employees, LSPs, agencies, tele-callers, field personnel and lawyers performing recovery activity. Outsourcing does not reduce the Company's responsibility. Agencies may act only under a valid agreement, approved allocation and identity / authorisation process.

2

Required conduct

  • identify themselves, name the Company and agency, and show official identity / authorisation on request;
  • verify they are speaking with the borrower / authorised person before revealing loan information;
  • communicate the outstanding amount, payment options and consequences accurately, without false legal claims;
  • maintain dignity, privacy and confidentiality and use a language understood by the borrower;
  • contact borrowers only during legally / regulatorily permitted and reasonable hours, unless a specific request or exceptional recorded circumstance applies;
  • issue an authorised receipt for permitted cash recovery and ensure same-day account reflection where required;
  • record visits, calls, promises, disputes and complaints accurately;
  • refer hardship, dispute, fraud, deceased-borrower and vulnerable-customer cases to authorised Company teams.
3

Prohibited conduct

  • threats, intimidation, violence, abusive language, stalking or persistent harassment;
  • public humiliation, disclosure to neighbours / employers / social-media contacts or unauthorised third parties;
  • anonymous calls, spoofing, misleading caller identity or impersonating police, courts, advocates or government officials;
  • contacting family / referees except for lawful location / contact assistance without disclosing debt details;
  • collecting into personal, agency pool or unauthorised accounts;
  • accepting gifts, side payments or negotiating unauthorised settlements;
  • taking possession of assets or documents outside an approved legal and contractual process.
4

Digital-loan communication

Before a recovery agent first contacts a borrower — or when the assigned agent changes — the Company will send the agent's name / particulars through registered SMS / email or another recorded channel. Payment will ordinarily flow directly to the Company's bank account; any permitted cash recovery will be promptly and fully credited.

5

Complaints, monitoring and consequences

Recovery complaints may be made at [INSERT CHANNEL]. Calls / visits may be monitored, sampled or audited. Breach may result in suspension, removal, clawback, termination, reporting to authorities and civil / criminal action. The Company will maintain training, due diligence, background checks and an approved agent list.

Regulatory basis

RBI (NBFC — Responsible Business Conduct) Directions, 2025; RBI Digital Lending Directions, 2025; applicable outsourcing, recovery-agent and customer-service directions.

Explore other policies

Part of the Transwarranty Finance Limited policy and disclosure framework.