Prompt and continuing collection of
customer receivables in an efficient
manner is the goal of the collection
organization. This document sets out the
principle followed during customer
interactions in the consumer finance
business. The actual policies and
procedures governing the collection of
receivables are governed by SOP’s. All
such policies or SOP’s are prepared in
compliance with the prevailing and
relevant regulations in the country.*
CODE OF CONDUCT FOR COLLECTIONS
It is the policy of Cholamandalam DBS
and its affiliates that all debt
collection activities be conducted in a
courteous, professional and lawful
manner at all times. It is the
responsibility of all employees &
associates to ensure compliance with the
instructions provided in this document.
The broad guideline for all persons
associated with the collections activity
would be as under,
Comply with all applicable laws,
regulations and policies, with
particular emphasis on those
laws, regulations and policies
that govern the time, place and
manner of customer contact.
Comply with all applicable data
privacy requirements in all
collection activities.
Apply a consistent approach in
all collection activities.
Collection activities may be
based on individual customer
circumstances only to the extent
permitted by applicable laws,
regulations and policies.
Create and maintain a set of
collections operating
instructions for each business
that reflect current local laws,
regulations and policies.
Create for each consumer finance
vertical a mandatory collections
training program that reflects
current local laws, regulations
and policies.
Ensure third-party providers of
collections servicing agree in
writing to comply with all
applicable laws, regulations and
CDFL policies.
Ensure a process is developed
for monitoring the compliance
performance of internal and
external collectors.
Instruct or permit any
authorized representative of
CDFL to engage in any form of
harassment, intimidation,
coercion or threatening behavior
in the course of conducting
collection activities.
Seize or take possession of any
property of the customer, except
to the extent permitted by local
laws, regulations and policies.
Collection being a diverse
activity, the process runs at
various levels within the
organization. Hence it is
imperative that all the
employees and outsource staff
adhere to a strict code of
conduct when engaging the
collection activity. Such a code
is as given below,
The collections activity
substantially relies on vendors
or agents appointed by the
company to visit the customer
and collect the payment. Thus
such affiliates become the
company representative and hence
must imbibe the company culture
and ensure total compliance to
the company’s policy. In
addition to the guidelines
stated above the following
points must be adhered to by all
the affiliates,
Broad Guidelines for Collections Agents
/ Affiliates
Render services strictly
in accordance with the terms
stipulated in the Service
Provider Agreement (entered into
between the Company and the
Service Provider) and
instructions/guidelines/
procedures/ process prescribed
by the Company, from time to
time and to conform in all
respects and all times to the
instructions, procedures,
processes, guidelines laid down
from time to time by the Company
for the purpose of effectively
performing the services
mentioned herein.
Issue suitable receipts to the
customers of the Company from
whom it has Collected amounts
Shall exercise utmost care,
circumspection and caution in
employing his employees so as to
ensure that such appointees do
not have any criminal
background, conviction by any
Court of Law for any offense or
their conduct and character is
not of such a nature that has
rendered them unworthy of any
such appointment.
Shall ensure that the task of
collection/repossession of the
vehicle, article or product
shall be exercised in a peaceful
manner only without giving any
opportunity to the hirer his
representative agents or
occupiers of the vehicle to make
any allegation against the
Service Provider.
Shall ensure to advise them to
peacefully deliver the vehicle,
article or other product without
using any force causing any
bodily injury, physical harm or
attack on the person in
occupation of the vehicle
including the hirer / lessee /
borrower his agent,
representatives etc.
Shall ensure that all identity
cards of its field
collectors/employees engaged in
collection Services mention the
name/entity of the Agency
clearly, as associate of the
Company.
Shall identify yourself as a
representative of the Company
and shall not use any false,
deceptive or misleading
representation while providing
Collection Services under this
Agreement and shall not make any
false statements and/or claims
of being affiliated with any
governmental agency, or being a
solicitor, or produce any
written communication that would
imply such affiliation or
indicate that the same is from a
solicitor.
It shall perform Collection
Services, through itself, its
employees/agents in a lawful
manner and shall not engage in
any unfair or misleading
practices or resort to any
forcible, oppressive vindictive,
unfair, illegal or criminal
means and shall not engage in
any conduct or practice which
harasses, oppresses or abuses
the Customer or any person in
connection with Collection
services.
Shall immediately notify the
Company in writing of any event
which may result in or which
give reason to believe that
there may be a work stoppage,
slowdown or other impediments or
disruptions in the due
performance of the obligations
of the Service Provider under
this Agreement.
Shall use only lawful measures
and on no account shall commit
violence to the person or the
property of anyone
Ensure courteous service and
maintain the service standard as
laid down by the Company.
Shall contact the customers of
the Company only at the place of
his choice, whether office or
residence. In the absence of any
specified place, customers to be
contacted only at their
residence.
Shall ensure the privacy of the
customer is respected during the
visit.
Shall contact the customers only
at the appropriate time, unless
the special circumstances of the
customer’s business or
occupation demands otherwise.
Shall honour the request of the
customers in cases where the
customer wants to avoid calls at
a particular time or place.
Shall document the number and
time of calls made to the
customers.
Shall provide the relevant
information to the customers
regarding the amount outstanding
enabling them to discharge their
dues.
Shall provide the customer all
assistance to resolve disputes
or differences, if any, as
regards the dues, in a mutually
acceptable and amicable manner.
Shall speak only in formal and
professional language while
interacting with the customers.
Shall maintain the decency and
decorum during visits to the
Customer’s place.
Shall avoid making calls or
visits during in appropriate
occasions such as bereavement in
the family or such other
calamitous occasions.
Shall not use any additional
trade name or symbol nor do or
permit anything to be done which
is not in accordance with the
system without the prior consent
in writing of the Company.
Shall not use any abusive
language or use any force in any
manner whatever against the
hirer / lessee / borrower or any
person whether connected or
unconnected with the
transaction.
Shall not permit the duplication
or disclosure of the
Confidential Information
It will not falsely state the
character, amount or legal
status of any Outstanding or
imply that the Customer has
committed a crime in order to
disgrace and/or humiliate the
Customer.
It shall not collect or attempt
to collect any amount that he is
not authorised to collect.
6. It shall not use violent or
any criminal means to harm the
physical person, reputation or
property of the Customer or any
person.
To be courteous, polite to the
Customer and shall under no
circumstances use obscene,
profane or abusive language or
hold out any threats that cannot
be legally carried out.
It shall not use the name of any
other company or organization
other than its own name or the
Company’s name.
Escalation:
When in doubt please contact the nearest
CDFL office and talk to our
Area/Regional Managers. Alternatively
you can contact our customer service
desk at the head office or the National
Collections Manager.
