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Deutsche Postbank Home Finance Limited (DPHFL/Company) - Code of Conduct followed by DPHFL/ authorized representatives for contacting a borrower/customer for collection of due payments.
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May 2009
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Deutsche Postbank Home Finance Ltd., a National Housing Bank (NHB) registered Company, is a 100% MNC housing finance company having its registered office in New Delhi & Corporate Office in Gurgaon. DPHFL is a part of Deutsche Postbank Group, which is the largest retail bank in Germany.
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DPHFL Code of Conduct:
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This Code of Conduct outlines minimum requirements that are adhered by the DPHFL/ authorized representative when contacting a borrower/customer for due payments. Besides DPHFL, other Third Party Vendors also contact borrowers/customers on behalf of DPHFL. The code is a mandatory requirement for all who contact the borrowers/customers on behalf of DPHFL. This document contains material proprietary to DPHFL. Duplication and dissemination either in part or in full, without authorization is prohibited.
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1.0 Summary:
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All customers (including customers who are late in paying or in default) are and must be treated with respect, dignity, courtesy and fairness in debt collection efforts. This Code of Conduct applies to all employees of DPHFL and/or other affiliates and employees/agents that may be retained to collect on consumer debts on behalf of DPHFL in India.
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2.0 Why to contact a borrower/customer:
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A customer is contacted for debt collection only under the following circumstances:
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• When not doing so may impose an additional cost on the borrower/customer or may impact the customer’s credit history/rating.
• When the borrower/customer has not paid on payment date and this is likely to impact the customer’s credit history and/or is likely to cause a financial loss to DPHFL.
• When PDC’s given by the borrowers/customers to DPHFL are finished & DPHFL has not received PCD’s even after information to the customer/borrower.
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3.0 When to contact a customer:
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• Unless the special circumstances of the customer’s business or occupation requires otherwise, customer is contacted between 7 AM and 7 PM.
• Calls/ visits for recovery are avoided on inappropriate occasions like bereavement in the family.
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4.0 Where to contact the customer:
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• Customer is contacted ordinarily at the place of his/ her choice and in absence of any specific place, at the place of his/ her residence and if unavailable at his/ her residence, at his place of business/ occupation.
• As far as possible, customer’s request to avoid calls at a particular time or place is honoured.
• Time, number of calls and the contents of call is documented.
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5.0 Which language is/should be used in the interaction:
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• Proper decency and decorum is maintained during visit to a customer’s place. Customers deserve to be treated with dignity.
• Recovery agents & agencies shall maintain courtesy and respect for the Customer in any circumstances. Recovery Agent & Agencies shall not become abusive, visibly irritated or demean the customer in any fashion.
• Identity and authority to represent the company is made known to the customer at the first instance.
• The person visiting the Customer should carry;
(a) Copy of the notice issued by the Company.
(b) Copy of Authorization Letter issued by the Company.
(c) Identity Card issued by the Company/Agency.
• Customer’s privacy is respected.
• Interaction with the customer is done in a civil manner.
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6.0 What is to be done if the Customer disputes the debt:
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• Proper mechanism has been put in place whereby borrower’s grievances regarding recovery are addressed to.
• However, if a customer is found to be continuously making frivolous/ vexatious complaints, cases are forwarded to the legal department even if the complaint is pending.
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7.0 Methods to be followed by Recovery Agents/ Agencies, in case Customer/Borrower refuses/fails to pay:
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• Proper and legal methods are used for taking possession and subsequent auction of the mortgaged property.
• Where ever possible, forum of Lok Adalat are to be used for recovery of housing loan with less than Rs. 10 Lac balance.
• Proper mechanism has been put in place whereby borrower’s grievances regarding recover is addressed to.
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8.0 Monitoring and Control:
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• A committee is formed to monitor and control the working of recovery agencies periodically so as to learn from experience and the suggestions if any are to be given to NHB for further improvement. The agreement with the recovery agency provides for such monitoring and control.
• Financial and operational condition of the service provider is reviewed annually so as to assess their ability to continue to meet their outsourcing obligations.
• The functioning of the recovery agencies is audited by internal or external audit team.
• Termination of agreement with the recovery agency is to be publicized so as to ensure that the customers don’t deal with the service provider in future.
• Grievance Redressal Machinery is constituted which will ensure that genuine grievances of the customers are addressed to promptly. The name, designation and telephone number of grievance redressal officer are displayed on our website. This machinery is also dealing with the grievances against Recovery Agencies.
• Time frame for disposal of complaint is also displayed on Website of the Company.
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