Code of Conduct for Direct Selling Agent (DSA) of SHCL

Introduction

Indian Bank’s Association (IBA), a voluntary association of Banks in India has issued a Model Code of Conduct for the Direct Selling Agents (DSAs)/Direct Selling Teams (DSTs) while operating as Agents of Banks and Financial Institutions. This Code of Conduct for DSAs is based on the Model Code of Conduct of IBA.

NHB keeping a view on the feedback and responses received in this regard has formulated a Model Code of Conduct covering the operations of the Agents marketing the financial products of the HFCs.

Objectives

The Code has been developed to
  • Promote good and fair banking practices by setting minimum standards in dealing with prospect/customer;
  • Increase transparency so that you can have a better understanding of what you can reasonably expect of the services;
  • Encourage market forces, through healthy competition, to achieve higher operating standards;
  • Promote a fair and cordial relationship between the prospect/customer and the company;
  • Foster confidence in the banking & financial system.
Application of the Code

Upon adoption and inclusion as part of Agreement between the Company and the DSA/DST/Agent, this code will apply to all persons involved in marketing of any loan or other financial product of the company. The DSA/DST/Agent (hereinafter referred to as “DSA” for convenience) and its Tele-Marketing Executives (TMEs) & field sales personnel namely, Business Development Executives (BDEs) must agree to abide by this Code prior to undertaking any direct marketing operations on behalf of the company. Any TME/BDE found to be violating this Code may be blacklisted and such action taken be reported to the company from time to time by the DSA. Failure to comply with this requirement may result in permanent termination of business of the DSA with the company and may even lead to permanent blacklisting by the industry. A declaration to be obtained from TMEs/BDEs and other personnel by the DSA before assigning duties is annexed to this Code.

The marketing personnel employed by the DSA would give clear information to prospects/customers about the company’s products and services, the terms and conditions of the loan products including interest rates, charges, refundable/non-refundable fees payable for processing, pre-payment options and charges and other relevant information which affects the interest of the borrower, so that a meaningful comparison with the loan products of other HFCs/Banks can be made and informed decision taken by the prospects/customers.

The marketing personnel of the DSAs would identify when they approach the prospects/customers for selling products of HFCs personally or through phone.

The Code of Conduct for DSA is as follows:
  1. Tele-calling a Prospect (A Prospective Customer)
    A prospective customer is to be contacted for sourcing a product only under the following circumstances:
     
    • When prospect has expressed a desire to acquire a product through the company’s internet site/offices/call centre or has been referred to by another prospect/customer or is an existing customer of the company who has given consent for accepting calls on other products of the company.

    • When the prospect’s name/telephone no./address is available & has been taken from one of the lists/directories/databases approved by the DSA Manager/Team Leader, after taking prospects consent.

    • The TME should not call a person whose name/number is flagged in any “do not disturb” list made available to him/her by ITD.

    When you may contact a prospect on telephone:
    Telephonic contact must normally be limited between 0930 Hrs and 1900 Hrs (0700 Hrs to 1900 Hrs as per FPC). However, it may be ensured that a prospect is contacted only when the call is not expected to inconvenience him/her. A prospect may also be contacted anytime after obtaining the prior appointment. Calls either or later than the prescribed time period may be placed only under the following conditions.

    • When the prospect has expressly authorized TME/BDE to do so either in writing or orally.

  2. Privacy and Confidentiality

    The marketing personnel of the DSA shall always treat all the personal information of the prospects/customers as confidential. They should not discuss the prospect’s interest with anyone else.

    DSA should respect a prospect’s privacy. The prospect’s interest may normally be discussed only with the prospect any other individual/family member such as prospect’s accountant/secretary/spouse, authorized by the prospect.

    Leaving messages and contacting persons other than prospect.

    Calls must first be placed to the prospect. In the event the prospect is not available, a message may be left for him/her. The aim of the message should be to get the prospect to return call or to check for a convenient time to call again. Ordinarily, such messages may be restricted to:

    • Please leave a message that XXXXXX (Name of officer) representing SHCL called and requested to call back at ZZZZZZ (phone number)”.

    As a general rule, the message must indicate

    • That the purpose of the call is regarding selling of a product of SHCL.

    No misleading statements/mis-representations permitted

    TME/BDE should not:

    • Mislead the prospect on any service / product offered;
    • Mislead the prospect about their business or organization’s name, or falsely represent themselves;
    • Make any false / unauthorized commitment on behalf of SHCL for any facility / service.


  3. Telemarketing Etiquettes
  1. PRE CALL
  2. No calls prior to 0930 Hrs or post 1900 Hrs unless specifically requested.
  3. No serial dialing
  4. No calling on lists unless list is cleared by team leader of the DSA.

  5. DURING CALL
  6. Identify yourself, your company and your principal
  7. Request permission to proceed
  8. If denied permission, apologize and politely disconnect
  9. State reason for your call
  10. Always offer to call back on landline, if call is made to a cell number
  11. Never interrupt or argue
  12. To the extent possible, talk in the language which is most comfortable to the prospect
  13. Keep the conversation limited to business matters
  14. Check for understanding of “Most Important Terms and Conditions” by the customer if he plans to buy the product
  15. Reconfirm next call or next visit details
  16. Provide your telephone no. your supervisor’s name or SHCL’s officer contact details if asked by the customer
  17. Thank you customer for his/her time.

  18. POST CALL
  19. Customers who have expressed their lack of interest for the offering should not be called for the next 3 months with the same offer.
  20. Provide feedback to the company on customers who have expressed their desire to be flagged “Do no Disturb”. DSAto submit such details to the company every month.
  21. Gifts or bribes

    TME / BDEs must not accept gifts from prospects or bribes of any kind. Any TME/BDE offered a bribe or payment of any kind by a customer must report the offer to his / her management.

  22. Recovery
  23. If after all attempts, the borrowers do not voluntarily repay the outstanding amount on the loan, the company reserves the right to initiate legal proceedings for recovery of the amount outstanding.
  24. The company remains committed to upholding the law of the land and will initiate procedures such as repossession / attachment etc. only under a strict legal compliance framework. Even at the time of repossession / attachment the company shall make all attempts to maintain the dignity of the borrower.
  25. The company would generally initiate repossession of the asset, if the default committed is more than 90 days. However on exceptional bases the same can be initiated on lesser default.
  26. The company would intimate the borrower before auction of the repossessed asset to foreclose and pay the amount and take back the asset. The company would need a maximum of 10 (ten) working days for returning the said asset after the foreclosure.

  27. Precautions to be taken on visits / contacts BDE should
    • Respect personal space – maintain adequate distance from the prospect.
    • Not enter the prospect’s residence/office against his/her wishes.
    • Not visit in large numbers – i.e. not more than one BDE and one supervisor, if required.
    • Respect the prospect’s privacy.
    • If the prospect, is not present and only family members/office persons are present at the time of the visit, he/she should end the visit with a request for the prospect to call back.
    • Provide his/her telephone number, supervisor’s name or the concerned company officer’s contact details, if asked for by the customer.
    • Limit discussions with the prospect to the business – Maintain a professional distance.

  28. Other important aspects – Appearance & Dress Code

    BDE’s must be appropriately dressed:
    For men this means
    • Well ironed trousers
    • Well ironed shirt, shirt sleeves preferably buttoned down.
    For women this means
    • Well ironed formal attire (Saree, suit etc.)
    • Well groomed appearance
    Jeans and/or T Shirt, open sandals are not considered appropriate.
  29. Handling of letters & other communications
    Any communication sent to the prospect should only be in the mode and format approved by the company.

  30. Declaration – cum – Undertaking
    (to be obtained by the DSA from its employees / representative)
    ____________________
    ____________________
    ____________________

    Re: Code of Conduct

    Dear Sir,

    I am working in your company as a ________________. My job profile, inter lia, includes offering, explaining, sourcing, and assisting documentation of products and linked services to prospective customers of Sahara Housingfina Corporation Limited.

    In the discharge of my duties, I am obligated to follow the Code of Conduct attached to this document.

    I confirm that I have read and understood and agree to abide by the Code of Conduct. I further confirm that the trainer mentioned below has explained the contents of the Code of Conduct in full to me.

    In case of any violation, non-adherence to the said Code, you shall be entitled to take such action against me as you may deem appropriate.

    Signed on this _________ day of ________, 20___

    Signature _______________

    Name ___________________

    Agency __________________
Procedures for Registering Complaints / Grievances

If at any stage, if a prospect/customer is not satisfied with the service given to him/her, he/she can to contact the Company. The first point of contact for redressal of any complaint will be our Branch Head who are fully capable of redressing customer grievances satisfactorily. If he/she does not receive a reply within 7 working days from the Branch Head, or if he/she is not satisfied with the reply received him/her, the customer can write to our Corporate Office, to the:
Shri D.J. Bagchi (CEO) /Shri Vivek Kapoor (Corp Manager – Corp. Affairs)
Sahara Housingfina Corporation Limited, Sahara India Sadan,
2ª Shakespeare Sarani, Kolkata – 700 071.
Web-site: www.saharahousingfina.com.
(033) 32984850
If the prospect/customer does not hear from the Company within next fortnight working days, or if he/she is not satisfied with the response, customer may write to the by the National Housing Bank to look into the provision of satisfactory service, if so desired by them.

General
  • An internal management structure to be put in place to monitor and control the outsourcing activities of the service providers like the DSA.
  • The company to review, at least on an annual basis, the financial and operational conditions of the service providers to assess their ability to continue to meet their outsourcing obligations.
  • The name of the DSA appointed / terminated shall be regularly updated in the company’s official web-site.
  • The Internal Auditors of the Company shall be conferred the responsibility to assess the adequacy of the risk management practices adopted in overseeing and managing the outsourcing agreement with respect to the Recovery Agents / Collection Agencies.
  • The Company reserves to itself the right to alter/delete/add to these codes at any time without prior individual notice and such alterations /deletion/addition shall be binding on the customers
Place: Lucknow
Date: 31st July, 2008

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