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Code of Practice

1. General Conduct
 

a) We shall act responsibly and with integrity in the day-to-day conduct of our business.
b) Conduct our business lawfully and comply with all relevant Irish legislation, regulation and judicial decisions and trade fairly and responsibly.
c) Provide adequate training for members of our staff, bringing to their attention the principles of this Code and requiring them to carry out their duties in accordance with it. Also, ensure continuous and appropriate training of staff in respect of current legislation and best practice.
d) Use plain English in all communications.
e) Show on all letters, postcards and forms the full business address, telephone number and email address, where used.
f) In all contacts by staff or agents, ensure that our identity is clearly disclosed.
g) Ensure by continuously examining debt collection procedures and those of any third parties employed, that they conform to the highest ethical standards.
h) Ensure that their agents, sub-contractors and subsidiaries comply with our Code and Guidelines.
i) Comply with all reasonable requests by debtors, clients or their appointed representatives for information concerning their agreements and accounts.

 

2. Confidentiality


a) We will keep in strict confidence any information supplied by debtors or their chosen third party, except where disclosure is authorised by the debtor or others permitted or required by law.

b) Information pertaining to clients, debtors, employees, sub contactors and third parties is held in strict compliance of current GDPR legislation.

3. Complaints


a) Complaints pertaining to clients, debtors, employees, sub contactors and third parties will be dealt with by a senior manager within the business.

b) All complaints will be acknowledged, investigated and responded to speedily, responsively and in a user friendly fashion.
c) Complaints procedures will be made available to the complainant or his/her advisor on request.

4. Debt Collection


a) The Company or its representatives will not use oppressive or intrusive collection procedures.
b) The Company or its representatives will not bring unreasonable pressure to bear on the debtor in default of payment.
c) The Company or its representatives will not act in a manner in public intended to embarrass the debtor.
d) The Company or its representatives will be circumspect and discreet when attempting to contact the debtor by telephone, SMS, email or by personal visit, with due regard to the Data Protection Act and Guidance.
e) The Company and its representatives ensure that all attempted contacts with debtors are made at reasonable times and at
reasonable intervals.
f) The Company unless instructed otherwise, accept all reasonable offers by debtors to pay by instalments, provided acceptable evidence of non-ability to pay is given.
g) The Company and its representatives will not use improper means to obtain the telephone number and address of a debtor and treat all information supplied as private and confidential unless specific authorisation has been
given by the debtor in writting to disclose information to third parties.
h) In respect of (g) above, with specific regard to the Data Protection Acts.
i) The Company will not pressurise debtors to sell property or to raise funds by further borrowing.
j) The Company and its representatives will have due regard and deal sensitively with individuals where evidence has been given, or is
apparent, that the individual is incapacitated by mental or physical disability.
k) The Company and its representatives will offer maximum co-operation with the debtor’s nominated or chosen Third Party.
l) The Company and its representatives will respond sympathetically and positively to debtors in severe financial difficulty where appropriate and truthful evidence is provided.
m) The Company and its representatives will take into consideration before determining whether to recommend enforcement proceedings for repayment, all information supplied in relation to the reason for non-payment, which may include a statement of means, or the debtor’s future ability to repay. If the debtor has disclosed multiple debt problems, the Company will inform them of the availability of advisory services.
n) The Company where available, will provide in all relevant correspondence the name or designation of a member of staff who may be contacted regarding financial difficulties.

5. Trace Guidelines


a) The Company and its representatives will in all attempts to trace, act with full regard to the Data Protection Acts.
b) The Company and its representatives will not misrepresent its/their position and will remain transparent.
c) The Company and its representatives will take all reasonable steps to verify that the person traced is in fact, the subject.
d) The Company and its representatives will verify data relating to a subject’s whereabouts via, for example, one or more of the following methods:
i. Public and other available databases
ii. Sending appropriate trace communication to the last known or alternative address
iii. Contacting third parties, for example neighbours, relatives
iv. Investigative/field enquiries, for example, visit to the last known address
f) The Company will where it becomes apparent that the located person is not the subject, update all appropriate records accordingly.

 

6. Conduct Regarding Clients


a) The Company will ensure fairness and transparency of contracts made with clients.
b) The Company will inform their clients of the true rates of charges for services rendered.
c) The Company and its representatives will safeguard the security of collected monies.
d) The Company will account and remit to their clients at least once a month, or as otherwise agreed all monies collected.

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