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Company’s Code of Ethics & Conduct of Staff

The objective of the Banking & Financial Institutions Act, 1989 (BAFIA) is “to provide new laws for the licensing and regulation of the institutions carrying on banking, finance company, merchant banking, discount house and money-broking business, for the regulation of institutions carrying on certain other financial businesses, and for the matters incidental thereto or connected therewith”.

How Does It Concern Us?

Section 97(1) provides that no director or officer of any licensed institution, whether during his tenure of office, or during his employment, or thereafter, shall give, produce, divulge, reveal, publish or otherwise disclose to any person any information or document whatsoever relating to the affairs or account of any customer. This section does not apply to information which at the time of disclosure is or has already been lawfully available to the public from any source other than the licensed institution, or to any information supplied in a summary form which does not enable relating it to any particular customer.


Note: Unless the court otherwise orders the name address or photograph of any parties to any civil proceedings shall not be published either during or after the conclusion of the proceedings

BNM Directives/ Instructions

When collecting any debt, every debt collector must show the authorization card to identify him-self. For external debt collectors, they should also show a copy of the authorization document issued by the financial service provider for whom they are acting on behalf.


When contacting any debtor either by telephone, via face-to-face contact or other forms of communication, debt collectors must confirm that the person they are dealing with is the borrower before divulging the details of the debt. Upon confirmation that the person they are dealing with is the borrower, debt collectors must make clear the purpose of the contact and the financial service provider for which they represent. The restrictions on disclosing information to third parties apply to the borrower’s spouse and family members unless permitted by the relevant legislations.


When collecting information on any borrower from a third party, debt collectors should not collect more information that is necessary to recover the debt. Examples of information which are not necessary in the course of debt collection include the borrower’s deposit account number, account balance and number of dependents.

Conduct of Debt Collectors

Violence or harassment

Debt collectors must not resort to intimidation or violence, either verbal or physical, against any borrower or person known to a borrower. In particular, debt collectors should not:-

Use threatening , foul or intimidating language ore remarks

Cause bodily injury to any borrower or third parties known to a borrower

Enter into a property uninvited or force their way into the property or not leaving when asked to

Destruct or forcibly remove any personal property belonging to any borrower

Threaten to publish any borrowers failure or disclose any of borrowers debt details to any third parties

Put up posters or writings at any borrowers residence to publicly humiliate the borrower.

Intrusion of privacy

In the course of collecting debts from a borrower, debt collector should not:-

Contact the borrower or the borrower’s family, relative, neighbors, friend or employer either by telephone, via face-to face contact or through other forms of communication at unreasonable hours. The appropriate contact times would be between 8a to pm. Debt collector should observe these contact times unless the borrower specifically asks to be contacted outside of these hours or if the borrower is not contactable during these hours

Contact the borrower by telephone more than 3 times per week or 12 times per month if the borrower has responded to the telephone contacts

Enter into a property uninvited or force their way into the property or not leaving when asked to

Visit the borrower at his workplace unless:

(a) the borrower had failed to respond to other means of communication, for example by telephone or written letters/notices

(b) is not contactable at other locations

(c) has agreed to the visit

(d) The borrower is the proprietor or director of a business to which the debt relates.

Harass the borrower’s family, relative, neighbors, friends or employer either by telephone or via forms of communication for information about the borrower’s whereabouts.

Recovery of debt from third parties

Debt collectors should not attempt to recover debts directly or indirectly from third parties including family members, friends, relatives or the employer of any borrower.

Complaints against Debt Collectors

Financial service providers remain accountable to customers for any complaints against their debt collectors, including external debt collectors and should not disclaim responsibility for their misconduct

Financial service providers should ensure that all customer complaints against debt collectors are properly investigated and appropriate remedial actions taken for any misconduct or unacceptable practices.

In the event that there are genuine complaints made against financial service providers on the conduct of their debt collectors and such complaints are left un-rectified, BNM will not hesitate to take necessary actions against the financial service providers concerned, including prohibiting the financial services providers concerned from further outsourcing their debt collection functions.

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