Last update: Jun 8th, 2026

CODE OF CONDUCT

1. Purpose

Padmalaya Finserve Private Limited (“Padmalaya” or “the Company”) is required to put in place a Board-approved Code of Conduct for its Collection-Recovery Agents (“CRAs”) in accordance with the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, issued by the Reserve Bank of India (“RBI”), as amended from time to time. Accordingly, the Company has adopted this Board-approved Code of Conduct for CRAs (“Code”).


2. Applicability

This Code applies to all arrangements between the Company and its CRAs, being any external collection agency, recovery agent, or individual representative engaged by the Company (directly or through such an agency) for the collection or recovery of dues on the Company’s Personal Loan (“PL”) product. This Code applies to all persons involved in the collection of any loan or other financial product of the Company, whether employed by the Company or by a third party engaged for this purpose.

CRAs must agree to abide by this Code prior to undertaking any collection activity on behalf of the Company. Any employee or representative of a CRA violating this Code may be blacklisted, and the concerned CRA shall promptly report any violation to the Company. Failure to comply with this requirement may result in permanent termination of the CRA’s engagement with the Company.


3. Call Guidelines

a. Telemarketing Conduct

The caller should identify himself/herself, state the purpose of calling, explain the product or the dues, and maintain a courteous disposition towards the customer at all times.

b. Pre-Call

  • No calls prior to 08:00 hrs or after 19:00 hrs, save where the customer has expressly authorised contact outside this window, in writing or orally.

  • No serial dialling.

  • No calling on lists unless the list has been cleared by the team lead.

c. During Call

  • Identify yourself and state that you represent the Company (or the CRA engaged by the Company);

  • Request permission to proceed;

  • State the reason for the call;

  • Never interrupt or argue;

  • To the extent possible, communicate in the language most comfortable to the customer;

  • Keep the conversation limited to business matters;

  • Reconfirm next call or visit details;

  • Provide your telephone number and your supervisor’s/the Company’s contact details if requested by the customer;

  • Thank the customer for their time


4. Gifts or Bribes

No CRA or representative shall accept gifts from customers or bribes of any kind. Where a customer offers a bribe or payment of any kind, the CRA must promptly report this to their management and to the Company.


5. Precautions

  • Respect personal space, maintain adequate distance from the customer;

  • Do not enter the customer’s residence or office against their wishes;

  • Do not visit in large numbers, not more than one or two representatives, if a visit is required at all;

  • Respect the customer’s privacy;

  • If the customer is not present and only family members/office persons are present, end the visit with a request for the customer to call back;

  • Provide your telephone number and your supervisor’s/the Company’s contact details, if requested;

  • Limit discussion to business matters and maintain a professional distance.

Any written communication sent to the customer shall only be in the mode and format approved by an authorised officer of the Company.


6. Contact with Customer

a. The customer should be contacted at an appropriate time.

b. The customer should ordinarily be contacted at the place of their choice and, in the absence of a specified place, at their residence, and if unavailable there, at their place of business/occupation.

c. A log of all calls made to delinquent/defaulted customers shall be maintained, with a brief note on the outcome of each call.

d. No demand for payment shall be made by telephone, personal call, or in writing, without indicating the name of the Company to whom the debt is owed, the balance of the account, and the identity and basis of claim of the person making the demand.

e. Except for references provided by the borrower with explicit consent, the CRA shall not communicate with an employer, acquaintance, friend, relative, or neighbour of the customer for matters relating to recovery.

f. Customer privacy shall be respected at all times.

g. The CRA shall not disclose or threaten to disclose information about a debt which, for valid reason, is disputed by the customer, without disclosing the fact that the customer disputes the debt.

h. The CRA shall not disclose or threaten to disclose information that could adversely affect the customer’s creditworthiness where it knows or has reason to suspect that such information is false.

i. The CRA shall not initiate or threaten to initiate communication with the customer’s employer prior to obtaining a final judgment against the customer in order to exert pressure – this does not prohibit contacting an employer solely to verify employment status or earnings, or where the employer maintains an established debt-counselling procedure.

j. The CRA shall not give, or threaten to give, information to a customer’s employer, spouse, or family member that may adversely affect the customer’s (or their family’s) employment or employment opportunities.

k. Interaction with the customer shall be polite and civil at all times.

l. A customer’s request to avoid calls at a particular time or place shall be honoured so far as possible.

m. The customer shall be provided with clear information regarding their dues.

n. Reasonable notice shall be given before repossession of any security and its realisation, where applicable.

o. All reasonable assistance shall be given to resolve disputes or differences in a mutually acceptable manner.

p. Decency and decorum shall be maintained during any visit to a customer’s place for collection of dues.

q. Calls/visits to collect dues shall be avoided on inappropriate occasions, such as a bereavement in the family or other calamitous events.

r. The CRA shall not use obscene, defamatory, abusive, or threatening language, or resort to intimidation or harassment of any kind (verbal or physical) against the customer or any person related to them. For the purposes of this Code, intimidation and harassment includes acts intended to humiliate publicly, intrude on the privacy of the customer’s family, referees or friends, make anonymous or threatening calls, or make false and misleading representations.

s. The CRA shall strictly avoid any conduct suggestive of criminal intimidation, threat, or violence.

t. The CRA shall not resort to false, deceptive or misleading representation; falsely represent or imply affiliation with a governmental or judicial authority; falsely represent the character, amount or legal status of the debt; or use any identification likely to result in a false representation.

u. CRAs shall be appropriately dressed and well-groomed at all times.

v. CRAs shall at all times abide by the Company’s Collection Policy.


7. Professional Representations and Conduct

CRAs and their representatives shall use their best efforts to ensure maximum recovery on all accounts. In the process of debt recovery, CRAs and their representatives shall, at all times:

  • comply with all laws and regulations governing the conduct of debt collectors, commercial agents, and similar persons;

  • not use any method or tactic inconsistent with the Company’s policies, or that may harm the Company’s reputation, where in doubt, the CRA shall consult the Company before employing such method or tactic, and abide by the Company’s decision;

  • not seek to secure the arrest or committal of any customer;

  • not do anything that could give rise to a civil liability in tort or a criminal liability.

1. Purpose

Padmalaya Finserve Private Limited (“Padmalaya” or “the Company”) is required to put in place a Board-approved Code of Conduct for its Collection-Recovery Agents (“CRAs”) in accordance with the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, issued by the Reserve Bank of India (“RBI”), as amended from time to time. Accordingly, the Company has adopted this Board-approved Code of Conduct for CRAs (“Code”).


2. Applicability

This Code applies to all arrangements between the Company and its CRAs, being any external collection agency, recovery agent, or individual representative engaged by the Company (directly or through such an agency) for the collection or recovery of dues on the Company’s Personal Loan (“PL”) product. This Code applies to all persons involved in the collection of any loan or other financial product of the Company, whether employed by the Company or by a third party engaged for this purpose.

CRAs must agree to abide by this Code prior to undertaking any collection activity on behalf of the Company. Any employee or representative of a CRA violating this Code may be blacklisted, and the concerned CRA shall promptly report any violation to the Company. Failure to comply with this requirement may result in permanent termination of the CRA’s engagement with the Company.


3. Call Guidelines

a. Telemarketing Conduct

The caller should identify himself/herself, state the purpose of calling, explain the product or the dues, and maintain a courteous disposition towards the customer at all times.

b. Pre-Call

  • No calls prior to 08:00 hrs or after 19:00 hrs, save where the customer has expressly authorised contact outside this window, in writing or orally.

  • No serial dialling.

  • No calling on lists unless the list has been cleared by the team lead.

c. During Call

  • Identify yourself and state that you represent the Company (or the CRA engaged by the Company);

  • Request permission to proceed;

  • State the reason for the call;

  • Never interrupt or argue;

  • To the extent possible, communicate in the language most comfortable to the customer;

  • Keep the conversation limited to business matters;

  • Reconfirm next call or visit details;

  • Provide your telephone number and your supervisor’s/the Company’s contact details if requested by the customer;

  • Thank the customer for their time


4. Gifts or Bribes

No CRA or representative shall accept gifts from customers or bribes of any kind. Where a customer offers a bribe or payment of any kind, the CRA must promptly report this to their management and to the Company.


5. Precautions

  • Respect personal space, maintain adequate distance from the customer;

  • Do not enter the customer’s residence or office against their wishes;

  • Do not visit in large numbers, not more than one or two representatives, if a visit is required at all;

  • Respect the customer’s privacy;

  • If the customer is not present and only family members/office persons are present, end the visit with a request for the customer to call back;

  • Provide your telephone number and your supervisor’s/the Company’s contact details, if requested;

  • Limit discussion to business matters and maintain a professional distance.

Any written communication sent to the customer shall only be in the mode and format approved by an authorised officer of the Company.


6. Contact with Customer

a. The customer should be contacted at an appropriate time.

b. The customer should ordinarily be contacted at the place of their choice and, in the absence of a specified place, at their residence, and if unavailable there, at their place of business/occupation.

c. A log of all calls made to delinquent/defaulted customers shall be maintained, with a brief note on the outcome of each call.

d. No demand for payment shall be made by telephone, personal call, or in writing, without indicating the name of the Company to whom the debt is owed, the balance of the account, and the identity and basis of claim of the person making the demand.

e. Except for references provided by the borrower with explicit consent, the CRA shall not communicate with an employer, acquaintance, friend, relative, or neighbour of the customer for matters relating to recovery.

f. Customer privacy shall be respected at all times.

g. The CRA shall not disclose or threaten to disclose information about a debt which, for valid reason, is disputed by the customer, without disclosing the fact that the customer disputes the debt.

h. The CRA shall not disclose or threaten to disclose information that could adversely affect the customer’s creditworthiness where it knows or has reason to suspect that such information is false.

i. The CRA shall not initiate or threaten to initiate communication with the customer’s employer prior to obtaining a final judgment against the customer in order to exert pressure – this does not prohibit contacting an employer solely to verify employment status or earnings, or where the employer maintains an established debt-counselling procedure.

j. The CRA shall not give, or threaten to give, information to a customer’s employer, spouse, or family member that may adversely affect the customer’s (or their family’s) employment or employment opportunities.

k. Interaction with the customer shall be polite and civil at all times.

l. A customer’s request to avoid calls at a particular time or place shall be honoured so far as possible.

m. The customer shall be provided with clear information regarding their dues.

n. Reasonable notice shall be given before repossession of any security and its realisation, where applicable.

o. All reasonable assistance shall be given to resolve disputes or differences in a mutually acceptable manner.

p. Decency and decorum shall be maintained during any visit to a customer’s place for collection of dues.

q. Calls/visits to collect dues shall be avoided on inappropriate occasions, such as a bereavement in the family or other calamitous events.

r. The CRA shall not use obscene, defamatory, abusive, or threatening language, or resort to intimidation or harassment of any kind (verbal or physical) against the customer or any person related to them. For the purposes of this Code, intimidation and harassment includes acts intended to humiliate publicly, intrude on the privacy of the customer’s family, referees or friends, make anonymous or threatening calls, or make false and misleading representations.

s. The CRA shall strictly avoid any conduct suggestive of criminal intimidation, threat, or violence.

t. The CRA shall not resort to false, deceptive or misleading representation; falsely represent or imply affiliation with a governmental or judicial authority; falsely represent the character, amount or legal status of the debt; or use any identification likely to result in a false representation.

u. CRAs shall be appropriately dressed and well-groomed at all times.

v. CRAs shall at all times abide by the Company’s Collection Policy.


7. Professional Representations and Conduct

CRAs and their representatives shall use their best efforts to ensure maximum recovery on all accounts. In the process of debt recovery, CRAs and their representatives shall, at all times:

  • comply with all laws and regulations governing the conduct of debt collectors, commercial agents, and similar persons;

  • not use any method or tactic inconsistent with the Company’s policies, or that may harm the Company’s reputation, where in doubt, the CRA shall consult the Company before employing such method or tactic, and abide by the Company’s decision;

  • not seek to secure the arrest or committal of any customer;

  • not do anything that could give rise to a civil liability in tort or a criminal liability.

Appearance

Dress Code

Belongings

Ethics

Confidentiality

Process/Product Discipline

Effectiveness

Confidentiality

Well-groomed; proper haircut; clean shave or well-maintained beard

Light-coloured, well-ironed shirts; well-ironed trousers of dark shade; a coat/plain pullover in winter; formal shoes

Daily Collection Run Rate (DCR) sheet; receipt book; minimal stationery; this Code; the Company’s Collection Policy; identity card

-

-

Perform your role within the framework of process notes and product-specific collection instructions issued by the Company

Prepare for each visit and document the outcome/action taken to improve results

Maintain a reasonable distance from the customer

-

-

-

Do not make any verbal or written promise to a customer without supervisor/Company approval on matters outside the CRA’s purview, or any ad hoc settlement/product feature.

Do not divulge written or verbal information to any customer, competitor, or other person without proper authorisation (e.g., photocopies of statements or prior customer trails).

-

-

No physical contact with the customer; no obstruction of customer movement; no use of muscle power

Appearance

Dress Code

Belongings

Ethics

Confidentiality

Process/Product Discipline

Effectiveness

Confidentiality

Well-groomed; proper haircut; clean shave or well-maintained beard

Light-coloured, well-ironed shirts; well-ironed trousers of dark shade; a coat/plain pullover in winter; formal shoes

Daily Collection Run Rate (DCR) sheet; receipt book; minimal stationery; this Code; the Company’s Collection Policy; identity card

-

-

Perform your role within the framework of process notes and product-specific collection instructions issued by the Company

Prepare for each visit and document the outcome/action taken to improve results

Maintain a reasonable distance from the customer

-

-

-

Do not make any verbal or written promise to a customer without supervisor/Company approval on matters outside the CRA’s purview, or any ad hoc settlement/product feature.

Do not divulge written or verbal information to any customer, competitor, or other person without proper authorisation (e.g., photocopies of statements or prior customer trails).

-

-

No physical contact with the customer; no obstruction of customer movement; no use of muscle power

Appearance

Dress Code

Belongings

Ethics

Confidentiality

Process/Product Discipline

Effectiveness

Confidentiality

Well-groomed; proper haircut; clean shave or well-maintained beard

Light-coloured, well-ironed shirts; well-ironed trousers of dark shade; a coat/plain pullover in winter; formal shoes

Daily Collection Run Rate (DCR) sheet; receipt book; minimal stationery; this Code; the Company’s Collection Policy; identity card

-

-

Perform your role within the framework of process notes and product-specific collection instructions issued by the Company

Prepare for each visit and document the outcome/action taken to improve results

Maintain a reasonable distance from the customer

-

-

-

Do not make any verbal or written promise to a customer without supervisor/Company approval on matters outside the CRA’s purview, or any ad hoc settlement/product feature.

Do not divulge written or verbal information to any customer, competitor, or other person without proper authorisation (e.g., photocopies of statements or prior customer trails).

-

-

No physical contact with the customer; no obstruction of customer movement; no use of muscle power

9. Customer Communication Guidelines for Representatives

In addition to the guidelines above, the following shall be adhered to by all individuals, associates, agents and entities (“Representatives”) authorised to represent the Company for collection of dues. Failure to comply shall attract appropriate and strict disciplinary action.

  • Treat the customer with dignity at all times. Maintain professionalism and transparency in every conversation (by telephone, in writing, or in person) and do not treat the matter as personal.

  • Use the language and mode the customer is most comfortable with. Strictly avoid tough, aggressive, threatening or abusive language, verbal or written, and avoid threatening, harassing or irritating the customer in any way.

  • Where a customer resorts to abusive or threatening conduct, the Representative shall document the incident and promptly inform the Company, including the customer’s name.

  • Representatives are not authorised to send any written communication (e-mail, letter, electronic message, social media, etc.) to the Company’s customers without prior Company approval, and should route any such requirement, with reasons, through the Company.

  • Representatives shall not mislead the customer about the action proposed or its consequences.

  • Representatives shall not mislead the customer as to their true identity or organisation, or falsely represent or imply that they are an attorney, government official, or officer of any court or police authority.

  • Representatives shall not make any promise or commitment to a customer on the Company’s behalf without prior Company permission.


10. Use/Disclosure of Confidential Information

  • CRAs shall at all times respect the confidentiality and privacy of information supplied by a customer, and shall be factual, truthful and tactful in using such information.

  • A customer’s affairs may only be discussed with the customer, or with another individual/family member (e.g., accountant, secretary, spouse) where the customer has authorised this.

  • CRAs must not use or disclose confidential information for any purpose other than that for which it was provided, as set out in the applicable appointment letter and its annexures.

  • CRAs must implement appropriate measures to secure confidential information against anticipated threats, and against unauthorised access, use, or disclosure that could cause substantial harm or inconvenience to any customer of the Company.

  • On termination of the engagement, the CRA shall hand over all confidential information and related material in its possession to the Company’s authorised representative.

  • In the event of a breach or threatened breach of this clause, the Company shall be entitled to injunctive relief, in addition to any other remedy, to restrain such breach.

  • CRAs shall never allow personal emotion or unfriendly feeling towards a customer to affect their dealings, and shall at all times retain a professional approach guided by sound principles of debt collection and management.


11. Reporting and Compliance

CRAs shall provide the Company with such information as it may require to assess the CRA’s continued ability to meet its obligations under this Code and the applicable engagement terms.


12. Review of this Code

This Code shall be reviewed at least annually by the Board, or earlier if required due to a change in applicable regulation or in the Company’s collection practices. This Code will be made available on the Company’s website.