Code of Conduct
Capital Resolve is committed to maintaining the highest standards of ethical conduct and integrity and to strictly comply with the guidelines, rules, and regulations that govern our business practices.
This Code of Conduct sets out our standards that we follow when we are collecting debts.
Our key commitments
- We will treat all personal information as private and confidential, and operate secure and reliable banking and payment systems
- We will monitor all activities to ensure compliance of this code of conduct
- We will not act in a manner intended to embarrass clients or customers
- We 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
- We will publicise this Code and make sure that our employees are trained to put it into practice
- We will deal quickly and sympathetically with things that go wrong and consider all cases of financial difficulty sympathetically and positively
- We will take into consideration before determining whether to enforce repayment, all information supplied in relation to the reason for non-payment, which may include The Common Financial Statement, or the customer’s future ability to repay. If the customer has disclosed multiple debt problems, inform them of the availability of accredited advisory services. Where available, provide in all relevant correspondence the name or designation of a specially trained employee who may be contacted regarding financial difficulties
- If asked, we will tell account holders how to get a copy of the information that credit reference agencies have about them, or how to obtain their leaflets that explain how credit referencing works
- We will explain that under the Data Protection Act account holders have the right to see the personal records we hold about them.
- We will be circumspect when attempting to contact customers by telephone, SMS, email or by personal visit, with due regard to current compliance and regulatory requirements. We will always ask security questions prior to discussing any aspects or details with a customer
- We will ensure that all attempted contacts with customers are made at reasonable times and at reasonable intervals
- We will not use improper means to obtain the telephone number and address of a customer
- We will treat all information supplied as private and confidential unless specific authorisation has been given by the customer to disclose information to third parties
- We will tell customers if we record their telephone conversations with us
- We undertake that we will act fairly and reasonably in all our dealings with customers by meeting all the relevant commitments and standards in this code.
- We will not use oppressive or intrusive collection procedures
- We will not use official looking documents intended or likely to mislead customers as to their status, for example, documents made to resemble court claims
- We will refrain from leaving out or presenting information in such a way that it creates a false or misleading impression or exploits a customer’s lack of knowledge
- When contact customers we will make it clear who we are, who we work for, what our role is and what the purpose of our contact is
- We will not use unnecessary and unhelpful legal and technical language, for example, use of Latin phrases
- On request we will provide customers, 3rd parties or creditors with information on status of debts such as balance statements when reasonably requested
- We will not ask or instruct customers to make contact on premium rate telephone numbers
- We will not ignore or disregard customers legitimate wishes in respect of when and where to contact them, for example, shift workers who ask not to be telephoned during certain times of the day
- We will not bring unreasonable pressure to bear on the customers in default of payment
- We will take the individual circumstances of a customer into consideration when dealing with each separate account
- Unless instructed otherwise, accept all reasonable offers by a customer to pay by instalments, provided acceptable evidence of non-ability to pay is given.
- If a customer finds themselves in financial difficulties, they should let us know as soon as possible and we will do all we can to help them to overcome their difficulties. With their co-operation, we will develop a plan with them for dealing with their financial difficulties.
- The sooner we discuss a customer’s problems, the easier it will be for both of us to find a solution. The more they tell us about their full financial circumstances, the more we may be able to help.
- We will not pressurise customers to sell property or to raise funds by further borrowing.
- We will not falsely imply by written or verbal means that criminal proceedings will be brought, nor that civil action has or will be instituted where we are unable to do so due to legal restrictions.
- We will encourage customers in financial difficulties to inform us of their difficulties and then respond sympathetically and positively on the evidence provided.
- We will offer maximum co-operation with the customers nominated or chosen 3rd party. Where the 3rd party is an accredited advisory service, and at first appointment and upon request, give a period of up to 30 days ‘grace’ before re-commencing collection activity.
- We will work with external money advice agencies, charities and care professionals to ensure that anyone who is classed a vulnerable are dealt with in a suitable manner.
Complaints and Disputes
- If a customer wants to make a complaint or raise a dispute, we will tell them how to do this and what to do if they are not happy about the outcome. Our employees will help them with any questions they have.
- When applicable we will tell a customer how to obtain details of our procedures for handling complaints fairly and quickly.