Code of Ethics and Conduct

Management bodies and all staff involved in credit intermediation are required, in their dealings with clients, lenders or other credit intermediaries, to act with diligence, loyalty, discretion and conscientious respect for the interests entrusted to them, in particular consumer rights.

A credit intermediary has a duty to:

• Refrain from acting as an intermediary in contracts about which you do not have accurate, objective and detailed information.
• We shall also endeavour to conduct our business based on the information obtained regarding the customer’s financial situation, their objectives and needs, whilst also taking into account the assumptions for risk analysis that may affect the consumer’s financial situation during the term of the contract.
• To work to prevent consumers from making unlawful, inaccurate, incomplete or unintelligible statements

They also undertake to:

• To act with loyalty, good faith, impartiality, rigour, efficiency, professionalism and common sense, thereby helping to foster clients’ trust in the credit intermediary.
• Always take consumers’ interests into account, providing advice and information about the products on offer to enable them to make conscious, informed and well-founded decisions.
• Employees and members of the management bodies are prohibited, in the course of their professional duties, from accepting any financial or non-financial benefits from clients or lenders that might compromise their duty of impartiality and respect for the interests of consumers.

Employees and members of the management bodies undertake to strictly observe the confidentiality inherent in the duties they perform, ensuring that any information arising therefrom remains confidential.

In addition to data and information relating to the financial, personnel or commercial circumstances of consumers and lenders, the duty of confidentiality extends to the business and corporate affairs of the credit intermediary, including: contracts, accounts, databases, IT systems and commercial strategies.

Employees with access to inside information must refrain from using it for their own benefit or that of others, and must not disclose it to third parties not involved in the process.

The credit intermediary has organisational and administrative mechanisms in place to identify potential conflicts of interest, and also takes measures to minimise their occurrence or, should they arise, to ensure that consumers’ interests are not prejudiced.

Measures to prevent conflicts of interest:

• Employees and members of the management are prohibited from taking part in any proceedings where they have a direct or indirect interest.
• Employees and members of the management shall refrain from engaging in business activities whenever they carry out any activity that could be regarded as in direct competition with the consumer’s business.
• Employees must take steps to avoid any actions that could prove detrimental to the interests of the employer, consumers or lenders.
• Should any conflict arise, the employee must immediately inform the credit intermediary.
• The credit intermediary shall inform the consumer whenever it finds that the existing mechanisms are insufficient to identify a conflict of interest; it shall provide the consumer with detailed and clear information (in writing), prior to the provision of the service, regarding the origin and nature of the conflict, as well as the measures taken to mitigate the risks. It shall also inform the lending institutions of the facts of the matter.

Organisational measures adopted to mitigate the risk of conflicts of interest:

• It adheres to a rigorous recruitment and human resources policy.
• Keep up-to-date records of your employees and carry out a post-recruitment check for any circumstances that could give rise to a conflict of interest.
• All employees and members of the management bodies must complete a declaration of no conflict of interest and a questionnaire designed to identify any situations that could give rise to conflicts of interest.
• It keeps a record of identified and properly documented conflict situations and the corresponding mitigation measures.

Procedures for Receiving Customer Complaints Customers and prospective customers may submit complaints using the IC’s complaints book.

The IC has a complaints book available in electronic format.