CODE OF CONDUCT

CODE OF CONDUCT FOR EMPLOYEES AND REPRESENTATIVES

1. Purpose and Scope
   
   This Code of Conduct sets out the standards of behaviour expected from all employees, consultants, agents and other representatives (“Team Members”) of Loansettlement.com (unit of Loanwise Financial Services Pvt Ltd) (“the Company”).
   The objective of this Code is to:
   • Protect the interests of our clients (borrowers) and counterparties (lenders) in a win-win approach.
   • Ensure all services are delivered in a lawful, ethical and transparent manner.
   This Code applies to all Team Members at all times, whether dealing with clients, lenders, vendors, or any other stakeholders, and in all forms of communication (in-person, phone, email, messaging apps, social media, or written material).


2. Our Role and Guiding Principles
   
   1.Advisory Role Only
   • The Company provides advisory and negotiation support to borrowers facing financial distress.
   • We do not guarantee any particular outcome, waiver, discount, or settlement.
   2.Lawful and Ethical Conduct
   • All actions must be consistent with applicable laws, regulations in India.
   • No Team Member may engage in or encourage any unlawful or unethical conduct, even if requested by a client.
   3.Respect for Contracts and Rights of Lenders
   • We recognise that lenders have valid contractual rights to recover amounts due.
   • Our role is to facilitate voluntary negotiated settlements, not to interfere with the rights of the lenders.
   4.Integrity and Honesty
   • Information provided to clients and lenders must be truthful and accurate.
   • We do not make false promises or misrepresent facts to any party.


3. Dealing with Clients (Borrowers)
   
   1.No Encouragement of Wilful Default

   Team Members must not advise or encourage clients to:

   • Deliberately stop making payments when they have the capacity to pay.
   • Falsely portray themselves as unable to pay when they are not.

   Any advice given must be based on the genuine financial situation of the client.

   2.Fair and Transparent Advice

   Clearly explain to clients:

   • That settlement is subject to lender’s discretion.
   • That lenders may or may not accept the proposed terms.
   • Possible impacts on credit score, future borrowing ability and legal consequences of default.

   Do not guarantee specific percentage reductions or assured success.

   3.Informed Consent & Documentation
   • Obtain written consent from clients before initiating discussions with lenders.
   • Ensure clients understand all documents they sign, including authorisation letters.


4. Dealing with Lenders and Their Representatives
   
   1.Professional and Courteous Communication
   • Treat all lenders, their officers, collection agents, and legal representatives with courtesy and respect.
   2.Honest and Accurate Representations
   • Do not provide false or misleading information about a client’s financial position or intentions.
   3.Respect for Negotiation Outcome
   • Any settlement reached is a voluntary commercial decision of the lender.
   • Team Members must not portray the outcome as forced, unlawful, or guaranteed by regulation.
   4.No Undisclosed Arrangements
   • Team Members must not accept any payment, commission, or benefit from lenders in relation to a client’s matter.
   • Team Members must not accept any payment, commission, or benefit from the clients for any personal enrichment.


5. Confidentiality and Data Protection
   
   1.Client Confidentiality
   • All financial, personal and transactional information of clients is strictly confidential.
   • Such information must be used only for providing services and must not be shared with unauthorised persons.
   2.Lender Information
   • Internal information received from lenders must not be misused or disclosed without proper authorisation.
   3.Compliance with Data Protection Laws
   • Team Members must follow Company policies on data security, record-keeping, and disposal of documents (physical and electronic).


6. Compliance, Training and Reporting
   
   1.Mandatory Compliance
   • Adherence to this Code is a condition of employment or engagement with the Company
   • Breach of this Code may result in disciplinary action, up to and including termination of employment/engagement and, where appropriate, reporting to relevant authorities.
   2.Ongoing Training

   The Company will provide periodic training on:

   • Applicable laws and regulations.
   • Ethical standards and best practices in debt advisory and settlement.

   Team Members are expected to participate actively and stay updated.

   3.Reporting Concerns or Violations
   • Any Team Member who becomes aware of a potential or actual violation of this Code, law, or Company policy must promptly report it through designated internal channels.
   • The Company will endeavour to protect bona fide whistle-blowers from any adverse consequences.


7. Interpretation and Updates
   
   • The Company reserves the right to amend or update this Code from time to time, in line with changes in law, regulation, or business practices.
   • In case of any doubt regarding the interpretation of this Code or the legality of any proposed action, Team Members must seek guidance from their reporting manager or the designated compliance/legal officer before acting.


8. Employee Acknowledgement
   

   All Team Members are required to read, understand, and comply with this Code of Conduct. By continuing in employment or engagement with the Company, each Team Member acknowledges:

   • That they have read and understood this Code.
   • That they agree to abide by its terms; and
   • That they understand violations may result in disciplinary and/or legal consequences.