The Financial Innovation Association Kosovo
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Code of Conduct

Introduction

The Standard of Good Practice (hereinafter – The Standard) as approved in a general
meeting of the members of the Association of Financial Inovation of Kosova (hereinafter –
The Association) is a summary of basic principles the Association’s members are practising
when issuing loans and offering other financial services and working with their clients until
full repayment of the loan.

The purpose of this Standard is to provide additional protection and predictable service
level for those customers who have received or expect to receive loans ose shërbime të
tjera financiare from members of the Association. This standard includes guidelines for fair
commercial practice and criteria for professional diligence, conforming to the fair market
practices, good faith and principles of responsible lending generally accepted in the nonbank lending industry.
Members of the Association are committed to work in accordance with the rules of this
Standard. The rules of the Standard in their current version are available at the Association’s
website.

With the approval this Standard, the Customer Charter, found in Appendix 1 of this
Standard, is approved as well. The Customer Charter is a document addressed to the clients
of the Association’s members, that contains an abridged version of the rules of the Standard
and expresses the good will and commitment of the Association’s members observe in
relations with their clients.

The Association members use the Association logo in a prominent place on their websites,
link to the Association website, this Standard, the Customer Charter and other documents
of the Association, thus confirming their adherence to this Standard. Association members
ensure that any person interested in obtaining a loan from Association members has access
to the rules of this Standard and Customer Charter free of charge.

I. GENERAL OBLIGATIONS OF ASSOCIATION MEMBERS

1.1. Association members conduct business legally, complying with normative acts
pertaining to their actions, the case law, the decisions, instructions and guidelines of
industry supervising institutions, such as the Central Bank of Kosovo, Ministry of Finance,
Personal Data Protection Agency, and other relevant institutions.

1.2. Association members ensure that they conduct business in a manner appropriate to
professional diligence, i.e., according to the non-bank lending field’s generally accepted fair
market practice, principle of good faith, and conducting business responsibly and prudently.

1.3. Association members are aware that with any activity in their business, their actions
affect the Association and the entire industry’s reputation, so that they refrain from any
action which may adversely affect the reputation of the Association and the industry.

1.4. Association members conduct business honestly and ethically, and treat their clients
fairly. In any credit transaction with clients, Association members must provide sufficient
information, and, wherever possible, ensure that their partners also adhere to such
standards of action.

1.5. Association members ensure the application of Association approved guidelines in their
practice.

1.6. Association members provide appropriate staff training to their employees, so the
employees could ensure this Standard’s requirements are met when performing their
duties.

II. GRANTING LOANS AND REPAYMENT

2.1. Association members must always act in good faith and responsibly in accordance with
the principles set out in this Standard, in order to promote clients borrowing responsibly,
evaluating their financial conditions and ability to meet obligations.

2.2. Association members ensure that each client is explained of the nature of the loan apo
shërbimit tjetër financiar, including the fact that loans are inadvisable for solving preexisting financial difficulties.

2.3. Before granting the loan any Association member must make its best eforts to check if
the loan, if accepted, will meet the client’s specified material circumstances, and, on the
client’s request, clarify which of his information is taken into account in the decision to grant
a loan.

2.4. To ensure the adequacy of the loan granted with the customer’s financial conditions
and prevent the client taking on undue financial obligations, each Association member at
the time of issuing the loan must make sure of the customer’s solvency, assessing it
pursuant to the legislation and the use of personal credit risk models.

2.5. In order for a client to assess if the rules of the proposed loan suit their needs and
financial situation, before signing the loan agreement or issuing the loan each member of
the Association:

2.5.1. Provides clients with the information that’s necessary to compare different offers and
make an informed decision about obtaining a loan;

2.5.2. Gives the client clear and unambiguous information on the total loan fees, loan
repayment rules and procedures, as well as the consequences that will occur if the client
fails to comply with contract specifications;

2.5.3. Informs the client of their statutory right to refuse acceptance of the loan;

2.5.4. Always gives the client the required explanation of the loan terms and other
information provided to the client in accordance with the laws (including details of
payments made by the client).

2.7. Every member of the Association shall ensure that the loan agreements contain all the
information and provisions set out in the normative acts, and have been prepared in simple
and understandable language.

2.8. Association members explain clients the way the client can contact the creditor during
the term of a loan agreement, as well as indicating how the customer will be contacted (by
phone, email, SMS or directly on-line). At the client’s request, Association members will
always promptly notify the client of any payment at maturity or changes in the interest rate
of the loan (if the loan terms foresee such changes) via e-mail, SMS or telephone.

2.9. In cases where a repayment schedule with the client has been agreed upon, Association
members ensure that the regular payments to be made within the repayment schedule
meet the client’s financial situation.

2.10. The client receives accurate information on the costs incurred in connection with the
extension of the maturity date or repayment of the loan in accordance with the individually
compiled loan repayment schedule.

2.11. Association members ensure the confidentiality of personal information received from
the client, and before receiving such information the Association member will inform the
clients about the purposes for which the information received from clients will be used for.
The information received from clients is disclosed to third parties only in cases envisaged by
the law.

2.12. Association members ensure that the personal data processing systems they use
comply with the requirements of the law.

III. DEBT RECOVERY

3.1. Association members ensure that their conduct in debt recovery is consistent with high
ethical criteria, ensuring the industry’s best practice consistent with the co-operative form
of collaboration with financially distressed clients. Each loan repayment problem is
addressed by assessing the situation.

3.2. All Association members ensure that all clients are aware of the necessity to
immediately contact the creditor in case of financial problems, and Association members
ensure that their employees will treat them with understanding.

3.3. In case that a client has made missed a repayment deadline; there is immediate
communication with the client to determine reasons for the delay. In case the customer
informs that he has incurred unexpected financial difficulties, Association members
encourage making a repayment agreement that corresponds with the client’s solvability.

3.4. In cases where the Association members have forwarded the client’s case to debt
collection service providers, the client is immediately informed of this as well.

3.5. Association members by their own discretion may forward the debt collection matters
to debt collection service providers and in such case will aim to choose only licensed debt
collection service providers, whose conduct is consistent with high professional standards.

IV. ADVERTISING AND MARKETING

4.1. In performing advertising and marketing efforts, Association members ensure that
these meet the regulatory requirements of normative acts regulating non-bank lending,
advertising, commercial practice, information society services, and the Standard of Good
Practice.

4.2. Association members ensure that the measures underwent for promotional and
marketing events promote responsible borrowing.

4.3. Association members evaluate with scrutiny those advertising and marketing activities
and content, which may adversely affect the economic behaviour of the consumer groups,
that due to their mental or physical condition, age or unwarranted trust (also, lack of
experience or knowledge), are considered particularly vulnerable borrowers.

4.4. Marketing activities where clients are addressed individually (for example, sending
commercial communications to customers via email or text message, etc.), when used by
Association members, are used prudently and gently, ensuring that clients are not unduly
disturbed, always pointing to the possibility of free withdrawal from receiving further
commercial communications in a way that’s simple and convenient for the client.

V. COMPLAINTS PROCEDURE

5.1. Association members establish their procedures for handling complaints, ensuring that
they contain the following minimum principles of the handling complaints:

5.1.1. The client’s complaints are dealt within no longer than 5 (five) weekdays;

5.1.2. Immediately inform the client if additional time is required to review the complaint;

5.1.3. The client is notified that in case of a negative outcome of the complaint case, he has
a right to apply to the Association to address future challenges;

5.1.4. The above complaints procedure does not restrict the Association member’s clients’
rights to refer to the relevant supervisory institutions and court.

5.2. Association members shall discuss the subject matter of the complaints on “no name
bases” within the sessions of the Association, together with information about the
complaint process and the solution status.

5.3. Association members inform their clients about the options available to the complaint
as follows:

5.3.1. Ensure that the information about the complaint handling, as well as the free help
desk phone is on the web site in a prominent place, on client contracts, as well as the
relevant Association member’s offices and customer service centres;

5.3.2. At the client’s request, information about the complaint handling policy, as well as the
free telephone assistance service is provided free of charge to the client in writing.

5.4. The Association undertakes to respond to Association member client’s complaints
immediately, but not later than 5 (five) weekdays; in case additional time is required to
conduct an investigation, informing the client about it. The assistance given from the
Association to Association member clients is free of charge.