Code of Conduct

This Code of Conduct sets out the standards of behaviour expected from all employees, consultants, agents and other representatives ("Team Members") of Expertt (unit of Eresolution Consultancy Services Pvt. Ltd.) ("the Company").

Objectives

• 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).

Our Role and Guiding Principles

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

Lawful and Ethical Conduct

• All actions must be consistent with applicable laws and regulations in India
• No Team Member may engage in or encourage any unlawful or unethical conduct, even if requested by a client

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

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

Dealing with Clients (Borrowers)

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
• Team Members must not advise or encourage clients to 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

No Assistance in Fraudulent Conduct

• Team Members must never advise, assist, or participate in hiding or transferring assets to defeat or delay lawful recovery by lenders
• Team Members must never advise, assist, or participate in fabricating documents, income proofs, or financial statements
• Team Members must never advise, assist, or participate in providing false information to lenders or any other stakeholders

Fair and Transparent Advice

• Clearly explain to clients that settlement is subject to lender's discretion
• Clearly explain to clients that lenders may or may not accept the proposed terms
• Clearly explain possible impacts on credit score, future borrowing ability and legal consequences of default
• Do not guarantee specific percentage reductions or assured success

No Legal Practice by Unauthorised Persons

• Only qualified advocates enrolled with a Bar Council may provide legal opinions or represent clients before courts/tribunals
• Non-lawyer Team Members must not hold themselves out as "lawyers", "legal experts", or provide legal opinions

Informed Consent & Documentation

• Obtain written consent from clients before initiating discussions with lenders
• Ensure clients understand all documents they sign, including authorisation letters

Dealing with Lenders and Their Representatives

Professional and Courteous Communication

• Treat all lenders, their officers, collection agents, and legal representatives with courtesy and respect
• Avoid hostile or threatening language in all communications

Honest and Accurate Representations

• Do not provide false or misleading information about a client's financial position or intentions
• Do not exaggerate regulatory provisions to pressure lenders

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

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

Communications, Marketing and Public Statements

No Misrepresentation of Regulatory Status

• Team Members must not claim to be "RBI approved", "RBI authorised", "bank-authorised", or "government approved"
• Team Members must not use names, logos, or emblems of regulators or banks in a way that suggests official endorsement

Truthful Advertising and Website Content

• All marketing material, including website content and social media posts, must honestly describe the nature and limitations of our services
• Avoid "Guaranteed settlement", "assured waiver" etc.
• Avoid misleading statistics that cannot be substantiated

No Defamation

• Team Members must not publish, post, or circulate false or unverified allegations against any lender or its staff
• Constructive criticism or general commentary must be factual, balanced and non-defamatory

Responsible Use of Social Media

• Personal social media use must not disclose client information, confidential settlement terms, or sensitive comments about lenders
• Team Members must not present personal views as the official position of the Company unless authorised

Confidentiality and Data Protection

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

Lender Information

• Internal information received from lenders (e.g., specific settlement offers, internal policies shared in confidence) must not be misused or disclosed without proper authorisation

Compliance with Data Protection Laws

• Team Members must follow Company policies on data security, record-keeping, and disposal of documents (physical and electronic)

Compliance, Training and Reporting

Mandatory Compliance

• Adherence to this Code is a condition of employment or engagement with the Company and must be signed every month
• Breach of this Code may result in disciplinary action, up to and including termination of employment/engagement and, where appropriate, reporting to relevant authorities

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.

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

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.

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, agree to abide by its terms and understand violations may result in disciplinary and/or legal consequences.