Code of Practice

Commercial Domestic Investigations

Code of Practice

1. GENERAL CONDUCT

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL ACT RESPONSIBLY AND WITH INTEGRITY
ON THE DAY TO DAY CONDUCT OF ITS BUSINESS FOR EXAMPLE

A CONDUCT ITS BUSINESS IN COMPLIANCE WITH ALL RELEVANT LEGISLATION, REGULATIONS,
REGULATORY GUIDANCE AND REQUIREMENTS AND THIS CODE OF PRACTICE

B CONDUCT ITS BUSINESS UNDER NAMES, TITLES AND TRADING STYLES WHICH ARE NOT
INTENDED TO CONFUSE, MISLEAD OR OTHERWISE EMBARRASS CLIENTS, CREDITORS, DEBTORS
OR MEMBERS OF THE PUBLIC AND WHICH WILL NOT IMPLY ANY ASSOCIATION WITH OTHER
ORGANISATIONS, GOVERNMENTAL BODIES OR PERSONS WHICH EITHER DO NOT EXIST OR
CARRY NO ASSOCIATION WITH THE BUSINESS

C COOPERATE WITH THE CSA, DBSG, REGULATORS AND ORGANISATIONS THAT REGULATE OR
SUPERVISE THE DEBT AND/OR RECOVERIES INDUSTRY

D MAKE AVAILABLE ON THEIR WEBSITE (IF THEY HAVE ONE), OR FOLLOWING A REQUEST, A
COPY OF THIS CSA CODE OF PRACTICE

E PROVIDE ADEQUATE AND SUFFICIENT TRAINING TO ITS EMPLOYEES IN ORDER TO ENSURE
THAT THEY CONDUCT THEMSELVES IN ACCORDANCE WITH THIS CODE OF PRACTICE

F REGULARLY EXAMINE AND AUDIT THEIR PRACTICES, STRATEGIES, COMMUNICATIONS AND
COMPLIANCE CULTURE AGAINST THIS CODE OF PRACTICE

G ENSURE THAT ANY COMMUNICATION COMPLIES WITH THIS CODE OF PRACTICE AND IS IN
PLAIN ENGLISH

H HAVE AND MAINTAIN CLEAR AND EFFECTIVE POLICIES AND PROCEDURES COVERING ALL
BUSINESS ACTIVITIES THEY ARE ENGAGED IN

I NOT UNLAWFULLY DISCRIMINATE AGAINST ANY PERSON

J HAVE IN PLACE A SEPARATE BUSINESS ACCOUNT FOR ALL MONIES COLLECTED ON BEHALF
OF CLIENTS AND INSTRUCT THEIR BANK THAT THE ACCOUNT ONLY HOLDS CLIENT MONEY

K INFORM THEIR CLIENTS OF THE TRUE RATES OF CHARGES FOR SERVICES RENDERED

L DISTRIBUTE CLIENT MONEY ONLY AS AGREED BY THE CLIENT

M REPORT SUMS COLLECTED AND REMIT TO THEIR CLIENTS AT LEAST ONCE A MONTH, OR AS
OTHERWISE AGREED, ALL MONIES COLLECTED

N ENSURE THEY UNDERTAKE DUE DILIGENCE AND AUDIT ANY THIRD PARTY AGENT ON A
REGULAR BASIS TO ENSURE ADHERENCE TO REGULATORY REQUIREMENTS AND THIS CODE OF
PRACTICE REGARDLESS OF WHETHER THEY ARE A CSA OR DBSG MEMBER

O COMPLY WITH ALL REASONABLE REQUESTS FOR INFORMATION MADE BY DEBTORS OR THEIR
REPRESENTATIVES, REGULATORS, CLIENTS AND CREDITORS, WHETHER STATUTORY OR NOT,
AND UPON PAYMENT OF THE STATUTORY FEE IF APPLICABLE

P NOT PLACE RESTRICTIONS OR TIME LIMITS ON THE LEGITIMATE QUERYING OF
UNALLOCATED PAYMENTS

Q TREAT BUSINESSES WITH WHOM THEY DEAL FAIRLY AND TRANSPARENTLY

R PROVIDE PRIOR WRITTEN NOTICE TO DEBTORS WHEN OUTSOURCING ACCOUNTS, TO ENSURE
THE DEBTOR’S AWARENESS OF WHO WILL BE CONTACTING THEM

S MAKE CONTACT AT REASONABLE TIMES AND AT REASONABLE INTERVALS, TAKING INTO
CONSIDERATION THE REASONABLE WISHES OF THE DEBTOR, WHICH MAY INCLUDE THE
PREFERRED METHOD OF COMMUNICATION. WHERE POSSIBLE, MAKE DEBTORS AWARE OF
BUSINESS OPENING TIMES AND HIGHLIGHT CONTACT PERIODS

T WHERE AUTOMATED DIALING SYSTEMS ARE USED, ENSURE COMPLIANCE TO THE OFCOM
STATEMENT OF POLICY*

U TAKE APPROPRIATE STEPS TO ENSURE THE ACCURACY OF DATA PROCESSED BY IT AND IN
PARTICULAR DATA RELATING TO INDIVIDUALS AND THEIR DEBTS

V WHEN AN ACCOUNT IS REASONABLY DISPUTED OR A COMPLAINT IS RECEIVED, SUSPEND
COLLECTION ACTIVITY AND INVESTIGATE AND WHERE APPLICABLE REFER THE MATTER TO
THEIR CLIENT

W ENSURE THAT IT DOES NOT PUT ANY DEBTOR UNDER UNDUE PRESSURE TO BORROW MONEY

X TAKE REASONABLE STEPS TO ENSURE THAT THE PERSON BEING CONTACTED IS IN FACT
THE DEBTOR

Y COMMUNICATE WITH DEBTORS FAIRLY AND TRANSPARENTLY, AND NOT INTENTIONALLY
MISLEAD THEM

Z COOPERATE WITH DEBTORS AND THEIR AUTHORISED THIRD PARTIES IN LINE WITH
REGULATORY GUIDANCE, AND NOT ACT IN A MANNER INTENDED TO PUBLICLY EMBARRASS OR
CAUSE THEM DISTRESS

AA TREAT DEBTORS FAIRLY AND NOT SUBJECT DEBTORS (OR THEIR AUTHORISED
REPRESENTATIVES) TO AGGRESSIVE PRACTICES, OR CONDUCT WHICH IS DECEITFUL,
OPPRESSIVE, UNFAIR OR IMPROPER, WHETHER LAWFUL OR NOT

BB EXERCISE FORBEARANCE AND CONSIDERATION OF DEBTOR’S CIRCUMSTANCES, OF WHICH
THEY ARE AWARE, IN PARTICULAR IN RELATION TO THOSE WHO ARE PARTICULARLY
VULNERABLE OR EXPERIENCING SEVERE FINANCIAL HARDSHIP

CC TAKE INTO ACCOUNT THE DEBTOR’S CIRCUMSTANCES AND ABILITY TO PAY WHEN SEEKING
TO RECOVER DEBTS

DD ENSURE THAT THEY TAKE INTO ACCOUNT THE DEBTOR’S DOMICILE AND THE LAW
APPLICABLE TO THE AGREEMENT UNDERLYING THE DEBT

*OFCOM STATEMENT OF POLICY ON THE PERSISTENT MISUSE OF AN ELECTRONIC
COMMUNICATIONS NETWORK OR SERVICE

2. FINANCIAL DIFFICULTIES

A UNLESS INSTRUCTED OTHERWISE, ACCEPT ALL REASONABLE OFFERS BY DEBTORS TO PAY
BY INSTALMENTS PROVIDED SUCH DEBTORS HAVE SUPPLIED (I) EVIDENCE OF INABILITY TO
PAY IN FULL, AND (II) ACCURATE INCOME AND EXPENDITURE INFORMATION DEMONSTRATING
THE MAXIMUM AMOUNT THEY CAN AFFORD TO PAY

B BE EMPATHETIC WITH DEBTORS EXPERIENCING FINANCIAL DIFFICULTIES

C ENCOURAGE THE DEBTOR TO ENGAGE WITH THE MEMBER OR OFFER APPROPRIATE
SIGNPOSTING TO MONEY ADVICE ORGANISATIONS WHO CAN ASSIST

D ALLOW THE DEBTOR TO APPORTION INCOME TO THE PAYMENT OF PRIORITY DEBTS SUCH AS
MORTGAGE OR RENT WHEN ASSESSING THE DEBTOR’S ABILITY TO REPAY

E SUSPEND ANY DEBT COLLECTION AND RECOVERY ACTIVITY WHERE THE DEBTOR
DEMONSTRATES THEY ARE SEEKING FINANCIAL ASSISTANCE AND PROVIDE THE DEBTOR
BREATHING SPACE OF AT LEAST 30 DAYS

F BE PREPARED TO ACCEPT A TOKEN OFFER MADE BY THE DEBTOR OR THEIR
REPRESENTATIVE WHEN EVIDENCE HAS BEEN PROVIDED THAT THEY CANNOT AFFORD TO PAY
MORE

G CONSIDER REDUCING OR STOPPING INTEREST, CHARGES OR FEES BEING APPLIED TO THE
ACCOUNT IF THE DEBTOR HAS DEMONSTRATED FINANCIAL DIFFICULTIES

H ENSURE INFORMATION IN RELATION TO THE DEBTOR’S FINANCIAL CIRCUMSTANCES IS
PASSED ON TO ANY THIRD PARTY AGENCY SUBSEQUENTLY INSTRUCTED TO COLLECT THE DEBT.
MENTAL HEALTH

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

I OBTAIN AND USE SENSITIVE INFORMATION ONLY WITH THE EXPLICIT CONSENT OF THE
DEBTOR. PROCESSING SUCH INFORMATION MUST BE IN ACCORDANCE WITH THE DATA
PROTECTION ACT 1998 AND ANY GUIDANCE PUBLISHED BY THE INFORMATION COMMISSIONER’
S OFFICE

J WHEN REQUESTING EVIDENCE OF MENTAL HEALTH PROBLEMS, SEEK APPROPRIATE
INFORMATION INCLUDING, WHERE NECESSARY, REQUESTS FOR THE COMPLETION OF THE DEBT
AND MENTAL HEALTH EVIDENCE FORM, OR SIMILAR, FROM AN APPROPRIATE/AUTHORISED
PERSON

K IN INSTANCES WHERE THE DEBTOR IS EXPERIENCING MENTAL HEALTH PROBLEMS, ONLY
INITIATE COURT ACTION TO PURSUE THE DEBT IF IT IS REASONABLE AND PROPORTIONATE
TO DO SO

L ENSURE INFORMATION IN RELATION TO THE DEBTOR’S MENTAL HEALTH PROBLEMS IS
PASSED ON TO THE INSTRUCTING CLIENT OR ANY THIRD PARTY AGENT SUBSEQUENTLY
INSTRUCTED

3. COMPLAINTS

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A CEASE RECOVERY ACTIVITY WHILST INVESTIGATING A COMPLAINT

B ACKNOWLEDGE RECEIPT OF A COMPLAINT, AND ADVISE OF THE TIMESCALES FOR
INVESTIGATION

C FOLLOWING A REQUEST, PROVIDE DEBTORS WITH A COPY OF ITS COMPLAINT HANDLING
PROCEDURES

D HANDLE AND DEAL WITH COMPLAINTS, WHETHER VERBAL OR WRITTEN, PROMPTLY AND IN A
CLEAR MANNER

E ADVISE COMPLAINANTS OF THEIR RIGHT TO REFER THEIR COMPLAINT TO THE CSA OR
DBSG, AS AND WHERE APPROPRIATE

F TAKE APPROPRIATE REMEDIAL ACTION IN INSTANCES OF FAILING OR ERROR

G UNDERTAKE ROOT CAUSE ANALYSIS OF COMPLAINTS AND TAKE CORRESPONDING ACTION TO
IMPROVE BUSINESS PRACTICES

H KEEP A RECORD OF ALL COMPLAINTS, HOWSOEVER RECEIVED, AND ENSURE THE
APPROPRIATE MANAGEMENT ARE AWARE OF THE LEVEL, NATURE AND ROOT CAUSE OF
COMPLAINTS

DISPUTES

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A ENGAGE WITH CLIENTS AND DEBTORS TO ENSURE DISPUTES ARE INVESTIGATED AND DEALT
WITH PROMPTLY

B CEASE RECOVERY ACTIVITY WHILST INVESTIGATING A VALID DISPUTE

C PROVIDE A RESPONSE DETAILING THE MEMBER’S CONCLUSION TO THE DISPUTE

D PROVIDE SUFFICIENT INFORMATION TO JUSTIFY THE STATED CONCLUSION

4. DATA PROTECTION AND CONFIDENTIALITY

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A PROCESS PERSONAL AND SENSITIVE DATA IN ACCORDANCE WITH THE RELEVANT DATA
PROTECTION LEGISLATION, ENSURING COMPLIANCE TO THE DATA PROTECTION PRINCIPLES

B ONLY OBTAIN AND PROCESS DATA FROM LEGITIMATE SOURCES OR DATABASES

C TAKE PROMPT STEPS TO CORRECT DATA, BOTH INTERNALLY AND WITH THE CREDIT
REFERENCE AGENCIES, WHERE IT IS AWARE THAT THE DATA IS OUT OF DATE OR INACCURATE

D PASS ON OR MAKE PROMPTLY AVAILABLE INFORMATION IN RELATION TO THE DEBTOR’S
FINANCIAL CIRCUMSTANCES, ANY DISPUTE OR COMPLAINT, OR MENTAL HEALTH PROBLEM IN
ORDER TO PREVENT COLLECTION ACTIVITY FROM CONTINUING WHERE IT IS INAPPROPRIATE
TO DO SO

E USE APPROPRIATE CONTROLS TO ENSURE THAT ANY EXCHANGE OF DATA TO ANY THIRD
PARTY IS LAWFUL AND ADEQUATELY PROTECTED

F ENSURE THEY HAVE THE TECHNICAL AND ORGANISATIONAL MEASURES IN PLACE TO
PREVENT UNAUTHORISED AND UNLAWFUL PROCESSING AND DISCLOSURE OF INFORMATION

G COMPLY WITH ANY SUBJECT ACCESS REQUEST RECEIVED FROM AN INDIVIDUAL OR ANY
THIRD PARTY REPRESENTATIVE ACTING ON BEHALF OF THE INDIVIDUAL

H ENSURE APPROPRIATE DATA PROTECTION CHECKS ARE CARRIED OUT WHEN SPEAKING WITH
DEBTORS TO VERIFY THEIR IDENTITY AND WHERE NECESSARY AND APPROPRIATE, VALIDATE
AND UPDATE INFORMATION RECEIVED FROM THE DEBTOR

I OBSERVE AND PROTECT EACH CLIENT’S DATA, STRATEGIES, INTEGRITY AND BUSINESS
METHODS

J OPERATE A WRITTEN DATA RETENTION POLICY

5. MONITORING COMPLIANCE

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A KEEP ABREAST OF RELEVANT LEGISLATION, REGULATIONS, REGULATORY GUIDANCE AND
REQUIREMENTS AND UPDATES TO, AND GUIDANCE RELATING TO, THIS CODE OF PRACTICE

B PERIODICALLY TEST THE COMPLIANCE KNOWLEDGE OF ITS STAFF AS APPROPRIATE TO
THEIR JOB FUNCTIONS

C EMPLOY APPROPRIATE AND SUFFICIENT ORGANISATIONAL PROCESSES TO ENABLE THE
ROUTINE MONITORING OF ITS COMPLIANCE PERFORMANCE, INCLUDING THAT OF ITS STAFF
AND AGENTS

D KEEP RECORDS OF COMPLIANCE MONITORING AND TESTING UNDERTAKEN IN SUFFICIENT
DETAIL TO ILLUSTRATE COMPLIANCE PERFORMANCE

BREACHES OF THIS CODE OF PRACTICE:

ALLEGATIONS OF BREACHES OF THIS CODE OF PRACTICE WILL BE INVESTIGATED BY THE
ASSOCIATION. IF ANY INVESTIGATION IDENTIFIES SERIOUS BREACHES OF THIS CODE OF
PRACTICE BY ANY MEMBER THE MATTER WILL BE REFERRED BY THE CHIEF EXECUTIVE TO
THE BOARD AND DBSG GOVERNING COMMITTEE. EACH MEMBER SHALL CO-OPERATE WITH THE
ASSOCIATION IN A TIMELY MANNER, PROVIDING REQUESTED INFORMATION. THE
ASSOCIATION SHALL DETERMINE ANY SANCTION FOR A BREACH OF THIS CODE OF PRACTICE
IN ACCORDANCE WITH ITS ARTICLES OF ASSOCIATION. THE ASSOCIATION MAY PUBLICISE
ANY SANCTIONS IT IMPOSES ON A MEMBER.

6. TRACING

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A WHEN SEEKING TO IDENTIFY AN INDIVIDUAL, TAKE REASONABLE STEPS TO ENSURE THAT
DATA AND INFORMATION USED IN THE IDENTIFICATION PROCESS IS, TO THE BEST OF
THEIR KNOWLEDGE, ACCURATE AND ADEQUATE

B ENSURE THAT ALL PRACTICES INVOLVED IN THE TRACING PROCESS ARE TRANSPARENT AND
IN LINE WITH RELEVANT REGULATION AND GUIDANCE PRIOR TO ANY COLLECTIONS ACTIVITY

C TAKE REASONABLE STEPS TO ENSURE THAT THE PERSON TRACED IS IN FACT THE DEBTOR

D ATTEMPT TO VERIFY DATA OBTAINED RELATING TO A DEBTOR’S WHEREABOUTS USING ONE
OR MORE INFORMATION SOURCES, WHICH COULD INCLUDE RELIABLE DATABASES, A SOFT
TRACE LETTER, CONTACTING OTHER PEOPLE OR DOORSTEP ENQUIRIES

E NOT USE NEIGHBOURS TO PASS ON MESSAGES AS PART OF THE TRACE PROCESS

F DEMONSTRATE THAT PROCESSES ARE IN PLACE TO DEAL EFFECTIVELY AND FAIRLY WITH
ANY INSTANCES OF MIS-TRACE (WHEN DATA OBTAINED PROVES TO BE INACCURATE) AND
KEEP RECORDS OF SUCH INSTANCES

G WHERE DATA IS PROVEN TO BE INACCURATE, UPDATE ALL RECORDS PROMPTLY AND ACCURATELY

7. TELEPHONE AND WRITTEN COMMUNICATION

COLLECTION AND RECOVERY

TELEPHONE COMMUNICATION

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A WHEN MAKING CONTACT BY TELEPHONE, ENSURE ADHERENCE TO DATA PROTECTION
REQUIREMENTS AND VERIFY THE IDENTITY OF THE DEBTOR OR THEIR AUTHORISED THIRD
PARTY BEFORE DISCUSSING THE NATURE OF THE CALL

B WHEN LEAVING A MESSAGE, NOT DISCLOSE THE NATURE OF THE CALL OR ANY DETAILS
RELATING TO THE DEBT, OR OTHER PERSONAL INFORMATION

C NOT REFER TO LITIGATION OR INSOLVENCY PROCEEDINGS UNLESS THE COMMENCEMENT OF
PROCEEDINGS IS GENUINE AND INTENDED

D ENSURE THAT STAFF MEMBERS WHO USE PSEUDONYMS CAN BE EASILY IDENTIFIED WITHIN
THE ORGANIZATION

WRITTEN COMMUNICATION

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

E WHEN MAKING CONTACT BY LETTER, ADHERE TO THE CSA & DBSG GUIDANCE ON STANDARD
DEBT COLLECTION LETTERS*, AND ENSURE LETTERS ARE WRITTEN AND PRODUCED IN LINE
WITH APPLICABLE REGULATIONS, LEGISLATION AND REGULATORY GUIDANCE

F ENSURE THAT ON TRANSFER OF A DEBT TO A THIRD PARTY AGENT THE DEBTOR RECEIVES
WRITTEN NOTIFICATION ADVISING THEM OF WHO IS NOW RESPONSIBLE FOR COLLECTING THE
DEBT, SO THAT THEY ARE AWARE AT ALL TIMES WHO WILL BE MAKING CONTACT

G PROVIDE DEBTORS WITH INFORMATION ON REPAYMENT METHODS

H WHEN USING EMAIL TO CONTACT DEBTORS, BEFORE SENDING DEBT RELATED
CORRESPONDENCE TAKE REASONABLE STEPS TO VERIFY THAT THE EMAIL ADDRESS OBTAINED
IS VALID AND IS AN ACCEPTABLE FORM OF COMMUNICATION

I CONSIDER ANY STATUTORY REQUIREMENTS WHICH REQUIRE A PARTICULAR METHOD FOR
SENDING CERTAIN DOCUMENTS OR NOTICES

J WHEN SENDING TEXT MESSAGES, TAKE REASONABLE STEPS TO VERIFY THAT THE MOBILE
TELEPHONE NUMBER OBTAINED IS VALID

K ENSURE TEXT MESSAGES DO NOT DISCLOSE THE NATURE OF THE CONTACT, OR REFER TO
THE DEBT OR OTHER PERSONAL DETAILS UNLESS PERMITTED TO DO SO BY THE DEBTOR

8. PRE-LITIGATION AND LITIGATION

PRE-LITIGATION

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A ONLY STATE AN INTENTION TO COMMENCE PROCEEDINGS THAT ARE REASONABLY LIKELY TO
BE UNDERTAKEN AGAINST OR APPLIED FOR IN RESPECT OF THE DEBTOR

B MAKE CLEAR TO DEBTORS PRIOR TO ISSUING A CLAIM OR MAKING AN APPLICATION ITS
INTENDED COURSE OF ACTION AND WHAT THE DEBTOR CAN DO TO PREVENT THAT COURSE OF
ACTION

C NOT MISLEAD DEBTORS AS TO THE CONSEQUENCES OR INEVITABILITY OF CONSEQUENCES
ARISING FROM ANY LEGAL OR BANKRUPTCY ACTION

D COMPLY WITH SECTION 2 V (LEGAL ACTION) OF THE CSA & DBSG GUIDANCE ON STANDARD
DEBT COLLECTION LETTERS*

E ADHERE TO APPLICABLE PRE-ACTION PROTOCOL

LITIGATION

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

F RESORT TO LITIGATION ONLY IF APPROPRIATE NON-LITIGIOUS RECOVERIES ACTIVITY
HAS BEEN UNDERTAKEN IN RESPECT OF THE DEBT

G COMMENCE ANY LITIGATION, ENFORCEMENT OR BANKRUPTCY ACTION ONLY IF IT INTENDS
TO OBTAIN THE RELATED ORDER AGAINST THE DEBTOR

H NOT SERVE A STATUTORY DEMAND ON A DEBTOR UNLESS IT INTENDS AT THE TIME OF
SERVICE TO SERVE A BANKRUPTCY PETITION ON THE DEBTOR

I CONSIDER REFRAINING FROM COMMENCING, OR CONSIDER SUSPENDING OR CEASING, ANY
LEGAL OR BANKRUPTCY ACTION UPON IDENTIFYING THAT THE DEBTOR IS PARTICULARLY
VULNERABLE AND THAT SUCH ACTION WOULD BE LIKELY TO EXACERBATE A PHYSICAL OR
MENTAL HEALTH CONDITION

J PROVIDE FORBEARANCE TO DEBTORS AS APPROPRIATE IN THE CIRCUMSTANCES

K ONLY IMPOSE SUCH COSTS AND INTEREST ON DEBTORS AS IT IS LAWFULLY ENTITLED

L SERVE ALL APPROPRIATE STATUTORY NOTICES ON DEBTORS PRIOR TO, DURING AND POST-
LITIGATION

M HAVE DEMONSTRABLE POLICIES RELATING TO ITS SELECTION OF DEBTS AND/OR DEBTORS
FOR LEGAL AND BANKRUPTCY ACTION

N COMPLY WITH SECTION 2 V (LEGAL ACTION) OF THE CSA & DBSG GUIDANCE ON STANDARD
DEBT COLLECTION LETTERS

O ADHERE TO ALL RELEVANT LEGISLATION AND REGULATIONS THROUGHOUT PROCEEDINGS

9. COMMERCIAL COLLECTION

COMMERCIAL AND DOMESTIC INVESTIGATIONS SHALL:

A ADHERE TO THE PRINCIPLES OF THIS CODE OF PRACTICE WHEN COLLECTING UNPAID
ACCOUNTS FROM BUSINESSES

B MAKE CLEAR ALL COSTS AND CHARGES ADDED TO DEBTS, INCLUDING THE LEGAL OR
CONTRACTUAL BASIS FOR ANY INTEREST APPLIED

C CONSIDER THE OFT DEBT COLLECTION GUIDANCE, AND ANY OTHER RELEVANT GUIDANCE,
WHEN COMMUNICATING WITH BUSINESSES

D HAVE IN PLACE AN ADEQUATE COMPLAINT HANDLING PROCESS WHICH INCLUDES REFERRAL TO THE CSA COMPLAINTS SCHEME