[INSERT THE NAME OF YOUR BUSINESS] EMPLOYEE CODE OF CONDUCT
1. Professionalism and Ethics:
1.1 Employees must conduct themselves professionally and ethically at all
times, including avoiding any unethical or unlawful activities in debt
collection activities.
1.2 Employees must comply with all relevant state and federal laws and
regulations relating to debt collection activities, such as the Fair Debt
Collection Practices Act (FDCPA) and the Telephone Consumer
Protection Act (TCPA).
1.3 Employees must treat all debtors with respect and dignity, including
avoiding the use of threatening, abusive or intimidating language, and
must communicate with debtors in a professional and respectful manner.
1.4 Employees must comply with all applicable privacy and confidentiality
laws, including the Gramm-Leach-Bliley Act (GLBA) and the Health
Insurance Portability and Accountability Act (HIPAA).
1.5 Employees must refrain from engaging in any activities that could damage
the reputation of the business, such as engaging in fraudulent or deceptive
activities.
2. Communication:
2.1 Employees must communicate with debtors in a clear and concise
manner, providing all relevant information about the debt and any legal
rights that the debtor may have.
2.2 Employees must communicate with debtors in accordance with applicable
laws and regulations, such as limiting the number of calls to a debtor to
avoid harassment and avoiding calling at times that would be inconvenient
to the debtor.
2.3 Employees must provide debtors with accurate information about their
accounts and must correct any errors in the information provided.
2.4 Employees must avoid any behavior that could be perceived as
discriminatory or harassing, including avoiding any comments or actions
that could be seen as sexist, racist, or homophobic.
2.5 Employees must refrain from contacting debtors at their place of
employment unless the debtor has given permission for such contact or
unless such contact is required by law.
3. Confidentiality:
3.1 Employees must maintain the confidentiality of all debtor information,
including any personal and financial information, as well as any
information related to the debtor’s account.
3.2 Employees must use appropriate safeguards to protect the confidentiality
of debtor information, including ensuring that all data and documents are
kept secure and are disposed of appropriately.
3.3 Employees must only share debtor information with authorized parties,
such as other employees who have a legitimate business need for the
information, or with government agencies in accordance with applicable
laws and regulations.
4. Conflict of Interest:
4.1 Employees must disclose any potential conflicts of interest that may arise
in connection with their debt collection activities, including any financial or
personal interests in the outcome of a particular account.
4.2 Employees must avoid any activities that could be seen as favoring their
own interests over the interests of the business or the debtor.
4.3 Employees must avoid any situations that could be seen as creating a
conflict of interest, such as attempting to collect on accounts where they
have a personal relationship with the debtor.
5. Reporting:
5.1 Employees must report any potential violations of this code of conduct or
any suspected illegal or unethical behavior to their supervisor or the
appropriate compliance officer.
5.2 Employees who report violations or suspected violations in good faith will
not face retaliation or adverse employment consequences.
5.3 Employees must cooperate with any investigations related to potential
violations of this code of conduct or any applicable laws or regulations.
6. Consequences:
6.1 Violations of this code of conduct may result in disciplinary action, up to
and including termination of employment.
6.2 The severity of the consequences will depend on the nature and severity
of the violation.
6.3 The business will take appropriate action to ensure that any violations of
this code of conduct are promptly addressed, and will take any necessary
steps to prevent future violations.
7. Training:
7.1 Employees will receive training on this code of conduct, as well as on all
relevant state and federal laws and regulations related to debt collection.
7.2 The business will provide ongoing training to ensure that employees
remain up-to-date on any changes to relevant laws and regulations.
7.3 Employees must complete all required training and must maintain the
knowledge and skills necessary to perform their job duties in accordance
with this code of conduct.
8. Compliance:
8.1 The business will establish and maintain a compliance program designed
to ensure compliance with all applicable laws and regulations related to
debt collection.
8.2 Employees must cooperate with the compliance program and must comply
with all policies and procedures established to ensure compliance with
applicable laws and regulations.
8.3 The business will conduct regular audits and reviews of its debt collection
activities to ensure compliance with this code of conduct, as well as with
all applicable laws and regulations.
8.4 The business will take appropriate action to address any identified
violations of this code of conduct or any applicable laws or regulations.
9. Independent Contractors:
9.1 Independent contractors who perform debt collection activities on behalf of
the business will be treated as separate entities from the business and will
be solely responsible for their own actions and compliance with all
applicable laws and regulations.
9.2 Independent contractors will not be considered employees of the business
and will not be entitled to any benefits or protections provided to
employees.
9.3 Independent contractors must comply with this code of conduct and all
applicable laws and regulations, and must provide their own insurance,
licenses, and permits as required by law.
9.4 The business will not be responsible for any fines or penalties imposed on
independent contractors for violations of this code of conduct or any
applicable laws or regulations.
9.5 Independent contractors must indemnify and hold the business harmless
from any claims, damages, or losses arising from their actions or
omissions, and must pay all fines or penalties imposed as a result of their
actions.
9.6 The business reserves the right to terminate its relationship with any
independent contractor who violates this code of conduct or any applicable
laws or regulations.
This code of conduct is intended to provide guidance for employees of [Insert the
Name of Your Business] debt collection located in Ohio and is not intended to create
any contractual rights or obligations. Employees should consult their supervisor or
the appropriate compliance officer if they have any questions or concerns about their
obligations under this code of conduct.
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