Our commitment to fair debt collection practices creates optimal conditions for the preservation of your good name, the integrity of your debtor, and the health of your bottom line.

I Preamble

As members of TCM Group we assume responsibilities to fellow Members of the Group, our industry, our customers, consumers, enterprises, and the public at large. In doing so we strive to:

1. Consistently maintain the highest standards of business conduct through the use of only legal and ethical means in all operations and debt recovery activity.
2. Actively promote and encourage the highest level of integrity within the industry while discouraging any activity that could compromise this integrity.
3. Cooperate in every way reasonable and appropriate with other Group Members and work with them to advance the credit and collection industry.
4. Be fair and respectful to any person or entity encountered through operations including employees, associates, competitors, customers, the public and employers in all business or professional relationships.
5. Maintain honesty and integrity in advertising and in all representations to the public and industry members concerning credit and collection industry products and services.
6. Develop and use the highest standards and practices for processing and handling consumer, business, customer and competitor disputes using TCM Group’s Code of Operations and Code of Compliance as guidance documents.
7. Observe all applicable laws, regulations, and rules pertaining to the processing and handling of accounts receivable.
8. Support TCM Group’s vision and agree to uphold this Code of Compliance, Code of Operations, and the governing documents of TCM Group International ehf.

II Conditions of Membership

To qualify for and maintain a membership in TCM Group the applicant or member shall:

1. Abide by the TCM Group Code of Compliance, Code of Operations, and Members Agreement (hereinafter collectively referred to as the “Rules”).
2. Supply information regarding the nature of the applicant or Member’s business, background information about the company policies and procedures, and management personnel.
3. Have not within the last ten years been convicted of a crime or found liable in a civil action for actions or inactions relating to credit or collection industry practices or procedures. This can include, but is not limited to, crimes relating to fraud, forgery, embezzlement, tax evasion, identity theft, misuse of funds, client trust accounts, or other theft of larceny.
4. Abide by the TCM Group’s self-regulation efforts, its formal and informal complaint resolution programs relating to inter- and extra-Group disputes, and the Group’s Rules.
5. Identify the designated contact person having sufficient responsibility within the organization to deal with complaints to the Group in accordance with the TCM Group’s Rules.
6. Respond promptly to complaints forwarded by the Group or from any other official complaint resolution program adopted by the TCM Group and make a good faith effort to resolve complaints in accordance with the Rules and generally accepted good business practices.
7. Meet all financial obligations, including and without limitation, financial obligations to the Group.

Each Member shall act responsibly and with integrity in the day-to-day conduct of its business. Each Member shall:

1. Conduct its business lawfully, comply with all relevant legislation, regulation, and judicial decisions and trade fairly and responsibly.
2. Conduct its business under a name, title, or style which will not confuse or mislead clients, creditors, debtors, or members of the public, or which will not imply any association with other organizations or persons that it does not actually maintain or that do not exist.
3. Comply with this Code of Compliance and follow any guidance notes issued by the TCM Group.
4. Comply with all applicable debt collections legislation, rules, and regulations. And in particular comply with local data protection and consumer protection legislation.
5. Follow where appropriate any requests conveyed to Members by the TCM Group or enforcement authorities.
6. Provide adequate training for staff, bringing to their attention the principles of this Code of Compliance and requiring them to act in accordance with it while performing their duties.
7. Use plain language in all communications.
8. Show the full business address, telephone number, email addresses, and other relevant contact information on all letter, postcards, and forms.
9. Ensure Member’s identity is clearly disclosed in all contacts by staff or agents.
10. Ensure that agents, sub-contractors, and subsidiaries comply with the Group’s Rules.
11. Comply with all reasonable requests for information concerning agreements and accounts made by debtors, clients, or their appointed representatives.
12. Keep client information strictly confidential at all times.

IV Legal Conduct

Each Member shall act within the parameters of law within their governing jurisdiction. Additionally, Members shall:

1. Familiarize themselves and all members of their staff with relevant legislation, rules, and regulations.
2. Provide information regarding relevant laws and guidelines to clients, creditors, debtors, or other Members of TCM Group as needed.
3. Ensure strict enforcement of behaviour compliant with the Rules within the Member’s organization.

In addition to a continuing duty to comply with the requirements of any applicable laws, regulations, and rules concerning the credit and collection industry practices, each Member has a duty to:

1. Treat all consumers and other enterprises with consideration and respect in all dealings.
2. Communicate with consumers and other enterprises with honesty and integrity, never attempting to mislead or misrepresent.
3. Provide verification of debt for which the Member has received a written or verbal request for verification by the consumer or business entity. Until verification has been provided, collection activities shall be suspended. If verification cannot be provided in response to a debtor’s written request, the Member will:
   • a) Cease all collection activities;
   • b) If applicable, direct or request removal of the item from the consumer or commercial credit report or report the item as disputed to the appropriate credit reporting agencies at the Member’s earliest opportunity (if applicable);
   • c) Notify the forwarding officer, credit grantor, client, or owner of the legal title to the debt that collection activity on the account was terminated due to the inability to provide verification of the debt; and
   • d) If requested by the debtor in writing, notify the consumer or business that any collection efforts have been terminated by the Member.
4. In addition to requirements imposed by law or regulation, in instances of alleged identity theft, fraud, or mistaken identity, conduct a reasonable investigation to determine the validity of the debt, the identity of the obligor on the account, and the accuracy of the information in the Member’s possession.
5. Not threaten or initiate collection litigation on time-barred debts.
6. Seek to obtain access to accurate and complete information about any accounts being purchased by the Member and obtain evidence of the chain of title to the debts being purchased.
7. Adopt an internal code of conduct.
8. Not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, including but not limited to misrepresentation for the purpose of obtaining membership in the TCM Group, a license, a certificate of registration, a certificate, a credential, or business-related insurance.
9. Not harass, threaten, or coerce a person, including but not limited to, on the basis of race, sex, age, creed, religion, colour, national origin, disability, sexual preference, gender or marital status in connection with a Member’s professional business, TCM Group activities, or while acting in a representative capacity of the Group.
10. Not engage in dishonourable, unethical, or unprofessional conduct of a nature or character likely to deceive, defraud, or harm a consumer or business, customer, member of the TCM Group, or the public.
11. Use reasonable efforts to safeguard the confidentiality, integrity, and availability of consumer information entrusted to the Member’s possession and control.
12. Refrain from using the name or logo of the TCM Group for commercial sales or advertising purposes in a manner not specifically authorized by the TCM Group.
13. Refrain from knowingly representing that the Member is affiliated with, or endorsed by, an institution or organization when such an affiliation or endorsement does in fact not exist, or that the Member has achieved a professional designation when such achievement does in fact not exist.
14. Make reasonable efforts to ensure the Member, its principals and its employees comply with the laws, regulations, and rules under which the Member performs credit or collection services or debt purchasing and the TCM Group’s Rules.
15. Take adequate precautions to distinguish between the Member’s personal views and the views of the TCM Group, its subsidiaries and affiliates when communicating with third parties.
16. Not communicate, show, or distribute any proprietary or confidential information which the Member acquires in the course of performing duties as a TCM Group Member, officer, director, committee member, or instructor which could have a detrimental impact upon the business or reputation of the TCM Group, its affiliates, alliances, or subsidiaries, or any other member of the TCM Group; nor shall any Member use any such information described herein to promote the Member’s self-interest or business interest.
17. Place any Member of the Group or the industry who they suspect or know to be violating the TCM Group Code of Compliance, Code of Operations or Rules on notice of the alleged violation and seek to identify a solution.

Members must keep in strict confidence any information supplied by debtors or their chosen third party, except where the debtor authorizes disclosure or others permitted or required by the law.

VII Complaints

Each member shall have in place adequate processes to deal with debtors or client complaints. These must contain the following minimum procedure:

• The management level at which complaints are handled.
• The time frame in which complaints are handled.
• The remedy, if the complainant is not satisfied.
• Complainants must be advised that one of the remedies is referral of the complaint to the Association where appropriate.

1. Members shall deal with complaints speedily, responsively, in a user-friendly fashion and at an appropriate management level.
2. Member’s complaints procedures must be made available to the complainant or his/her advisor on request.
3. If a complaint is made to the TCM Group in relation to dealings with a member, the Group will deal with the complaint in accordance with the TCM Group complaints procedure.

VIII Enforcement

Any Member may be admonished, suspended, or expelled for cause due to conduct, acts, or omissions contrary to the Rules. Such conduct, acts, or omissions can result in review of membership status by the TCM Group’s Complaints Committee. All final actions of TCM Group’s board of directors regarding the suspension or expulsion of a Member may become a matter of public record. At the request of the Member, a notice of exoneration may become a matter of public record.

Approved in Los Angeles 2012