Emergency Paisa
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Code of Conduct

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01

Introduction

Suburban Finance & Investment Private Limited (“Emergency Paisa” or “the Company”) is a NBFC registered with the Reserve Bank of India (“RBI”) is presently engaged in the business of providing personal loan to the customers throughout India. Pursuant to Reserve Bank of India (RBI) Master Directions Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025 dated 28th Day of November 2026 or any other Directions, Circulars, Notifications or other law for the time being in force, the Board of Directors of the company have adopted a Code of Conduct cum recovery policy.

02

Applicability

This policy shall be unanimously applicable to all employees, recovery agents, outsourced agencies, and authorized representatives irrespective of their gender, designation, profile etc. In no event, any of the employees, recovery agents, outsourced agencies, and authorized representatives shall be given relaxation to comply with

03

Objectives

  • Ensure ethical recovery
  • Follow due process of recovery
  • Prevent harassment
  • Protect borrower dignity
  • Avoid using foul words/language
  • Ensure compliance
04

Code of Conduct

4.1 General Principles

All the employees, recovery agents, outsourced agencies, and authorized representatives shall maintain at all times Integrity, fairness, transparency while dealing with customers/borrowers. The Company is committed to ensuring that all written and verbal communication with its customers/borrower will be in simple language and it will adopt civil manners in its interaction with the customers/borrower.

4.2 Prohibited Practices

No employees, recovery agents, outsourced agencies, and authorized representatives shall take recourse to or adopt including but not limited to coercion, harassment, threats, or public humiliation for recovery of loan amount or any other charges. Decency and Decorum would be maintained during visits to the customer/borrower’s place for collection of dues

4.3 Communication

All employees, recovery agents, outsourced agencies, and authorized representatives that they will communicate with the customer/borrowers in the gentle manner Only between 9 AM to 7 PM.

4.4 Identification

All employees, recovery agents, outsourced agencies, and authorized representatives must carry Company issued ID Card and/or authorization and whenever is required, produce the same while doing field verification, inspection, visit etc., outside the business premises.

4.5 Privacy

The Company hereby undertakes it shall maintain confidentiality of borrower data and shall deploy appropriate measures to make sure that confidential data are remain protected at all time. The Company shall not disclose any confidential data of borrowers to third parties except when it is required under law for the time being in force.

05

Recovery Process

  • Pre-Recovery: Reminders via SMS/Email
  • Soft Recovery: Negotiation and follow-ups
  • Field Recovery: Professional conduct
  • Legal Action: As per law
06

Recovery Agents

All the recovery agents employed by the Company either directly or indirectly, on board or third parties’ agents, must adhere to this Code of Conduct and maintain decency and decorum during authorised visits to the customer/borrower’s place for collection of dues. Always carry valid ID card issued by the Company and produce the ID whenever asked for the same customers/borrowers or any other having legal authority to ask for same. Avoid unnecessary threatening for legal/criminal action as well as Use of abusive, aggressive, or defamatory language.

The Company will not initiate any legal or other measures including forfeiting of the security, if any without giving 7 days’ notice, requiring the customer/borrower to discharge his/her liability in full.

The Company make sure that it is providing necessary trainings to its staff as required by the RBI or other legal Authority for recovery mechanism as well as regulatory & compliance part whenever required.

07

Grievance Redressal

First Escalation Customer Care

Phone: +91 9821388824,
Email: info@emergencypaisa.com

If the issue is not resolved within 15 working days of raising the issue, the customer shall raise the issue with the Grievance Officer

Second Escalation Grievance Officer

Name: Sunny Sharma
Phone: +91 7678378898
Email:nodal.officer@emergencypaisa.com

If the issue is not resolved within 10 working days of raising the issue, the customer shall raise the such issue with the Nodal Officer.

Final escalation Nodal Officer

Name: Pankaj Dhall
Phone: +91 7675378901
Email:nodal.officer@emergencypaisa.com

Final escalation level for unresolved grievances.
If the Complaints of borrowers shall be resolved within 30 working days, the borrower may escalate the matter to the Reserve Bank of India – Complaint Management System (CMS).

08

Penal Charges

The Company may charge for overdue/delay payments charges at rate as specified by the management. However, such overdue/ delay payments charge can not exceed at the rate of 2% per day. The details of Penal Interest or other charges, if any, will be mentioned in the sanctioned letter, KFS & loan agreement so that customers/borrowers can take informed decisions.

09

Board Responsibility

The Board shall approve and management take steps to implement this policy at all levels in the organization. The Board shall review this code of conduct annually or as when required due to regulatory changes to make sure, it remains updated with RBI or other law which are in force. The Company shall publish this Code on its official website for public access as required under RBI guidelines.

10

Review

This Code would be reviewed annually or whenever required, considering the various amendments to guidelines and regulations (if any), Business models and placed with the Board for approval. However, if there are any substantial changes in the guidelines by regulators, before the annual cycle, the Company will take necessary steps and review the Code.