National Interest

Homefirst is commited to benefit the economic development of the country. No Homefirst employees,agent shall undertake any project or activity to the detriment of the wider interests of the community. The company’s management practices and business conduct shall benefit the country, localities and communities in which it operates, to the extent possible and affordable, and shall be in accordance with the laws of the land.

Corporate Citizenship

Homefirst shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates.

Political Non-Alignment

Homefirst shall not support any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence/ favour with any political body or person, and it shall not offer or give any company funds or property as donations to any political party, candidate or campaign.

Regulatory Compliance

Employees,agent s of Homefirst, in their business conduct, shall comply with all applicable laws and regulations, in their letter and spirit. If the ethical and professional standards of applicable laws and regulations are below that of the Code, then the standards of the Code shall prevail.
The management of Homefirst shall comply with applicable laws and regulations of all the relevant regulatory and other the relevant regulatory and other authorities. As good governance practice they shall safeguard the confidentiality of all information received by them by virtue of their position.

Financial Reporting and Records

Homefirst shall prepare and maintain its accounts fairly and accurately and in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards laws and regulations of the country in which the company conducts its business affairs.Interal accounting and audit procedures shall reflect, fairly and accurately, all of the company’s business transactions and dispositions of assets, and shall have internal controls to provide assurances to the company’s board and shareholders that the transactions are accurate and legitimate. All required information shall be accessible to company auditors and other authorized parties and government agencies. There shall be no willful omissions of any company transactions from the books and records, no advance-income recognition and no hidden bank account and funds.

Any willful, material misrepresentation of and / or misinformation on the financial accounts and reports shall be regarded as a violation of the Code, apart from inviting appropriate civil or criminal action under the relevant laws. .

Equal Opportunities Employer

HomeFirst shall provide equal opportunities to all its employees,agent s and all qualified applicants for employment without regard to their race, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability.

Human resource policies shall promote diversity and equality in the workplace, as well as compliance with all local labor laws, while encouraging the adoption of international best practices.

Employees,agent s of HomeFirst shall be treated with dignity and in accordance with the HomeFirst policy of maintaining a work environment free of all forms of harassment, whether physical, verbal or psychological. Employees,agent policies and practices shall be administered in a manner consistent with applicable laws and other provisions of this Code, respect for the right to privacy and the right to be heard, and that in all matters equal opportunity is provided to those eligible and decisions are based on merit.

Health, Safety & Environment

HomeFirst shall strive to provide a safe, healthy and clean working environment for its people.

Ethical Conduct

Every employees,agent of the company, shall exhibit culturally appropriate deportment and deal on behalf of the company with professionalism, honesty and integrity, while conforming to high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be so by third parties.

Every employees,agent of a HomeFirst shall preserve the human rights of every individual and the community and shall strive to honor commitments.

Every employees,agent shall be responsible for the implementation of and compliance with the Code in his / her environment. Failure to adhere to the Code could attract severe consequences, including termination of employment.

Concurrent Employment

Consistent with applicable laws, an employees,agent of the company shall not, without the requisite, officially written approval of the company, accept employment or a position of responsibility (such as a consultant or a director) with any other company, nor provide freelance services to anyone, with or without remuneration.

Protecting Company Assets

The assets of HomeFirst shall not be misused; they shall be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorized. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers.

Integrity of Data Furnished

Every employees,agent of the company shall ensure, at all times, the integrity of data or information furnished by him / her to the company. He / she shall be entirely responsible in ensuring that the confidentiality of all data is retained and in no circumstance transferred to any outside person / party in the course of normal operations without express guidelines from or, the approval of the management.

Competition

HomeFirst or its employees,agent s shall market the company’s products and services on their own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.

Third Party Representation

Parties which have business dealings with HomeFirst, such as consultants, agents, sales representatives, distributors, channel partners, contractors and suppliers, shall not be authorized to represent HomeFirst without the written permission of the company.

Third parties and their employees,agent s are expected to abide by the Code in their interaction with, and on behalf of HomeFirst. The company is encouraged to sign a non-disclosure agreement with third parties to support confidentiality of information.

Conflict of Interest

An employees,agent of the company shall always act in the interest of the company, and ensure that any business or personal association which he / she may have does not involve a conflict of interest with the operations of the company and his / her role therein.

An employees,agent of the company shall not engage in any business, relationship or activity which might conflict with the interest of the company.

Notwithstanding such or any other instance of conflict of interest that exist due to historical reasons, adequate and full disclosure by interested employees,agent s shall be made to the company’s management. It is also incumbent upon every employees,agent to make a full disclosure of any interest which the employees,agent or the employees,agent ’s immediate family, including parents, spouse and children, may have in a family business or a company or firm that is a competitor, supplier, customer or distributor of or has other business dealings with his / her company.

Upon a decision being taken in the matter, the employees,agent concerned shall be required to take necessary action, as advised, to resolve / avoid the conflict.

If an employees,agent fails to make the required disclosure and the management of its own accord becomes aware of an instance of conflict of interest that ought to have been disclosed by the employees,agent , the management shall take a serious view of the matter and consider suitable disciplinary action against the employees,agent .

Reporting Concerns

Every employees,agent of the company shall promptly report to the management, when she / he becomes aware of any actual or possible violation of the Code or an event of misconduct, act of misdemeanor or act not in the company’s interest. Such reporting shall be made available to suppliers and partners, too.

Any HomeFirst employees,agent can choose to make a protected disclosure under the whistle blower policy of the company. Such a protected disclosure shall be forwarded, when there is reasonable evidence to conclude that a violation is possible or has taken place, with a covering letter, which shall bear the identity of the whistle blower.

The company shall ensure protection to the whistle blower and any attempts to intimidate him / her would be treated as a violation of the Code.

The employees,agent Code of Conduct outlines the appropriate code and duties that employees,agent s are expected to adhere to. Vector Finance Private Limited is a NBFC- MFI registered with Reserve Bank of India (RBI).

The Company follows various guidelines issued by Reserve Bank of India (RBI) and has also adopted Industry Code of Conduct developed by MFIN (Microfinance Institutions Network).

An employees,agent code of conduct is a set of guidelines that define how employees,agent s at a company should behave on a daily basis. It reflects the day-to-day duties, beliefs, and culture of a company. As a result, each set of accepted rules is unique to the organization to which it applies.

As our foundation, we prioritize integration and uphold integrity to ensure the safety and success of our team, company, and clients. This commitment to ethical behaviour is a core focus, emphasizing our distinctiveness in the competitive landscape.

Purpose & Scope

The expectations for employees,agent s' behavior toward their coworkers, supervisors, and the company as a whole are described in our company's Employees,agent Code of Conduct policy.

We promote open communication and freedom of expression. However, every employees,agent of the company is expected to adhere to our code of conduct.

They should avoid insulting others, becoming involved in heated arguments, and disrupting our workplace. We also want them to create a well-organized, respectful, and collaborative workplace environment.

Irrespective of employment agreement, rank, or location, all of our employees,agent s are subject to the application of this policy.

Furthermore, this policy is applicable to third parties such as agents, consultants, or others acting on the company's behalf.

This Code applies to the following activities:
1. Providing credit services to the clients in groups.
2. Recovery of credit provided to clients.
3. Providing insurance services or any other related products and services.
5. Formation of joint liability groups and their federations.
6. Business development services including marketing of products or services extended to the eligible clients or for any other purpose for the welfare and benefit of clients.

The Core Values of the Company are as follows:
Providing credit services to the clients in groups.
Recovery of credit provided to clients.
Providing insurance services or any other related products and services.
Formation of joint liability groups and their federations.
Business development services including marketing of products or services extended to the eligible clients or for any other purpose for the welfare and benefit of clients.
Simplicity: Our foundation is built on simplicity and straightforward way of working.
Teamwork: We nurture a culture of togetherness. The only way to succeed is to succeed collectively
Respect: We will respect our colleagues, our customers and all stakeholders.
Integrity: We will stay to our principles and choose right over wrong every time.
Discipline: We will not compromise on process or principles.
Excellence: We aim for quality, shun mediocrity and look for room for improvement.

Components of Code of Conduct Policy

In order to adhere to the core values of Microfinance, the Code of Conduct, as mentioned below, must be abided by all the employees,agent s while providing microfinance services.

INTEGRITY AND ETHICAL BEHAVIOUR

1. Appropriate policies and operating guidelines have been designed to treat clients and employees,agent s with dignity.
2. Transparent and professional governance system to ensure that staff and persons acting on their behalf are oriented and trained to put this Code into practice.
3. Educating clients on the Code of Conduct and its implementation.
4. Consumption of alcohol, gutkha, paan and any addictive consumables should neither be consumed inside office premise nor enter office or client place consuming these items.
5. Gambling of any kind is not restricted inside office premises.
6. POSH guildelines must be adhered to within and outside the office premises.

TRANSPARENCY

1. The terms and conditions are communicated to the client for all services offered prior to disbursement in the vernacular language in accordance with the Reserve Bank of India’s (RBI) fair practices code (FPC), in the following ways:

a) Individual sanction letter
b) Loan card
c) Loan schedule
d) Passbook
e) Through Group/Centre meetings

2. The following terms are also disclosed before disbursement takes place:
a) Rate of interest on a reducing balance method
b) Processing fee
c) Any other charges or fees howsoever described
d) Total charges recovered for insurance coverage and risks covered
3. Formal records of all transactions are maintained in accordance with all regulatory and statutory norms.

CLIENT PROTECTION

A. Fair Practices
1. We must ensure that the provision of micro finance services to eligible clients is as per RBI guidelines.
2. We must obtain copies of relevant documents from clients, as per standard KYC norms. Additional documents sought must be reasonable and necessary for completing the transaction.
3. The terms of insurance is transparently conveyed to the client and must comply with RBI & Insurance Regulatory and Development Authority (IRDA) norms. Consent of the client is taken in all cases.

B. Avoiding Over-indebtedness
1. We must conduct proper due diligence as per internal credit policy to assess the need and repayment capacity of client before making a loan and must only make loans commensurate with the client’s ability to repay.
2. We must not, under any circumstance, breach the total debt limit for any client, as prescribed by RBI or Central/State Government(s).

C. Non-coercive method of collection
1. We have clearly defined guidelines for employees,agent interactions with clients.
2. We must ensure that all Staff and persons acting on our behalf
a) Use courteous language, maintain decorum, and are respectful of cultural sensitivities during all interaction with clients.
b) DO NOT indulge in any behaviour that in any manner would suggest any kind of threat or violence.
c) DO NOT contact clients at odd hours, as per the RBI guidelines for loan recovery agents.

3. We must provide a valid receipt (in whatever form decided by the Company) for each and every payment received from the borrower.
4. We must have a detailed Board approved process for dealing with clients, at each stage of default.
5. We must not collect shortfalls in collections from employees,agent s and the HR policies must categorically denounce this practice. An exception can however be made in proven cases of frauds by employees,agent s.

D. Privacy of client information
We must keep personal client information strictly confidential. Client information may be disclosed to a third party subject to the following conditions:
a) Client has been informed about such disclosure and permission has been obtained in writing.
b) The party in question has been authorized by the client to obtain client information from the Company.
c) It is legally required to do so.
d) This practice is customary amongst financial institutions and available for a close group on reciprocal basis (such as a credit bureau)

CLIENT EDUCATION

1. We have a dedicated process to raise clients’ awareness of the options, choices and responsibilities vis-à-vis financial products and services available.
2. New clients are informed about the organization’s policies and procedures to help them understand their rights as borrowers.
3. We ensure regular checks on client awareness and understanding of the key terms and conditions of the products/ services offered / availed. (As part of internal audit systems or through some other regular monitoring)

DATA SHARING

We agree to share complete client data with all RBI approved Credit Bureau, as per the frequency of data submission prescribed by the Credit Bureaus.

FEEDBACK/ GRIEVANCE REDRESSAL MECHANISM

1. Dedicated feedback and grievance redressal mechanisms to correct any error and handle/receive complaints speedily and efficiently has been developed.
2. We inform clients about the existence and purpose of these mechanisms and how to access them.
3. Designated grievance redressal official has been appointed to handle complaints and/ or note any suggestions from the clients and make his/ her contact numbers easily accessible to clients.
4. Where complainants are not satisfied with the outcome of the investigation conducted by us into their complaint, they shall be notified of their right to refer the matter to the grievance redressal mechanism established by the Industry Associations.

RECRUITMENT

1. As a matter of free and fair recruitment practice, there will be no restriction on hiring of staff from other MFIs by legitimate means in the public domain like general recruitment advertisements in local newspapers, web advertisements, walk-in interviews, etc. Provision of recruiting freshers have also been made to provide fair opportunity to all the aspirants.
2. Whenever we recruit from another MFI, it is mandatory to seek a reference check from the previous employer. The reference check will be sought from current employer only after an offer is made and an offer letter is issued to the prospective employees,agent .
3. We shall respond to the reference check request from another MFI within two weeks.
4. We shall respect the notice period policy for an outgoing employees,agent as well as for new entrants.
5. We ask for relieving letter from the previous MFI employer while recruiting an employees,agent of another MFI, irrespective of the grade/level of the employees,agent . We provide such relieving letter to the outgoing employees,agent in case he/she has given proper notice, handed over the charge and settled all dues, except in proven cases of fraud or gross misconduct by the employees,agent .

LEARNING AND DEVELOPMENT

To comply with the standard operating principles the employees,agent s are imparted training on a regular basis in order to enhance their learning and continuous development.

COMPLIANCE WITH LAW

All laws, whether municipal, national, or regional, are followed. The legitimacy of the organization must be protected by all the employees,agent s of the company and those working on our behalf. All environmental, fair dealing and safety rules must be followed. Every individual involved with us is expected to be accountable and ethical when it comes to our company's finances, goods, collaborations, and public image.

CORDIAL ATMOSPHERE IN THE WORKPLACE

Employees,agent s should treat one another with respect. Any form of discrimination, victimization, or harassment will not be tolerated by the company.
Employees,agent s are expected to follow the company's equal opportunity policy in all areas of their work, including interpersonal contacts, recruitment, and performance evaluation.

PROTECTION OF COMPANY ASSET

Our Company's assets, be it physical or digital, should be treated with care by all employees,agent s. Employees,agent s should not abuse or misuse the company's equipment, property or asset of any kind and they should treat all corporate assets with respect, with utmost care and cost effectively.
This comprises intellectual property, trademarks, copyrights, and/ or any other physical or non-physical assets.
Employees,agent s are expected to use them only for fulfilling their job responsibilities. Furthermore, using company's assets for personal benefit or any illegal reason is strictly prohibited.

1. Personal Appearance
All employees,agent s are expected to follow our company's dress code and look professional in the workplace.

2. Corruption
Employees,agent s should not accept gifts from clients or third parties. Our organization discourages bribery for the advantage of any external or internal party.

3. Job Duties and Authority
All employees,agent s are expected to perform their duties with honesty and respect towards their coworkers, stakeholders, clients, and community. Managers and supervisors are not encouraged to misuse their power. The responsibilities should be distributed to their team members based on their skills and workload. Similarly, we expect team members to follow their team leaders' directions and execute their tasks competently and as per schedule.

4. Absenteeism and Tardiness
Employees,agent s are expected to follow their work schedules. We can consider exceptions for emergencies/occasions that prevent the employees,agent s from working during their standard working hours or days. Employees,agent s are expected to always keep their supervisors informed about their delayed reporting or absenteeism.

5. Collaboration
We encourage our employees,agent s to be friendly and collaborative. They should not try to hinder the workplace culture or present obstacles to the work of their colleagues.

6. Communication
All employees,agent s should be open to communication with their colleagues, team members, and their supervisors. Simultaneously, they should uphold the confidentiality of information as required.

7. Benefits
Employees,agent s are not expected to take advantage of their benefits. The benefits include facilities, insurance, paid leaves, subscriptions, and other perks given by the company.

8. Policies
The company policies should be carefully read and adhered to by all the employees,agent s of the company. Employees,agent s should approach the HR managers or the supervisors for any type of query they have.

LIMITED USE OF SOCIAL MEDIA

Employees,agent s are encouraged to adhere to all the applicable laws and government social media standards. This Code of Conduct policy must be adhered to when using any social media. Confidential information pertaining to the Company, whether concerning employees,agent s, customers, or third-party vendors, must be safeguarded by employees,agent s.
Unless specifically requested by the company, employees,agent s are not anticipated to engage in or disclose any political or social endorsements on behalf of the Company.

CONFLICT OF INTEREST

Employees,agent s are expected to put their personal, financial, and other interests aside that may distract or stop them from performing their duties the right way. Employees,agent s with any form of relationship should not be placed within the same team or reporting structure.

FINANCIAL INTEGRITY AND AUTHORITY

It is crucial to maintain accurate and dependable financial and company records. Employees,agent s should refrain from actions that might result in the Company or its clients receiving inaccurate financial information. Any submissions made on behalf of the company to the Company or clients must be thorough and precise. Any action that harms the company's financial interests will be dealt with severely.

OUR DELIVERABLES

In all company opportunities, employees,agent s are required to act with fairness and ethics. Our service to clients is guided by their best interests, regardless of our role.
All interactions, communications, and statements to customers must be precise, thorough, and truthful.
Additionally, making unlawful promises on behalf of the Company or our customers is strictly prohibited.
Employees,agent s must refrain from involving or entangling the Company improperly in conflicts with clients or others.

CONFIDENTIAL INFORMATION

For any company, certain information is highly confidential, and also a valuable asset. Therefore, every director, agent, employees,agent , or individual related to the company must protect it. Confidential information refers to any information that cannot be shared in front of the public, and personal information obtained from any source during the entire course of business.
The only solution is to maintain the confidentiality of such information. Any violation shall attract disciplinary action against the concerned offender.

DISCIPLINARY ACTIONS

The organization may take serious disciplinary actions against employees,agent s who intentionally or repeatedly fail to abide by the code of conduct policy. The disciplinary actions may vary depending on the seriousness of the violation.

Disciplinary actions may include the following:
- Demotion
- Reprimand
- Suspension or termination depending on the seriousness of the issue

The following rules and Regulation shall apply to all employees,agent s of the Company while in the Company’s premise at all times including break times and overtime:
1) Each employees,agent must act in accordance with the company’s policies, orders, rules, regulations, guidelines etc applicable from time to time.

2) The Company expects each employees,agent to maintain proper decorum Employees,agent are expected to conduct themselves on the job in a manner that contributes to operating effectiveness, productivity, safety and a harmonious work environment.
3) The duty must be performed in good faith and a brief reporting of the work done in entire day must be given to the head office.
4) Proper registers must be maintained for easy tracking and record keeping.
5) No employees,agent shall be under the influence of or using alcoholic beverages including drinking such beverages during the work hours. Any employees,agent arriving to work under the influence of alcohol or an illegal substance will not be permitted to work.
6) No employees,agent shall drive a company’s vehicle or operate any equipment while under the influence of a alcohol.
7) You are required to be at your appointed work place and ready to begin work at the appointed starting time. Irregular attendance or tardiness will not be tolerated and may result in termination.
8) Employees,agent who will be late or absent from work must inform their Supervisor at least one (1) hours prior to normal starting time.
9) Under no circumstances should employees,agent s leave the assigned work area early without express permission from a Supervisor.
10) Designated break times are assigned to have meals.
11) Employees,agent s who work late or on overtime must ensure that all lights, air-conditions and Equipments are shut off when they leave the work place.
12) Dress code is to be followed strictly. Employees,agent must wear their uniforms at locations where uniforms are required. You are expected to look neat and presentable while on the job.
13) An increment based on individual performances shall be given every year.
14) If employees,agent do not meet the company’s expectations of performances or conduct, necessary corrective action may be taken. It is within management’s discretion to determine what measure would be appropriate under each circumstance.
15) Every employees,agent of the SHK Microfinance private limited must have to follow and obey the act, guidance, policy, rules, and regulations, imposed by the company authority and applicable from time to time.
16) The company expects formal and acceptable behavior from the employees,agent s of the SHK Microfinance private limited .The prime motive of the SHK Microfinance private limited is to attract customers through outstanding conduct of the employees,agent .
17) Employees,agent s are liable to protect the company’s belongings what they are using for office purpose. They will be responsible for breaking any type of official equipment such as computer, printer, scanner, camera, and so on.
18) Further our company the SHK Microfinance private limited very aware of maintaining the record, therefore, every employees,agent has to be conscious to protect documents. The office will not accept any argument without proper evidence.
19) Further more the employees,agent will be permitted to work who are under the influence of alcoholic beverage during work time. Also, no employees,agent shall drive the company’s vehicles or operate any official equipment under the influence of an alcoholic.
20) SHK Microfinance private limited is very alert to follow the employees,agent ’s ethical principles. The company will be fired on those employees,agent s who are indulged with corruption and bribery without notifying them.
21) Employees,agent must have to inform the supervisor or manager at least one hour prior to starting work if they could be absent or late on the day.