Code of Conduct For Connector

Title

This Code shall be called the 'Code of Conduct for Direct Selling Agents (DSAS)' or "Code".

Objective

Home First Finance Company India Limited (the "Company") is committed to deal with all stakeholders with full transparency and fairness, ensuring adherence to all laws and regulations and achieving highest standards of corporate governance. In compliance with the Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated February 17, 2021, the Company has formulated this Code as detailed under:

1. Product Categories - The Model Code of Conduct for Direct Selling Agents (DSAs) will apply to all the agents of HFFC involved in marketing and/or distributing the following financial products:

• Home Loans and other Mortgage Loans

2. Applicable to - The model code of conduct will apply to the following entities:

• All sales channels – HFFC Sales, other third-party DSAs and their employees.
• HFFC Call Centers

3. Code of Conduct
The code of conduct lays down the rules and regulations with respect to the following important aspects of the selling & distribution process.

3.1 Tele calling process for prospect identification:

A prospective customer may be contacted for prospect identification or sales only under the following circumstances:

1. When a prospective customer expresses the desire to acquire a housing loan / financial product through the website / telecall center / email service / SMS service / office / promotional event or exhibition of the sales and promotion agents / subagents of HFFC for a HFFC product.
2. Has been referred by another customer / prospective customer or is an existing customer of HFFC who has given consent for accepting calls on other products of HFFC.
3. Has been referred by his/her employer under an arrangement with HFFC.
4. Has been referred by a developer or a housing society with whom the customer has booked a property.
5. When the prospective customer's name/telephone no./address is available and obtained after taking his /her consent.
6. DSA and its employees/ representatives should not call a person whose name/ number is flagged in any "Do Not Disturb" list.

4) When you may contact a prospect on telephone:

1. DSAs must introduce themselves and before calling must share their contact details through message or any other written mode including his/ her name, contact number, DSA they are employed with and the HomeFirst they are representing.
2. Telephonic contact must normally be between 09:30 hours and 19:00 hours. However, it may be ensured that a prospect is contacted only when the call is not expected to inconvenience him / her.
3. Calls earlier or later than the prescribed time period may be placed only when the prospect has expressly authorized the DSA and its employees / representatives to do so either in writing or orally.
4. Residence / Business /office Address visit must normally be limited between 09:30 hours and 19:00 hours. Visit earlier or later than the prescribed time period may be made only when prospect has expressly authorized DSA or/and its employees / representatives to do so either in writing or orally.

5) Respect prospect's privacy

DSA and its employees / representatives should respect a prospect's privacy and his/her interest may normally be discussed only with the prospect and with any other individual/family member such as prospect's accountant/secretary/ spouse only when authorized to do so by the prospect.

6) Leaving messages and contacting persons other than the prospect

Calls must first be placed to the prospect. If the prospect is not available, a message may be left for him / her. The aim of the message should be to get the prospect to return the call or to check for a convenient time to call again. Ordinarily, such messages may be restricted to

"Please leave a message that XXXXXX (name of officer) representing HOME FIRST called and requested to call back at ZZZZZZ (phone number)". As a general rule, the message must indicate that the purpose of the call is regarding selling or distributing a product of HOME FIRST.

7) No misleading statements / misrepresentations permitted

DSA and its employees / representative should not:

1. Mislead the prospect on any product / service offered by HOME FIRST;
2. Mislead the prospect about their business or organization's name or falsely represent themselves as HOME FIRST's employee;
3. Make any false / unauthorized commitment on behalf of HOME FIRST for any facility / loan / service.

8) Telemarketing Etiquettes

8.1. Pre Call

1. No calls prior to 09:30 hours or post 19:00 hours unless specifically requested;
2. No serial calling;
3. No calling on lists unless list is cleared by the DSA leader.

8.2 During Call

1. Identify yourself, your company and your principal;
2. Request permission to proceed;
3. If denied permission, apologize and politely disconnect;
4. State reason for your call;
5. Always offer to call back on landline, if call is made to a cell number;
6. Never interrupt or argue;
7. To the extent possible, talk in the language which is most comfortable to the prospect/ customer;
8. Keep the conversation limited to business matters;
9. Check for understanding of "Most Important Terms and Conditions" by the prospect/ customer if he plans to buy the product;
10. Reconfirm next call or next visit details;
11. Provide your telephone no, your supervisor's name or the HomeFirst officer contact details if asked for by the prospect/ customer;
12. Thank the prospect/customer for his/ her time.

8.3 Post Call

1. Prospects/ Customers who have expressed their lack of interest for the offering should not be called for the next 3 months with the same offer;
2. Provide feedback to the HomeFirst on prospects/ customers who have expressed their desire to be flagged "Do Not Disturb";
3. Never call or entertain calls from customers regarding products already sold;
4. Advise them to contact the Customer Service Staff of HomeFirst.

9. Gifts or Bribes

DSA and its employees / representative will

1. not accept gifts or bribes of any kind from prospects / customers. Further, if he / she is offered a bribe or payment of any kind by the prospect / customer, it must be reported to his/her management.
2. not offer any gifts / gratitude in cash or in kind to the prospect / customer to solicit business.

10. Precautions to be taken on visits/ contacts

DSA or/and its employees/ representatives should:

1. respect personal space, maintain adequate distance from the prospect/ customer;
2. ensure that prospect/ customer is not visited within a period of 3 months of expression of lack of interest for the offering by him/ her.
3. not enter the prospect's/ customer's residence/ office against his/ her wishes;
4. prospect's/ customer's residence/ business is visited by not more than one employee/ representative of DSA and one supervisor, if required;
5. respect the prospect's privacy;
6. end the visit with a request for the prospect to call back, if the prospect/ customer is not present and only family members/ office persons are present at the time of the visit;
7. provide his/ her telephone number, name of the supervisor or the concerned HomeFirst officer's contact details, if asked for, by the prospect/ customer; and
8. limit discussions to prospects of the business and maintain a professional distance.

11. Appearance and Dress Code

DSA or / and its employees/ representatives must be in proper formal attire while meeting up with prospect/ customer.

12. Handling of letters and other communication

Any communication sent to the prospect shall only be in the mode and format approved by the HomeFirst.

13. HomeFirst DSA Clauses:

1. Every new DSA will undergo a 2-day preliminary training and a day training every year.
2. Any employee/ representative of DSA found to be violating this Code may be blacklisted and such action taken be reported to the Home First from time to time by the DSA
3. If the DSA is contacting the customers directly then the DSA should be registered in terms of the guidelines issued by TRAI.
4. If the DSA is contacting the customers directly then DSA or its employees/ representatives should not call a person whose name/ number is flagged in any "Do Not Disturb" list.
5. DSA should be continuously monitored and assessed so that any necessary corrective measure can be taken immediately.
6. Yearly audit/inspection of DSA to be conducted
7. Quarterly DSA training to be conducted
8. List of DSA and all related details to be maintained
9. Annual review of DSAs financial and operational conditions to be conducted to assess their ability to continue to meet their outsourcing obligations.
10. In case of Termination, same should be publicized
11. Grievance Redressal Policy effective as updated on Home First's Official website and will be applicable.

Review

The Board may review and/or amend the Code at any time subject to the provisions of the applicable law and rules framed thereunder.