Code Of Conduct - HomeFirst Finance Company (HomeFirst)

Code of Conduct For Connector


Model Code of Conduct for Connectors of HomeFirst Finance Company India Ltd.


1. Product Categories The Model Code of Conduct for Connector will apply to all the agents of HomeFirst involved in marketing and/or distributing the following financial products:

  1. Home Loans and other Mortgage Loans

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

  1. All sales channels – HomeFirst Sales, other third-party Connectors and their employees.
  2. HomeFirst 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.

  1. Tele calling process for prospect identification:
    1. A prospective customer may be contacted for prospect identification or sales only under the following circumstances:
      • 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 HomeFirst for a HomeFirst product.
      • Has been referred by another customer / prospective customer or is an existing customer
        of HomeFirst who has given consent for accepting calls on other products of HomeFirst.
      • Has been referred by his/her employer under an arrangement with HomeFirst.
      • Has been referred by a developer or a housing society with whom the customer has booked a property.
      • When the prospective customer’s name/telephone no./address is available and obtained after taking his /her consent.
    2. The prospective customer should be contacted over the telephone on timings convenient to him/her. Ideally, calls should be made between 8:00 hours to 18:00 hours.
    3. If the prospective customer is unavailable during a particular telecall, a voice or text message describing the purpose of call and caller name and official identity should be sent.
    4. Standard telecalling etiquette should be practiced. The caller should identify himself, state the purpose of calling, educate the customer about important terms and conditions of the product and services and maintain courteous disposition towards the customer, whatsoever.
    5. Customers who have expressed their lack of interest in a HomeFirst product should not be called for the next 3 months with the same offer.
  2. Sales visit for loan counseling or active selling.
    • Sales visit to the office or residence of a prospective client should be made only
    • After seeking prior appointment and only after customer prior consent.
    • The Connector or its employees should be formally dressed for any sales call.
    • Visit the prospective customer should not be in large numbers. Preferably not more than two executives should visit the customer.
    • The agent should educate the customer in detail about the products and services he/she is willing to buy.
    • The customer should be provided with HomeFirst’s printed product brochure and application form.
  3. Sales Ethics & Integrity
    1. Misrepresentations are prohibited. The Connector and its employees/representatives should uphold the highest levels of sales ethics and should not:
      • Mislead the prospective customer on any service/product offered by HomeFirst.
      • Mislead the prospect about their business or organization’s name, or falsely represent themselves.
      • Make any false/unauthorized commitment on behalf of HomeFirst for any facility/housing loan / other product or service.
      • Employees/representatives of Connector must maintain the highest levels of integrity and should not accept gifts in kind or cash from prospective customers. Any employee/representative of the Connector, who is offered a bribe or payment of any kind by a customer, must report the offer to his /her management.
      • The prospective customer should not be denied any information regarding office telephone
        numbers or email addresses of any concerned employee of HomeFirst.
  4. Privacy of Transaction and Customer:
    1. Connectors should respect the prospective customer’s privacy and his /her interest may normally be discussed only with him /her and with any other individual/family member such as prospect’s accountant /secretary

4. Events of Violation of Code of Conduct

  1. The following will construe as event/s of violation of the Corporation’s Code of Conduct for its Connectors if within 30 calendar days of the violation.
    1. The company receives a written complaint from an aggrieved person with or without sufficient proof of violation of the code of conduct.
    2. Reporting of violation of code of conduct during any internal or regulatory audit of the company’s marketing and sales process.

5. Punitive Action on violation of the code of conduct

    1. In event of a violation of the HomeFirst’s code of conduct for Connectors, the company will seek written explanation from the concerned entity and may on its sole assessment based on the seriousness and the extent of the violation, take any of the following action:
      1. Seek detailed explanation on the customer complaint and/or any of the following,
      2. Issue written warning against allowing violation of code of conduct and seek details of the control process to be adopted by the entity to avoid re-occurrence of the act of violation and/or any of the following,
      3. Blacklist or seek blacklisting of erring employees of the concerned entity and/or any of the following,
      4. Permanent termination of the agency with an advertisement in the paper informing the public that the said Connector has seized to be a representative of the organization. and/or the following,
      5. Seek from the violating Connector, reimbursement of any expenses incurred by the organization and / or payment of penalties levied by any competent authority on the organization due to violation of model code of conduct for Connectors.

Additionally, the connectors are expected to comply with the principles and standards of the Code to the best of their ability as below:

6. Legal Compliance

This Code must be read in conjunction with applicable law, regulation and relevant contractual arrangements. Connectors must comply with all applicable laws, regulations, and industry standards where each such Connector is located and conducts business. Connectors have a duty to protect and safeguard confidential and personal information (in accordance with applicable privacy, data protection and data export/import laws, regulations, and industry standards) and to take precautions before sharing with anyone.

7. Environment

The supplier shall strive to be environmentally responsible in accordance with the prevailing market standard in its operations and providing its services to Home First

8. Labour, Workplace And Human Rights

Home First is committed to providing a fair and ethical workplace that recognizes diversity, equity and inclusion. Home First expects its Connectors to act similarly, in accordance with the below principles:

  1. All employment must be freely chosen at Connectors place of work. Home First will not tolerate the use of involuntary, trafficked or forced labor.
  2. No child Labour: All employees must be of a specified age respecting all local laws at all times at Connectors place of work. Connectors must comply with age employment standards. Child labour must not be used.
  3. Compliance with wage laws including working hours and salaries: Home First requires the Connectors to provide a living wage to its employees – a wage which enables employees to enjoy acceptable living conditions. 
  4. Humane treatment of the Employees: Connectors must provide and maintain a safe work environment and integrate reliable physical and mental health and safety policies for conducting its business. Connectors’ premises and facilities must comply with relevant legal and regulatory requirements. Any unfair disciplinary practices or corporal punishment by any of its Connectors will not be tolerated by the Company. In addition, Connectors must not retaliate against employees or staff who report abuse, discrimination, ethical concerns or violations of law, and should have a mechanism for employees or staff to safely report any such issues.
  5. Anti-discrimination at workplace: Connectors should strive to ensure that equal employment opportunity exists for all persons, without discrimination or harassment and in strict accordance with applicable laws and regulations.
  6. Health and Safety: Safe and Hygienic working conditions to be provided by the Connectors to its employees. Connectors must comply with all relevant health and safety laws and regulations, both in letter and in spirit, in all the regions in which they operate. Home First expects the Connectors to provide all their employees with adequate information and instruction on health and safety matters and to enable their employees to meet their responsibilities for the maintenance of a safe and healthy workplace.

9. Ethics and Anti-Corruption

  • Connectors must comply with the anti-bribery, anti-corruption and money laundering laws applicable in India as may be in force from time to time. Connectors or its representatives/employees shall not offer/receive or authorize any payment, gift, promise or other advantage, whether directly or through any other person or entity, to or for the use or benefit of any government official or any entity or other person where such payment, gift, promise or other advantage would violate the Applicable Laws.


10. Conflicts Of Interest

  • In an effort to prevent or manage potential conflicts of interest, Home First also expects its Connectors to recognize and avoid (on a continuous basis) situations that can create an actual or potential conflict of interest when working with or on behalf of Home First or customers of Home First. Connectors must disclose any actual conflict of interest, or any activity, interest, or relationship that could give rise to a conflict of interest, or the appearance of a conflict of interest. Home First may require that Connectors take steps to manage a potential conflict of interest.