Code of Conduct

1. Purpose and Scope

This Code of Conduct sets out the standards of behaviour expected from all employees, consultants, agents, legal associates, and other representatives (“Team Members”) of SettleXpert (A unit of Akaria Innovations Pvt. Ltd.) (“the Company”).

Objectives

• Protect the interests of our clients (borrowers) and counterparties (lenders) in a balanced, win-win approach.
• Ensure all advisory, mediation, and documentation services are delivered in a lawful, ethical, and transparent manner.

This Code applies to all Team Members at all times, whether dealing with clients, lenders, financial institutions, vendors, or any other stakeholders, and in all forms of communication (in-person, telephone, email, messaging applications, social media, or written correspondence).

2. Our Role and Guiding Principles

2.1 Advisory Role Only

The Company provides advisory and negotiation support to borrowers facing genuine financial distress. We do not guarantee any particular outcome, waiver, discount, or settlement sanction, as all final settlement approvals rest solely with the lender bank or financial institution.

2.2 Lawful and Ethical Conduct

All actions must be consistent with applicable laws, judicial precedents, and regulations in India. No Team Member may engage in or encourage any unlawful or unethical conduct, even if requested or pressured by a client.

2.3 Respect for Contracts and Rights of Lenders

We recognise that lenders have valid contractual rights to recover lawful amounts due. Our role is to facilitate voluntary negotiated settlements, not to obstruct or interfere with the lawful rights of creditors.

2.4 Integrity and Honesty

Information provided to clients and lenders must be truthful, verified, and accurate. We strictly forbid making false promises, unrealistic guarantees, or misrepresenting financial or legal facts to any party.

3. Dealing with Clients (Borrowers)

3.1 No Encouragement of Wilful Default

Team Members must not advise or encourage clients to:

• Deliberately stop making payments when they have the financial capacity to pay.
• Falsely portray themselves as unable to pay when they are financially capable.

Any advice given must be grounded strictly in the genuine, documented financial hardship of the client.

3.2 No Assistance in Fraudulent Conduct

Team Members must never advise, assist, or participate in:

• Hiding, dissipating, or transferring assets to defeat or delay lawful recovery by lenders.
• Fabricating documents, income proofs, or financial statements.
• Providing false or misleading information to lenders, courts, or any other stakeholders.

3.3 Fair and Transparent Advice

Team Members must clearly explain to clients:

• That settlement is subject entirely to the lender’s internal policy and board-approved discretion.
• That lenders may or may not accept the proposed compromise terms.
• The possible impacts on credit score (such as "Settled" status reporting in CIBIL), future borrowing ability, and potential legal consequences of default.
• Do not guarantee specific percentage reductions, fixed discounts, or assured success.

3.4 No Legal Practice by Unauthorised Persons

• Only qualified advocates enrolled with a State Bar Council may provide formal legal opinions or represent clients before courts and tribunals.
• Non-lawyer Team Members must not hold themselves out as “lawyers” or “legal experts”, nor offer unauthorized legal practice.

3.5 Informed Consent & Documentation

• Obtain written consent and formal client authorization before initiating representations or discussions with lenders.
• Ensure clients understand all documents they sign, including authorization letters, representation drafts, and settlement agreements.

4. Dealing with Lenders and Their Representatives

4.1 Professional and Courteous Communication

• Treat all lenders, bank officers, authorized recovery agents, and legal representatives with courtesy, professionalism, and mutual respect.
• Avoid aggressive, hostile, or threatening language in all interactions.

4.2 Honest and Accurate Representations

• Do not provide false, exaggerated, or misleading information about a client’s income, medical condition, or repayment capability.
• Do not misquote or exaggerate regulatory provisions to improperly pressure lenders.

4.3 Respect for Negotiation Outcome

• Any settlement reached is a voluntary commercial decision of the lender.
• Team Members must not portray the outcome as forced, statutory, or guaranteed by regulations.

4.4 No Undisclosed Arrangements or Bribery

• Team Members must not accept any payment, commission, secret gift, or benefit from lenders in relation to a client’s matter.
• Team Members must not accept cash payments, commissions, or personal favors from clients for private enrichment. All professional fees must be paid directly to authorized Company accounts.

5. Communications, Marketing and Public Statements

5.1 No Misrepresentation of Regulatory Status

Team Members and company publications must not:

• Claim to be “RBI approved”, “RBI authorised”, “bank-authorised”, or “government approved”.
• Use official names, logos, or emblems of regulatory authorities or banks in a manner suggesting endorsement or affiliation.

5.2 Truthful Advertising and Website Content

All marketing material, including website content, educational blogs, and social media posts, must:

• Honestly describe the nature and limitations of our advisory services.
• Strictly avoid terms such as “Guaranteed settlement”, “assured waiver”, or “100% debt cancellation”.
• Avoid misleading statistics that cannot be substantiated with verified empirical data.

5.3 No Defamation

• Team Members must not publish, post, or circulate false or unverified allegations against any bank, NBFC, or its staff members.
• Constructive criticism or consumer awareness commentary must remain strictly factual, balanced, dignified, and non-defamatory.

5.4 Responsible Use of Social Media

• Personal social media accounts must never disclose client information, confidential settlement letters, or derogatory remarks about financial institutions.
• Team Members must not present personal views as the official position of the Company unless expressly authorized in writing.

6. Confidentiality and Data Protection

6.1 Client Confidentiality

All financial, personal, and transactional information belonging to clients is strictly confidential. Such information must be used solely for the purpose of providing contracted services and must never be shared with unauthorized third parties.

6.2 Lender Information

Internal information received from lenders (such as specific compromise approval memos or internal bank policies shared in confidence) must not be misused, disclosed publicly, or exploited.

6.3 Compliance with Data Protection Laws

Team Members must strictly adhere to Company data security protocols, secure document retention frameworks, and proper disposal mechanisms for both physical and electronic files.

7. Compliance, Training and Reporting

7.1 Mandatory Compliance

Adherence to this Code of Conduct is an absolute condition of employment or contractual engagement with SettleXpert. Breach of this Code may result in immediate disciplinary action, up to and including termination of employment or engagement and, where appropriate, reporting to competent regulatory or law enforcement authorities.

7.2 Ongoing Training

The Company conducts periodic compliance training covering:

• Applicable banking laws, fair recovery codes, and relevant Indian regulations.
• Ethical negotiation practices and customer data protection standards.

All Team Members are expected to participate actively and maintain up-to-date compliance knowledge.

7.3 Reporting Concerns or Violations (Whistleblower Protection)

Any Team Member or stakeholder who becomes aware of a potential or actual violation of this Code, Indian law, or Company policy must promptly report it through our internal compliance channels:

• Email: info@settlexpert.com

The Company strictly prohibits retaliation and will protect bona fide whistleblowers from any adverse professional consequences.

8. Interpretation and Updates

The Company reserves the right to amend or update this Code from time to time in alignment with evolving legal frameworks, regulations, and best industry practices. In case of any doubt regarding the interpretation of this Code, Team Members must seek written guidance from their reporting manager or the designated Compliance Officer before acting.

9. Employee & Representative Acknowledgement

All Team Members are required to read, understand, and comply with this Code of Conduct. By continuing in employment or engagement with SettleXpert, each Team Member acknowledges and agrees:

• That they have carefully read and understood this Code in its entirety.
• That they agree unconditionally to abide by all its principles and standards.
• That they understand non-compliance or breach will attract strict disciplinary, contractual, and legal consequences.

10. Contact Information

For any queries, compliance reviews, or reporting under this Code of Conduct, please contact:

Compliance Officer: SettleXpert (Akaria Innovations Pvt. Ltd.)

Email: info@settlexpert.com

Phone: +91 81305 99469

Address: HNO.202A,OFF NO.77,RN-77A, KH NO.922 993 2056/994 GF, Naraina Village, South West Delhi, New Delhi, Delhi, India, 110028