Become a Member Knowledge Series
info@pslai.org membership@pslai.org
PSL > Code of Conduct

Code of Conduct

PSL Association Code of Conduct for Members

1. Introduction

The Priority Sector Lenders Association of India (“PSL Association”) stands at the forefront of India’s efforts to drive financial inclusion and socio-economic development across key sectors. In an economy where priority sectors such as agriculture, MSMEs, and healthcare remain underserved, the role of institutions that focus on inclusive lending has never been more critical. PSL Association unites financial institutions, technology service providers, business trade bodies, professional service providers, and experts to work in tandem with regulatory bodies with the shared mission of expanding access to credit, creating opportunities for sustainable growth, and ensuring that the vast potential of India’s priority sectors is realized. By representing the interests of stakeholders focused on these sectors, PSL Association plays a pivotal role in shaping policies and initiatives that foster a more inclusive financial ecosystem.

At the core of PSL Association’s purpose is the desire to enhance industry standards and advocate for regulatory reforms that support fair and responsible lending. The PSL Association helps its members navigate the complexities of the financial landscape through capacity-building initiatives, policy advocacy, knowledge sharing and fostering collaborations that encourage innovation in lending practices. PSL Association works towards leveraging and promoting digital public infrastructure (“DPI”), particularly Open Credit Enablement Network (“OCEN”), to create a more transparent, efficient, and secure lending environment for MSMEs and other priority sectors. OCEN helps priority sector lending by allowing banks and financial institutions to easily offer loans to farmers, small businesses, and weaker sections through DPI. It simplifies credit assessment and loan disbursement, ensuring faster access to credit for these targeted groups. PSL Association aims to strengthen the financial ecosystem by expanding market opportunities and driving innovation within the priority sector by utilizing DPI, ensuring equitable access to credit and fostering socio-economic development across underserved sectors. By doing so, the PSL Association seeks to expand the market size of priority sector lending industry to 5 times its current size.

Customer protection is central to the ethos of PSL Association and its member institutions. Recognizing that the long-term success of priority sector lending is contingent on borrower trust, PSL Association is committed to upholding the highest standards of transparency, fairness, and accountability in lending practices. By fostering a borrower-friendly ecosystem, where access to credit is equitable and responsible, PSL Association ensures that the interests of customers—particularly those from underserved sectors—are protected. The association’s focus on ethical practices helps safeguard against predatory lending, ensuring that financial products are accessible, suitable, and designed to uplift borrowers, thus enhancing their financial well-being.

The PSL Association Code of Conduct (“Code”) is a cornerstone of the association’s governance, providing a framework for ethical practices, responsible lending, and industry-wide collaboration. The Code is essential not only in setting the standards for member institutions but also in ensuring that the shared objectives of financial inclusion and sustainable growth are met. It serves as a self-regulatory mechanism, guiding members on compliance, risk management, and ethical responsibilities, while also offering a means to address any deviations from expected conduct. By committing to the Code,members reinforce their dedication to maintaining the integrity of the priority sector lending ecosystem, helping to foster trust among borrowers, regulators, and industry partners alike.

In addition, the Code promotes fair and transparent interaction between Members, encouraging them to act collaboratively and in good faith toward one another. Members are expected to treat each other with respect, ensuring open communication and a cooperative approach to solving industry challenges. The Code encourages the Members’ commitment to confidentiality and transparency which strengthens the relationships within the Association and helps maintain a unified and ethical approach to achieving collective goals. By upholding these principles, Members contribute to a strong, collaborative environment that advances the broader objectives of the PSL Association.

2. Applicability

2.1.

The Code is designed to establish a framework of ethical and responsible lending practices for all Members of the PSL Association, ensuring that priority sector lending aligns with both regulatory standards and customer protection principles.

2.2.

The Code does not replace the existing legal rights and protections under various laws and regulations but complements them by reinforcing ethical conduct within the industry. In case of any conflict between the Code and legal or regulatory frameworks, the latter will always prevail.

2.3.

It is important to note that the Code addresses specific responsibilities regarding fair lending, transparency, and customer engagement, and does not cover other legal and regulatory obligations, such as governance or corporate responsibilities, that Members may be subject to.

2.4.

The Code is applicable to all members of the PSL Association, including banks, non-banking financial companies, technology service providers, business trade bodies, professional service providers and other entities and persons involved in priority sector lending under the umbrella of the PSL Association (“Members”). For Members, adherence to the Code is mandatory and a precondition for membership.

2.5.

Members should ensure compliance with all aspects of the code as applicable to them. For example, provisions of the code relating to dealing with customers will not be applicable to Members who do not have any interactions with customers. Members are required to read the code and determine their obligations for compliance accordingly. Members are directed to raise any queries regarding applicability of any portion of the Code to the Membership Committee on [--].

2.6.

Compliance with this Code will be enforced by the PSL Association, which will monitor Members' conduct to ensure adherence. The Code applies to all interactions and transactions that Members have with customers, partners, and stakeholders related to priority sector lending.

2.7.

While the Code is obligatory for all Members, PSL Association encourages all stakeholders involved in the priority sector lending ecosystem, even those beyond its membership, to voluntarily adopt the Code. The principles of responsible lending, including fairness, transparency, and the protection of borrowers, should extend across the industry to ensure a robust and sustainable financial ecosystem that promotes financial inclusion for all.

2.8.

This Code is a living document, subject to periodic review and updates by the PSL Association’s Board, ensuring its relevance in the face of evolving market dynamics, regulatory changes, and technological advancements. Any revisions to the Code will be communicated to Members, along with appropriate timelines for compliance.

3.Application for Membership

3.1.

Any entity or individual that wishes to become a Member of PSL Association, has to provide the relevant details as intimated by PSL Association and must provide an undertaking agreeing to comply with this Code. They will also need to make payment of the membership fee as prescribed by PSL Association.

3.2.

Membership shall be granted for a period of one (1) year and shall be renewed by paying the membership fee as applicable at the time of renewal.

3.3.

Members who provide services to customers through mobile based applications, must ensure that their customer facing applications comply with all applicable laws and further comply with the requirements specified on platform they seek to utilize for distributing their customer facing application (such as Google Play Store, Apple App Store etc.).

3.4.

All entities applying for membership must ensure that they have not been penalized by a regulator for any matter pertaining to harassment or harm to customers.

4. Transparency and integrity

4.1. Ethical Practices and Integrity

4.1.1.

Members must uphold the highest ethical standards in all their dealings, ensuring fairness, honesty, and accountability in interactions with customers, stakeholders, and regulatory bodies.

4.1.2.

All communication with borrowers, potential clients, and third parties must be conducted transparently, avoiding any deceptive, misleading, or ambiguous statements. Clear and accurate representations of products and services should be a priority.

4.1.3.

Members are responsible for ensuring that their lending processes are fair, non-discriminatory, and in line with the principles of responsible finance. Borrowers should be treated equitably, irrespective of their financial status, background, or location.

4.1.4.

Conflicts of interest must be avoided at all times. In cases where conflicts may arise, full disclosure to relevant parties is required, and appropriate steps should be taken to manage and mitigate any potential impacts.

4.2. Compliance with Laws and Regulations

4.2.1.

Members must comply with all relevant laws, regulations, and guidelines issued by the Reserve Bank of India (“RBI”), and other applicable regulatory authorities as applicable to them. This includes, but is not limited to, lending laws, data protection regulations, and fair practices codes.

4.2.2.

Members should implement robust internal compliance mechanisms, including regular audits and compliance reviews, to ensure that they are in full alignment with the latest legal and regulatory requirements.

4.2.3.

Any changes in laws or regulatory frameworks applicable to them must be promptly adopted by Members, and all necessary steps must be taken to ensure that customers are informed of how such changes may impact them.

4.2.4.

Members must provide detailed disclosures and ensure their operations are transparent, especially concerning loan terms, pricing structures, interest rates, penalties, and repayment schedules, to enable borrowers to make informed decisions.

4.2.5.

Regulatory filings and reporting to authorities must be done accurately and on time to maintain operational transparency and accountability.

4.3. Transparency in Operations

4.3.1.

Disclosures to borrowers should be clear, comprehensive, and communicated at appropriate times, including during the pre-loan, loan agreement, and post-loan stages. Members must ensure that key terms such as interest rates, loan tenure, repayment obligations, and any penalties for default are fully understood by borrowers.

4.3.2.

Loan agreements must contain clear terms, with no hidden fees or unexpected charges. Members should ensure that all costs, including interest rates, processing fees, penalties for late payments, and any additional fees, are explicitly disclosed upfront, with clear examples provided.

4.3.3.

Members must use simple, legible, and unambiguous language in all disclosures, and these must be made available in languages understood by the target customer groups. Where necessary, technical terms should be explained in plain language or local dialects.

4.3.4.

Borrowers should have easy access to detailed information about their loans throughout the entire contract period, including repayment schedules, outstanding amounts, interest and principal breakdowns, and payment receipts. This information should be accessible through secure platforms such as Member websites, apps, or upon request via customer service.

4.3.5.

Members should ensure timely and professional communication of decisions regarding loan applications, including rejections. Reasons for rejection should be provided in a clear and respectful manner, ensuring transparency in decision-making processes.

4.3.6.

Any changes in loan terms or conditions that are to the detriment of the borrower (such as fee increases or new charges) must be communicated to the borrower at least 15 working days in advance, giving them the option to close the loan without penalties. If changes are favourable or neutral, borrowers must still be informed within 30 days.

4.3.7.

Members must send timely reminders to borrowers about upcoming payment obligations, including due dates, amounts payable, and any potential consequences of late payments, such as additional fees or negative credit reporting.

4.3.8.

Members must ensure customers are aware of their rights regarding repayment, including options for pre-payment or part-payment, without unfair penalties. This information should be clearly stated in loan agreements and made accessible to the borrower at any time.

4.3.9.

Late payment penalties must be transparent, non-compounding, and limited to the remaining outstanding loan balance. Such penalties should be reasonable and in accordance with the member’s established policies.

4.3.10.

Predatory or usurious pricing models are prohibited, and cost structures should not confuse or mislead borrowers. The goal must be to ensure transparency and borrower understanding of all costs. All details in relation to interest, penal charges etc. should be disclosed at appropriate places as required under applicable law.

4.4. Transparency in Disclosures

4.4.1.

Members must ensure that all marketing and promotional materials are not false, deceptive, or misleading. The presentation of financial products should be clear, factual, and designed to facilitate informed decision-making by customers.

4.4.2.

Detailed product information, including loan features, eligibility criteria, repayment schedules, pricing, fees, and terms, must be prominently displayed on member websites, digital lending platforms, and in customer communications.

4.4.3.

Members should provide a key fact statement to every borrower, outlining the most critical aspects of the loan, including the Annual Percentage Rate (“APR”), total loan cost, instalment amounts, and any applicable fees (e.g., processing, late payment, and pre-closure fees). This statement should be provided both digitally and physically, where applicable, in a language the borrower can easily understand.

4.4.4.

All recovery agents, loan service providers (“LSPs”), and third-party partners must be clearly listed and disclosed to borrowers. The borrower should be informed who their loan provider is, who will collect payments, and what role each entity plays in the loan process.

4.4.5.

Members must ensure customers understand their responsibilities in repaying the loan, the consequences of non-payment, and the potential impact on their credit score. Customers should be encouraged to review the terms thoroughly and provided with the tools to understand their obligations.

4.4.6.

Information on data privacy policies, particularly regarding the collection, use, storage, and sharing of borrower data, must be transparently communicated to borrowers. Members must explain what data is collected, why it is collected, how it is used, and who it may be shared with, ensuring full compliance with relevant data protection laws.

5. Commitment to Financial Inclusion

5.1. Fair and Equitable Access

5.1.1.

Members must ensure that all individuals, regardless of their background, are provided with fair and equitable access to financial services, especially within priority sectors such as MSMEs, agriculture, housing, and healthcare.

5.1.2.

No borrower shall face discrimination based on factors such as religion, caste, gender, marital status, sexual orientation, geographic location, or economic standing when seeking access to financial products.

5.1.3.

Members should prioritize underserved and financially excluded segments of society, aiming to provide tailored financial solutions that meet the specific needs of these groups.

5.1.4.

Financial products must be designed to address the unique needs of these priority sectors, ensuring that they are affordable, accessible, and flexible enough to meet the demands of diverse borrower segments.

5.2. Customer Sensitivity and Inclusiveness

5.2.1.

Members must train their staff and representatives to be sensitive to the social, cultural, and economic realities of underserved borrowers. This includes using respectful language, maintaining decorum, and showing respect to local customs and sensitivities in all customer interactions.

5.2.2.

Employees must be trained to empathically deal with customers facing financial difficulties, guiding them to connect with free and independent debt counselling services when appropriate.

5.2.3.

Members should ensure that customer service, loan processing, and repayment methods are designed to accommodate the unique needs of rural or marginalized populations, including access to services in local languages and through various digital platforms.

5.2.4.

Members should design digital financial services to be user-friendly for all populations, with simplified processes and language options to accommodate borrowers from diverse educational and socio-economic backgrounds.

5.3. Collaboration for Sectoral Growth

5.3.1.

Members should collaborate with government bodies, regulators, and other stakeholders to support initiatives that further financial inclusion and economic development in priority sectors.

5.3.2.

Members are encouraged to participate in collective efforts, including advocacy for policy reforms and participation in capacity-building programs, to address the systemic challenges faced by underserved sectors.

6. Fair Lending Practices

6.1. Product Suitability and Affordability

6.1.1.

Members must ensure that all financial products, including loans and associated fees, are suitable for the borrower's financial situation and capacity to repay.

6.1.2.

A comprehensive assessment of the borrower’s income, occupation, age, and other relevant economic data must be conducted to evaluate creditworthiness before extending any loan.

6.1.3.

Members are prohibited from automatically increasing credit limits without explicit, recorded consent from the borrower for each increase.

6.1.4.

Borrowers should always be informed about their right to a look-up period, during which they can repay the loan without penalties, and this period must be clearly stated in the loan agreement.

6.2. Loan Disbursement and Repayment

6.2.1.

Loans must be disbursed in amounts that are commensurate with the borrower’s ability to repay, ensuring that monthly repayment obligations do not exceed 50% of the borrower’s household income.

6.2.2.

Pre-payment of loans must be allowed at any time, in line with applicable RBI guidelines, and borrowers should be provided with convenient options to restructure loans if necessary.

6.2.3.

Members must take reasonable steps to verify the accuracy of borrower information, including income, credit history, and existing financial obligations, ensuring that the loan is appropriate for the borrower’s circumstances.

6.3. Borrower Protection and Financial Responsibility

6.3.1.

Members must educate borrowers on the importance of maintaining a good credit history and provide guidance on responsible credit behaviour to prevent over-indebtedness.

6.3.2.

Borrowers should be provided with secure and accessible interfaces to manage their loans, ensuring that digital platforms meet the highest standards of cybersecurity.

6.4. Non-coercive Recovery Practices

6.4.1.

Members must ensure that all recovery processes are carried out in a respectful, non-coercive manner. Borrowers should not be harassed or intimidated through physical or verbal means, nor should their family or social circles be contacted or involved in recovery efforts.

6.4.2.

Staff, agents, and representatives involved in loan recovery must be trained to handle borrowers with care, ensuring that recovery efforts are professional and compliant with RBI and other regulatory guidelines.

6.4.3.

Contact with borrowers regarding overdue payments must be restricted to normal business hours (between 8:00 a.m. and 7:00 p.m.), and under no circumstances should recovery actions be taken during socially sensitive times such as during bereavement, illness, or other personal or social occasions like weddings.

6.4.4.

Members should strive for amicable resolutions and propose payment methods that allow the repayment of outstanding liabilities in the least inconvenient manner for the customer.

6.4.5.

A clear standard operating procedure on recoveries must be established for employees and third-party recovery agents, outlining sequential steps for recovery, points of contact for customers, ethical standards, and an escalation matrix for complaints.

6.4.6.

Reported cases of infringement of customers’ rights due to debt collection activities must be thoroughly investigated, with a clear policy in place to outline actions taken if such complaints are validated.

6.4.7.

Members should leverage optimal technology solutions, such as diallers and automated digital nudges, to facilitate efficient communication and recovery efforts.

7. Confidentiality and Data Protection

7.1. Informed Consent and Privacy Policy

7.1.1.

Members must maintain a publicly available, board-approved privacy policy compliant with applicable laws, regulations, and RBI guidelines. This policy must clearly state:

(i)

What customer data is collected, when and how it is collected, and for what purposes.

(ii)

Whether the data is mandatory or optional, and the implications of withholding optional data.

(iii)

How the data will be stored, protected, and retained, including encryption methods.

(iv)

Any third parties involved in data processing, along with their roles.

(iv)

Any third parties involved in data processing, along with their roles.

(v)

Customer rights regarding data use, including options for revoking or modifying consent, and how to update or delete data.

7.1.2.

Members must ensure that customer consent is obtained before collecting, storing, or using any personal data, with clear, simple, and comprehensive disclosures provided in relevant languages.

7.1.3.

Borrowers should have modular choices when giving consent, such as selecting specific data points to share or opting out of sharing with third parties.

7.2. Confidentiality

7.2.1.

Each Member of the PSL Association agrees to maintain strict confidentiality regarding all business, financial, and personal information obtained in the course of its operations. This includes but is not limited to information related to Borrowers, merchants, and other stakeholders as required under applicable laws. Members are prohibited from disclosing such information to any third party without the explicit consent of the involved parties, unless required by law.

7.2.2.

Members shall not share or disclose confidential information obtained through their membership with the PSL Association or through their business dealings unless the disclosure is authorized by the concerned party or mandated by regulatory authorities. This includes any sensitive information about business operations, strategic decisions, or internal communications.

7.2.3.

Members must enforce robust internal policies to safeguard confidential information. Access to such information should be restricted to authorized personnel only. Members should ensure that employees, agents, and representatives are fully aware of and comply with these confidentiality obligations.

7.2.4.

All communications involving sensitive business or customer data must be conducted securely. Members must ensure that such communications are protected from unauthorized access or interception, maintaining the privacy and confidentiality of all parties involved.

7.2.5.

Members agree not to use confidential information for personal gain or competitive advantage, whether for themselves or for any third parties. All information received in the course of interaction with other Members should be used strictly for confidential and not used for any purpose other than as permitted by the disclosing Member.

7.2.6.

Even after the termination of a business relationship or membership with the PSL Association, Members are required to maintain the confidentiality of any information obtained during the relationship. This obligation persists indefinitely beyond the termination of membership or business dealings.

7.2.7.

Each Member agrees that it shall inform the PSL Association promptly upon becoming aware of any unauthorized use or disclosure of any confidential information and take prompt corrective action to recover materials containing the confidential information and prevent further unauthorized use or disclosure of the confidential information.

7.3. Data Collection and Use

7.3.1.

Data collected must be proportionate, necessary, and relevant for the specified purpose, with the scope of data collection clearly disclosed to the customer at every stage.

7.3.2.

Members may only use customer data for the purposes that have been explicitly notified to and consented by the borrower. Data use for unnotified or different purposes is prohibited.

7.3.3.

Customers must be given the option to withdraw or modify their consent at any time, with the process for doing so being as simple as the process for giving consent.

7.3.4.

Members must not collect, store, or use unnecessary or excessive data and must avoid “umbrella consent” practices that overwhelm customers with broad data permissions.

7.3.5.

Customers must have meaningful control over their personal data, with the ability to:

(i)

Give or withdraw consent for specific data points.

(ii)

Restrict data sharing with third parties.

(iii)

Specify the retention period for which their data is stored.

(iv)

Require the deletion of data once it is no longer needed.

7.3.6.

Members must provide a process for customers to easily access, review, and update their personal data, ensuring data accuracy and relevance.

7.3.7.

Members must not access or use a customer’s phone resources other than as permitted under applicable laws.

7.4. Data Security and Protection

7.4.1.

Members must implement robust cybersecurity measures to protect customer data from fraud, identity theft, and misuse. This includes regularly updating safeguards and ensuring compliance with prevailing data protection and cybersecurity regulations.

7.4.2.

In the event of a data breach, Members must promptly notify the affected customers, take immediate steps to address the breach, and mitigate any potential harm to the borrower.

7.4.3.

Personal data must only be stored on servers located in India, unless otherwise permitted under applicable law. Members must comply with all relevant applicable laws with respect to processing of personal data of the customers.

7.5. Third-Party Data Sharing and Use

7.5.1.

Data shared with third parties must be limited to the purposes that the customer has consented to, and no data may be sold or shared without explicit customer permission.

7.5.2.

Members must ensure that any third-party partners handling customer data follow the same stringent privacy and security standards and disclose such relationships to the borrower.

8. Employee Training and Engagement

8.1. Comprehensive Induction and Training

8.1.1.

Members must provide comprehensive induction training to all new employees, covering the organization’s policies, processes, and applicable regulations. New employees who will have direct interactions with customers should only be engaged in business operations after successfully completing their induction training. This training should emphasize the Code, focusing on borrower-interface aspects such as:

(i)

Fair treatment of customers;

(ii)

Privacy and security of customer data;

(iii)

Service quality standards;

(iv)

Customer grievance redressal systems;

(v)

Prevention of sexual harassment;

(vi)

Relationship management;

(vii)

Assessing the repayment capacity of customers;

(viii)

Strategies for dealing with repayment difficulties;

(ix)

Understanding performance and recovery targets; and

(x)

Ongoing Training and Assessment.

8.1.2.

Members must regularly assess employees’ understanding of the training materials and conduct refresher training sessions to address any knowledge gaps identified.

8.1.3.

Training programs should include modules on understanding and addressing gender issues, ensuring that employees know how to interact appropriately with female colleagues and customers.

8.1.4.

Members must establish a well-defined protocol for employees to follow when handling risks associated with working in challenging areas and managing cash.

8.2. Professional Conduct

8.2.1.

Members must orient employees on issues of professional conduct and integrity, outlining expected behaviours and ensuring that employees do not engage in any unlawful or anti-social activities.

8.2.2.

Employees must be made aware of the ethical standards and expectations associated with their roles, particularly when interacting with customers and must also be made aware of the repercussions of not adhering to the Code.

9. Meetings

9.1.

PSL Association may host meetings for setting out future projects and business of the organization. Members are required to attend such meeting. PSL Association shall provide adequate prior notice of such meetings. Members who are unable to attend such meetings are required to intimate PSL Association in advance.

9.2.

Members shall maintain decorum at such meetings and shall not cause any disturbances during the meetings.

9.3.

Where any Member is afforded time to speak during a meeting other Members shall ensure that they do not interrupt or cause any disruptions. PSL Association shall strive to provide all Members a platform to present their views.

9.4.

All Members shall treat each other with respect and shall cooperate with one another to ensure that such meetings are fruitful and successful.

10. Committee Specific Obligations

10.1.

Members who are part of committees of PSL Association may have additional obligations as set out herein.

10.2. Governing Council

10.2.1.

Members who are part of the Governing Council of PSL Association shall act in a fair and transparent manner and put the interests of PSL Association and its Members as a whole before any individual Member.

10.2.2.

Members who are elected to the Governing Council shall disclose any conflict of interests that may affect their ability to perform their obligations as part of the Governing Council.

10.3. Membership Committee

10.3.1.

Members who are part of the Membership Committee and performing dispute resolution functions shall recuse themselves from looking into disputes between Members in relation to this Code, if they are in any manner part of the dispute or have any interest in relation to the dispute.

10.3.2.

Members of the Membership Committee shall look into all Member disputes and non-compliance with the Code in a fair and transparent manner.

11. Grievance Redressal Mechanism

11.1.

Each Member undertaking must have a board-approved customer grievance redressal policy that outlines the process for registering, resolving, and escalating complaints. This policy should include:

11.1.1.

Internal and external escalation mechanisms.

11.1.2.

Clearly defined complaint categories.

11.1.3.

Turnaround time for resolution.

11.1.4.

Procedures for reviewing and auditing the redressal system.

11.1.5.

Reporting requirements to the board and top management.

11.2.

Each Member must appoint a dedicated nodal grievance redressal officer responsible for overseeing the grievance redressal function. Contact details for the nodal officer must be prominently displayed on the Member’s website, digital lending application, and in key communication materials.

11.3.

Members must provide clear information to customers on how to contact customer service or the compliance officer regarding grievance redressal. Non-RE Members should also offer details on how customers can contact the relevant REs involved in providing financial products or services.

11.4.

Members must educate customers about their rights to raise complaints with consumer forums, including the RBI-Integrated Ombudsman Scheme, providing guidance on how to approach these authorities.

11.5.

Members must incorporate a mechanism within their grievance redressal framework specifically for recovery-related grievances. Details of this mechanism must be communicated to borrowers at the time of loan disbursal.

11.6.

Members must maintain records of individual and aggregate-level data concerning the grievance redressal system. This data should capture:

11.6.1.

Nature of complaints received.

11.6.2.

Actions taken to resolve complaints.

11.6.3.

Turnaround time for resolutions.

11.7.

Reports on grievances received, resolved, and pending, along with their nature, should be submitted quarterly to the PSL Association within 15 days after the end of each quarter and presented to the board as part of good governance practices.

11.8.

In instances where a complaint resolution lies with a third party (e.g., related to product/service purchase), Members must guide customers to the appropriate channels and support them in obtaining redress.

12. Adherence to the Code

12.1.

Each Member is individually responsible for ensuring compliance with applicable laws, regulations, and this Code in both letter and spirit.

12.2.

The provisions in this Code are complementary and in addition to the obligations of each Member under applicable laws and regulations.

12.3.

Members must affirm in writing their commitment to adhere to the Code of Conduct at the time of joining the PSL Association, backed by a resolution from their board of directors or a written undertaking in case of individuals and during each renewal of the membership.

12.4.

Each Member will designate an officer responsible for all correspondence and reporting with the PSL Association. The name and contact details of the Designated Compliance Officer must be communicated to the PSL Association within five days of nomination.

12.5.

Members must follow advisories and directives issued by the PSL Association that are relevant to their business.

12.6.

Members must provide the PSL Association with requested data and information for sector publications, research, or as required by any governmental agency.

12.7.

In the event of non-adherence to the Code of Conduct or applicable laws, Members are encouraged to voluntarily self-report such non-compliance to the PSL Association within seven business days.

12.8.

Cybersecurity incidents affecting a Member must be reported to the PSL Association and the relevant authorities under applicable law within six hours of detection.

12.9.

Every quarter, each Member must analyse, and record data related to the grievance redressal system, capturing the nature of complaints, actions taken, and turnaround times. Reports on grievances received, resolved, and pending must be submitted to the PSL Association quarterly within 15 days after the end of each quarter.

12.10.

Members must submit an annual confirmation to the PSL Association regarding compliance with the Code, including certification from a director or key managerial personnel that they are in compliance with the Code and applicable laws.

12.11.

The annual submission is necessary for continued membership and participation in PSL Association activities.

12.12.

The PSL Association will monitor compliance with the Code of Conduct and may take actions against non-compliant Members, including issuing warnings, barring membership, and reporting violations to authorities.

12.13.

The dispute resolution mechanism applies to disputes between Members concerning the interpretation or applicability of the Code.

12.14.

Members must first seek bilateral consultation for any disputes and, if unresolved, may request the PSL Association to decide.

12.15. Dispute Resolution Mechanism

12.15.1.

Any dispute arising between Members of the PSL Association in relation to this Code of Conduct shall first be referred to a mediation process before a panel comprising individuals from a pre-selected pool of neutral and qualified representatives from the PSL Association (“Mediation Panel”). The Mediation Panel shall be constituted to facilitate discussions between the parties in an effort to resolve the dispute amicably. The Mediation Panel shall work in good faith to mediate and arrive at a mutually acceptable resolution.

12.15.2.

If the Mediation Panel fails to resolve the dispute within 30 days or if any Member chooses to withdraw from mediation, the matter shall be escalated to the Membership Committee of the PSL Association.

12.15.3.

The Membership Committee of the PSL Association shall act as the first forum for reviewing non-compliances by Members, dispute resolution inter-se Members and for addressing market threats.

12.15.4.

The Member who has raised the dispute (“Complainant”) will need to submit a written dispute report to the Membership Committee providing comprehensive details of the actions, or events forming the basis of the dispute.

12.15.5.

The respondent Member (“Respondent”) shall have a reasonable time of no less than 21 days from the date of receipt of the dispute report to submit to the Membership Committee a response to the Complainant’s dispute report.

12.15.6.

The Complainant and the Respondent will be given a fair and equal opportunity to present their cases before the Membership Committee, and the Membership Committee will consider all facts, evidence, and arguments presented.

12.15.7.

Following the review of the submissions made, the Membership Committee shall issue a reasoned order (“Order”). This Order will convey the decision of the Membership Committee which shall include the reasons for the final decision. The Order rendered by the Membership Committee shall be final and binding on all parties involved in the dispute. No further appeal shall lie against the Membership Committee's decision, except in cases where the dispute falls outside the scope of this Code.

12.15.8.

This dispute resolution mechanism shall govern only those disputes arising between Members of the PSL Association in relation to their obligations, rights, or conduct under this Code of Conduct.

12.16. Enforcement of the Code of Conduct

12.16.1.

The Membership Committee shall monitor the compliance by Members with the Code. In the event any instances of suspected non-compliance are noted, the Membership Committee shall investigate the suspected non-compliance by a Member.

12.16.2.

If the Membership Committee is of the opinion that sufficient cause exists to take further action, they may issue a show cause notice to the Member suspected of breaching the Code.

12.16.3.

On receipt of a show cause notice, the Member shall be afforded the opportunity to present their defence. All proceedings shall be conducted in a fair and transparent manner in compliance with the principles of natural justice.

12.16.4.

In the event a Member is found guilty of non-compliance with the Code, the Membership Committee shall be empowered to determine suitable action to be taken against the Members which may include issuing a warning letter to the Member, restricting the Member from a fixed number of PSLAI sponsored events, suspending the member from participating in elections for any committee of PSLAI, intimating of such non-compliance to the relevant regulatory authority or revoking membership of the Member amongst other actions as deemed necessary.

12.16.5.

Any appeal against the decision of the Membership Committee shall be to the Governing Council.

PSLCode of Conduct