Code of Conduct

I. INTRODUCTION

Chamroeun as a licensed microfinance takes pride in its professional reputation as one of the leading Cambodian social microfinance institution that conducts its businessto achieve positive and lasting changes in the livelihoods of economically active poor families in a socially responsible manner with utmost integrity, honesty and respect for all our partners, service and goods suppliers and employees.

To ensure the highest level of integrity, quality of services, transparency, fair practices, confidentiality and non-discrimination is maintained, it isessential that this is embedded as a core value or element for the working culture at Chamroeun.

In order to support this, we have designed and developed the code of conduct by outlining the standards of codes and behavior which every employee is expected to maintain.

II. EMPLOYEE GENERAL CONDUCT

1   PERSONAL BEHAVIOR AND INTERNAL REGULATIONS

Chamroeun expects all its employees to conduct themselves in a businesslike manner.  Some activities such as drinking, gambling, smoking, violence or fighting, swearing and similar unprofessional activities are strictly prohibited while on the job.

Employee must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate material in their work area, or accessing in appropriate materials on their computer.

Also, the employees are required to respect the working hour as set by the company and employee’s personal information are required to be updated on time when there is any change.

Examples of such activitiesare expressly defined below:

    -   Gambling: In the working hours, employees are not allowed to gambling, betting, and lottery. Using of Chamroeun’s assets for gambling is forbidden. Attitude opposed to this notice will be considered as gross misconduct and the employment contract will be terminated.

    -    Violence: the fighting or any physical violence of employee to employees or partners is forbidden.Acts of violence are considered as gross misconduct and the employment contract will be terminated immediately.

   -   Punctual Time: being on time is important. Employees have to be punctual for working, meeting and appointment both internally and with partners.

    -    Personal information: employees have to inform to Chamroeun regarding personal changes on qualification, address, cell phone number, marital status, spouse and children, and other details needed for Chamroeun administration.

2    EQUAL EMPLOYMENT OPPORTUNITY

Chamroeun is committed to prohibiting the discrimination against employees or applicants based on race, color, religion, sex, national origin, age, disability, economic status, sexual orientation and apply to hiring practice, employer/employee relations, and business opportunity.

As part of this commitment, all employees must share responsibility for implementing Chamroeun’s policies for equal opportunity in employment. The following discriminatory practices in employment are absolutely prohibited at Chamroeun:

   -     Harassment on the basis of race, color, religion, sex, national origin, disability, sexual orientation or age;

  -  Retaliation against an individual for filing a charge of discrimination, participating in a discrimination investigation, or opposing discriminatory practices;

  -   Employment decisions based on stereotypes or assumptions about the abilities, traits, or performance of individuals of a certain sex, race, age, religion, or ethnic group, or individuals with disabilities; and

  -    Denying employment opportunities to a person because of marriage to, or association with, an individual of a particular race, religion, national origin, or an individual with a disability. We also prohibit discrimination because of participation in political party or legal strike…etc.

3    ANTI-HARASSMENT

As part of our commitment to having a respectful and inclusive work environment, Chamroeun has long maintained an anti-harassment practice. Harassment at Chamroeun is understood and includes language or conduct that may be derogatory, intimidating, or offensive to others.

All employees as well as lenders, partners and other visitors to our premises are protected under this practice and are expected to abide by it. Violations of company’s anti-harassment practice will result in discipline, up to and including termination or release as defined in disciplinary action guidelines. The core requirement for employee at Chamroeun for anti-harassment is as below:

  -     Don’t make jokes, use language or participate in activities that may be offensive to others;

   -    Don’t intimidate others through bullying, threats, or practical jokes;

  - Report, and encourage others to report, incidents of harassment or retaliation. Report any incidents to appropriate Human Resources personnel, or use the company’s reporting system;

   -   Take all harassment complaints seriously. Managers and supervisors should immediately address behavior or conduct that maybe offensive, and should encourage an atmosphere in which everyone feels free to report potential violence;

   -    Do not retaliate against anyone who makes a report. The company prohibits retaliation against anyone making a good faith complaint of harassment, which cooperates in a company investigation of complaint that alleges harassment.

4    HEALTH AND SAFETY

Chamroeun is committed to protecting health and safety. Safety is one of the most important factors in any decisions.  In addition, our most valuable asset is our people, nothing is more important than their safety and wellbeing.

When it comes to health and safety concerns, compliance with legal requirements represents a minimum. When necessary or appropriate, we establish and comply with standards of our own, which may go beyond legal requirements. In seeking ways to protect health and safety, the issue of cost should not rule out consideration of any reasonable alternatives. Employee at Chamroeun is obliged to conduct as below:

  -      Take personal responsibility for the protection of health and safety while at work;

  -      If you are a member of management, consult with employees and/or their representatives and involve them in matters affecting their health and safety. Management of each activity is expected to accept this responsibility as an important priority, and to commit the necessary resources to health and safety;

  -     Comply with the company’s health and safety requirements. Failure to do so may result in discipline, up to and including termination or release.

5    DRUG, ALCOHOL, AND SUBSTANCE ABUSE

To ensure a safe and enjoyable working environment for everyone, Chamroeun strictly prohibits the use of alcohol and illicit substances during work:

Any employee found to be under the influence of illicit substances or to be in the possession of illicit substances at Chamroeun or while representing Chamroeun will be summarily dismissed.

6   BRIBES AND COMMISIONS

Each of Chamroeun’s employee is expected to act in a way that promotes Chamroeun’s best interests. Personal relationships with suppliers, dealers, and partners or customers must not affect your ability to act in a manner that is best for Chamroeun. Those relationships must not harm Chamroeun’s reputation by creating the appearance of impropriety. One good test is to ask yourself how others might view your actions if they were disclosed to Chamroeun’s management or reported in the media.

Chamroeun’s employee must not acceptnor give entertainment, gifts, personal favor or personal discount that could, in any view,influence, or appear to influence, business decisions in favor of any person or any institution with whom or with which Chamroeun has, is likely to have, business dealings. Similarly Chamroeun’s employee must not accept any other preferential treatment under these circumstances because their positions with Chamroeun might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

Regarding Chamroeun’s business activities, employee must not receive payment or compensation of any kind,except as authorized byChamroeun’s Management.

Chamroeun’s employees must also not provide /obtain unusual business or something which could harm the reputation of Chamroeun. In case of obtaining personal benefit, Chamroeun’s employees must report to their direct supervisor within three days

III. CONDUCT AND COMMUNICATION  WITH STAKEHOLDERS

1    DEALING WITH PARTNERS/CLIENTS, LENDERS, PEOPLE

Chamroeun values its partnerships with clients, lenders, and people and treat these partners in the same manner we expect to be treated. Chamroeun always deals fairly with partners, lenders, treating them honestly and with respect.

Chamroeun employees must not engage in unfair, deceptive or misleading practices and always present its products and services in an honest and forbright manner. Furthermore, Chamroeun’s employee should observe the following principles when meeting partners:

  -     Warmly salute the clients in the smiling, attractive manner and with good communication;

  -     Must call clients with acceptable, soft and modest word such as elder, Miss, Mrs., Mr….etc;

  -     Listen carefully and respectively;

  -     Provide clear information about products and services and properly answer on time;

  -     Say “thank you” to clients/people and motivate them to provide feedback to improve the company.

For service to clients, Chamroeun is committed to providing it with the best quality. Before providing services or financing to clients, Chamroeun loan officer must strictly assess the client’s ability to pay loan by gathering all information regarding their financial situation, purpose of using loan, troubles, loan history with other finance institution and advise them accordingly. In this regard; it is unavoidable for loan officers to be aware of the address of the clients.

2    CLIENT PROTECTION

Chamroeun has endorsed the SMART campaign and is committed to implementing the core Client Protection Principles (CPP) in the operations and daily practices to make sure that clients are fairly and respectfully treated.

Chamroeun has strong intention and focus in terms of abiding by the CPPs, in which some common behaviors should be expected from employees as below:

(i)        Appropriate Product Design and Delivery Channels:Providers will take adequate care to design products and delivery channels in such a way that they do not cause clients harm. Products and delivery channels will be designed with client characteristics taken into account.

For the employees a special attention should be paid to assure that:

  -     The loan size matches the target clients’ main financial needs;

  -    The repayment schedule (grace period, repayment frequency, and term) is tailored to the business activity and household cash flow;

  -    Prepayment is not subject to excessive penalties or unjustified interest charges after a minimum period;

  -    Employees must not force clients to sign contracts.

(ii)       Prevention of Over-indebtedness: Providers will take adequate care in all phases of their credit process to determine that clients have the capacity to repay without becoming over-indebted. In addition, providers will implement and monitor internal systems that support prevention of over-indebtedness and will foster efforts to improve market level credit risk management (such as credit information sharing).

For the employees a special attention should be paid to assure that:

  -    Reasonable steps are taken to ensure that credit services are based on the need and repayment capacity of the clients and those services will not put clients s at significant risk of over indebtedness;

  -   All noncredit, financial products or services extended to low income clients are appropriate and the terms are made know to the clients;

 -    Clients are visited to review the loan use and monitor the risk of over-indebtedness (multiple borrowings, lack of effective credit bureau);

  -     Loan assessment includes a cash flow analysis of both the business and the household, and takes into account liabilities from other sources, including indirect loans (as guarantor);

  -     Loan approval is not based solely on guarantees (whether peer guarantees, co-signers, or collateral).

 -   Checking is performed on the credit bureau for client’s current debt levels to assess the client repayment capacity to inform credit analysis and decisions prior to disbursement at each loan cycle;

 -    Rescheduling, refinancing, and write-off are allowed on exceptional basis if clients experience a significant reduction in income and have the willingness to repay but not the capacity to repay.

(iii)      Transparency: Providers will communicate clear, sufficient and timely information in a manner and language clients can understand so that clients can make informed decisions. The need for transparent information on pricing, terms and conditions of products is highlighted.

For the employees a special attention should be paid to assure that:

  -    Clients are provided with all the prices, terms, and conditions of all financial products, including any possible changes to these over time to enable to make informed decision;

  -   Loan documentation includes charges and fees, terms/maturity, conditions, penalties for later payment and condition for early repayment;

   -    Employees read contracts aloud to illiterate or low-literate clients;

  -  Clients are explained the loan terms and conditions and provided adequate time to review the terms and conditions, and an opportunity to ask questions and receive additional information prior to signing contract;

  -     Loan contract is provided to clients (both group and individual loan clients) at the time of signing the contract;

  -     Multiple channels are used for disclosing the prices of products/services, such as brochures, and websites;

  -    All written and verbal communication with clients is in the local language and that plain language and terms are used to describe products, prices, terms, and conditions;

  -     Client understanding is checked by asking follow-up questions and using checklist before loan disbursement;

  -     Clients are provided receipts for each transaction (disbursement and collection).

(iv)      Responsible Pricing: Pricing, terms and conditions will be set in a way that is affordable to clients while allowing for financial institutions to be sustainable. Providers will strive to provide positive real returns on deposits.

For the employees a special attention should be paid to assure that:

  -      All products are designed according to the market study, pilot-tested to test the relevance of new product and product cost analysis;

  -      All prices are established based on market-based offer and comparable to peers;

  -    All prices do not differ based on ethnicity, gender, disability, political affiliation, sexual orientation and religion.

(v)       Fair and Respectful Treatment of Clients: Financial service providers and their agents will treat their clients fairly and respectfully. They will not discriminate. Providers will ensure adequate safeguards to detect and correct corruption as well as aggressive or abusive treatment by their staff and agents, particularly during the loan sales and debt collection processes.  

For the employee a special attention should be paid to assure that:

  -     Service is provided using efficient and cost effective methods;

  -     No collateral security as immovable asset is obtained except for loan size of over $500;

  -   Interaction with clients is done in appropriate language and dignified manner and no effort is spared in fostering client’s confidence and long-term relation;

  -     A policy of zero tolerance for PAR is not endorsed;

  -    Clients are informed about procedures about collateral seizing and the institution ensures that clients will not be deprived of their basic survival capacity, including business asset in case of loan default;

  -   Employees are not allowed to involve in the process of collateral liquidation. They are prohibited to purchase and sell all kinds of client’s collateral;

   -    Decency and decorum is maintained during the visit to the clients s’ place for collection of dues;

  -    Inappropriate occasions such as bereavement in the family, or such as calamitous occasions for making calls or visits to collect dues is avoided;

  -     Avoid any demeanor that would suggest any kind of threat or violence.

(vi)      Privacy of Client Data: The privacy of individual client data will be respected in accordance with the laws and regulations of individual jurisdictions. Such data will only be used for the purposes specified at the time the information is collected or as permitted by law, unless otherwise agreed with the client.

For the employees a special attention should be paid to assure that:

  -     Employee cannot disclose to third parties information about clients’ identity unless:

  • Clients agree through a written document to disclose the information about themselves,
  • Enforcement by court, authority,
  • Enforcement by Legality, for example the law of anti-corruption and money laundering;

  -     An explicit confidentiality clause is included in all client loan contracts;

  -     Disciplinary action is taken in case of misuse or misappropriation of client data;

  -     Access to client data, both in soft and physical format, is restricted only to authorized people;

 -   Staff must obtain the client’s written consent if client personal data or photo is used for promotion and marketing purposes.

(vii)     Mechanisms for complaint resolution: Providers will have in place timely and responsive mechanisms for complaints and problem resolution for their clients and will use these mechanisms both to resolve individual problems and to improve their products and services.

For the employees a special attention should be paid to assure that:

  -     Employees are trained on how to:

  • Use the complaints mechanism;
  • Explain clients about their right to ask questions and make complaints;
  • Inform clients to use the complaints mechanism (hotline, suggestion box available in each branch);

  -      All marketing materials include the institution’s contact information and instructions on how to ask a question or make a complaint;

  -     Make the complaint system available to record, analyze and report client questions and complains;

  -     A monthly report on complains is provided to senior managers and people involved to make sure that they are informed and take necessary corrective actions (compiling written and oral issues).

3    DEALING WITH GOVERNMENT OFFICIAL, REGULATOR  AND AUDITOR

The nature of Chamroeun business often requires that we interact with officials of various government ministries. As anti-bribery law has already been passed criminalizing bribery of government officials, offering anything of values to a government official - directly or indirectly –is forbidden unless it is counseled with CEO and legal unit.    

Chamroeun also widely collaborates with regulators and auditors and will provide information requested by regulators and auditors on time. Chamroeun will comply with regulations issued by government including:

  -       Implementation of policy, procedure and requirement defined by regulation;

  -       Fair practice, and preserving the client’s benefit;

  -       Develop and maintain feedback to regulator and auditors.

In addition, Chamroeun challenges itself to achieve the following objectives thanks to the commitment of all its employees:

  -       Kindly collaborate with regulators and auditors;

  -       Answer without conceal to regulators and auditors;

  -       Immediately implement recommendations raised by audit;

  -       Immediately reply to regulators and auditors requirements and reporting;

  -     Regularly have meeting with regulators and auditors to confer about business, regulations, and other mutual benefits.

 

4    DEALING WITH COMPETITORS

(i)       Competitive Intelligence

Chamroeun employees are encouraged to collect, share and use information about our competitors, but to do so only in legal and ethical manner. Just as Chamroeun values and protects its own nonpublic information, we respect the nonpublic information of other companies.

(ii)      Acceptable Intelligence Gathering

It is acceptable to collect competitive intelligence through publicly available Information or ethical inquiries. Examples of such acceptable intelligence gathering are as below:

  -       Public speech of company executives

  -       Annual report

  -       News and trade journal article and publications

The following basic restrictions apply to our ability to gather competitive intelligence

 -    Do not engage in any illegal or illicit activity to obtain competitive information. This may include theft, trespassing, computer hacking, invasion of privacy, bribery;

 -       Do not accept, disclose or use competitive information that you know or have reason to believe was disclosed to you in breach of a confidentiality agreement between a third party and one of our competitor.

(iii)    Cooperation/Collaboration with other MFIs

Chamroeun employees are encouraged to ensure a fair and healthy competition with other MFIs. Chamroeun involves in national activities undertaken under the Cambodian Microfinance Association and Central Bank of Cambodia as follow:

  -     Join MFI club and provincial network to build up strong relationship and to share challenges and best practices;

   -     Relationships with other MFIs are based on mutual respect and good collaboration;

  -      Reporting to CMA the operating areas, number of clients, loan portfolio, portfolio quality, etc;

  -      Sharing client data with the industry through Credit Bureau Cambodia

5    MEDIA COMMENT

Chamroeun’s professionalism includes ensuring that any comments made to media are truthful, honest and consistent. No officer or employee of Chamroeun with the exception of the Chief Executive Officer and those with direct responsibility for media contact is authorized or permitted to make comment to media representatives regarding any activity or event associated with Chamroeun either as an individual or in the capacity as an officer of Chamroeun.

IV. CONFIDENTIALITY   

During employment with Chamroeun, employees have to sign confidential agreements with Chamroeun. S/he must not spread confidential information related to notification, events, letters, data, finance/administration, business operation, and client’s information unless they have official obligation or written approval from authorized persons.

Also when handling financial and personal information about clients or others with whom Chamroeun has dealings, Chamroeun Employee must observe the following principles:

  -     Collect, use and retain only the personal information necessary for Chamroeun’s business. Whenever possible, obtain any relevant information directly from the person concerned;

  -     Retain information only for as long as necessary or as required by the law. Protect the physical security of this information;

 -  Limit internal access to personal information to those with legitimate business reason for seeking that information;

 -   Obtain the consent of the person concerned before externally disclosing any personal information, unless the legal process or contractual obligation.

V. INTEGRITY OF BUSINESS AND FINANCIAL RECORD   

Accurate and reliable records of many kinds are necessary to meet Chamroeun’s legal and financial obligations and to manage the affairs of Chamroeun. Chamroeun’s books and records must reflect in accurate and timely manner all business transactions.

The employee responsible for accounting and record keeping must fully disclose and record all assets, liabilities or both and must exercise diligence in enforcing these requirements.

Employee must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

  -         False expense, attendance, financial, or similar reports and statement;

  -         False advertising, deceptive marketing practice, or other misleading representations.

VI. CONFLICT OF INTEREST

Chamroeun expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of Chamroeun. Employee must not use their positions or the knowledge gained as a result of their positions for personal advantage.

Regardless of any circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they immediately have to communicate all the fact to their supervisor.In addition, Chamroeun Employeesmust not be employed or sign contract with other employer, or otherwise provide services or receive payment from any customer, supplier when working with Chamroeun unless there is a written approval from Chief Executive Officer.

VII. DUTY TO REPORT VIOLATIONS

All employees must report all known or suspected violation of Chamroeun policies or business related legal requirements, including:

  -      Applicable laws  and government regulation in Cambodia ( Civil and Criminal Laws, and government rules and regulation)

  -       Chamroeun’spolicies,procedures, guidelines and decisions

  -       This Code of Conduct

If you become aware of a known or suspected violation of Chamroeun Policy or business-related legal requirements, you should report it promptly to one of the following:

  -       Your direct supervisor

  -       HR Department

  -       Staff Representative

  -       Concerned Department

  -       Recipient person authorized to receive reports through other procedures.