At Finpro, our Code of Ethics serves as the foundation of our commitment to integrity, professionalism, social responsibility and lawful conduct in all aspects of our business. We believe in treating every individual with respect and fairness, ensuring transparency and honesty in our communications and maintaining the highest standards of professionalism and excellence in our work consistent with our obligations under the following Philippine laws and regulations:

• Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations that mandates the protection of personal data and confidentiality;
• Bangko Sentral ng Pilipinas (BSP) Circular No. 1133, Series of 2022, which prescribes rules on fair and respectful debt collection practices for financial service providers and their third-party collection companies;
• Securities and Exchange Commission (SEC) Memorandum Circular No. 18, Series of 2019, which prohibits unfair collection practices and
• Republic Act No. 7394 (Consumer Act of the Philippines), which promotes consumer welfare and safeguards against deceptive practices.

We prioritize client satisfaction by being responsive, attentive, and dedicated to achieving the best possible outcomes. Our debt collection practices are firmly grounded in ethical conduct and legal compliance ensuring that all actions taken are fair, respectful, and lawful. We also safeguard the confidentiality and privacy of all data entrusted to us in accordance with RA 10173.

Accountability is central to our operations, as we take full responsibility for our actions and decisions, striving for continuous improvement and innovation in our services. We are deeply committed to social responsibility, respecting the communities we serve, and contributing positively through initiatives that promote financial literacy and responsible borrowing.

Above all, we act with unwavering integrity ensuring that every decision and action we take reflects our core ethical principles and legal responsibilities. By upholding these values, Finpro fosters trust and reliability, protects stakeholder interests and contributes to raising the standard of ethical conduct within the Philippine financial services industry.

Building on this strong foundation, we at Finpro are committed to conducting our business with the highest standards of ethics and integrity. Our Code of Ethics outlines the principles that guide our actions and decisions, ensuring that we operate lawfully, responsibly and respectfully in all interactions.

The following are Finpro's detailed Code of Ethics which sets out the specific standards, values and principles that govern our conduct as a third-party debt collection company. These ethical commitments are designed to ensure lawful, respectful and transparent operations in all areas of our business. Each section addresses a key pillar of ethical practice which ranges from fairness in client and debtor treatment, transparency in communication, lawful debt collection methods, data privacy and security up to our social and corporate responsibilities. Our code of ethics outlines the principles that guide our actions and decisions, ensuring that we operate responsibly and respectfully with the highest standards of integrity in all interactions.

1. Respect and Fairness

We treat all clients and debtors with dignity, professionalism and impartiality, in strict adherence to BSP Circular No. 1133 and SEC Memorandum Circular No. 18, Series of 2019. Our actions are grounded in fairness and factual decision – making and we expressly prohibit any form of bias, discrimination, harassment or abusive collection practices in all interactions.

2. Transparency and Honesty

We are committed to full transparency and honesty in all our communications with clients and debtors ensuring that all information we provide are clear, accurate and truthful. We likewise strictly prohibit any form of misrepresentation, deception or misleading conduct in all our interactions in accordance with the BSP Circular No. 1133 and applicable consumer protection laws.

3. Professionalism and Excellence

We uphold the highest standards of professionalism by honoring our commitments, meeting deadlines, and maintaining respectful, courteous conduct in all interactions. In line with our obligations under BSP Circular No. 1133 and relevant industry standards, we are committed to excellence through continuous training, adherence to best practices, and the ongoing development of our capabilities to deliver responsible and compliant debt collection services.

4. Commitment to Client Satisfaction

We are committed to delivering a high standard of client service by being responsive, attentive and solutions – oriented in addressing their concerns. We also foster strong and positive relationships with our clients through clear communication and professional engagement ensuring that every interaction upholds our ethical standards and complies with applicable laws, including BSP Circular No. 1133 and the principles of fair and responsible service delivery.

5. Ethical and Responsible Debt Collection Practices

We conduct all debt collection activities in a lawful, fair, and respectful manner, fully complying with BSP Circular No. 1133, SEC Memorandum Circular No. 18 and the Data Privacy Act of 2012. We strictly prohibit any form of harassment, intimidation or coercion, and ensure that our collection methods uphold the dignity, rights and privacy of debtors. Our practices are designed to reflect both the letter and spirit of the law, promoting ethical recovery while avoiding undue pressure or harm.

6. Confidentiality and Privacy

We are committed to protecting the confidentiality and privacy of all client and debtor information in strict compliance with the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations. Personal data is collected, processed, and stored only as necessary and with lawful purpose, safeguarded by strict security measures and accessed solely by authorized personnel. We uphold the principles of transparency, proportionality, and legitimate purpose in all our data handling activities.

7. Accountability and Responsibility

We take full accountability for our actions, decisions and their outcomes, upholding the highest ethical and legal standards in accordance with the BSP, SEC, and data privacy regulations. We act responsibly by considering the impact of our conduct on clients, debtors, regulators and the community, ensuring that all our practices reflect transparency, integrity and respect for the law.

8. Continuous Improvement

We are committed to continuously enhance our services through ongoing training, performance evaluation and the adoption of industry best practices. In compliance with regulatory expectations under BSP Circular No. 1133 and relevant standards, we invest in the professional growth of our team to ensure our methods remain effective, ethical and aligned with evolving legal requirements and client needs.

9. Social Responsibility

We recognize our role in promoting financial well – being and contribute positively to the communities we serve by supporting initiatives that encourage financial literacy and responsible borrowing. In line with our ethical standards and broader legal obligations, we ensure our practices are socially conscious, culturally sensitive and aligned with national development goals.

10. Integrity in All Actions

We act with integrity in all aspects of our business, ensuring that our decisions and conduct consistently align with our ethical values and legal obligations. We promote trust through honesty, transparency and consistency and remain steadfast in doing what is right upholding our commitment to responsible and principled operations even in challenging situations.

11. Non-Retaliation and Complaint Resolution

We uphold a zero – tolerance policy against retaliation toward any individual who raises a concern or reports unethical, unlawful or unfair conduct in good faith whether client, debtor or employee. We also maintain accessible and confidential channels for filing complaints, and we ensure that all concerns are addressed promptly, fairly and without prejudice to the rights of the reporting party in accordance with applicable labor, consumer protection, and regulatory laws.

12. Use of Ethical Code

This Code of Ethics applies to all Finpro employees, contractors, and authorized representatives, and forms an essential part of our internal governance, compliance, and operational protocols. All personnel are expected to understand, uphold, and apply the principles outlined herein, in accordance with applicable laws, regulatory guidelines, and Finpro's commitment to ethical and lawful business conduct.

By adhering to this Code of Ethics, Finpro reaffirms its unwavering commitment to lawful, ethical, and socially responsible business practices, fostering trust among clients, partners, and the communities we serve.