ACA Internationals Code of Conduct and Ethics 2014

ACA International’s Code of Conduct and Ethics © 2014 ACA International. All Rights Reserved. Ethical Considerations for the Credit and Collection Industry 1 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

The ACA International Legal Disclaimer The content provided herein ("Content") is presented for educational and general reference purposes only. ACA International, either directly or indirectly through speakers, independent contractors, employees or members of ACA International (collectively referred to as "ACA") provides the Content as a courtesy to be used for informational purposes only. The Contents are not intended to serve as legal or other advice. ACA does not represent or warrant that the Content is accurate, complete or current for any specific or particular purpose or application. This information is not © 2014 ACA International. All Rights Reserved. intended to be a full and exhaustive explanation of the law in any area, nor should it be used to replace the advice of your own legal counsel. ACA is the sole owner of the Contents and all the associated copyrights. ACA hereby grants a limited license to the Contents solely in accordance with the copyright policy included on the acainternational. org website that is incorporated herein by reference ("Agreement"). By utilizing this product, you, as the user agree to be bound by the terms of the Agreement. If you do not agree to the terms of the Agreement, you should not utilize this product. By using the Contents in any way, whether or not authorized, the user assumes all risk and hereby releases ACA from any liability associated with the Content. 2 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Please Note These materials are not legal, accounting, or consulting advice and should not be relied upon as such. Attendees should consult with independent legal, accounting or © 2014 ACA International. All Rights Reserved. consulting professionals for advice pertaining to their operation and unique facts and circumstances. 3 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

“Particularly in this day and age of complex regulatory requirements, companies err if they assume that their tone can be set by having effective procedures and policies in place. Having effective procedures and policies is certainly necessary, but it’s not sufficient. A company must also have the right people in leadership positions, leaders who are truthful, transparent, and fair, just as they expect their companies and©employees to be. That means leaders must 2014 ACA International. All Rights Reserved. not only talk the talk, they must also walk the walk … a whole succession of technological revolutions can’t do away with the need for character or the ability to think and act ethically. ” Harvey Pitt, former Chairman of the SEC 4 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

What does “ethics” mean? 1. the discipline dealing with what is good and bad and with moral duty and obligation 2. a: a set of moral principles: a theory or system of moral values © 2014 ACA International. All Rights Reserved. b: the principles of conduct governing an individual or a group c: a guiding philosophy d: a consciousness of moral importance Source: Merriam-Webster’s Online Dictionary: http: //merriam-webster. com/dictionary/Ethics 5 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Why do businesses and industries need ethics programs? • Avoid hidden costs associated with unethical behavior © 2014 ACA International. All Rights Reserved. • Increase productivity 6 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Hidden costs of unethical behavior: • Harms client relationships • Increases risks for scandal © 2014 ACA International. All Rights Reserved. • Increases risk of employee fraud 7 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Good business ethics can drive productivity. • Put the mission first, above personal considerations • Use common language of values, to increase mutual understanding © 2014 ACA International. All Rights Reserved. • Make sure your organization lives up to your employees’ values 8 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Good business ethics can drive productivity (cont. ) • Make ethics decisions in groups • Develop a code of ethics and code of conduct, and stand behind them © 2014 ACA International. All Rights Reserved. • Fully support the ethics program and set the example 9 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Good business ethics can drive productivity (cont. ) • Foster transparency and trust • Strengthen your business ethics skills © 2014 ACA International. All Rights Reserved. • Understand that no one’s perfect • Pay attention to the little things Source: Josephson Institute Reports www. josephsoninstitute. org 10 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

The ACA International Code of Conduct © 2014 ACA International. All Rights Reserved. ACA members agree as a condition of membership to adhere to the Association’s Code of Conduct and to the Ethics Committee Review Rules with respect to reports of code violations. https: //www. acainternational. org/about/code-of-conduct 11 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

ACA’s Code of Conduct • Most recent updates were approved on September 28, 2016 • Current version became effective on November 12, 2016 © 2014 ACA International. All Rights Reserved. • Accompanying Review Rules were adopted on Mach 18, 2014 12 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Structure of the Code of Conduct • Starts with ACA’s mission and values, the Collector’s Pledge, and a preamble ASSOCIATION PEERS INDUSTRY PARTICIPATION © 2014 ACA International. All Rights Reserved. • Divided into 5 Canons based on the type of relationship involved 13 ACA Ethics and Code of Conduct Training v. 15 COLLECTIVE MEMBERSHIP Helping Members Succeed! BUSINESS RELATIONSHIPS CONSUMER RELATIONSHIPS © 2020 ACA International

Canon I: Relationships with Association Peers 14 • Advance collegiality and professionalism toward fellow members • Prompt fellow members to correct any instances of known unethical conduct © 2014 ACA International. All Rights Reserved. • Will not misrepresent another member • Will abide by Association governance on Association social media platforms ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Canon II: Business Relationships 15 • Honor terms agreed to • Honesty with customers and clients about charges for goods and services rendered • Distribute client ©money as agreed and required by law, and 2014 ACA International. All Rights Reserved. maintain proper procedures • Timely remittance to clients, as agreed upon • Honest and open communication with clients • Avoid unreasonable barriers to submit a complaint ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Canon III: Relationships with Consumers • Effective communication • Effective compliance management system • All individuals interacting with consumers will understand the laws and regulations © 2014 ACA International. All Rights Reserved. • Respond to disputes timely and without malice • Establish and maintain policies to keep personal data secure and resolve disputes • Implement safeguards to ensure reliable data 16 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Canon IV: Supporting the Collective Membership • Provide true and accurate information to ACA • Never assist a nonmember in accessing member-only benefits • Only use ACA materials and information for the intended and © 2014 ACA International. All Rights Reserved. allowed use • Only speak on behalf of ACA with authority • Have internal policies that comply with the ACA Code of Conduct 17 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Canon V: Participation in the Industry • Act within ACA’s mission and values in all industry dealings, with all individuals • Operate with transparency to the public • Encourage awareness of the mission and values © 2014 ACA International. All Rights Reserved. • Improve all ineffective processes and procedures • Comply with all laws, including anti-trust • Never misrepresent • Follow ACA’s anti-harassment policy 18 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Ethics Committee Review Rules • Rules of General Application • Reports of Code Violations © 2014 ACA International. All Rights Reserved. 19 • Sanctions • Appeals ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Frequently Asked Questions • How will/does the Ethics Committee view the very likely scenario that an agency is sued for FDCPA violations and the agency loses the case? • What do we do if we receive a complaint directly from a © 2014 ACA International. All Rights Reserved. consumer? • Should the Code be included in our training program? • How do I submit a complaint? 20 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International

Thank you for your membership and commitment to ACA International’s Code of Conduct © 2014 ACA International. All Rights Reserved. and Ethics expectations. Submit questions to: ethics@acainternational. org. 21 ACA Ethics and Code of Conduct Training v. 15 Helping Members Succeed! © 2020 ACA International