Article 25 of the Law of Ukraine "On Consumer Lending"

Requirements for Interaction with Consumers and Other Persons in the Settlement of Overdue Debt (Ethical Conduct Requirements)

1. Interaction between the lender, new lender, or debt collection company and the consumer, their close relatives, representative, heir, guarantor, property guarantor, or other third parties specified in the consumer credit agreement and who have provided consent for such interaction, may be carried out exclusively through:

1. Direct interaction (telephone and video calls, personal meetings). Personal meetings are permitted only between 9:00 AM and 7:00 PM, provided that the person with whom the interaction occurs does not object and has given prior verbal or written consent. The time and place of the meeting must be pre-agreed;

2. Sending text, voice, or other messages via telecommunications, including using software or technologies without the involvement of the lender’s, new lender’s, or debt collection company’s employee;

3. Sending postal correspondence marked "Deliver in Person" to the person's residence, stay, or workplace.

1. During the first interaction with the consumer, their close relatives, representative, heir, guarantor, property guarantor, or other authorized third parties, within the framework of overdue debt settlement, the lender, new lender, or debt collection company must provide:

1. The full name of the lender (if the interaction is initiated by the new lender or debt collection company), their full name, contact phone number, and address (email or postal) for correspondence;

2. The full name of the person interacting with the consumer or authorized persons, or the identifier/code used to identify the person, or indication that software or technology is used for interaction;

3. The legal basis for the interaction;

4. The amount of overdue debt (loan amount, interest, commissions, and other payments related to the loan), as well as any penalties or charges due to non-fulfillment of obligations. If third parties (e.g., relatives) are involved per the credit agreement, this information may be shared with them only if the consumer has consented. The calculation is carried out by the lender or new lender.

1. Upon the consumer’s or authorized person's request, the new lender or debt collection company must provide, within 5 business days after the first interaction, documents confirming the information specified in part 2 of this Article, including a detailed calculation of overdue debt and its legal basis, either in person, via email, post, or by any other method specified in the agreement.

The lender must provide such documents within 7 business days unless otherwise specified by law.

No repeated interaction is allowed from the new lender or debt collection company until the documents are provided. The same rule applies to the lender.

Providing documents is considered completed when:

1. The lender, new lender, or debt collection company receives confirmation that the documents were sent via email;

2. 11:59 PM on the 10th business day from the dispatch date of registered mail with delivery receipt, or earlier if a delivery notice is received.

1. All direct interactions must be recorded using video and/or audio recording equipment, as required by the National Bank of Ukraine, to protect legal interests. All involved parties must be informed of the recording.

Recordings must be kept for 3 years.

Only personal data permitted by law and consented to may be processed. Processing of data from unauthorized third parties or specific sensitive data (e.g., work schedules, health status, religion, social media info, photos, etc.) is prohibited unless required by law or written consent is provided.

1. Ethical standards must be upheld by all involved entities. The following is prohibited:

• Threats, blackmail, or actions harming dignity, health, reputation;

• Misleading about debt size, legal consequences, affiliation with authorities;

• Contact outside 9:00 AM–8:00 PM or on holidays, unless initiated by the consumer;

• More than 2 daily interactions, except when initiated by the consumer;

• Hiding contact information;

• Using autodial for more than 30 minutes daily;

• Threatening markings or misleading messages on envelopes;

• Informing unauthorized third parties about debt;

• Forcing unrelated persons to assume debt;

• Damaging or threatening consumer's reputation;

• Demanding repayment outside agreed terms;

• Interacting after the consumer has appointed a representative and provided documents;

• Meeting without prior agreement;

• Contacting persons not consented to in the agreement.

1. The lender, new lender, or collection company may interact with third parties whose data was provided by the consumer for the purpose of informing them about overdue obligations. The consumer is responsible for obtaining their consent.

The information form must include a warning about criminal liability under Article 182 of the Criminal Code of Ukraine.

If a third party objects during the first interaction, data processing must cease immediately. If multiple collection companies are involved, all must be informed to stop processing.

1. Actions taken by third parties on behalf of the lender, new lender, or debt collection company are considered as actions of those entities.

2. Consumers cannot be charged for debt settlement costs. All expenses must be borne by the lender, new lender, or debt collection company.

3. Direct interaction aimed at debt recovery is prohibited if documents are received showing that the person is:

1. Legally incapable or with limited capacity;

2. Under inpatient medical treatment;

3. A person with Group I disability;

4. A minor.

If documents are not provided, the condition is considered unconfirmed.