POLICY for protection, fair and ethical treatment of borrowers

  1. General principles

1.1. This policy governs the principles and basic rules by which “Finance Info Assistance ” EAD (hereinafter referred to as the “Company”) carries out the activity of acquiring and servicing receivables, so as to guarantee protection, fair and ethical treatment of borrowers and all obligated persons and full transparency in servicing receivables.

1.2. The Policy is adopted on the basis of Art. 8, item 7 of the Act on Credit Servicers and Credit Purchasers (CSPCC).

1.3. The policy regulates the principles, procedures and organizational measures for correct treatment of debtors throughout the life cycle of receivables (from transfer to repayment or sale).

1.4. The Company carries out its activities in compliance with:

  • The Law on the Protection of the Rights of Persons with Disabilities and the by-laws for its implementation;
  • The Obligations and Contracts Act, the Consumer Protection Act (where applicable) and other relevant substantive and procedural laws;
  • The Law on Measures Against Money Laundering (LAM) and the Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction (LMFTROMU);
  • Regulation (EU) 2016/679 (GDPR), the Personal Data Protection Act and related internal rules on personal data protection;
  • The Credit Institutions Act and the subordinate legislation implementing it;
  • The relevant regulations of the Bulgarian National Bank;
  • The Consumer Protection Act, in cases where this is relevant to the specific case;
  • Law on Protection from Discrimination;
  • Moral and ethical rules of conduct and good practices in the field of debt collection;
  • the Company’s internal policies, rules and procedures.

1.5. The Company undertakes to treat all borrowers/obligors:

  • with respect and without discrimination;
  • honestly, transparently and in good faith;
  • while respecting their dignity and privacy;
  • in accordance with the principles of proportionality and necessity.

1.6. All employees and managers act with professionalism , integrity and openness . The emphasis is on the incorrect ones practices – prohibit is aggression , threats or discrimination against the borrower. Communication must be clear , respectful and understandable , without​ hidden identities or misleading information.

  1. Honest and correct communication

2.1. Communication with borrowers and obligors is carried out by authorized employees of the Company, in compliance with the legal, moral and ethical rules of conduct and internal instructions for working with clients.

2.2. The Company’s employees are expressly prohibited from:

  • use threatening, abusive, degrading or aggressive language;
  • to exercise undue pressure, harassment or actions that could be perceived as intimidation;
  • provide misleading, intentionally incomplete or inaccurate information regarding the amount of the debt, the legal consequences of default or the debtor’s rights.
  • to harm the honor, good name and reputation of clients and obligated persons.
  • to make telephone calls between 8:00 p.m. and 7:00 a.m., as well as on weekends and holidays;
  • to make contact in connection with or on the occasion of the claim with persons against whom it has not been transferred;
  • to post notices and information about the consumer’s debt in any form in public places.
  • the application on aggressive and misleading commercial practices by the meaning on The law for protection on users .

2.3. Contacts with borrowers are carried out on the days and hours established by law, in accordance with the provisions of the Law on Credit Servicers and Credit Buyers and other applicable regulations governing communication with clients and obligated persons, taking into account the need not to unreasonably violate the privacy of personal and family life, professional commitments and peace of mind of individuals.

2.4. The Company communicates only by making telephone calls or sending requests in written and electronic form, addressed personally to the debtor. The Company provides the debtor with the opportunity to visit our office at 8 Vrabcha Str., 1000, Oborishte district, Sofia, on its own initiative, during the Company’s working hours every working day from 08:30 to 17:00.

2.5. Contact is maintained regularly, but reasonably and unobtrusively , so that the debtor does not feel persecuted – on the principle of “the number of messages should be proportional and not create unnecessary pressure”.

  1. Transparency and right to information

3.1. The Company sends the client/obligor a notification of the transfer of receivables, signed by the transferor and the buyer, with content according to Art. 18, para. 4 of the ZLOKKK.

3.1. 1 The notification is sent after each transfer of a claim and always before the first action to collect a receivable, as well as when the buyer on credits not established in the European union or no headquarters or central governance in the European union or upon request by the borrower.

3.1.2 In cases where the Company concludes an agreement with a credit institution or a person servicing loans to carry out the activities under Art. 6, para. 2 of the LOCCC, with respect to receivables under non-performing loans provided to consumers and where the notification under Para. 1 is sent by the credit institution or the person servicing loans, and in cases under Art. 35, para. 2 of the LOCCC the notification is sent by the buyer of loans.

3.1.3. The notification under paragraph 1 shall be provided to the borrower free of charge, on paper or on another durable medium.

3.1.4. The notification under para. 1 shall contain:

  1. information about the transfer made, including the date of the transfer;
  2. identification and contact details of the credit buyer;
  3. identification and contact details of a person servicing loans or a credit institution

institution where the credit purchaser has outsourced the credit servicing activities;

  1. data certifying an issued license when the credit buyer has outsourced activities

on loan servicing to a loan servicer, and when the loan buyer

performs independent servicing under a loan agreement;

  1. identification and contact details of the external contractor, where applicable;
  2. clearly identified person or contact point for providing information from:
  3. a) the credit buyer;
  4. b) a credit institution when outsourcing loan servicing activities;
  5. c) a loan servicer, when outsourcing loan servicing activities;
  6. d) external contractor, where applicable;
  7. information about the borrower’s obligation as of the date of sending the notification, containing the type and amount of the claim, its basis, the date of the claim becoming due, if announced and known, the amounts repaid to date – by type, amount and date of repayment, and all amounts due, including principal, interest, fees and other costs, indicating the methodology for calculating the legal interest that is charged on the interest-bearing part of the non-performing loan, as of the date of sending the notification;
  8. an indication of the applicability of Bulgarian legislation and European Union law in the field of contract law enforcement, consumer protection, borrowers’ rights and criminal law after the assignment of the claim;
  9. the purposes for which the personal data are processed and the legal basis for their processing;
  10. the type of personal data;
  11. the period for storing personal data or the criteria to be used to determine this period;
  12. the existence of the right to access, correct, and delete personal data;
  13. the existence of the right to restrict the processing of personal data, to object to the processing or to transfer personal data;
  14. name, address and contact details of the competent authorities for lodging a complaint in the Member State in which the borrower has his habitual residence or his registered office, or of the Member State in which his head office is located where, under national law, he has no registered office;
  15. information about the right to protection in the event of expired statute of limitations, unfair clauses in the contract with the initial creditor and the possibilities for legal challenge when the borrower is a consumer.

3.2. If necessary, the Company issues certificates of settled obligations, references and/or concludes written agreements under the terms and conditions of its internal rules and the applicable legislation.

3.3. Upon a request for correction of inaccurate data, including those submitted to the Central Credit Register (CCR) of the Bulgarian National Bank, the Company shall conduct an inspection and, if justified, undertake the relevant corrections within the time limits established by law.

  1. Consideration of the financial situation of borrowers

4.1. When discussing ways to repay the obligations, the Company’s employees, to the extent possible and based on the information provided by the borrower, strive to take into account his real financial situation and workload.

4.2. Where permissible under internal rules and in the interest of the lender and the borrower, the following options may be offered, depending on individual circumstances:

  • deferral of obligations;
  • grace period;
  • reduction of the receivable or suspension of interest accrual;
  • consolidation of obligations in the presence of more than one obligation;
  • concluding an agreement with agreed payment terms;
  • other forms of voluntary settlement that do not result in a violation of the law or in manifestly unfavorable and unfair conditions for the debtor.

4.3. Each proposal is considered individually. Making a decision does not relieve the borrower of his obligation to repay the debt, but aims to find a balanced, legal and practical solution that satisfies both parties, taking into account their legal interests.

4.4. Legal and coercive actions to collect receivables under the Civil Procedure Code or Commercial Code shall be undertaken only if all other options for voluntary settlement have been exhausted.

  1. Referral to counseling, mediation, and social services

5.1. When, in the process of communication, employees establish that the borrower is in a particularly difficult financial or social situation (e.g. loss of job, reduced income, serious illness, difficulties in supporting a family, etc.), they may, at their discretion and without assuming any obligation for the result, inform him about the possibility of seeking independent assistance, including:

  • free or low-cost legal and financial advice regarding his obligations;
  • consultations from non-governmental consumer protection organizations, when such have been established and are applicable to the specific case;
  • social services and support from the competent state and municipal authorities, in cases where such are available and applicable in the specific case.

5.2. The Company may informatively direct borrowers to:

  • Consumer Protection Commission (CPC) – on issues related to consumer rights in consumer loans and contractual relations, in cases where the law provides for it as a competent authority;
  • The Ombudsman of the Republic of Bulgaria – in case of complaints about actions or inactions affecting the rights and legitimate interests of citizens;
  • Recognised consumer protection organisations and non-governmental organisations that provide assistance with over-indebtedness and personal finance management;
  • Mediation centers , including those attached to courts, for disputes that are subject to out-of-court settlement.

5.3. The Company recognizes the possibility of disputes arising between it and the borrowers being resolved through mediation – a voluntary, confidential and extrajudicial method of resolving disputes, in which an impartial third party (mediator) assists the parties to reach a mutually acceptable agreement. The Company is not obligated under the previous sentence, as the assessment is made on a case-by-case basis, taking into account the interests of both parties.

5.4. Referral to consultants, mediation and social services is informative in nature and:

  • does not constitute individual legal, financial or social advice from the Company;
  • is not a recommendation or guarantee of the quality of a specific consultant, organization or mediator;
  • does not relieve the borrower from his obligation to independently monitor the protection of his rights and interests and, if necessary, to seek qualified legal assistance.
  1. Protection of personal data and response to abuse

6.1. The Company processes the personal data of borrowers and other obligated persons in strict compliance with Regulation (EU) 2016/679, the Personal Data Protection Act and its internal rules on personal data protection.

6.2. Personal data are processed only to the extent necessary for:

  • establishment, management and collection of receivables;
  • fulfillment of legal obligations of the Company (e.g. under the Law on the Protection of the Financial Markets,
  • protection of the legitimate interests of the Company, while respecting the rights and freedoms of data subjects.

6.3. The Company applies technical and organizational security measures, including:

  • access control to systems and premises;
  • use of personal accounts and passwords;
  • encryption and secure data storage when necessary;
  • restriction on exporting and copying information;
  • procedures for responding to personal data incidents.

6.4. In case of suspicion of misuse of personal data, identity theft or unauthorized use of other people’s documents, borrowers may:

  • to contact the Company for assistance and verification of the case;
  • in case of reasonable suspicion of a crime being committed – to file a report to the Ministry of Interior (police) and/or the Prosecutor’s Office of the Republic of Bulgaria.

6.5. The Company, within the framework of its legal obligations (including under the Anti-Money Laundering Act and the Criminal Code), also takes action to report to the competent authorities (e.g. SANS/Financial Intelligence Directorate, Ministry of Interior, Prosecutor’s Office) when it finds evidence of fraud, document crimes, identity theft or other crimes.

  1. Additional mechanisms for the protection of rights and external bodies

7.1. In addition to the possibility of submitting complaints directly to the Company, borrowers and obligors have the right, in case of disagreement with the Company’s response or behavior, to also refer the matter to competent state authorities, including, as the case may be:

  • Bulgarian National Bank (BNB) – as the supervisory authority under the LCACC and the legislation governing loan servicers and loan purchasers;
  • Consumer Protection Commission (CPC) – on issues related to consumer rights, when the relations fall within the scope of consumer protection legislation;
  • Personal Data Protection Commission (PDPC) – in case of complaints about the way personal data is processed;
  • Ombudsman of the Republic of Bulgaria – in cases of violations of rights and legitimate interests from the activities of bodies and institutions, as well as in cases of systemic practices affecting citizens;
  • Civil and administrative courts ;
  • Other competent authorities, as appropriate.

7.2. In case of reasonable suspicion of crimes committed – for example, fraud, document crimes, unlawful collection or use of personal data, identity theft, etc. – borrowers and obligated persons have the right to file a report or complaint to:

  • The bodies of the Ministry of Interior (police) ;
  • The Prosecutor’s Office of the Republic of Bulgaria .

7.3. The Company encourages borrowers to use the legal mechanisms to protect their rights and, if necessary, to seek qualified legal assistance from a lawyer or from organizations providing free legal assistance under the Legal Aid Act.

  1. Training, internal control and periodic review

8.1. The company organizes introductory and periodic training for employees regarding:

  • ethical and fair treatment of borrowers;
  • correct and non-discriminatory communication;
  • the requirements of the ZLOKKK, ZMIP, ZMFTROMU, GDPR and internal rules;
  • recognizing cases of vulnerable borrowers and appropriate behavior towards them.

8.2. The management and the responsible departments carry out ongoing control for compliance with this policy. The complaints and signals received are analyzed periodically in order to:

  • identifying recurring problems;
  • taking corrective and preventive measures;
  • increasing the quality of service and the level of protection for borrowers.

8.3. The Policy is reviewed periodically, as well as in the event of significant changes in the regulatory framework or in the business model of the Company. The amendments are approved by the Board of Directors and are published in an up-to-date form on the Company’s website www.infoassistance.eu .

By adopting and implementing this Policy for the Protection, Fair and Ethical Treatment of Borrowers, “Finance Info Assistance ” EAD declares its commitment to carry out the activity of acquiring and servicing receivables in a transparent, lawful and responsible manner, while respecting the rights and legitimate interests of borrowers and all obligated persons.

This policy was adopted by the Board of Directors of “Finance Info Assistance ” EAD on 27.11.2025.

Executive Director :

Dimitar Mihaylov