Consumer Protection Policy


The following Consumer Protection Standards reflect the core principles, which the Bank employees observe at all times in their dealings with financial consumers. Bank employees ensure that the clients have a reasonable holistic understanding of the products and services, which they may be acquiring or availing. Thus, any information given to consumers whether in writing, electronically, or orally should be fair, clear, transparent, and easily comprehensible in order for them to make an informed choice about a product or service. This is made possible by providing the consumer with ready access to information that accurately represents the nature and structure of the product or service, its terms, and conditions, as well as its fundamental benefits and risks. Bank employees adhere to the following principles:

a. Ensures that offering documents of products and services contain the information necessary for customers to be able to make an informed judgment of the product or service. All key features and risks of the products are highlighted prominently in a succinct manner. Where a product is being offered continuously, its offering documents are updated in accordance with the Bank’s existing policies.

b. Readily and consistently makes available to the customer a written copy of the Terms and Conditions (T&C) that apply to a product or service. The contents are fully disclosed and explained to customers before initiating a transaction. Where and when warranted, reference to the T&C is made while transacting with the consumer and before consummating the transaction, if such reference is material to the understanding of the consumer of the nature of the product or service, as well as its benefits and risks. As a written document, the T&C is complete but concise, easily understandable, accurate, and presented in a manner that facilitates the consumer’s comprehension. The T&C includes at least the following:

i. The full price or cost to the customer including all interest, fees, charges, and penalties. The T&C clearly states whether interest, fees, charges, and penalties can change over time. The method for computing said interest, fees, charges, and penalties are presented in accordance with Truth in Lending dated 20 July 2011. The Bank may only charge interest based on the outstanding balance of a loan at the beginning of an interest period. For a loan where the principal is payable in installments, interest per installment period shall be calculated based on the outstanding balance of the loan at the beginning of each installment period.

ii. General information about the operation of the products or services including the customer’s obligations and liabilities;

iii. The cooling-off period, if applicable.

iv. Cancellation, return and exchange policies, and any related cost;

v. The actions and remedies that the Bank may take in event of a default by the customer;

vi. Procedures to report unauthorized transactions and other contingencies, as well as the liabilities of parties in such cases; and

vii. Summary of the Bank’s complaints handling procedure.

c. Advises customers to read and understand the applicable T&C when considering a product or service.

d. Communicates in such a manner that clients can understand the terms of the contract, their rights, and obligations. Staff communicates with techniques that address literacy limitations, e.g., (1) where a consumer is unable to understand English, provide an oral explanation in a language the consumer understands; or (2) where a consumer is unable to understand written information, explain orally to the consumer the written information.

e. Provides customer adequate time to review the T&C of the product or service, asks questions, and receives additional information prior to signing contracts or executing the transaction. The staff is available to answer the questions and clarifications from the financial customer.

f. Fully knowledgeable about the products and services marketed, including statutory and regulatory requirements, and are able to explain the nuances to the consumer.

g. Uses a variety of communication channels to disclose clear and accurate information. Such communication channels are available to the public without the need for special access requirements, which may entail additional expenses. Communication channels should be sufficient.