ICM Partners Code of Practice
ICM Partners Code of Practice is the benchmark for the collections team performance, playing a central part in the creation of ICM Partners Debt Collection Guidelines. It is essential that all members follow our Code of Practice.
Our Code of Practice guarantees that the very highest standards are applied by our team members; this not only adds value to our industry clients, but adds confidence to clients, reassuring them and potential clients that they can expect the very highest standards from ICM Partners.
Our code has been evolving since its implementation in 2004. We continually update the code to ensure it is fully applicable to the changes and new demands of the overall collections market and our clients.
ICM Partners has been ISO9001 compliant since 2007, and prides itself on its compliance within the industry.
Every team member shall:
- conduct our actions in compliance with all relevant legislation, regulations, regulatory guidance and requirements and this Code of Practice
- conduct our actions under ICM Partners, titles and engagement styles which are not intended to confuse, mislead or otherwise embarrass clients, creditors, debtors or members of the public and which will not imply any association with other organisations, governmental bodies or persons which either do not exist or carry no association with the business of ICM Partners
- cooperate with the IMA, AICM, regulators and organisations that regulate or supervise the debt and/or recoveries industry
- make available on ICM Partners website, a copy of this ICM Partners Code of Practice
- provide adequate and sufficient training to our team members in order to ensure that they conduct themselves in accordance with this Code of Practice
- regularly examine and audit our practices, strategies, communications and compliance culture against this Code of Practice
- ensure that any communication complies with this Code of Practice and is in plain English
- have and maintain clear and effective policies and procedures covering all business activities we are engaged in
- not unlawfully discriminate against any person
- have in place a separate business account for all monies collected on behalf of clients and instruct their bank – that the account only holds client money
- inform our clients of the true rates of charges for services rendered
- distribute client money only as agreed by the client
- report sums collected and remit to our clients at least once a month, or as otherwise agreed, all monies collected
- ensure we undertake due diligence and audit any third party agent on a regular basis to ensure adherence to regulatory requirements and this Code of Practice regardless of whether they are a IMA or AICM member
- comply with all reasonable requests for information made by debtors or their representatives, regulators, clients and creditors, whether statutory or not, and upon payment of the statutory fee if applicable
- not place restrictions or time limits on the legitimate querying of unallocated payments
- treat businesses with whom we deal fairly and transparently
- provide prior written notice to debtors when outsourcing accounts, to ensure the debtor’s awareness of who will be contacting them
- make contact at reasonable times and at reasonable intervals, taking into consideration the reasonable wishes of the debtor, which may include the preferred method of communication. Where possible, make debtors aware of business opening times and highlight contact periods
- take appropriate steps to ensure the accuracy of data processed by ICM Partners and in particular data relating to individuals and their debts.8 Code of Practice
- when an account is reasonably disputed or a complaint is received, suspend collection activity and investigate and where applicable refer the matter to their client
- ensure that it does not put any debtor under undue pressure to borrow money
- take reasonable steps to ensure that the person being contacted is in fact the debtor
- communicate with debtors fairly and transparently, and not intentionally mislead them
- cooperate with debtors and their authorised third parties in line with regulatory guidance, and not act in a manner intended to publicly embarrass or cause them distress
- treat debtors fairly and not subject debtors (or their authorised representatives) to aggressive practices, or conduct which is deceitful, oppressive, unfair or improper, whether lawful or not
- exercise forbearance and consideration of debtor’s circumstances, of which they are aware, in particular in relation to those who are particularly vulnerable or experiencing severe financial hardship
- take into account the debtor’s circumstances and ability to pay when seeking to recover debts
- ensure that we take into account the debtor’s domicile and the law applicable to the agreement underlying the debt.