CODE OF CONDUCT
1. Delay Resolution Procedure (DRP)
Cepal Hellas and debtors facing financial difficulties follow the Delay Resolution Procedure (DRP) as described in detail in the Information Booklet.
Stage 1: Contact
- In case of a Delinquent Debt for more than 30 calendar days: Cepal Hellas sends you a Notification (by registered mail) within the next 15 calendar days, informing you of your inclusion in the D.E.C., and enclosing the “Information Booklet for Borrowers in Financial Distress”. The notice also requests information on your current financial situation, which is expected to be provided exclusively through the digital platform of the Code of Conduct (hereinafter the “Digital Platform of the Code of Conduct” or the “Platform”), in accordance with article 39 of Law 4818/2021 and the Decree No, Vol. B, 5909/10.10.2023), within 15 working days from receipt of the Notification.
- In case of a new delay for the same loan: a repeat communication will be made only if one year has elapsed since the last dispatch of the notice.
- In the event of no response from you within the 15 working days deadline: a registered mail will be sent within the next 15 calendar days, informing you of your inclusion in the Non-Cooperative Borrower status. The notification will also include information on your right to object to your inclusion in this scheme.
Step 2: Application
During Stage 2, it is necessary to provide information on your current financial situation exclusively through the Digital Platform of the Code of Conduct, in accordance with Article 39 of Law 4818/2021 and the Decree No. 145947 of the Government Decree issued pursuant thereto (Official Gazette, Vol. B, 5909/10.10.2023).
In particular, if you are a Natural Person (individual/freelancer/individual enterprise) or a Legal Person, you must, within fifteen (15) working days from the receipt of the relevant notice, enter the digital platform of the Code of Conduct. Access to the platform is provided through the Single Digital Portal of Public Administration (gov.gr-EPSP) and the link here (sections: “Property and taxation” > “Debt management” > “Code of Conduct“).
Using your codes from the G.G.P.S.D. (taxisnet), submit the application provided for in Article 39 of Law 4818/2021, together with the required information on your current financial and property situation, through the “Create New Application” field. When submitting the application through the Digital Platform of the Code of Conduct, please note that you must submit a separate application for each portfolio belonging to a different financial institution.
Stage 3: Assessment
During Stage 3, we carry out an assessment of your financial and asset situation based on all the data you have submitted through the Digital Code of Conduct Platform, as well as data we obtain from other sources and databases of financial behaviour, such as TIRESIA S.A. This assessment aims to be as objective as possible:
- If you are a physical person: we analyse your financial situation, the total amount and nature of your debts, your current ability to repay, your history of financial behaviour and your projected ability to repay. In this process, we take into account your Reasonable Cost of Living and other factors related to your professional, family and social profile.
- If you are a legal entity or a very small business: We consider the collectability of the receivables based on the current financial situation of the company and its prospects, as well as the corresponding circumstances relating to the partners of the company
Stage 4: Proposal/ Counter-proposal
- Following the completion of the assessment in Stage 3, we will inform you via the Digital Platform of the Code of Conduct and in writing, of one or more proposed Regulatory and/or Final Settlement Solutions. This information will be provided within 2 months from the date of receipt of your request.
- Within 15 working days of being informed of the proposed solution, you must respond via the Code of Conduct Digital Platform and proceed to one of the following options:
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- accept the proposed solution or one of the proposed solutions
- submission of an alternative
- rejection of the proposed solution.
- If you submit an alternative proposal, we will evaluate it within 1 month of receipt. You then have the following options:
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- a) Agree with the alternative in question
- b) Reject the alternative proposal, keeping the original proposal in force, with the necessary documentation
- c) Submission of a new proposal, which will be the final proposal.
- If you choose one of the cases (b) or (c), you will need, within 15 working days, to accept or reject the original/final proposal. via the Platform
Stage 5: Objection
At Stage 5, if you have been categorised as “Ineligible”, as provided for in the previous Stages, you may submit an objection using the relevant Standard Objection Form. Your objection will be examined by the Cepal Hellas Objections Committee.
2. Objections Procedure
Objection
If you have received written notification that you have been identified as a “Non-Cooperative Borrower”, you may file an objection within thirty (30) calendar days of receipt of the notification. The objection is made through Cepal’s Standard Objection Form, which can be found at the Special Contact Points (see below, point 9), as well as on the official website www.cepal.gr. Along with the objection you will need to submit supporting documents related to the procedure followed for this categorisation.
According to the Code of Conduct, the possibility to lodge an objection is only available once after the application of the Delayed Debt Resolution Procedure for each debt. It is important to note that no objection to the content of the proposal or alternative proposal is allowed.
Examination and response to an objection
The Special Objections Committee shall examine the objection and, on the basis of the data, issue a written and reasoned decision.
The decision, together with any relevant information on possible next steps, shall be sent, by registered mail, within 2 months of the submission of the objection or of the date of submission of any additional information requested by Cepal.
3. When a borrower is classified as Cooperative or Non-Cooperative
We strive to build a mutually honest working and communicative relationship with our borrowers and to maintain a constructive relationship with those who are considered Cooperative when:
- provide complete and up-to-date contact information to lenders (e.g., landline, cell phone or fax numbers, email address, home and work addresses) and designate a contact counterpart for any situation where they are unavailable,
- are available for communication with the lender and respond honestly and clearly to calls and letters from the lender, in person, within fifteen (15) business days,
- provide full and honest information to the lender regarding their current financial situation within fifteen (15) business days of the day it changes or within fifteen (15) business days of the day such information is requested from them,
- fully and honestly inform the lender of anything that may affect their financial situation in the future within fifteen (15) working days of the day they become aware of such a change (e.g. receipt of an allowance, acquisition of new assets (inheritance, etc.), loss of assets, notice of dismissal, termination of lease, purchase of insurance products, gains of any kind, etc.); and
- agree to explore alternative proposals for arrangement or restructuring with the creditor.
The concept of Lender and Borrower includes any natural or legal persons legally acting on their behalf.
The conditions set out above must be met in their entirety. If they do not apply, while at the same time, the debt of the Borrowers or Lenders remains outstanding, they will be classified as “Non-Cooperative Borrowers”. In addition, they will be informed in writing, by registered letter, of the following:
- That they have been categorized as an “Uncooperative Borrower”,
- That if they do not immediately proceed with the repayment of their overdue debt or the required actions for which they have been advised, Cepal has the right to:
- declare their financing contracts due and payable,
- initiate legal proceedings to enforce collection of the debt (e.g. issue an order for payment),
- proceed with the seizure and auction of their property,
- that, until their debt is paid in full, they and any other co-responsible parties will continue to be liable to Cepal.
- that they are excluded from the special favourable provisions of the legislation.
4. Contact points
You can contact us for any clarifications regarding the Delay Resolution Procedure applied by Cepal Hellas, from the following points:
- 209-211 Sygrou Avenue, 209-211, N. Smyrni, Attica, P.O. Box 171 21
- Exclusive telephone line for information on the Code of Conduct: 213 088 7643
- Exclusive e-mail address for the Code of Conduct: coc@cepal.gr
- Special section on the Company’s website www.cepal.gr
