>OPERATING FRAMEWORK>Code of Conduct in the relations with Borrowers (L. 4224/2013)

Cepal Hellas’ aim, with regards to Borrower relations, is to enhance and strengthen a climate of trust through the adoption of flexible, beneficial, and effective solutions. In this context, Cepal Hellas fully complies with the Code of Conduct under L.4224/2013, which was introduced in 2014 by the Bank of Greece and applies to all credit and financial institutions as of December 31st, 2014 and which was amended and restated by virtue of the Credit and Insurance Committee Decision

no. 392/1/31.05.2021.

General Principles of the Code of Conduct

The Code of Conduct establishes the general principles and rules of conduct to be observed by financial institutions and Borrowers and adopts best practices and procedures aimed at strengthening the climate of trust, mutual commitment and exchange of necessary information between the Borrower and the institution, with a view to finding alternatives for the arrangement or final settlement of debts in arrears.

At Cepal Hellas, we responsibly follow and apply all of the Code of Conduct principles to better facilitate the Borrowers who are unable to fulfil their financial obligations. We inform them in a timely and accurate manner about the appropriate solutions for the arrangement or final settlement of their debt, always taking into consideration the capabilities and specificities of each Borrower.

Ιn the aforesaid context, the Arrears Resolution Process (A.R.P.) is applied by both Cepal Hellas and Borrowers facing financial difficulties, as described in detail in the Information Booklet.

Cepal Hellas is obliged to include in Stage 3 of the A.R.P. the Borrower who submits, on his/her own initiative, the information that is required by the Code of Conduct for the assessment of the repayment ability of his/her debts, except in the cases of Section C.2 of the Code Conduct (cases under which Cepal Hellas is not obliged to commence or may suspend or suspends the A.R.P that has already commenced), as indicated in the Information Booklet.

It is noted that in the case of Borrowers, assigned for management by Institutions supervised by the Bank of Greece, the implementation of the A.R.P. stages of the Code of Conduct, is carried out on a case-by-case basis by the relevant supervised Institutions.

Code of Conduct Application Forms

Points of Contact

For any information regarding the Code of Conduct, you can turn to the following special Contact Points:

  • Telephone Line: 2130887643
  • Email Address: coc@cepal.gr
  • Cepal Hellas’s Registered Office: 209-211 L. Syggrou, 171 21, Nea Smyrni Attica

Non-cooperative Borrower

Within the framework of the Code of Conduct, a Borrower is characterized as “Cooperative” to his/her lenders, when he/she:

  • provides complete and up-to-date contact details to his/her lenders (telephone number, email) and designates a relative or friend as an authorized representative, in case the Borrower is not available;
  • is available to communicate with his/her lender and responds to calls and letters sincerely and clearly, by any appropriate mean within 15 working days;
  • fully and sincerely discloses information regarding his/her current financial situation to his/her lender within 15 working days from the day his/her financial situation has altered, or within 15 working days from the day on which the relevant information is requested by the lender;
  • fully and sincerely discloses information to the lender that will have a substantial effect on  his/her future financial situation (loss of assets ownership, dismissal announcements), within 15 working days from the day he/she becomes aware of such events; and
  • consents to the pursuit of an alternative restructuring proposal with the lender, according to the provisions of the Code of Conduct.

The definition of Lender or Borrower encompasses any individual or legal entity that acts on their behalf, respectively. Any Borrower that does not fall within the above definition of Cooperative Borrower is characterized as “Non-Cooperative Borrower”.

In case of a lack of cooperation from Borrower’s side and the non-fulfilment of the above conditions, Cepal Hellas will inform the Borrower in writing about his/her characterization as “Non-cooperative Borrower”. From that point on, there is a significant risk of him/her being excluded from any beneficiary legal provisions or/and other advantages that he/she could have, had he/she cooperated with Cepal Hellas to find a suitable solution (e.g. Cepal Hellas refraining from any legal enforcement actions). Cepal Hellas’ right to initiate any legal/judicial actions is maintained, while at the same time the Borrower shall remain liable for any outstanding balance, which continues to bear interest, in accordance with the initial agreement and the applicable law.

In any case, the Borrower may request support and additional information in relation to the Code of Conduct from specialized bodies of Advisory Support and Extra-Judicial Μediation, such as:

  • The Offices and Centers for the Information and Support of Borrowers of the Special Secretariat for Private Debt Management (E.G.D.I.X.) or on the respective website (http://www.keyd.gov.gr)
  • The Registry of Accredited Mediators of Article 7 of L. 3898/2010 accessible on the website HERE
  • Other bodies, established for this purpose, in accordance with the current legislation.

List of the Portfolios under Servicing for the Information of Borrowers

By virtue of the Servicing Agreement dated 23.09.2021 and the Private Agreement for the Servicing of Receivables dated 21.10.2021, entered into between Cepal Hellas and Burlington Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Piraeus Bank, in accordance with the provisions of Law 4354/2015.

By virtue of the Servicing Agreement dated 08.10.2021 and the Private Agreement for the Servicing of Receivables dated 17.12.2021, entered into between Cepal Hellas and Cosmos Securitisation Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 03.04.2024 and the Private Agreement for the Servicing of Receivables dated 03.04.2024, entered into between Cepal Hellas and CREDITABLE OPPORTUNITIES FUND II SCS RAIF acting on behalf of its compartment Southrock II, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from the company Cosmos Securitization Designated Activity Company, in accordance with the provisions of Law 5072/2023.

By virtue of the Servicing Agreement dated 08.04.2021 and the Private Agreement for the Servicing of Receivables dated 18.06.2021, entered into between Cepal Hellas and Galaxy II Funding Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 30.11.2020 and the Private Agreement for the Servicing of Receivables dated 25.06.2021, entered into between Cepal Hellas and Galaxy III Funding Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 08.04.2021 and the Private Agreement for the Servicing of Receivables dated 18.06.2021, entered into between Cepal Hellas and Galaxy IV Funding Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 30.11.2020 and the Private Agreement for the Servicing of Receivables dated 25.06.2021, entered into between Cepal Hellas and Gemini Core Securitisation Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 31.12.2021 and the Private Agreement for the Servicing of Receivables dated 17.01.2022, entered into between Cepal Hellas and GLX ONE Holding Single Member S.A., as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Galaxy II Funding Designated Activity Company, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Cepal Hellas in the name and on behalf of Galaxy II Funding Designated Activity Company.

By virtue of the Servicing Agreement dated 25.05.2023 and the Private Agreement for the Servicing of Receivables dated 25.05.2023, entered into between Cepal Hellas and Hermes Acquisitions B Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

a) Cell Portfolio

 

By virtue of the Servicing Agreement dated 16.10.2023 and the Private Agreement for the Servicing of Receivables dated 20.10.2023, entered into between Cepal Hellas and Hoist Finance AB (PUBL), as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

 

b) Light Portfolio

 

By virtue of the Servicing Agreement dated 21.10.2022 and the Private Agreement for the Servicing of Receivables dated 7.11.2022, entered into between Cepal Hellas and Hoist Finance AB (PUBL), as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

 

 

c) Mercury Portfolio

 

By virtue of the Servicing Agreement dated 18.06.2019 and the Private Agreement for the Servicing of Receivables dated 18.06.2019, entered into between Cepal Hellas and Hoist Finance AB (PUBL), as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

 

d) Orbit Portfolio

 

By virtue of the Servicing Agreement dated 22.03.2022 and the Private Agreement for the Servicing of Receivables dated 24.03.2022, entered into between Cepal Hellas and Hoist Finance AB (PUBL), as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank

 

e) Pearl Portfolio

 

By virtue of the Servicing Agreement dated 13.02.2024 and the Private Agreement for the Servicing of Receivables dated 13.02.2024, entered into between Cepal Hellas and Hoist Finance AB (PUBL), registered in Sweden (P.O. Box 7848 10399 Stockholm Sweden) with registration number at the business registry of Sweden 556012-84889 (“Hoist Finance”), as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from the companies Cosmos Securitization Designated Activity Company, Galaxy II Funding Designated Activity Company and Orion X Securitization Designated Activity Company (the “Sellers”), in accordance with the provisions of Law 5072/2023. The Sellers, pursuant to art. 21 of Law 5072/2023 proceeded on 16.02.2024 with the sale and transfer of receivables from loans and/or credits (the “Receivables”), which they had initially acquired from ALPHA BANK SA by way of securitization, to Hoist Finance.

 

For any information regarding the processing of personal data by Hoist Finance, please visit the link https://cepal.gr/wp-content/uploads/2023/10/Hoist-Customer-Privacy-Notice.pdf., already notified with relevant individual letters that were sent to borrowers and guarantors of the Receivables.

By virtue of the Servicing Agreement dated 31.07.2019 and the Private Agreement for the Servicing of Receivables dated 31.07.2019 entered into between Cepal Hellas and  Lana Securitisation S.A.R.L, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 08.04.2021 and the Private Agreement for the Servicing of Receivables dated 18.06.2021, entered into between Cepal Hellas and Orion X Securitisation Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 25.05.2023 and the Private Agreement for the Servicing of Receivables dated 25.05.2023, entered into between Cepal Hellas and Pluto Financial Investor Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 03.07.2020 and the Private Agreement for the Servicing of Receivables dated 17.07.2020 entered into between Cepal Hellas and Poseidon Financial Investor Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Alpha Bank, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 12.07.2019 and the Private Agreement for the Servicing of Receivables dated 12.07.2019, entered into between Cepal Hellas and Samco Holdings S.A.R.L., as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from Credit M Single Person SA, in accordance with the provisions of Law 4354/2015.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Credit M Single Person SA.

By virtue of the Servicing Agreement dated 25.05.2023 and the Private Agreement for the Servicing of Receivables dated 25.05.2023, entered into between Cepal Hellas and Saturn Financial Investor Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by Alpha Bank.

By virtue of the Servicing Agreement dated 05.12.2019 and the Private Agreement for the Servicing of Receivables dated 06.12.2019, entered into between Cepal Hellas and Symbol Investment NPLCo Designated Activity Company, as in force, Cepal Hellas has undertaken the servicing of the receivables acquired by the aforesaid company from National Bank of Greece, in accordance with the provisions of Law 3156/2003.

 

For additional information in relation to the abovementioned transfer you may refer to the relevant Announcement published by National Bank of Greece.