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Code of Conduct pursuant to Law 4224/13

The implementation of Code of Conduct pursuant to Law 4224/13 at Pancreta Bank

General Information

The Code of Conduct lays down general principles of conduct and establishes practices aiming to enhance the climate of trust, mutual commitment and the exchange of the necessary information between the Bank and borrowers.

In the context of the Arrears Resolution Process (ARP), which was established with the Code of Conduct adopted under Law 4224/2013, PANCRETA BANK provides its clients/borrowers who face financial difficulties with the possibility to contact the Bank and settle their obligations.

Arrears Resolution Process (ARP)

The ARP describes the stages, deadlines and the minimum content of information,
that should be mutually provided by the Bank and the borrower, in order that the
risks and repayment ability of each borrower can be evaluated properly.

To whom is the Arrears Resolution Process (ARP) addressed to?

  • To the borrowers (debtors/guarantors) Individuals / Professionals and Small
    Businesses facing financial difficulties
  • To enterprises facing financial difficulties to meet their debt repayment plan,
    (small businesses i.e. Legal Entities whose annual turnover in the past 3 fiscal years
    did not exceed an average amount of one million euros (€ 1.000.000)
  • ARP Process is applied once for each debt and applies to all parties involved
    (borrowers / co-debtors / guarantors).
  • Debts from loan agreements that have been denounced prior to 01/01/2015, or
    debts denounced after 1.1.2015 for which the ARP has already been applied
  • Debts for which borrowers have made an application for protection under the L.
    3869/2010 for which a trial date has already been set
  • Debts against borrowers for which third party creditors have initiated legal
    action to ensure those debts or borrowers who are already in special liquidation
    under applicable legislation
  • Debts against borrowers who have been under clearing regime in accordance
    with current legislation.

The implementation stages of the Arrears Resolution Process (ARP)

Stage 1 Communication between borrower-Bank
Stage 2 Submission of borrower’s financial data
Stage 3 Assessment of borrower’s financial data and overall financial situation
Stage 4 Submission of suitable arrangement proposal or final settlement solution of the
borrower’s debts
Stage 5 Process of borrower’s appeal assessment

The Cooperating Borrower

Within the framework of the Code of Conduct under L.4224/2013, a borrower is
characterized as “Cooperating” when:
• Provides complete and updated contact data to the Bank
• Is available for a contact with the Bank and responds to the calls and letters with
honesty and clarity within fifteen (15) working days
• Discloses information to the Bank regarding his current financial situation within
15 working days from the day of change or from the day on which the relevant
information will be requested by the Bank
• Proceeds, with the complete and sincere disclosure of information to the Bank
which will have substantial implications to his future financial situation, within
fifteen (15) working days from the day on which he will take cognizance of such
information and
• Consents to the investigation of an alternative restructuring proposal with the
Bank as laid down by the Code of Conduct under L. 4224/2013
The classification of a borrower as “Non-cooperating”, entails the risk of auctioning
the borrower’s primary residence and the exclusion from the benefits of L.
3869/2010 and of L. 4354/2015