1. Preface:

Aurum Afghanistan Mobile Money Services (AAMMS) consumer protection policy sets clear rules of conduct regarding customers. It aims to ensure that consumers: (1) receive information to allow them to make informed decisions, (2) are not subject to unfair or deceptive practices and (3) aimed at giving consumers the knowledge and skills to understand the risks & rewards of using Aurum Afghanistan products and service & legal rights/obligations in using it. Clear rules of conduct for AAMMS, combined with programs of awareness for consumers, will increase consumer trust in AAMMS & will support the development of the Aurum Mobile Money Services. AAMMS consumer protection policy provides effective safeguards for consumers while empowering consumers to exercise their legal rights/fulfill their legal obligations.

2. Introduction:

Aurum-Afghanistan is an Afghan Mobile Money Service Company regulated by the Central Bank of Afghanistan-EMI section. The head office of Aurum-Afghanistan is located in Kabul, Afghanistan with the intention of 34 branches across Afghanistan. Aurum Mobile Money Services offer significant opportunities for improving the efficiency of financial services by expanding access and lowering transaction costs. Mobile money is a recent innovation that provides financial transaction services via mobile phone smoothly, the technology has spread rapidly in the developing world. In recent times, we have seen that Da Afghanistan Bank, our regulator is keenly working and promoting Electronic Money Service organizations to bring efficiency in the financial services of Afghanistan. Considering this need and to be the part of improvements, Aurum-Afghanistan invested in Mobile Money services and came up with highly qualified and skilled professionals. Aurum-Afghanistan is equipped with advanced technology to be the leader in the mobile money services in Afghanistan.

3. Purpose of customer Protection Policy:

The rights of the customer, being significant stakeholder, be ensured and protected by AAMMS with best of its capacity. Following are the purposes of Customer Protection policy:

  • To create an effective and efficient system to ensure customer’s interest.
  • To recognize and acknowledge the customer’s rights.
  • To promote and protect Customer’s economic interest.
  • To ensure that the customer’s rights should be taken care of with regulated Electronic Money Institution’s regulation based on best prudent approaches.
  • To seek prudent measures to redress in case of infringement of customer’s right.
  • To increase Brand loyalty and help to retain the customers.
  • To encourage high levels of ethical conduct for those engaged in the providing financial services to consumers.

AAMMS provides clear consumer protection guidelines regarding products and services, and all arrangements are in place to ensure the thorough, objective, timely and fair implementation and enforcement of all such directions.

a. AAMMS created an effective system for the protection of a consumer of AAMMS products and services.
b. There should be coordination and cooperation between the various departments mandated to implement, oversee and enforce consumer protection policy.

4. Customer Protection Policy:

  • This policy provides clear consumer protection rules regarding AAMMS products and services. The necessary points are highlighted to ensure objective, timely and fair implementation (and enforcement) of the guidelines.
  • Prudential supervision and consumer protection supervision may be placed by Risk Department of the institution, this is adequate to enable the effective implementation of consumer protection rules.
  • A proper system ensures that the ultimate resolution of any consumer protection dispute regarding a AAMMS product or service is affordable and timely delivered in a professional manner.

 

5. Disclosure and Sale:

AAMMS, at the time or before making a recommendation to a consumer regarding a specific GB`s product or service, the bank collects information from the consumer with an understanding to ensure that the products or services is likely to meet the needs and capacity of that consumer.

  • Before a consumer avails AAMMS product or service, AAMMS provides a written copy of the AAMMS`s general and specific terms and conditions applicable for the products or services.
  • Except for securities and derivatives, AAMMS`s products or services with a long-term savings component—or those subject to high-pressure sales practices have a “cooling-off” period, during which the consumer may cancel the contract without penalty. Nothing prevents AAMMS from recovering any processing fees incurred.
  • Whenever an individual borrower is obliged by AAMMS to avail a product or service as a pre-condition for receiving another product or service, the borrower is free to choose the provider for the product or service.
  • In AAMMS advertising we need to disclose that we are regulated and the advertising materials identify the relevant points.
  • It is binding on the part of AAMMS, in keeping informed all the stakeholders, the periodic performance of the institutions and charter of consumer’s / customer’s to be displayed in institution’s website. Since Electronic Money Institution’s business being regulated by the Central Bank of Afghanistan as well as other country laws and regulations, AAMMS is under obligation to disclose its business affairs and rights and obligations of consumers / customers.
  • Staff of AAMMS who deal directly with consumers receive adequate training, suitable for the complexity of the products or services they sell. In particular, employees should be qualified as appropriate for the complexity of the AAMMS product or service they sell.

6. Privacy & Data Protection:

Bellow are some steps to be take care off by Institutions:

  1. AAMMS is required to protect the confidentiality and technical security of customer data. The law states specific rules and procedures concerning the release of customer records to Afghanistan authority.
  2. The law provides consumer rights regarding information sharing, including access, rectification, blocking and erasing of errors, and out- dated personal information.
  3. AAMMS will inform each of its customers of its policies for the use and sharing of the customer’s personal information, if necessary, otherwise AAMMS has right to share the data as per current law and regulations in the country.

 

7. Dispute and Resolution Mechanism:

  1. AAMMS has a designated contact point and may have clear procedures for handling customer complaints, including complaints submitted verbally. AAMMS also maintain up-to-date records of all complaints they receive and develop internal dispute resolution policies and practices, including processing time deadlines, complaint response, and customer access.
  2. Consumers have access to an affordable, efficient, respected, professionally qualified and adequately resourced mechanism for dispute resolution, such as independent officer of the bank with effective enforcement capacity.
  3. Statistics of customer complaints, including those related to breaches of codes of conduct, are periodically compiled. The complaints are compiled by product type to facilitate identification of patterns and opportunities for improvements of service.

 

8. Disclosure and Sales:

8.1. Information on Customers

a. When making a recommendation to a consumer, AAMMS should gather, file and record sufficient in- formation from the consumer to enable the institution to render an appropriate product or service to that consumer.
b. The extent of information the AAMMS gathers regarding a consumer should:

  • Be commensurate with the nature and complexity of the product or service either being proposed to or sought by the consumer; and
  • Enable the institution to provide a professional service to the consumer in accordance with that consumer’s capacity.

c. Sufficient information on the product or service should be provided to the consumer to enable him or her to select the most suitable and affordable product or service.

8.2. Affordability:

a. When AAMMS makes a recommendation regarding a product or service to a consumer, the product or service it offers to that consumer should be in line with the need of the consumer.
b. The consumer should be given a range of options to choose from to meet his or her requirements.

8.3. Bundling & tying Clauses:

a. As much as possible, AAMMS has avoided bundling services and products and the use of tying clauses in contracts that restrict the choice of consumers.
b. In particular, whenever a borrower is obliged by AAMMS to purchase any product, precondition for receiving a service from the institution, the borrower will be free to choose the provider of the product and this information will be made known to the borrower.

8.4. Protection of Rights:

Except where permitted by applicable legislation, in any communication or agreement with a consumer, AAMMS will not exclude or restrict, or seek to exclude or restrict:

  • Any duty to act with skill, care and diligence toward the consumer in connection with the provision by AAMMS or,
  • Any liability arising from the AAMMS’s failure to exercise its duty to act with skill, care and diligence in the provision of any AAMMS`s service or product to the consumer.
 
8.5. Advertising & Sales Materials:

a. AAMMS will ensure that their advertising and sales materials and procedures do not mislead customers.
b. All advertising and sales materials of institution should be easily readable and understandable by the general public.
c. AAMMS will be legally responsible for all statements made in their advertising and sales materials (i.e. be subject to the penalties under the law for making any false or misleading statements of Afghanistan.

8.6. Professional Competence:

a. In order to avoid any misrepresentation of fact to a consumer, AAMMS staff member who deals directly with consumers, or who prepares AAMMS advertisements (or other materials of the AAMMS for external distribution), or who markets any service or product of the AAMMS, should be familiar with the legislative, regulatory and code of conduct guidance requirements relevant to his or her work, as well as with the details of any product or service of the bank which he or she sells or promotes.
b. Management of AAMMS should collaborate to establish and administer minimum competency requirements for any AAMMS staff member who:

  • Deals directly with consumers,
  • Markets the AAMMS’s services and products.
8.7. Customer Record:

AAMMS will maintain up-to-date records in respect of each customer of the institution that contain the following:

  • A copy of all documents required to identify the customer and provide the customer’s profile;
  • The customer’s address, telephone number and all other customer contact details;
  • Any information or document in connection with the customer that has been prepared in compliance with any statute, regulation or code of conduct;
  • Details of all products and services provided by the bank to the customer;
  • A copy of correspondence from the customer to the bank and vice-versa and details of any other information provided to the customer in relation to any product or service offered or provided to the customer;
  • all documents and applications of GB completed, signed and submitted to the GB by the customer; a copy of all original documents submitted by the customer in support of an application by the customer for the provision of a product or service by GB; and

viii. Any other relevant information concerning the customer.

9. Internet Banking & Mobile Banking:

Below are the steps to be take care of:

a. The provision of internet banking and mobile banking is supported by a sound legal and regulatory framework, AAMMS will ensure that providing internet & m-banking have in place a security program that ensures:

  • Data privacy, confidentiality and data integrity;
  • Authentication, identification of counterparties and access control;
  • Non-repudiation of transactions;
  • A business continuity plan; and
  • The provision of sufficient notice when services are not available.
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b. A customer will be informed by AAMMS whether fees or charges apply for internet or m- banking and, if so, on what basis and how much.

  • There will be clear rules on the procedures for error resolution and fraud.
  • AAMMS will try to undertake measures to increase consumer awareness regarding internet and m-banking transactions.
9.1. Electronic Fund Transfer:

a. AAMMS have clear rules on the rights, liabilities and responsibilities of the parties involved in any electronic fund transfer.

b. AAMMS is providing information to consumers on prices and service features of electronic fund transfers and remittances in easily accessible and understandable forms. This information is included:

  • The total price (e.g. fees for the sender and the receiver, foreign exchange rates and other costs);
  • The locations of the access points for sender and receiver; and
  • The terms and conditions of electronic fund transfer services that apply to the customer.

c. To ensure transparency, it is made clear to the sender if the price or other aspects of the service vary according to different circumstances, and AAMMS will disclose this information without imposing any requirements on the consumer.

d. AAMMS which sends or receives an electronic fund transfer will document all essential information regarding the transfer and make this available to the customer who sends or receives the transfer or remittance without charge and on demand.

e. There is a clear, publicly available and easily applicable procedures in cases of errors and frauds in respect of electronic fund transfers.

9.2. Privacy & data Protection:

Confidentiality and security of customer’s information.

a. The Electronic transactions of any AAMMS customer should be kept confidential by the AAMMS employees.

b. AAMMS ensure that it protects the confidentiality and security of the personal data of its customers against any anticipated threats or hazards to the security or integrity of such information, as well as against unauthorized access.

9.3. Sharing Customer Information:

a. AAMMS will inform its customers in writing, or E-mail/SMS/Phone call and any other means:

  • Of any third-party dealing for which the institution is obliged to share information regarding any transaction of the customer.
  • As to how it will use and share the customer’s personal information.

b. Without the customer’s prior written consent, AAMMS will not share personal information regarding a customer of AAMMS to or with any party not affiliated with the institution for the purpose of telemarketing or direct mail marketing.

9.4. Permitted Disclosures:

AAMMR is permitted to disclose the data or any other information which is asked by:

  • The specific rules and procedures concerning the release to any government authority of the records of any customer of the institution, as per DAB law and regulations;
  • Rules on what the government authority may and may not do with any such records;
  • The exceptions, if any, that apply to these rules and procedures; and
  • The penalties for the institution and any government authority for any breach of these rules and procedures.

 

10. Internal Complaints and Procedure:

a. AAMMS is having in place a written complaints procedure and a designated contact point for the proper handling of any complaint from a customer, with a summary of this procedure forming part of the institution Terms and Conditions and suggestion in the same Terms and Conditions of how a consumer can easily obtain the complete statement of the procedure.

b. Within a short period of time following the date AAMMS receives a complaint, it will:

  • Acknowledges in writing to the customer/ complainant the fact of its receipt of the complaint; and
  • Provide the complainant with the name of one or more individuals appointed by the institution to deal with the complaint until either the complaint is resolved or cannot be processed further within the institution.

c. AAMMS will also provide the complainant with a regular written update on the progress of the investigation of the complaint at reasonable intervals of time.

d. Within a few business days of its completion of the investigation of the complaint, AAMMS will inform the customer/complaint in writing of the outcome of the investigation and, where applicable, explain the terms of any offer or settlement being made to the customer/complainant.

e. When AAMMS receives a verbal complaint, it will offer the customer/complainant the opportunity to have the complaint treated by AAMMS. AAMMS will not require, however, that a complaint be in writing.

f. AAMMS will maintain an up-to-date record of all complaints it has received and the action it has taken in dealing with them.

g. The record will contain the details of the complainant, the nature of the complaint, a copy of the AAMMS’s response(s), a copy of all other relevant correspondence or records, the action taken to re- solve the complaint and whether resolution was achieved and, if so, on what basis.

h. Institution may keep all record of compliant up to five years.

i. Institution will make these records available for review by internal audit or regulator when requested.

11. Policy Renewal:

The company’s Customer Protection policy is normally renewed once in two years.