Alliance Code of Ethics


We, the members of the FinTech Alliance.Ph, declares our common resolve and objective of setting industry standards including the institutionalization of Code of Ethics in the digital space and adoption of Code of Conduct among its member-companies in support of and in compliance with existing laws and regulations particularly on promoting transparency, consumer protection, financial literacy, excellence, and global best practices.



We shall abide by and adhere to this Code which incorporates Best Practices, and Governance defining the highest standards in conducting our business while being responsible players in an inclusive economy.



We support the Alliance and its initiatives in professionalizing the digital industry fully compliant with relevant and applicable laws and regulations ensuring integrity, data privacy, and security.



As a self-regulating organization, its Board of Trustees, through its Standards Committee, shall review all reported violations of its Codes and will direct concerned Alliance member that is subject of the report to address the issue.



The Alliance, through its Board of Trustees, after proper evaluation and due process, reserves the right to determine possible reprimand, suspension or termination of membership with the Alliance, if found to be in violation of this Code.



Code of Ethics for Board of Trustees and Alliance Members
FinTech Alliance members are committed to observing and promoting the highest ethical conduct being a member of this organization.
Members pledge to accept this code as a minimum guideline for ethical conduct  and shall. 
On Accountability
  1. Faithfully abide by the Articles of Incorporation, by-laws and policies of FinTech Alliance.
  2. Exercise reasonable care, good faith and due diligence in organizational affairs.
  3. Fully disclose, at the earliest opportunity, information that may result in a perceived or actual conflict of
  4. Fully disclose, at the earliest opportunity, information of fact that would have significance in board decision-making.
  5. Remain accountable for prudent fiscal
  6. Maintain a professional level of courtesy, respect, and objectivity in all FinTech ph activities and no abuse of authority.
  7. Strive to uphold practices that will assist and positively develop FinTech Alliance. ph members and not for personal
  8. Exercise the powers vested, for the good of all members of the organization rather than for his or her personal benefit.
On Equal Opportunity
  1. Ensure the right of all members to appropriate and effective services without discrimination on the basis of geography, political, religious, or socio- economical
  2. Ensure the right of all members to appropriate and effective services without discrimination on the basis of the organization’s volunteer or staff make-up in respect to gender, sexual orientation, national origin, race, religion, age, political affiliation or disability, in accordance with all applicable legal and regulatory
On Confidential Information
  1. Respect the confidentiality of sensitive information known to you as
  2. Respect the diversity of opinions as expressed or acted upon by the FinTech ph Board of Trustees, Committees and Membership, and formally register dissent as appropriate.
  3. Promote collaboration, cooperation, and partnership among association members.
Part 2: Ali Alliance members must submit Code of  Conduct  that  are applicable  to  their respective industries (see attached Annex A as sample)
ADOPTED by the Members of the FinTech as affirmed by its Board of Trustees this 16th day of September 2019 at the National Privacy Commission, 5F Secretariat Building, Philippine International Convention Genter, Pasay City, witnessed by officials of the Bangko Sentral ng Pilipinas, Securities and Exchange Commission, Insurance Commission, National Privacy Commission, and Anti-Money Laundering Council Secretariat.


Code of Conduct (individual Alliance members to ensure submission of said Code) and adhered to by respective Board, Management and all employees and certified by its Chairman or its President and CEO or Managing Director.
All members of the Alliance must: (red only for lending- delete if not applicable)
  1. Treat every customer fairly, honestly, and with utmost respect.
  2. Always treat consumers with respect. and use fair, professional and non-abusive collection practices.
  3. Never use unlawful threats, intimidation or harassment to collect accounts.
  4. Ensure consumers are making educated financial decisions by fully disclosing all loan terms in a transparent and easy to understand way.
  5. Give consumers a chance to change their mind by maintaining a reasonable cancellation policy.
  6. Be a company in good standing with the officials and regulatory bodies that govern each member.
  7. Comply with all applicable laws and regulations.
  8. Never engage in activities that are unfair, abusive or deceptive.
  9. Protect every consumer’s personal data with comprehensive website security and a privacy policy and ensure that your vendors protect consumer personal data in the same manner.
  10. Provide consumers with a copy of your privacy policy and an ability to opt out of information sharing.
  11. Help consumers help themselves by providing referrals to credit counseling, education and assistance when appropriate.
  12. Use advertising and marketing practices that promote the responsible use of short-term credit services.
  13. Do not engage in any false, misleading or deceptive advertising campaigns.
  14. Take applications from consumers and originate loans consistent with all applicable laws.
  15. Ensure that payments are authorized and processed consistent with applicable laws and regulations and those consumers fully understand the options available to the consumer.
  16. Provide comprehensive website security and fraud prevention practices that include timely and accurate reports on loan activity, consumer notification of account use, and validation of routing numbers.
  17. Appropriately manage third-party service providers to ensure that consumer information is shared and protected consistent with applicable law.
  18. Members should welcome public scrutiny and comments, and jointly resist and rectify malpractice.
  1.  All marketing and promotional material must be clear, balanced, fair and not misleading and set out both the risks and benefits of the Member’s product or service.
  2. (if with Platforms) Platforms should set out in a clear and balanced way the information that enables customers and prospective customers to make an informed decision.
  3. (with Lending) Alliance members are required to publish the highlights of Truth in Lending Act on their respective websites and other digital channels to ensure full disclosures enabling customers to have informed decision whether to avail of the product or service.
  4.  Do not discriminate on the basis of race, color, religion, national origin, sex, marital status, age, sexual orientation or identity, or any other protected class.
  5. Platforms of Alliance Member must demonstrate compliance with regulatory requirements or, if unregulated, should adopt similar arrangements that effect equivalent consumer protection.
  1. Clearly disclose privacy practices to all customers by providing a privacy policy at all times on the marketplace’s website. Honor customer privacy by complying with all applicable privacy laws.
  2. Do not share a customer’s personally identifiable information with third parties, except as related to providing requested services to a customer, with a customer’s consent or after providing a customer a clear disclosure, and an opportunity to opt‐out, of such sharing.
  3. Each Member must be compliant with all privacy and data protection laws and regulations.
  1. Maintain a complaint resolution system that tracks complaints and provides, where appropriate, fast and reasonable resolution to any investors or borrowers who complain.
  2. Participate in regulator‐sponsored complaint portals that are applicable to the Member’s business and operations.
  1. Members shall operate a prudent and robust policy to manage credit risk and undertake sufficient assessment to satisfy themselves that those who borrow can properly afford to do so. The objective should be to ensure default rates remain broadly within published estimates.
  2. Each member should be able to explain their credit risk management approach coherently to a customer. Maintain a governance framework for managing enterprise risk appropriate to the size and risk profile of the Member.
  1. All Alliance members must be able to undertake AML certification conducted by regulators.
  2. Members must comply with applicable anti-money laundering regulations and such other anti-fraud measures as it reasonably considers appropriate and in line with best practice, such as membership of a fraud prevention service.
  3. Non-regulated platforms should ensure their AML/Fraud prevention systems are independently audited each year.
  1. Members must ensure that their overall information technology (IT) strategies and systems are secure, reliable, and proportionate to the nature, scale and complexity of their business and are sufficiently robust and fit for purpose.
  2.  Members should operate systems that minimize the risk of IT failures or data theft.
  1. Members should retain appropriate records for regulatory reporting purposes, responsible management of the business and fair treatment of customers.
  2. Members must safeguard and protect the privacy of customer information in line with data protection requirements.
  1. Maintain a plan that adequately addresses possible risks to the business, designed to enable the Member’s service to resume reasonable operations without material disruption to their investors or customers
  1. Bad debt recovery should be undertaken in accordance with acceptable industry wide standards of responsible business practice. Report loan repayment information to major credit bureaus and ensure that the borrower’s credit data is consulted in the loan underwriting process.
  1. Members must make arrangements to ensure the orderly administration of the business and run-off of its customers’ contracts in the event the member or the member’s platform ceases to operate. Such arrangements should be in line with regulatory requirements and either a suitably-governed entity established by the firm to run down the loan book or a reputable third party that has:
  • sufficient manpower to administer the contracts in run off;
  • a suitable collection and payment process for repayments;
  • a suitable disbursement process for net proceeds due to lenders;
  • the ability for customers to communicate with the operator;
  • maintenance of requisite license approvals;
  • compliance with applicable law, regulations; and
  • Allowance for office and sundry expenses.
  1. Each Alliance Member must be able to adhere and adapt to the basic principles of corporate governance, i.e. on accountability, fairness, transparency, and responsibility.
  2. Each Member recognizes the rights of all interested parties subject to applicable laws and regulations, and seeks to cooperate with such persons or companies for their own development and financial stability.
  3. Review necessary governance requirements under the Law (eg: Revised
    Corporation Code)
  1. Protect private customer information by maintaining proper security controls, including recurring penetration tests and remediation within a reasonable period.
  2. When sharing anonymized data, ensure that the data is fully de‐identified and does not include personally identifiable information.
  1. An Alliance member may seek a waiver from any of the specific principles in this Code, but the Member will need to demonstrate that their alternative approach is consistent with the high-level principles.
  2.  Waivers are subject to the approval of the Board of Trustees through the
    Standards Committee