Respectful Communication Policy

DCA BR Ltd, trading as DCA Business Recovery

Effective date: 6 August 2026
Review date: 6 August 2027

1. Purpose of this policy

DCA Business Recovery is committed to communicating professionally, fairly and respectfully with everyone who uses, contacts or works with our business.

We recognise that insolvency, financial difficulty and business closure can be stressful and upsetting. People may be frustrated, disappointed or strongly disagree with a decision or outcome. We will listen to concerns and will not regard someone as behaving unreasonably simply because they are persistent, distressed or critical of us.

However, behaviour may become unacceptable when its nature, frequency or effect threatens the safety or wellbeing of our team, prevents us from carrying out our work properly, or unfairly affects the service we can provide to other people.

This Respectful Communication Policy explains:

• the behaviour we may consider unacceptable or unreasonable;
• how we will consider the circumstances of each situation;
• the steps we may take to manage the behaviour; and
• how a decision made under this policy may be reviewed.

2. Who and what this policy covers

This Respectful Communication Policy applies to anyone who communicates or interacts with DCA Business Recovery, including:

• clients and prospective clients;
• company directors and shareholders;
• creditors, debtors and employees;
• complainants;
• professional advisers and representatives;
• suppliers and other third parties; and
• members of the public.

It applies to all methods of communication and interaction, including:

• telephone calls and voicemail messages;
• emails, letters and other correspondence;
• meetings and visits to our offices;
• video calls and online meetings;
• text messages and messaging services;
• social media; and
• comments or communications directed at or about members of our team outside our normal communication channels.

Where one of our insolvency practitioners is acting as an office-holder, this policy does not override any person’s legal rights or our statutory, regulatory and professional responsibilities.

3. Our commitments

We will:

• treat people with courtesy, dignity and respect;
• listen to legitimate concerns and respond in accordance with our procedures;
• explain our role, processes and likely response times as clearly as reasonably possible;
• consider relevant personal circumstances, communication needs and vulnerabilities;
• make reasonable adjustments where appropriate;
• distinguish between forceful or persistent communication and genuinely unacceptable behaviour;
• respond proportionately and apply restrictions only where they are necessary; and
• keep restrictions under review.

A person may raise a valid concern or complaint while communicating in an unacceptable manner. Where possible, we will continue to consider the underlying issue while separately managing the behaviour.

4. What we expect from people who contact us

We ask everyone who communicates with DCA Business Recovery to:

• treat our team and other people involved with respect;
• avoid abusive, threatening, discriminatory or intimidating language or behaviour;
• provide relevant information clearly and honestly;
• allow us a reasonable opportunity to consider and respond to correspondence;
• use the appropriate communication channels;
• comply with reasonable requests concerning meetings, calls and correspondence; and
• respect decisions where a matter has been properly considered and no material new information has been provided.

5. Behaviour we may consider unacceptable or unreasonable

Whether behaviour is unacceptable will depend on its nature, frequency, seriousness and effect. The following examples are not exhaustive.

5.1 Aggressive, abusive or threatening behaviour

This may include:

• shouting, swearing at or insulting members of our team;
• threats of violence, harm or damage;
• intimidating conduct or language;
• harassment or targeted personal abuse;
• discriminatory comments or conduct;
• sexual, indecent or offensive comments or material;
• malicious communications intended to frighten, humiliate or distress someone;
• aggressive behaviour during a meeting or visit;
• threatening to attend our premises or a team member’s home without invitation;
• contacting members of our team through personal telephone numbers, accounts or addresses without permission; or
• encouraging other people to threaten, abuse or harass members of our team.

We distinguish between a person expressing anger about a situation and directing aggression or abuse towards an individual. Our team is not required to tolerate personal abuse as part of their work.

5.2 Unreasonable demands

This may include:

• demanding a response or action within a timeframe that is not reasonably achievable;
• insisting that normal procedures, legal requirements or professional obligations should not apply;
• demanding an outcome that we do not have the power or authority to provide;
• insisting on speaking only to a particular person after an appropriate alternative has been offered;
• repeatedly demanding meetings, calls or responses where these are unnecessary;
• expecting immediate responses to complex issues;
• requiring us to prioritise one person’s matter unfairly over other work; or
• demanding that staff answer questions outside their role or authority.

5.3 Excessive or persistent contact

Contact may become unreasonable where its frequency or volume prevents us from progressing the matter or carrying out other work effectively.

Examples include:

• repeatedly contacting several members of our team about the same issue;
• sending frequent emails, letters, messages or voicemail messages without allowing reasonable time for a response;
• repeatedly raising substantially the same issue after it has been answered;
• continuing to contact us about a matter that has completed the relevant complaints or review process, without providing material new information;
• repeatedly changing the substance of a complaint or request;
• sending excessive volumes of irrelevant or duplicate information;
• copying large numbers of unrelated people into correspondence;
• using several communication channels simultaneously to pursue the same issue; or
• repeatedly contacting us after communication arrangements or response times have been clearly explained.

There is no fixed number of contacts that will automatically be treated as excessive. We will consider the circumstances and the effect of the contact in each case.

5.4 Obstructive or inappropriate conduct

This may include:

• refusing to provide information reasonably required for us to carry out our work;
• knowingly providing false or misleading information;
• impersonating another person or misrepresenting authority to act for someone;
• recording or broadcasting meetings or calls contrary to an agreed arrangement;
• publishing personal information about members of our team;
• disrupting meetings or refusing to follow reasonable safety or conduct instructions;
• attending our premises without an appointment after being asked not to do so;
• pursuing a complaint or request in a way primarily intended to cause disruption or distress; or
• making repeated allegations about individual members of our team without providing information that would allow the allegations to be properly considered.

6. Personal circumstances, vulnerability and reasonable adjustments

Before taking formal action, we will consider whether there are circumstances that may be affecting the person’s behaviour or ability to communicate.

Where appropriate, we may ask whether:

• the person is experiencing distress or a vulnerable situation;
• there is a disability, health condition or communication difficulty we should take into account;
• information could be provided in a clearer or more accessible format;
• a different communication method would assist;
• additional time would be reasonable; or
• communication through an authorised representative, friend, family member or professional adviser would help.

A reasonable adjustment or personal circumstance will be considered carefully. It will not, however, normally justify threats, violence, harassment or serious abuse.

7. How we will respond

For most situations, we will follow an ask, warn and manage approach.

Ask

We may explain which aspect of the behaviour is causing concern and ask the person to change the way they communicate or interact with us.

We may also try to identify whether there is an underlying problem, misunderstanding or reasonable adjustment that could help.

Warn

If the behaviour continues, we may give a verbal or written warning. The warning will usually explain:

• what behaviour we consider unacceptable;
• how it is affecting our team or our work;
• what change we require; and
• what action may be taken if the behaviour continues.

Manage

Where the behaviour continues, or where its seriousness requires immediate action, we may introduce proportionate arrangements or restrictions.

We are not required to provide a warning before acting where there is an immediate safety concern, a threat of harm, serious harassment or similarly serious conduct.

8. Actions we may take

Depending on the circumstances, we may:

• end a telephone call, video call or meeting;
• ask a person to leave our premises;
• decline an unarranged visit;
• require communication to be polite, relevant and limited to the matter being dealt with;
• appoint one member of our team as the person’s principal point of contact;
• restrict contact to a particular email address, postal address or other channel;
• require communication to be made in writing;
• set reasonable limits on the frequency or length of telephone calls, meetings or correspondence;
• specify when updates will be provided;
• respond only to communications containing material new information;
• place repetitive correspondence on file without sending a further substantive response;
• decline to reconsider a matter that has already been properly concluded;
• communicate only through an authorised representative;
• require meetings to be conducted remotely, at a specified location or with additional members of staff present;
• restrict or refuse access to our premises;
• cease direct contact where it is no longer safe or reasonable to continue;
• progress an insolvency, complaint or other matter without the person’s further participation where legally and practically possible;
• report threats, harassment, suspected criminal conduct or safety concerns to the police or another appropriate authority;
• notify a relevant professional, regulatory or supervisory body; or
• consider appropriate legal action where necessary.

Any restriction will be tailored to the behaviour and will not be broader or last longer than reasonably necessary.

9. Decisions, notification and review

A formal restriction under this policy will normally be authorised by a director, insolvency practitioner or appropriately senior member of staff.

Where reasonably possible, we will notify the person in writing. The notification will normally explain:

• the behaviour that led to the decision;
• the arrangements or restrictions being introduced;
• when the arrangements take effect;
• how long they are expected to remain in place;
• any conditions for changing or removing them; and
• how the person may ask for the decision to be reviewed.

A person may request a review by writing to us within 10 working days of receiving the decision and explaining why they believe it should be changed.

The review will be undertaken by another director or senior person who was not principally responsible for the original decision, where this is reasonably practicable.

We may maintain the arrangements while the review is taking place.

Restrictions will be reconsidered at an appropriate interval, taking account of:

• the seriousness of the original behaviour;
• whether the behaviour has continued;
• any change in circumstances;
• the effect of the restriction; and
• whether a less restrictive arrangement would now be suitable.

10. Complaints and legal rights

The application of this policy does not, by itself, prevent someone from:

• making a legitimate complaint;
• providing relevant evidence or information;
• exercising a legal or statutory right;
• communicating through an authorised representative; or
• contacting an appropriate regulator, professional body, ombudsman, court or other authority.

However, we may manage how direct communication with DCA Business Recovery takes place.

A complaint about our service will be considered under the applicable complaints procedure. Repeated disagreement with the outcome of a complaint will not ordinarily lead to the matter being reconsidered unless material new information is provided or another review or appeal route remains available.

11. Records and privacy

We will keep proportionate records of significant incidents and formal decisions made under this policy. These may include:

• details of the behaviour or incident;
• any warning given;
• the reasons for a restriction;
• the nature and duration of the restriction;
• relevant reasonable adjustments; and
• the outcome of any review.

Records will be handled in accordance with our privacy and information-retention arrangements. Information will be shared internally or externally only where there is an appropriate reason to do so, including safety, legal, regulatory or professional requirements.

12. Contacting us about this policy

Questions about this policy or requests for a review should be sent to DCA Business Recovery using the contact details published on our website.

Please clearly mark the correspondence:

“Unacceptable Behaviour Policy – Review Request”

13. Policy review

This Respectful Communication Policy will be reviewed periodically and may be amended to reflect operational experience, changes in guidance, legal or regulatory requirements, or the needs of the people who use our services.