Circular No. 3 of 2025: Reporting Requirements for Non-Banking Microfinance Companies on ESG-sustain Portal

SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN
Specialized Companies Division
Lending & Private Fund Department

No. SC/NBFC-1-196/Circular/2025/253
January 30, 2025
Circular No. 3 of 2025

**Subject: Reporting Requirement for Non-Banking Microfinance Companies on ESG -Sustain Portal**

The Securities and Exchange Commission of Pakistan (SECP) in exercise of powers conferred under sub-section (3) of section 282B of the Companies Ordinance, 1984 (XLVII of 1984), hereby directs the Non-Banking Microfinance Finance Companies (NBMFCs) to report their Gender Disaggregated and Complaint Data through SECP’s ESG Sustain Portal.

The Gender Disaggregated Data is required to be reported as per the periodicity indicated against each data field given in Annexure-A for the identified indicators. Moreover, monthly complaints data is required to be reported as per the data field given in Annexure-B. For the purpose of the annual reporting, the calendar year (i.e., January to December) shall be followed. The data, as specified above, shall be submitted no later than the 10th day of the month succeeding the reporting period.

This Circular shall come into force immediately and any non-compliance shall attract the penal provisions of section 282J of the Companies Ordinance, 1984 (XLVII of 1984).

(Zeeshan Rehman Khattak)
Commissioner (SCD)

**Distribution:**
1. Chief Executive Officers of All Non-Banking Microfinance Finance Companies
2. Chief Executive Officer, Pakistan Microfinance Network

SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN
Specialized Companies Division
Lending & Private Fund Department

Annexure-A

Dashboard of Key Performance Indicators (KPIs) (incl. gender disaggregated data) for NBMFCs

| Indicators | Total | # Women | # Men | Reporting Frequency |
| :--- | :--- | :--- | :--- | :--- |
| **Human Resources** | | | | |
| 1 | # Directors on the Board¹ | | | Half Yearly |
| 2 | # Employees² | | | Half Yearly |
| 3 | # of Permanent Staff³ | | | Half Yearly |
| 4 | # of Contractual staff⁴ | | | Half Yearly |
| 5 | # Employees in senior management⁵ | | | Half Yearly |
| 6 | # Employees in middle management⁶ | | | Half Yearly |
| 7 | # Employees in non-management cadre⁷ | | | Half Yearly |
| 8 | # Credit/Loan/Business Development Officers⁸ | | | Half Yearly |
| 9 | # Admin and Support Staff⁹ | | | Half Yearly |
| 10 | # Internship program participants in the company in last FY | | | Annual |
| 11 | # Promotions during last FY¹⁰ | | | Annual |
| 12 | # Employees hired during last FY¹¹ | | | Annual |
| 13 | # Permanent Employees hired during last FY¹² | | | Annual |
| 14 | # Contractual Employees hired during last FY¹³ | | | Annual |
| 15 | Average retention rates in # Months (Total, male, female, department wise) | | | Annual |
| **Gender Pay Gap** | | | | |
| 16 | Median salary for senior management last FY¹⁴ | | | Annual |
| 17 | Median salary for middle management last FY¹⁵ | | | Annual |
| 18 | Median salary for non-management cadre last FY¹⁶ | | | Annual |
| **Gender Responsive Training & Development** | | | | |
| 19 | % staff who attended technical trainings in the last 12 months | | | Annual |
| 20 | # senior management who attended technical training in the last 12 months | | | Annual |
| 21 | # middle management who attended technical training in the last 12 months | | | Annual |
| 22 | # non-management cadre who attended technical training in the last 12 months | | | Annual |
| 23 | # staff who attended gender sensitization training in the last 12 months | | | Annual |
| 24 | # senior management who attended gender sensitization training in the last 12 months | | | Annual |
| 25 | # middle management who attended gender sensitization training in the last 12 months | | | Annual |
| 26 | # non-management cadre who attended gender sensitization training in the last 12 months | | | Annual |
| **Gender Inclusive Outreach** | | | | |
| 27 | Outreach in last three years¹⁷ | | | Annual |
| 28 | Digital Outreach in last one year¹⁸ | | | Annual |
| 29 | New branches opened in last FY¹⁹ | | | Annual |
| 30 | Increase in number of branches in current FY²⁰ | | | Annual |
| **Gender Inclusive Workplace** | Women | Men | | |
| 31 | # Paid maternity/paternity leave days allowed as per HR policy | | | Annual |
| 32 | Company provides on-site day-care for employee’s children across HQ and branches (options tabs for HQ and branches and subsidized and free) | | | |
| 33 | Company provides childcare allowance to employees for coverage of daycare costs | | | |
| 34 | Average retention rates in # Months (Total, male, female, department wise) | | | |
| 35 | Pick and Drop Facility is Provided (options for Yes and No – further bifurcation into Women, Men, Both, Senior Management, Middle Management, Non-Management Cadre) | | | |
| 36 | Transport Allowance is Provided (options for Yes and No – further bifurcation into Women, Men, Both, Senior Management, Middle Management, Non-Management Cadre) | | | |

¹ Use SECP definition of BoD  
² Total staff on payroll  
³ Total active staff on payroll with contracts providing all institutional benefits  
⁴ Total active staff on payroll with contracts providing only remuneration  
⁵ Senior Management includes all executive management  
⁶ Middle Management includes all subordinates to executive management  
⁷ All staff excluding Senior Management and Middle Management  
⁸ Staff responsible for client acquisition and recoveries  
⁹ Includes all staff that are in the administration department and all staff supporting the working of the organization including kitchen helpers, cleaners, peons, bank runners etc.  
¹⁰ All staff promoted with title change and/or grade change  
¹¹ Total staff added to payroll in the last FY  
¹² Refer to definition of permanent and contractual staff  
¹³ Refer to definition of permanent and contractual staff  
¹⁴ The median salary is the middle value in a list of salaries where half of the workers earn more and half earn less  
¹⁵ The median salary is the middle value in a list of salaries where half of the workers earn more and half earn less  
¹⁶ The median salary is the middle value in a list of salaries where half of the workers earn more and half earn less  
¹⁷ Cumulative number of unique clients served by a microfinance institution during that three-year period. The KPI is intended to reflect the institution’s reach and ability to extend its services over time  
¹⁸ Total number of clients that on-boarded themselves digitally and received loans  
¹⁹ Full branches launched by the company in last FY  
²⁰ Total branches at current FY close – [minus] Total branches in last FY close

| 37 | Fuel Allowance is Provided (options for Yes and No – further bifurcation into Women, Men, Both, Senior Management, Middle Management, Non-Management Cadre) | | | | |
| :--- | :--- | :--- | :--- | :--- | :--- |
| **Gender Diversity Policy Adoption** | | **Yes** | **No** | **Date if Yes** | |
| 38 | The company has a gender diversity policy (GDP), approved by its Board (create an option to indicate date of approval, in case presence of policy at place) | | | | Annual |
| 39 | The company has established a formal mechanism for GDP implementation | | | | Annual |
| 40 | The Board oversees the implementation of the GDP and reviews progress annually (Incl. assessment of gender disaggregated data) | | | | Annual |
| 41 | The diversity objectives are part of the KPIs of senior management | | | | Annual |
| 42 | At least 1 independent Director of the Board is a woman | | | | Annual |
| **Anti Sexual Harassment Policies & Provisions** | | | | | |
| 43 | The company has a board approved anti-harassment policy | | | | Annual |
| 44 | There is functional anti-harassment committee | | | | Annual |
| 45 | The company has a gender diversified committee to oversee harassment complaints | | | | Annual |
| 46 | Dedicated hotline is established to report harassment incidents to harassment committee point of contact | | | | Annual |
| 47 | The Board monitors the implementation of the harassment policy on a quarterly basis | | | | Annual |
| **Gender Centric Design** | | | | | |
| 48 | Number of new women centric products that have been offered in the last FY<sup>21</sup> | | | | Annual |
| 49 | Number of women-centric marketing campaign that have been deployed in the last FY<sup>22</sup> | | | | Annual |
| 50 | Financial literacy/financial training offered to clients in last FY | | | | Annual |
| 51 | Digital literacy trainings offered to clients in last FY | | | | Annual |
| 52 | Business development trainings offered to clients in last FY | | | | Annual |
| 53 | A post-disbursement assessment of use of funds has been conducted with at least 50% of borrowers | | | | Annual |
| 54 | A Social Impact and Performance tool has been implemented in the last FY<sup>23</sup> (e.g., PACRA’s tool) | | | | Annual |

<sup>21</sup> Women-centric financial/ non-financial products are intentionally designed for women and are aimed at closing gender gaps in access to and usage of financial services. They (a) are designed to target women customers and businesses in specific sub-demographics (eg women agro-processers), (b) consciously integrate women’s perspective in the problem definition phase (ie seek to understand what is the problem and why from women’s perspective), (c) analyze sex-disaggregated data for understanding female customer behaviour (ie engagement, usage of products/ services), (d) conduct interviews with women clients and front line staff and observe them to complement the diagnosis, (e) identify practical barriers (eg women’s limited mobility) and behavioural barriers (eg women’s lack of trust of banks), (f) based thereupon design commercially-viable solutions for women, and (g) pilot test the solutions and request feedback from women for final improvements.

<sup>22</sup> Women centric marketing means putting women at the front and center of campaigns (in messages and imagery), and as recipients of campaigns. This can be done by first conducting women-centric segmentation to identify specific sub-demographic being targeted. Women centric campaigns achieve one or more of the following: a) mention women, b) showcase a female face, c) portray women in economic functions where they typically participate (eg as business owners in different activities) or where the campaign seeks to integrate women, d) highlight how a specific product/ service/ advantage can benefit women in their specific conditions (eg as small animal farmers).

<sup>23</sup> E.g. using PACRA’s social impact tool

| | **Portfolio Reporting Categories** | **By District / Province** | **Reporting Frequency** |
| :--- | :--- | :--- | :--- |
| | | **Women** | **Men** | |
| 1 | **Active Borrowers**<br>Total active unique borrowers at end of reporting period | | | Monthly |
| 2 | **Number of Loans Disbursed**<br>Total loans disbursed in reporting period | | | Monthly |
| 2.1 | **Number of Loans Disbursed (individual lending)**<br>Total loans disbursed in reporting period through individual lending methodology | | | Monthly |
| 2.2 | **Number of Loans Disbursed (group lending)**<br>Total loans disbursed in reporting period through group lending methodology | | | Monthly |
| 2.3 | **Number of Loans Disbursed (Branch onboarding)**<br>Total loans disbursed in reporting period through institution initiated onboarding | | | Monthly |
| 2.4 | **Number of Loans Disbursed (Digital onboarding)**<br>Total loans disbursed in reporting period through institution initiated onboarding | | | Monthly |
| 2.5 | **Number of Loans Disbursed - Nano**<br>Total loans disbursed in reporting period under PKR 10,000 | | | Monthly |
| 2.6 | **Number of Business Loans Disbursed**<br>Total loans disbursed in reporting period aimed at investment into a business (loans under PKR 300,000) | | | Monthly |
| 2.7 | **Number of Consumption Loans Disbursed**<br>Total loans disbursed in reporting period aimed at consumption purpose (consumption smoothening, medical expenses, utility bills, childrens’ marriage, etc.) | | | Monthly |
| 2.8 | **Number of Loans Disbursed – Micro enterprise**<br>Total loans disbursed in reporting period over PKR 300,000 under PKR 3,000,000 | | | Monthly |
| 2.9 | **Number of Climate Adaptation and/or Climate Mitigation Loans Disbursed**<br>Total loans disbursed in reporting period aimed at climate adaptation and/or climate mitigation | | | Monthly |
| 2.10 | **Number of Agriculture Loans Disbursed**<br>Total loans disbursed in reporting period for agriculture purposes (excluding agriculture trading and off-farm enterprises) | | | Monthly |
| 2.11 | **Number of Livestock Loans Disbursed**<br>Total loans disbursed in reporting period for purchase of livestock for dairy or meat | | | Monthly |
| 2.12 | **Number of Home Loans Disbursed**<br>Total loans disbursed in reporting period for Home building and/or Home improvement | | | Monthly |
| 3 | **Loan Tenure**: The duration or length of time over which the loan is to be repaid. To be measure in months | | | |
| 3.1 | **Number of Loans with Tenure less than 1 month**: Total loans disbursed in reporting period with loan completion tenures of upto 1 months | | | Quarterly |
| 3.2 | **Number of Loans with Tenure more than 1 month and less than 9 months**: Total loans disbursed in reporting period with loan completion tenures more than 1 month and less than 9 months | | | Quarterly |

| 3.3 | **Number of Loans with Tenure of 12 months**: Total loans disbursed in reporting period with loan completion tenures of 12 months | | | Quarterly |
| 3.4 | **Number of Loans with Tenure more than 12 months but less than 18 months**: Total loans disbursed in reporting period with loan completion tenures more than 12 months but less than 18 months | | | Quarterly |
| 3.5 | **Number of Loans with Tenure more than 18 months but less than 24 months**: Total loans disbursed in reporting period with loan completion tenures more than 18 months but less than 24 months | | | Quarterly |
| 3.6 | **Number of Loans with Tenure more than 24 months**: Total loans disbursed in reporting period with loan completion tenures more than 24 months | | | Quarterly |
| 4 | **Gross Loan Portfolio – Total**: All outstanding principal for all outstanding client loans, including current, delinquent and restructured loans, but not loans that have been written off. It does not include interest receivable in PKR Million | | | Monthly |
| 4.1 | **Gross Loan Portfolio – Branch**: GLP of loans disbursed through institution-initiated onboarding | | | Monthly |
| 4.2 | **Gross Loan Portfolio - Digital**: GLP of loans disbursed through client-initiated digital onboarding via website and/or app | | | Monthly |
| 5 | **Average Disbursement Size**: Total number of loan amount disbursed divided by total loans disbursed | | | Monthly |
| 6 | **Average Loan Size**: Total GLP divided by total number of loans | | | Monthly |
| 7 | **PAR > 30 days (%)**: The PAR30 days indicates that loans are effectively at risk compared to PAR1-30 days. The PAR30 ratio is calculated by dividing the outstanding balance of all loans with arrears over 30 days by the outstanding gross loan portfolio. | | | Monthly |
| 8 | **# (Insurance) Policy Holders**: Total number of insurance policy holders in client base in reporting period | | | Quarterly |
| 8.1 | **Number of Credit for Life Insurance Policy Holders**: Total number of Credit for Life Insurance policy holders in client base in reporting period | | | Quarterly |
| 8.2 | **Number of Health Insurance Policy Holders**: Total number of Health Insurance policy holders in client base in reporting period | | | Quarterly |
| 8.3 | **Number of Crop/Livestock Insurance Policy Holders**: Total number of Crop/insurance policy holders in client base in reporting period | | | Quarterly |
| 9 | **Total number of claims submitted**: No. of claims submitted in reporting period | | | Quarterly |
| 9.1 | **No. of credit insurance claims for life insurance raised**: No. of credit for life claims submitted in reporting period | | | Quarterly |
| 9.2 | **No. of claims for health insurance raised**: No. of health claims submitted in reporting period | | | Quarterly |
| 9.3 | **No. of claims for crop/livestock insurance policy raised**: No. of crop/livestock claims submitted in reporting period | | | Quarterly |

SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN
Specialized Companies Division
Lending & Private Fund Department

Annexure – B

| Category | Type of complaint | No. of complaints | | |
| :--- | :--- | :--- | :--- | :--- |
| | | **Male** | **Female** | |
| Product & Process | Loan amount not adequate | | | |
| | Unsuitable to business need | | | |
| | Service charges | | | |
| | Tenor | | | |
| | Disbursement mode | | | |
| | Turnaround time | | | |
| | Installment | | | |
| | Flexibility in repayment | | | |
| | Too many visits | | | |
| | Affiliated products | | | |
| Digital App (if applicable) | Connectivity issue | | | |
| | OTP issue | | | |
| | PIN | | | |
| | App download | | | |
| | App update | | | |
| | Incorrect information displayed | | | |
| | Sign up | | | |
| | New loan application | | | |
| Loan Eligibility Requirement | Documentation | | | |
| | Post dated cheque | | | |
| | Group guarantee | | | |
| | Guarantee/guarantor | | | |
| | Age | | | |
| | CNIC issues | | | |
| | Business exclusion list | | | |
| | Multiple borrowing | | | |
| | Discriminatory behaviour due to caste, religion, gender, community, location etc | | | |
| Third Party Related Complaints | Client experience using ADCs | | | |
| | Repayment collection channel | | | |
| | Disbursement channel | | | |
| | Insurance Company delays | | | |
| Debt Collection Process | Bad language | | | |
| | Forceful seizure of household assets | | | |
| | Aggressive recovery practice | | | |
| | Threatening behaviour | | | |
| | Repayment followups before due date | | | |
| | Lack of support for clients facing genuine repayment difficulty | | | |
| Communication Practices | Miscommunication of T&C | | | |

SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN
Specialized Companies Division
Lending & Private Fund Department

| | Withholding of information regarding other products and services | | |
|---|---|---|---|
| | Incomplete information of T&C | | |
| | Marketing collateral hard to read/understand | | |
| **Infrastructure** | Branch too far/does not serve community | | |
| | Branch too crowded | | |
| | Too much waiting | | |
| | Unclean washrooms | | |
| | unclean branch premises | | |
| | Branch not easily accessible (eg. too many stairs) | | |
| **Conduct of NBMFC Staff** | Breach of confidentiality | | |
| | Disrespectful behaviour | | |
| | Recovery harassment | | |
| | Asking for favours | | |
| | Asking for extra charges | | |
| | Harassment | | |
| | Denial of service | | |
| | Flexibility in repayment | | |
| | Too many visits | | |
| | Staff not responsive to complaints or requests | | |
| | Discriminatory behaviour due to caste, religion, gender, community, location etc | | |