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1 PEMBRIDGEINTERNATIONALINSURANCEADVISORS COMPLAINTSPROCEDUREMANUAL UPDATED:12MARCH2015 TableofContents Background: 2 Obligations&Commitments,Statutory&Other: Terminology: 3 DescriptionofComplaintHandlingProcedures:.. 4 AlternativeResolutionsofDispute: 5 AssignmentofResponsibility:. 5 ConsiderationsRelatingtoProcedure:. 6 Exceptions: 6 1 Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.

2 Background This document is published upon instruction from the Superintendent of Insurance in accordance with Article 16 of Regulation (EU No 1094/2010 of the European Parliament and of the Council dated 24 November 2010; and taking into account Recital 22 and Article 10 of Directive 2002/92/EC on insurance mediation ( IMD of the European Insurance and Occupational Pensions Authority (EIOPA issued on 27 November 2013 in the Official Journal of the European Union, Guidelines on complaints-handling by insurance intermediaries. The aim of these Guidelines is for the National Competent Authorities, members of EIOPA, to ensure that there are sufficient and appropriate regulations and procedures in place for the examination of complaints reported to insurance intermediaries. In order to ensure adequate protection of the insured, policyholders and beneficiaries, arrangements for the examination of all complaints submitted should be subject to a minimum level of supervisory convergence. Obligations&Commitments,Statutory&Other We will establish, maintain, and implement a robust complaints handling procedure. This procedure shall be effective, transparent, and shall be followed in the instance of a complaint, grievance, or expression of dissatisfaction lodged by a client. We will keep accurate records of the measures taken in our efforts to reach resolution. We will not refuse to publish or provide this manual upon request and as set out in the provisions of our Terms of Business. We will communicate with you in a clear, plain and simple manner. This policy is endorsed by our management team, who are also responsible for its implementation. We ask that any complaints be submitted directly to us, as set out in our Terms of Business, and that you include as much detail and supporting documentation/evidence as possible to assist us in understanding your complaint fully and responding to all of your concerns raised. Complaints which do not contain the name and other relevant details of the complainant, and a reasonable and measurable interest in resolution, will not be considered. We will extend every effort to handle complaints honestly, fairly and professionally, applying high ethical standards at all times. 2 Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.

3 Terminology For the purposes of applying the procedures described herein, as confirmed by the Superintendent of Insurance, in its decision dated 30/1/2015 and based on article 193(4(f of the Laws on Insurance Services and other related issues ; A Complaint means: A statement of dissatisfaction addressed to an insurance intermediary by a person relating to the mediation activities of the intermediary in accordance with the definition of insurance mediation in Article 2 paragraph 3 of the Directive 2002/92/EC for Insurance Mediation as well as with the definition of intermediary in Article 2 of the Laws on Insurance Services and Other Related Issues Complaints-handling should be differentiated from claims - handling as well as from simple requests for execution of the insurance contract, information or clarification. A Complainant is: A person who is presumed to be eligible to have a complaint considered by an insurance intermediary and has already lodged a complaint e.g. a policyholder, insured person, beneficiary. 3 Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.

4 DescriptionofComplaintHandlingProcedures We will firstly establish if we believe ourselves the correct entity to deal with any complaint lodged. o If we do not believe we are responsible for the matter in question, we will advise the complainant accordingly and direct the complainant to where we feel the complaint should be lodged; Where the above is applicable, we shall have no obligation, statutory or otherwise, to follow any further steps as laid down in the guidance issued by our regulator. We shall register any complaint received within three (3 working days of receipt in a central register and in a corresponding separate file. We shall acknowledge any complaint in writing to each complainant (if applicable within two (2 working days of receipt. We shall thoroughly investigate any complaint and examine all related documents. We shall take steps to gather evidence to assist us. We shall provide a written response within fifteen (15 working days where we are able to make a decision in this period, after taking into account all relevant information. o Where we are unable to do so within fifteen (15 working days, we shall inform the complainant in writing why we are unable to do so, before fifteen (15 working days have elapsed, and provide guidance on when we expect to be in a position to provide a response. Such additional time shall not exceed thirty (30 working days from the expiry of the initial deadline of fifteen (15 working days. We shall issue a Final Response as soon as practically possible. o Such response shall be by way of either Full or partial acceptance of the complaint Refusal of the complaint We will keep all documents relating to a complaint in a file in chronological order and in a secure manner. o Each file will contain the following: A copy of the complaint and confirmation of the date submitted Personal details for the complainant A summary description of the complaint, and the cause/reason of/for the complaint The class of business the complaint relates to Details of our investigation Details of the result and outcome of the complaint, including reasons for reaching our decision Confirmation of whether or not the subject of the complaint was a result of lack of internal procedures/processes by any person connected to us directly or indirectly The date the complaint is considered closed, or our Final Response is issued. We shall provide information to complainants regarding their complaints in a fair and timely manner and upon request. 4 Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.

5 AlternativeResolutionsofdispute: When our final response response does not satisfy the complainant, we may or may not enter into further communication in an endeavor to reach an amicable resolution, although we will consider additional information offered by the complainant. When a complainant has made a specific and measurable demand for resolution, and we are not agreeable, we will advise them of the right to insist on the complaint and the complainant s rights to pursue the complaint via other means. We will do this in writing. In the event that our Final Response is unsatisfactory, we will advise the complainant of their right to insist on the complaint and their rights to pursue the complaint via other means. We will do this in writing. If the results of our investigation show that the complaint is not reasonable and fair, and the decision is taken not to accept or partially accept the complainant s demands (when the complainant seeks compensation and the Client is not satisfied with the outcome, all measures will be taken to resolve the matter by the out-of- court settlement of consumer disputes, either through the use of a mutually acceptable ombudsman or the officially appointed ombudsman for disputes. Assignmentofresponsibility The Managing Partner nominated as having responsibility to ensure the fair treatment of complainants, and the fair and thorough investigation of complaints, is detailed below (The Responsible Manager. Mr Stephen Coppen He can be reached by Post Compliance Officer, Pembridge International Insurance Advisors Ltd., PO Box 52481, Limassol 4064, Cyprus admin@pembridge-international.com Telephone Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.

6 Considerationsrelatingtoprocedure. (a Article 16 of Regulation (EU No 1094/2010 of the European Parliament and of the Council of 24 November 2010 for establishing a European Supervisory Authority (European Insurance and Occupational Pensions Authority, amending Decision No 716/2009/EC and repealing Commission Decision 2009/79/EC and taking into account Recital 22 and Article 10 of Directive 2002/92/EC of the European Parliament and of the Council of 9 December 2002 on insurance mediation ( Directive on insurance mediation - IMD,. (b The European Insurance and Occupational Pensions Authority Report with number. BoS 13/171 dated 27 November 2013 on Best Practices in handling complaints by Insurance Intermediaries,. (c The European Insurance and Occupational Pensions Authority Guidelines on complaintshandling by insurance intermediaries issued on 27 November 2013 in the Official Journal of the European Union, (d The powers vested on the Superintendent of Insurance under article 193(4(f of the Laws on Insurance Services and Other Related Issues , Exceptions an insurance intermediary receives a complaint about activities other than those supervised by the Superintendent of Insurance and regulated in accordance with the Laws on Insurance Services and Other Related Issues , as amended or replaced from time to time, or an insurance intermediary handles a complaint on behalf of another financial institution under the legal provisions applicable to that institution. In such circumstances, we shall endeavor to respond detailing reasons why we do not feel we are the correct entity to complain to. 6 Cyprus. Regulated and licensed by Insurance Companies Control Service in Cyprus (ICCS under registration number E. A/B 8667 FOS188.