POLICY ON HANDLING CLIENTS COMPLAINTS 1. GENERAL PROVISIONS This policy has been developed based on the effective legislation, regulating client complaints in line with the rendered banking services, the Policy of National Bank of Greece and its Group on handling client complaints and the established by UBB good practice of considering complaints and resolving disputes with clients. Detailed internal rules have been developed on the basis hereof, regulating the process of filing complaints, the internal procedures for performing checks, reviewing of complaints, preparation and providing replies to the Bank s clients and undertaking of corrective measures and actions. Main purpose of the internal regulatory framework, treating complaints by UBB clients, is to have those resolved in a clear, fair and impartial way, within the framework of the preliminary established response time frame. While resolving disputes it is aimed at achieving speed and objectivity during decision making and preparation of the reply, preventing litigation, maintaining the good name of the Bank, analyzing and eliminating the reasons that have brought about the filing of complaints. 2. CENTRALIZED HANDLING OF COMPLAINTS Considering the above-described targets UBB has established a Specialized Unit for handling client complaints with full-time and exclusively employed personnel. All client complaints are considered in a centralized manner by the Specialized Unit, except in cases when due to the specific nature of the complaint the responsibility for considering the complaint and the preparation of a reply to the client has been assigned to another unit, in which case the specialized unit monitors the timely preparation of a reply and closing of the case in view of the commitments, undertaken by the Bank. All employees and structural units in the Bank, within their functions and competencies, shall be obligated to render assistance to the Specialized Unit for handling client complaints. Complaints shall be considered with the help of an IT system, supported and developed by the Bank. 3. GOVERNANCE - RESPONSIBILITIES The Bank s senior management shall be responsible for implementing this policy in view of resolving - in an appropriate way - client complaints that may originate in the process of providing products and rendering of services. The employees of the Bank shall be obliged to be familiar with this policy and act accordingly. The specialized unit for handling client complaints is within UBB AD Compliance Department and is responsible for the implementation and observance of the rules, issued on the basis hereof. The Specialized Internal Audit Department of the Bank shall perform, when necessary, within its responsibilities, independent audits in view of ensuring the proper observance of the policy and procedures for handling complaints. The senior management shall be responsible for reviewing this Policy by recommendation of UBB Compliance Department and / or NBG Group Compliance Division, in case of need and following the changes in the regulatory and legal environment, as well as the changes in the strategic objectives of the Bank or the Group, or in the internal (organizational - business) and the external (market) environment. This Policy shall be subject to approval by UBB Board of Directors, following its prior endorsement by NBG Group Compliance Division. 4. INFORMING CLIENTS OF THE PROCEDURES FOR FILING COMPLAINTS UBB assumes, that its clients should be informed of the established procedures for submitting and considering complaints. The Bank shall inform its clients always and through the appropriate manner, when this is required in accordance with the effective laws and as is suitable in the rest of the cases.
The procedures for submitting and considering complaints shall be announced through: Established order and procedures for providing pre-contractual information; Information materials, available in the Bank s branch network; Other documents (for example, General Terms for various services, periodic account statements); The bank s internet page. 5. COMPLAINT CATEGORIES IN ACCORDANCE WITH THE PROCEDURE FOR THEIR SUBMISSION A complaint, within the meaning hereof, shall be any oral or written expression of dissatisfaction, suggestion or comment of a client regarding the quality level of the provided products and rendered services, involving any member of the Bank s personnel. The Bank shall group the complaints of its clients in accordance with the manner of their submission, as follows: Oral complaints; Complaints over the phone; Written complaints, submitted in the Bank; Written complaints by clients, forwarded to the Bank through supervisory or other administrative and government authorities (Presidency, Bulgarian National Bank, Commission for Consumer Protection, Commission for Personal Data Protection, Commission for Protection of Competition, Ombudsman of the Republic of Bulgaria, Ministry of Finance and others). These types of complaints shall be resolved by the Specialized Unit, in collaboration with all involved units, as well as with the assistance of Legal Department, whenever needed. 6. COMPLAINT CATEGORIES IN ACCORDANCE WITH THEIR SUBJECT In view of improving the banking practice, the efficient collecting and analyzing of information, monitoring of client complaints and control on the observance of the respective procedures, the Bank shall group complaints in accordance with their subject, in a manner, described in the respective rules. Complaint types according to this criterion can be, as follows: Complaints, relating to poor servicing of clients (non-observance of the Customer Service Standards); Complaints, related to standard products (including fees, different terms and conditions, etc.); Complaints, relating to processing, effecting of transactions and disputes on transactions; Complaints, relating to the quality of services (information, etc.); Complaints, relating to banking practices or business policy / practice; Complaints, relating to frauds (with forged personal documents, powers of attorneys etc.); Complaints, relating to companies, to which the bank has assigned the rendering of services (under the terms and conditions of outsourcing or in another form), etc. The centralized complaints handling framework shall ensure the effective collection, replying, monitoring of clients complaints and the control on the adherence to the respective procedures. The Heads of each Business Unit shall, with courtesy and affability - within the scope of their responsibilities exhaust every possibility for resolving oral complaints, and shall also inform clients about the Specialized Unit for handling client complaints and the Payment Disputes Conciliation Commission, as appropriate. 7. REGISTRATION AND PROCEDURE FOR HANDLING COMPLAINTS There are procedures in the Bank, which, depending on the complaint category, regulate respectively: The procedure for filing complaints, including the various manners for that;
Registration of complaints and the responsibilities of employees in line with that; Internal actions, based on the procedure and their assignment to the unit, competent to perform the check; Internal actions and competencies for performing a check and collecting of evidence; Cooperation and coordination between the various units, engaged in the process of handling complaints; Preparation and sending the reply to the client; Corrective measures and actions. When the effective laws require the maintaining of separate registers of complaints with a specific subject (for example regarding the provided investment services), the Bank shall maintain such registers with the respective content and in accordance with a procedure, described in the rules, based on this policy. When the effective laws require to separately inform a supervisory body on a regular basis of the received complaints with a particular subject (for example the Financial Supervision Commission regarding the client complaints in terms of the rendered investment or additional services), the notification shall be made pursuant to the effective laws by the respective responsible unit. Detailed description of the procedure and the responsible units regarding the notification of such nature has been stipulated in the Internal Rules for Resolving Disputes with the Bank s Clients. 8. DEADLINES FOR RESPONDING TO CLIENT COMPLAINTS The bank has established the following deadlines for response to complaints: Complaints, received through supervisory bodies with explicitly stated response deadline, shall be prepared in accordance with it. Replies to complaints, submitted in relation to effecting of payment services (operations on accounts, transfers, issuing and using bank cards, electronic banking etc.) shall be prepared within seven business days, with effect from the date of receiving the complaint. All other replies shall be prepared within fourteen business days, with effect from the date of receiving the complaint, as in case of factual or legal complexity the period may be extended up to 45 business days, of which the complainant shall be explicitly informed. 9. DISPUTES IN TERMS OF RENDERING PAYMENT SERVICES. PAYMENT DISPUTES CONCILIATION COMMISSION. The Payment Disputes Conciliation Commission is independent and functions within the Commission for Consumer Protection. Pursuant to the Act on Payment Services and Payment Systems, the Commission is a conciliatory body for resolving disputes between payment service providers and payment service users, which conciliatory body reviews the disputes, after they have been communicated to the payment service providers, including the Bank, and the latter have failed to express an opinion within 7 days of filing the protest, as well as when the decision on the protest is dissatisfactory to the payment service users. When involved in a conciliation procedure, led by the Payment Disputes Conciliation Commission, the Bank shall perform the respective actions (submit opinions, protests, evidence) within the deadlines, prescribed by the commission opinions and evidence on the case shall be submitted within 10 business days after receiving the materials. A conciliation proposal shall be either accepted or rejected by the Commission, approving the payments of compensations to clients, envisaged in the Rules for Resolving Disputes with UBB AD Clients, by proposal of Compliance Department or by proposal of the department, to which the complaint has been assigned. 10. ADMINISTRATIVE INFORMATION AND REPORTING The Specialized Unit for handling client complaints shall prepare the following periodic reports: A monthly report on complaints for poor servicing, listing the branches in relation to which actions the complaint has been lodged;
A quarterly summary report on complaints in accordance with the categorization of complaints, with a specified number of received complaints, as well as the measures, adopted for resolving of frequenting problems. When the Rules for Resolving Disputes with UBB AD Clients envisage other additional categories, complaints shall be categorized in accordance with those. The quarterly reports shall include, as follows: - the number of complaints, received and the progress of their handling; - the type of complaints by categories and percentage of increase / decrease; - the manner of submission; - the Business Units involved; - the average time for resolving; - the number of complaints, considered reasonable, as well as the means of resolving those; Annual summarizes the data related to complaints and the adopted measures. The reports shall be submitted to the Executive Directors, Chief Operating Officer, Branch Network Management Department, Human Resources Management Department, the Specialized Internal Audit Department. The Annual Report, as well as any other relevant report that may be requested, shall be presented before the NBG Compliance Division. 11. ANALYSIS OF COMPLAINTS The Specialized Unit for handling complaints shall perform a systematic (in terms of quantity and quality), as well as comparative analysis of complaints. The maintained statistical information shall be analyzed and compared against the respective complaints from previous periods for the purpose of achieving the following: Improvement of the offered products and services; Better quality of servicing clients on the part of staff (staff training in view of customer service improvement); Perfecting the procedure for handling complaints. The analysis shall be performed and shall be presented together with the summarized annual report on complaints, as well as upon request by the bank s senior management. The analysis shall also contain proposals for adopting of respective corrective measures and actions, as well as a summary of the results from the measures, undertaken in this respect during previous years. All business units, to which the senior management has assigned to undertake appropriate corrective measures for reducing the number of complaints, concerning their activity, shall be responsible for the development of a plan for the introduction of such measures. The implementation of the plan shall be reported to the Bank s senior management within the prescribed deadline for initiation of measures, and in case such has not been specified - within a year of the order date at the latest. 12. MAINTAINING OF ARCHIVES With regard to the reviewed complaints the Specialized Unit for handling complaints shall maintain a case file of each complaint, which shall contain the entire information and documentation, collected during the check on the matter, including the reply to the client. The complaint case file, together with the supported IT system, shall contain sufficient information for performing a subsequent check on the case and the progress of the procedure, under which the complaint has been considered, the minimum of such information being: Client s identification data; Client s complaint; Complaint submission manner and date; Reply to the complaint, manner and date of its providing;
The concerned Business Unit; Third parties to which the client has referred (e.g. BNB, Commission for Consumer Protection, etc.); Other outcomes and disclosed data; The total time needed for resolving the case; Relevant documents; Initiated actions The created record files shall be archived and stored in the manner and within the deadlines, envisaged in the Rules for Archiving Document Files in UBB. This Policy was approved by UBB Board of Directors on 27.09.2010 and entered into force 3 days thereafter.