Terms Used

Complainant – a person who intends to conclude an insurance or reinsurance contract, a policyholder, an insured person, or a person entitled to claim insurance compensation under a concluded insurance contract, as well as a reinsurance policyholder.

Company – Colemont FKB Latvia Ltd.

Complaint – a statement expressing dissatisfaction with the insurance or reinsurance distribution activities carried out by the Company or by an ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries. For the purposes of these Rules, a statement shall not be considered a Complaint if, in the case of a natural person, it does not include the person's first name, surname, and information that allows the person to be clearly identified, or, in the case of a legal entity, it does not include the entity's name and registration number.

Employee – an employee of the Company directly involved in insurance or reinsurance distribution, or an employee of an ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries, whose actions in relation to insurance or reinsurance distribution are the subject of the Complaint.

Person responsible for handling the Complaint – a person appointed by the Company's Management Board who is responsible, at the management level, for the Complaint handling process and who ensures that the facts stated in the Complaint are verified, the effectiveness of the Complaint handling process is monitored, potential conflicts of interest are prevented, and reporting is carried out in accordance with this document.

General Provisions

1.1. This document and any amendments thereto shall be approved by the Company's Management Board.

1.2. The Company shall consider complaints only in relation to insurance distribution activities carried out by its Employees.

1.3. The Company shall make this document available to all persons involved in the complaint handling process, and it shall be accessible to all Company employees directly involved in insurance and reinsurance distribution.

1.4. The Company shall ensure that the following information is clearly presented, accurate, up to date, and freely available at all insurance and reinsurance distribution locations during business hours and on all of its websites, where more than one website exists:

1.4.1. A Complaint must include all the information specified in Section 2.4 of this document;

1.4.2. The handling of Complaints is free of charge;

1.4.3. The Complaint shall be addressed to the person specified in Section 2.2 of this document;

1.4.4. A Complaint may be submitted using the methods specified in Section 2.3 of this document;

1.4.5. The Complaint will be examined by the person specified in Section 2.2 of this document;

1.4.6. In accordance with Section 4.9 of this document, the person whose actions are the subject of the Complaint shall not be involved in the examination of the Complaint;

1.4.7. A response to the Complaint will be provided within the period specified in Section 4.2 of this document;

1.4.8. The Company's supervisory authority is the Bank of Latvia, address: Kr. Valdemāra iela 2A, Riga, LV-1050, email: info@bank.lv, website: www.bank.lv;;

1.4.9. The Complainant may also submit a Complaint to the institutions referred to in Section 2.6 of this document.

1.5. If the Company receives a Complaint concerning another market participant, the examination of which falls outside the Company's competence as defined in Section 1.2 of this document, the Company shall, within seven days from the date of receipt of the Complaint, forward the Complaint to the relevant market participant and inform the Complainant accordingly.

1.6. The Company shall ensure that the person responsible for handling Complaints is familiar with this document and that this document is available to all Company employees directly involved in insurance or reinsurance distribution, both on the Company's premises and in its electronic system.

Rights and Obligations of the Complainant

2.1. Any person has the right to submit a Complaint to the Company.

2.2. The person responsible for handling Complaints is Arvils Pūpols, to whom all Complaints submitted to the Company shall be addressed.

2.3 A Complaint may be submitted in paper form by post or delivered in person to the Company's address: 34 Āraišu Street, Riga, LV-1039. A Complaint may also be submitted electronically by sending it to the Company's email address: info@colemontfkb.lv. A Complaint may also be submitted orally by contacting the person responsible for handling Complaints by telephone at +371 6724 0066 or by meeting with that person in person.

2.4 A Complaint must contain at least the following information:

2.4.1 For a natural person – the first name, surname, and information enabling the person to be clearly identified; for a legal entity – the name and registration number;

2.4.2. The specific Employee whose actions in the course of insurance or reinsurance distribution are the subject of the Complaint;

2.4.3. The grounds for dissatisfaction with the actions of the specific Employee in the course of insurance or reinsurance distribution, including, as far as possible, a detailed description of the factual circumstances, the reasons for the dissatisfaction, and supporting documents substantiating the grounds for the Complaint;

2.4.4. Where the Complaint is submitted in writing, it must bear the personal signature of the complainant if the complainant is a natural person. In the case of a legal entity, it must bear the personal signature, first name, surname, and position of its representative. If the Complaint is signed by an authorised representative, the original power of attorney shall be attached to the Complaint.

2.5. The Complainant has the right to request, in the Complaint, that the Company compensate for losses that have arisen directly and causally as a result of the Employee's intentional, malicious unlawful conduct or gross negligence.

2.6. In the event of a dispute between the Complainant and the Company, a Complaint may also be submitted to the institution (Ombudsman) established by the Latvian Insurance Brokers Association, information about which is available at www.brokers.lv, or to the Company's supervisory authority, the Bank of Latvia, address: Kr. Valdemāra iela 2A, Riga, LV-1050, email: info@bank.lv, website: www.bank.lv.

3.1. The Company and the person responsible for handling Complaints are obliged to accept any Complaint that has been submitted in accordance with the requirements of this document. Where a Complaint is submitted orally, the person responsible for handling Complaints may request that the Complainant prepare the Complaint in writing or may record it in writing and request the Complainant to sign it.

3.2. Only Complaints that have been submitted in accordance with the requirements of this document shall be considered. A statement shall not be regarded as a Complaint and shall not be considered if, in the case of a natural person, it does not include the person's first name, surname, and information enabling the person to be clearly identified, or, in the case of a legal entity, it does not include the entity's name and registration number.

3.3. The Company and the person responsible for handling Complaints have the right to request that the Complainant provide additional information regarding the circumstances referred to in the Complaint where this is necessary to clarify the facts set out in the Complaint.

3.4. At the request of the Complainant, the Company shall provide written information regarding the Complaint handling process. Depending on how the request has been submitted or how the Complainant has requested to receive the information, the information shall be provided either in paper form or electronically.

3.5. If a Complaint concerning its activities is received by an ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries, the intermediary shall forward the Complaint to the Company within seven days of its receipt.

3.6. The Company shall ensure the protection of the information provided by the Complainant and the Complainant's personal information in accordance with the General Data Protection Regulation (GDPR) and the Company's Information System Security Procedure.

4.1. Within the limits of their competence and legal authority, the person responsible for handling Complaints shall examine the evidence and information related to the Complaint. As part of the examination of the evidence and information relating to the Complaint, the person responsible for handling Complaints shall perform at least the following actions:

4.1.1. Request explanations from the Employee and verify the information provided therein;

4.1.2. Where necessary, examine the information held by the Company or by the ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries (where the Complaint concerns an ancillary insurance intermediary), including documents, electronically stored information, email correspondence from the Company's email system, and similar records;

4.1.3. Where necessary, obtain additional information electronically from public registers and other publicly available information sources;

4.1.4. Where necessary, request explanations or additional information from other employees of the Company or of the ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries (where the Complaint concerns an ancillary insurance intermediary);

4.1.5. Where necessary, request additional information from persons who are not employees of the Company or of the ancillary insurance intermediary registered in the Company's register of ancillary insurance intermediaries.

4.2. The person responsible for handling Complaints shall examine the Complaint and provide a response within 20 days from the date the Complaint is submitted. Where this is not possible for objective reasons, the person responsible shall provide a justified explanation of the need to extend the response period and indicate a reasonable deadline by which the response will be provided.

4.3. The person responsible for handling Complaints shall provide the Complainant with a reasoned response based on a comprehensive and objective assessment of the evidence and information contained in the Complaint and obtained during the Complaint handling process, using language that is as simple and easy to understand as possible. If the response does not fully satisfy the claims made by the Complainant, the response shall also inform the Complainant of other available complaint resolution options.

4.4. The response to the Complaint shall indicate whether the Company accepts or rejects the claims made in the Complaint and shall set out the Company's position regarding the grounds for those claims.

4.5. If the Company accepts the claims made in the Complaint, the response letter shall specify whether the Complainant is entitled to compensation for any losses incurred and, if so, the procedure by which such compensation may be obtained, provided that the losses were directly and causally related to the actions of the Company's Employee that are the subject of the Complaint.

4.6. If the Company rejects the claims made in the Complaint, the response letter shall specify the facts, circumstances, and documents forming the basis for rejecting the claims raised by the Complainant.

4.7. If the Company determines that the claims raised in the Complaint do not relate to the Company's activities or concern the actions of a person who is not an Employee, the Company shall notify the Complainant thereof in writing.

4.8. The response to the Complaint shall be provided in the Latvian language. If the Complaint has been submitted in another language, the Company may, provided that this does not result in additional administrative costs, respond in the language in which the Complainant submitted the Complaint.

4.9. If the Complaint concerns an Employee who is also the person responsible for handling Complaints, all duties assigned under this document to the person responsible for handling Complaints in relation to that Complaint shall be performed by another person appointed by the Company's Management Board specifically for the examination of that Complaint. If the Complaint concerns a member of the Company's Management Board, that board member shall not participate in any decisions relating to the examination of the Complaint. If the Complaint concerns the Company's sole Management Board member, who is also the person responsible for handling Complaints, that board member shall appoint another person to examine the specific Complaint, and this circumstance shall be indicated in the response to the Complaint. If the Complaint concerns the Company's sole Management Board member, who is also the person responsible for handling Complaints and the Company's only employee, the Complaint shall be examined by that person responsible for handling Complaints, and this circumstance shall be stated in the response to the Complaint.

4.10. After conducting a comprehensive and objective assessment of the evidence and information contained in the Complaint and obtained during the Complaint handling process, and after preparing the response, the person responsible for handling Complaints, or the person referred to in Section 4.5 of this document, shall analyse the cause of the Complaint and determine the measures necessary to prevent similar issues from recurring.

5.1. The Company shall register submitted Complaints no later than the next business day following receipt of the Complaint and shall register responses to submitted Complaints on the date the response is prepared. The Complaint and Response Register shall contain at least the following information:

5.1.1. Information about the Complainant (for a natural person – first name and surname; for a legal entity – name and registration number), as well as the Complainant's contact details;

5.1.2. The date the Complaint was received;

5.1.3. The reason for the Complaint as stated in the Complaint;

5.1.4. The type of insurance;

5.1.5. The date on which the response to the Complaint was sent;

5.1.6. The outcome of the Complaint examination;

5.1.7. The country in which the insurance or reinsurance distribution activity that gave rise to the Complaint was carried out.

5.2. The Company shall retain information relating to received Complaints and the responses provided for at least 10 years and 6 months from the date on which the response to the Complaint was provided. The Company shall provide information regarding received and examined Complaints to the Financial and Capital Market Commission upon its request.

6.1. At least once a year, by 31 March of each year, the person responsible for handling Complaints shall prepare a report on the compliance of the Complaint handling process during the previous calendar year with this document and on the effectiveness of the Complaint handling process. The report shall also include the information referred to in Section 4.10 of this document concerning the analysis of the causes of Complaints and the measures necessary to prevent those causes. The person responsible for handling Complaints shall submit this report to the Company's Management Board. The person responsible for handling Complaints shall not prepare the report referred to in this section if no Complaint handling process took place during the previous calendar year.

6.2. Within one calendar month of receiving the report referred to in Section 6.1 of this document, the Company's Management Board shall review it and assess whether any measures are required to eliminate the causes of Complaints, and, where necessary, shall decide on the implementation of specific measures within specified time limits. Responsibility for monitoring the implementation of the measures required to eliminate the causes of Complaints shall be assigned to the person responsible for handling Complaints, who shall inform the Company's Management Board both of the implementation of those measures and of any delays or obstacles affecting their implementation, indicating the reasons for the delays, the obstacles encountered, and recommendations for their elimination.

Arvils Pūpols

Member of the Management Board

Colemont FKB Latvia Ltd.