Client Complaint Handling Procedure

Purpose

This procedure establishes the Bank's formal framework for handling client complaints. It ensures that all complaints are received, acknowledged, investigated, and resolved in a fair, consistent, and timely manner, in compliance with regulatory expectations and the Bank's commitment to client satisfaction.

Scope

This procedure applies to all complaints received from individual and corporate clients, whether relating to products, services, fees, staff conduct, or any other aspect of the Bank's operations. It covers complaints received through all channels, including branches, telephone, email, online banking, social media, and regulatory referrals.

Definition of a Complaint

A complaint is defined as any expression of dissatisfaction by a client (or potential client) regarding the Bank's products, services, or conduct, where a response or resolution is explicitly or implicitly expected. Routine enquiries, service requests, and feedback that do not indicate dissatisfaction are excluded from this definition.

Complaint Channels

Channel	Contact Point
Branch	Branch Manager or designated Complaints Officer
Telephone	Client Services hotline (24/7)
Email	complaints@bank.com
Online Banking	Secure messaging / complaint form
Written Correspondence	Head Office — Client Services Department
Regulatory Referral	Compliance Department

Procedure

Step 1: Receipt and Acknowledgement

All complaints must be logged in the Complaint Management System (CMS) within two (2) hours of receipt, regardless of the channel through which they were received.
The complainant receives a written acknowledgement within one (1) business day, including a unique complaint reference number, the name of the assigned complaint handler, and the expected resolution timeline.
Complaints received via branches are logged by the Branch Complaints Officer. Complaints received via telephone or email are logged by the Client Services Centre.

Step 2: Classification and Prioritisation

Complaints are classified and prioritised as follows:

Priority	Criteria	Resolution Target
Critical	Regulatory referral, potential financial loss exceeding USD 50,000, media exposure risk, systemic issue	3 business days
High	Financial loss USD 10,001–50,000, repeated complaint, senior client (Private Banking / Corporate)	5 business days
Medium	Financial loss up to USD 10,000, service quality issue, fee dispute	10 business days
Low	General dissatisfaction, minor inconvenience, informational complaint	15 business days

Step 3: Investigation

The assigned complaint handler conducts a thorough investigation, reviewing all relevant transaction records, system logs, correspondence, call recordings, and staff statements.
Where the complaint involves another department, the handler coordinates with the relevant team and obtains their input within two (2) business days.
If additional information is required from the client, the handler contacts the client promptly and documents the interaction in CMS.

Step 4: Resolution

Based on the investigation findings, the handler determines an appropriate resolution, which may include a written explanation, correction of the error, fee reversal, financial compensation, or a combination thereof.
Financial remediation above USD 5,000 requires approval from the Head of Client Services. Remediation above USD 25,000 requires approval from the Chief Operating Officer.
The resolution is communicated to the client in writing (letter or secure email), including a clear explanation of the investigation findings, the resolution offered, and the client's right to escalate if dissatisfied.

Step 5: Escalation

If the client is dissatisfied with the initial resolution, the complaint is escalated to the Senior Complaint Review Panel, comprising the Head of Client Services, a Compliance representative, and a representative from the relevant business line.
The Panel reviews the case within five (5) business days and issues a final response.
If the client remains dissatisfied after the Panel's response, they are advised of their right to refer the complaint to the relevant external ombudsman or regulatory authority.

Step 6: Closure and Reporting

Upon resolution, the complaint is marked as closed in CMS with a full resolution summary.
A monthly Complaint Report is compiled and presented to the Executive Committee, detailing complaint volumes, categories, resolution rates, average resolution times, and identified trends.
Systemic issues identified through complaint analysis are escalated to the Operational Risk Committee for remediation.

Record Retention

All complaint records, including correspondence, investigation notes, and resolution documentation, must be retained for a minimum of seven (7) years from the date of closure.