1. GENERAL PURPOSE
1.1 The purpose of the given internal regulation for the resolution of Client Complaints (the “Procedure”) is to regulate the procedure for the resolution of Client Complaints in AS Redgate Capital and its subsidiaries (hereinafter collectively the “Company”).
1.2 Client Complaints shall be handled transparently, efficiently, and systematically. Information obtained through the Complaint handling process is used to improve and refine the services and products provided within the Company as well as internal regulations, to mitigate the risks of the Company, as well as to increase the quality of service, which ultimately benefits both the Company and its Clients.
1.3 Definitions:
1.3.1 The Client is, for the purposes of the given Procedure, any natural or legal person who uses, has used, or has expressed a wish to use the Company’s services.
1.3.2 A Client Relationship Manager is a person who manages a specific Client relationship. As a rule, the Client Relationship Manager is the project manager who organises the provision of the relevant advisory service.
1.3.3 A Complaint is, for the purposes of the given Procedure, an oral or written expression of the Client’s dissatisfaction with a product or service terms of the Company or with the behaviour or an obligation of the Company. The following situations are deemed as Complaints:
1.3.3.1. A clearly expressed dissatisfaction by the Client with the behaviour of an employee of the Company (or, in general, with the Company);
1.3.3.2. A clear reference by the Client to an error made by the Company, including by an employee of the Company, or its unfulfilled obligation;
1.3.3.3. A clearly expressed dissatisfaction by the Client with the terms of the services of the Company.
An expression of dissatisfaction by the Client is not considered clear and accordingly not considered as a Complaint, if it has been submitted in a vague manner and its expression does not make it possible to understand the nature of an error or an unfulfilled obligation made by the Company or its employee, or a specific defect in the terms of the product/service.
The Client’s proposal to amend some of the terms and conditions of the service by an agreement of the parties shall not be considered as the Client’s Complaint.

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Procedure for the resolution of Client Complaints (26.09.2022)
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