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Complaint Handling Policy of Credipass Kft.

Last amended: 16 June 2025

I. Definitions

Complaint: Any objection concerning the conduct, activities or omissions of CREDIPASS Kft., hereinafter referred to as the “Company”.

A request for general information, an opinion or a statement of position from the Company does not constitute a complaint.

Complainant: A complainant may be a natural person, a legal person or an organisation without legal personality that uses the Company’s services or receives information or an offer relating to those services.

Where a complaint is submitted through a representative or authorised agent, the Company verifies their authority to act. An authorised agent must demonstrate this authority by providing a power of attorney. In the absence of a power of attorney, the Company contacts the Customer directly to expedite the handling of the matter.

In addition to the Company’s Customers, a complainant may be a person who objects to the Company’s conduct in connection with another service-related activity, such as advertising, rather than the service itself.

Complaint handling: A problem-solving process that strengthens customer loyalty and aims to ensure customer satisfaction.

II. Purpose of the Policy

The purpose of this Complaint Handling Policy is to establish the procedures for recording and handling complaints received by CREDIPASS Kft.

Matters not covered by this Policy are governed by MNB Decree 66/2021 (XII. 20.).

III. General rules and principles

  • The Company records every complaint received in the complaint register folder, taking particular care to ensure that data requested for identification purposes complies with data protection requirements.

  • Complaints are handled in Hungarian. Wherever possible, however, the Company must provide complaint handling in a language spoken and understood by the complainant.

  • The Company assists complainants in formulating and submitting their complaints. For this purpose, it makes the complaint form included in Annex 1 to this Policy, together with the complaint form published by the Magyar Nemzeti Bank, available at its customer service office and on its website. Where a complaint is submitted in person, the complainant receives a copy of their complaint letter or form bearing an acknowledgement of receipt.

  • Customers may act through an authorised representative. In such cases, the power of attorney must be set out in a public document or a private document with full probative force.

  • If additional information held by the Customer is required to investigate the complaint, particularly information needed to identify the Customer or concerning the legal relationship to which the complaint relates, the complainant must be contacted without delay to obtain it.

  • The Company may request copies only of documents that are necessary to substantiate the complaint, are held by the Customer and are not already available to the Company.

  • Complaint letters must be answered within 30 calendar days of receipt.

  • Wherever possible, an employee who participated in the disputed action or decision should not take part in deciding the complaint.

  • If the Customer is dissatisfied with the Company’s initial response, the impartiality and objectivity of the staff responsible for handling the matter must be ensured. Every response rejecting a complaint must identify the authorities to which the complainant may turn for a remedy, including their precise contact details.

  • The Company provides several methods of submitting complaints, taking account of Customers’ needs and circumstances. Complaints may be submitted by letter, fax, telephone, in person or electronically. The Company endeavours to ensure that disadvantages such as a remote place of residence, a physical disability or restrictions on freedom of action do not prevent complainants from submitting a complaint.

  • Complaints are investigated free of charge. The Company does not charge a separate fee.

  • Complaints are investigated taking account of all relevant circumstances.

  • After investigating a complaint, the Company must provide a response detailing the outcome of the full investigation, the measures taken to settle or resolve the complaint or, if the complaint is rejected, the reasons for rejection.

  • The Company provides accurate, clear and understandable reasons when communicating the outcome of its investigation. Depending on the subject of the complaint, the explanation includes the exact wording of the relevant contractual provision and refers to statements sent to the Customer and other information provided during the contractual relationship.

  • If a Customer submits a repeated complaint containing the same objection and grounds as an earlier complaint, the Company sends its reasoned position within the statutory deadline, taking account of legal requirements, and attaches its response to the previous complaint. The earlier response need not be attached again if it is beyond doubt that the Customer received it.

  • Printed statistics must be generated quarterly from the complaint registration system. The Duna House Franchise Professional and Customer Coordinator is responsible for this task.

IV. Complaint handling procedure

1. Methods of submitting complaints

Complainants may submit their complaints to the Company as follows:

Orally

  • In person at the Company’s customer service office during opening hours, from 08:00 to 17:00 on every working day.

  • By telephone on 06-1-555-2222, from 08:00 to 20:00 on every working day.

In writing

  • In person or by delivering a document through another person to the Company’s customer service office at 1027 Budapest, Kapás u. 6–12., Building A.

  • By sending a letter signed by the complainant to 1027 Budapest, Kapás u. 6–12., Building A.

  • By sending a fax signed by the complainant to 06-1-555-2220.

  • By email to panasz@dh.hu, attaching a document signed by the complainant.

Where possible, complaints must be resolved immediately at the point of contact. If this is not possible, or the complainant does not accept the proposed solution, the complaint must be forwarded through a regulated process that can be tracked within the organisational hierarchy.

If the complainant acts through an authorised representative, the power of attorney must be set out in a public document or a private document with full probative force.

2. Handling oral complaints

Complainants may submit oral complaints in person at the Company’s customer service office or by telephone.

For oral complaints submitted by telephone, the Company provides for answering the call and beginning to handle the matter within a five-minute waiting period. It must act as generally expected in the circumstances to enable a customer service representative to answer the call live within five minutes after the call has been successfully connected.

When handling a complaint by telephone, the complainant must be informed that the conversation will be recorded. The Company records telephone communications with the complainant and retains the recording for five years.

At the complainant’s request, the Company must allow them to listen to the recording and provide a certified extract of the recording free of charge within fifteen days, according to the complainant’s choice.

The Company may request copies only of documents that are necessary to substantiate the complaint, are held by the Customer and are not already available to the Company.

Where possible, the Company immediately investigates an oral complaint and takes remedial action as necessary.

If the complainant disagrees with how the complaint is handled, the Company prepares a complaint record using the template included in Annex 2 to this Policy and authenticates it with its signature. For an oral complaint submitted in person, a copy is handed to the complainant. The Company then follows the rules applicable to written complaints.

For an oral complaint submitted by telephone, the Company prepares a complaint record and sends it to the complainant, then follows the rules applicable to written complaints.

If the complaint cannot be investigated immediately, the Company also prepares a complaint record and authenticates it with its signature. For an oral complaint submitted in person, a copy is handed to the complainant, after which the rules applicable to written complaints are followed.

For an oral complaint submitted by telephone, the Company prepares a complaint record and sends it to the complainant, then follows the rules applicable to written complaints.

For telephone complaints, the representative handling the matter informs the complainant of the complaint record’s unique reference number during the call.

Where a complaint record is prepared, it must contain at least:

a) the Customer’s name;

b) the Customer’s residential address or registered office and, where necessary, correspondence address;

c) the place, time and method of submitting the complaint;

d) the name and address of the service provider concerned;

e) a detailed description of the complaint, recording its individual elements separately to ensure that every objection is fully investigated;

f) the number of the contract concerned and, depending on the matter, the customer number or the member’s fund identification number;

g) a list of the records, documents and other evidence presented by the Customer;

h) the place and time at which the complaint record was prepared;

i) for an oral complaint submitted in person, the signatures of the person preparing the record and the Customer.

3. Handling written complaints and oral complaints documented in a complaint record

3/a. Registering complaint letters

The IT system forwards complaint letters received electronically to the Duna House Franchise Professional and Customer Coordinator and the Company’s Division Head.

All complaint letters received must be recorded in the Complaint Handling subfolder of the designated folder. Their main category, meaning the complaint type, must be indicated, together with any additional complaint types under the “Categories” tab.

The Duna House Franchise Professional and Customer Coordinator registers complaint letters received immediately after the mail is opened or handed over by the designated representatives of other departments.

Complaint letters may be registered only by linking them to a customer contract and providing the customer identifier, which may be an application number or contract number.

Once the customer contract has been identified, the system displays its current status and the date on which that status was last changed.

The registration system is specifically intended for recording customer complaints.

The sender of a complaint letter, hereinafter referred to as the complainant, may be:

  • the Customer;

  • the Customer’s legal representative;

  • a guarantor;

  • an authorised representative;

  • the MNB, the Magyar Nemzeti Bank;

  • another party.

During registration, the person entering the complaint may assign its investigation and response to a specific person working in the same department. The assignment and its date must be recorded.

3/b. Documenting complaints submitted orally or by telephone

Complaints submitted orally or by telephone are documented in the Complaint Handling subfolder of the designated folder.

The representative receiving the complaint records the Customer’s name, contract number, the complainant’s status and, if the complainant is not the Customer, the complainant’s name, together with the main complaint category.

Where necessary, the representative also records a list of the records, documents and other evidence presented.

For a complaint submitted orally in person, after recording the data, the representative prints the complaint record from the internal computer system, signs it, obtains the complainant’s signature and hands a copy to the complainant.

After registration, a unique reference number is generated for complaints documented in a complaint record. This enables the complaint to be retrieved from the internal computer system.

For telephone complaints, the representative informs the complainant of the unique reference number. The identifier indicates the complaint’s sequential number and the year of submission, for example: xxx / 2017.

When registering records of complaints submitted orally or by telephone, the Duna House Franchise Professional and Customer Coordinator assigns them for response either to themselves or to another representative designated by the Managing Director.

3/c. Responding to complaint letters and complaints documented in a complaint record, collectively referred to as “complaint cases”

The Company provides accurate, clear and understandable reasons for its substantive decision on a complaint and sends the decision to the complainant in writing.

The Company may request copies only of documents that are necessary to substantiate the complaint, are held by the Customer and are not already available to the Company.

If the response refers to legislation, it must identify the precise statutory provision and explain its substantive content.

When communicating its substantive decision, the Company informs the complainant of the available means of enforcing claims and obtaining a remedy as follows.

If a complaint is rejected or the statutory response deadline of 30 calendar days expires without a response, a Customer who does not qualify as a consumer may bring proceedings before a court.

If a complaint is rejected or the statutory response deadline of 30 days expires without a response, a Customer who qualifies as a consumer may bring proceedings before a court or contact the following bodies or authorities:

a) Financial Arbitration Board

For disputes concerning the formation, validity, legal effects or termination of a contract, or a breach of contract and its legal effects:

  • Address: 1122 Budapest, Krisztina krt. 6.

  • Postal address: H-1525 Budapest, P.O. Box 172

  • Telephone: +36-80-203-776

  • Email: ugyfelszolgalat@mnb.hu

b) MNB customer service for financial consumer protection enquiries

In the absence of a settlement, the acting panel of the Financial Arbitration Board may issue a binding decision even if the service provider has not made a declaration accepting its decisions as binding, provided that the application is well-founded and the consumer Customer’s claim does not exceed HUF 2 million, either in the application or at the time the binding decision is issued.

If a complaint is rejected or the statutory response deadline of 30 calendar days expires without a response, the consumer Customer must be informed that they may request the application form required to initiate proceedings before the Financial Arbitration Board or the MNB customer service for financial consumer protection enquiries.

Complaint letters and complaints documented in a complaint record must be answered within 30 calendar days of receipt. The Duna House Franchise Professional and Customer Coordinator is responsible for ensuring compliance with this deadline.

For responses sent to the MNB, the Supervisory Authority specifies the deadline in its enquiry; this is generally 30 days.

A response sent to the Supervisory Authority must also be sent to the complainant at the same time. Responses sent to the MNB are signed by the Managing Director.

Unless the Customer instructs otherwise, the Company sends its reasoned response electronically, through the same channel used to submit the complaint, if the Customer submitted the complaint:

a) from the email address provided for contact purposes and recorded by the Company; or

b) through an online portal operated by the Company and accessible exclusively to its Customers.

Electronic delivery as described above may not be used if the Company cannot ensure that the method of delivery identifies the recipient and notification address and conclusively demonstrates that the response was sent and when it was sent.

It may also not be used if data protected by confidentiality rules cannot be safeguarded against unauthorised third parties.

In other cases, the Company sends its response by registered post with acknowledgement of receipt.

3/d. Actions after responding to complaint letters and complaints documented in a complaint record

Once the designated person has answered the complaint letter or documented complaint, this must be recorded in the registration folder.

All documents generated in connection with a complaint, particularly the complaint and the response, must be digitised and linked to the relevant Customer in the designated complaint handling folder.

Original documents must be filed in the customer file and retained for five years. They must be presented to the Supervisory Authority upon request.

The Managing Director retains complaints received from the Supervisory Authority and the responses to them, including all attachments, and maintains a separate register.

3/e. Rules on processing data during complaint handling

The data of a Customer submitting a complaint must be processed in accordance with Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information.

After registration, complaint letters and complaints documented in a complaint record are automatically entered into the complaint register folder. The Company takes particular care to ensure that data requested for identification purposes complies with data protection requirements.

When handling a complaint, the Company may request the following data from the Customer:

a) name;

b) contract number, customer number or fund identification number;

c) residential address, registered office and correspondence address;

d) telephone number;

e) preferred notification method;

f) the product or service concerned;

g) a description of the complaint and its grounds;

h) copies of documents necessary to substantiate the complaint that are held by the Customer and are not already available to the service provider;

i) a valid power of attorney if the Customer acts through an authorised representative;

j) other data necessary to investigate and answer the complaint.

4. Queries, records and statistics

4/a. Monitoring unanswered complaint letters and complaints documented in a complaint record

To enable continuous monitoring of complaint processing, a list of unanswered complaint letters and documented complaints can be generated.

The list contains:

  • contract number;

  • Customer’s name;

  • name of the person recording the complaint;

  • name of the person assigned to take action;

  • assignment date;

  • complainant’s name;

  • main category.

The Duna House Franchise Professional and Customer Coordinator checks the list of unanswered complaints weekly and ensures that they are answered within the deadline.

4/b. Contents of the complaint register

The register contains:

a) a description of the complaint, identifying the event or fact to which it relates;

b) the date the complaint was submitted;

c) a description of the action taken to settle or resolve the complaint or, if it was rejected, the reasons for rejection;

d) the deadline for completing the action and the name of the person responsible;

e) the date the response was posted or, for electronic responses, the date it was sent.

The complaint and the response must be retained for five years.

4/c. Statistics

Statistics may be generated for a specified period concerning complaint letters received and complaints documented in a complaint record, containing the following information:

  • date of recording or receipt;

  • name of the person recording the complaint, for complaints documented in a complaint record;

  • name of the person registering the complaint;

  • complainant’s status and name;

  • contract number;

  • reference number, for complaints documented in a complaint record;

  • main category;

  • additional categories;

  • Customer’s name;

  • name of the person responding;

  • response date;

  • number of days between receipt of the letter and the response;

  • content of the response.

The Duna House Franchise Professional and Customer Coordinator prints the statistics from the system quarterly, files them in a designated folder and also saves them electronically in the Company’s computer system.

Based on its complaint register, the Company monitors complaints and:

a) groups them by subject at the intervals used for preparing the above statistics, but at least annually;

b) identifies and establishes the facts and events causing the complaints;

c) examines whether the facts and events identified under paragraph b may affect other procedures, products or services;

d) initiates a procedure to remedy the facts and events identified under paragraph b;

e) summarises recurring or systemic problems and legal risks.

V. Regulatory supervision of complaint handling

In relation to consumer reports concerning financial organisations, the Magyar Nemzeti Bank does not intervene in individual disputes between a financial organisation and its Customer.

It examines written consumer reports submitted to it and, where direct action is not warranted, forwards them to the financial organisation concerned for comments and investigation.

During its supervisory activities, the Magyar Nemzeti Bank may examine complaint handling practices and compliance with legislation at individual financial organisations and across financial sectors.

It may publish its general supervisory findings to support improvements in complaint handling.

The Company prepares quarterly statistics in the format prescribed by the Supervisory Authority concerning complaints received during the relevant period and how they were handled.

The Finance and Controlling Department prepares the statistics and submits them to the Managing Director for review.

The statistics may be sent to the Supervisory Authority only after approval by the Managing Director.

VI. Contact person responsible for consumer protection matters

Under Section 288(5) of the Hpt., financial institutions and independent intermediaries must appoint a contact person responsible for consumer protection matters and notify the Supervisory Authority in writing of the appointment or any change within fifteen days.

Within the Company, the consumer protection contact person’s activities primarily aim to ensure that statutory, supervisory and other requirements protecting consumers’ interests are effectively integrated into the Company’s regular operations and daily practices.

Duties and responsibilities of the consumer protection contact person

  1. Coordinates and oversees the transparent implementation of consumer protection legislation and supervisory and other requirements within the Company’s operating framework. In cooperation with the Company’s internal auditor and legal counsel, regularly reviews internal policies and procedures to ensure that they appropriately reflect these requirements.

  2. Takes action within the Company to ensure that its practices are established in accordance with legislation and supervisory and other expectations promoting good practice, are documented in internal policies and are required to be followed by the representatives handling matters.

  3. Ensures or facilitates the timely communication of new legislation and requirements to the relevant departments and employees and their application in daily work.

  4. When products, services and their contractual terms are being defined, ensures, wherever possible from the product development and process design stages, that the Company also considers compliance with consumer protection requirements.

  5. Takes action to ensure that the relevant department submits consumer protection supervisory reports to the MNB with the required content and within the prescribed deadlines.

  6. Participates in establishing processes to measure the effectiveness of customer communication and information, such as customer satisfaction surveys and mystery shopping, evaluates the results and assists with any improvements required.

  7. Takes action to ensure that representatives involved in service provision, customer service and call centre staff, intermediaries and other agents acting on behalf of the Company receive appropriate training so that they can provide consumers with accurate, useful and understandable information.

  8. Ensures or facilitates the inclusion of consumer protection legislation and requirements in the Company’s internal training materials, alongside training on product and service terms.

  9. Initiates the publication of information materials, glossaries, household finance guides and calculators intended to promote informed consumer decisions on the Company’s website and their availability at customer service premises. Monitors these materials to ensure they remain up to date.

  10. Encourages the Company to participate in cooperation with the MNB and other relevant institutions and organisations to improve consumers’ financial knowledge, thereby supporting the MNB’s financial literacy activities.

Dóra Palánkai was appointed as the Company’s contact person responsible for consumer protection matters with effect from 7 June 2025.

The Company notifies the MNB of any change in the identity or details of its consumer protection contact person within fifteen days of the change.

CREDIPASS Szolgáltató Kft.