Complaint Handling Policy

DUNA HOUSE Biztosításközvetítő és Pénzügyi Tanácsadó Kft.

Last amended: 15 April 2025

I. Definitions

Complaint: Any objection concerning the conduct, activities or omissions of DUNA HOUSE Biztosításközvetítő és Pénzügyi Tanácsadó 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 DUNA HOUSE Biztosításközvetítő és Pénzügyi Tanácsadó Kft.

Matters not covered by this Policy are governed by Act LXXXVIII of 2014 on the Business of Insurance (Bit.) and 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, complaint handling must be provided 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 06-1-555-2250, 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.

2. Handling oral complaints

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

The Company ensures that calls are answered and handling of the matter begins within a five-minute waiting period.

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