Complaints procedure

Definitions

The terms used in this complaints procedure have the following meanings:
The financial services provider:   Triple A – Risk Finance B.V.
The complainant                                The individual who makes a complaint and/or his representative.
Complaint:                                     Any statement intended by the complainant to be a complaint.
Employee:                           Any person who, under the responsibility of the financial service provider, carries out activities in the financial services sector.

Notification to the management

All third-party statements that can be interpreted as a complaint will be immediately directed to the management.

Handling of complaint

Management will deal with each complaint.

Complaints file

Management will draw up a special complaints file for each complaint.

Confirmation

Within two working days after complaint, the complainant will receive written confirmation that their complaint has been received and that it will be dealt with by management. This confirmation shall contain:

• The date the complaint was received
• Short description of the content of the complaint
• The means used management to investigate the complaint
• Deadline for expecting further contact to be made with the complainant. In principle we try to deal with each complaint within a maximum of 6 weeks.
• Name of member of management dealing with the complaint
• Manner in which the complainant can approach management for further contact about the complaint.

Professional indemnity insurance

If the complaint could lead to a claim for liability, the professional indemnity insurer will be immediately informed. All further steps in the processing of the complaint take place after discussion with the professional indemnity insurer.

Adversarial Procedure

If the complaint concerns persons working under the responsibility of the financial service provider, management shall inform the person(s) concerned of the complaint received and request their comments. A written summary of the response of the person(s) involved will be made and, after person(s) involved have signed, will be added to the complaint file.

Assessment

After the management believes it has obtained sufficient information to reach a justifiable decision on the submitted complaint, the complainant will be contacted. As a matter of course, an attempt is made to hold a personal interview with the complainant. If the complainant chooses against this, they will be informed in writing of the management’s decision. If the management informs the complainant in writing of its opinion, the letter will at a minimum contain the following information:

• The date on which the complaint was received
• Short description of the complaint
• Information that the complaint has been dealt with immediately by the management
• Results of the management’s investigation into the complaint
• Management’s opinion on the complainant’s complaint
• Any follow-up action that the financial services provider may take in regard to the complainant
• Possibility for the complainant to have further contact in response to management’s position
• Information regarding the Ombudsman connected with the Financial Services Complaints Tribunal (Stichting Klachteninstituut Financiële dienstverlenging – KIFID) as well as about the Disputes Committee of the KIFID to which the complainant can refer if they believe the complaint has been incorrectly dealt with.

Structural measures

After dealing with each complaint, management will consider whether there are ways to prevent a repeat of this type of complaint and, if so, what they are. If concrete measures are taken to this end, these will be recorded in the complaint file.

Archiving

Each complaint file shall be kept for at least 12 months, starting from the moment the complaint is settled. If the complainant applies to a disputes committee, the complaint file will be kept for at least 12 months after the disputes committee has rendered its decision.

Coming into force

This complaints procedure will take effect immediately.