2.1 General principles

When resolving complaints and other customer requests, the company ensures that the internal complaints resolution procedure complies with the principles of equal treatment of customers, prevention of conflicts of interest, fairness, proportionality, lawfulness and professionalism, confidentiality and data protection, and efficiency, objectivity and speed.

2.2 Jurisdiction and responsibility for complaints resolution

The responsible person shall obtain all relevant evidence and objectively, professionally and impartially examine and assess its truthfulness, credibility and significance in relation to the circumstances of the specific complaint.

The responsible person is independent and autonomous in their work. All customer data in the procedure must be protected as confidential. All communication with the customer shall be conducted in a clear and unambiguous manner.

2.3 Procedure for lodging and accepting complaints

Customers may lodge their complaints in writing (by post or email at zavarovalnistvo@findes.si) or orally (in person — directly with company employees, where a record shall be made).

A written complaint from a customer must be intelligible and shall contain the name and surname of the customer, the address of the customer, the reasons for the complaint and the signature of the customer. For a complaint received by email, in the absence of doubt as to the authenticity of the filing, it is deemed to have been signed by the person named as the signatory in the filing.

An oral statement from a customer shall be treated as a complaint if it is made on record at the company. The responsible person shall previously inform the customer of these rules.

If a customer's complaint is unclear or does not contain the necessary information to be processed, the responsible person shall request the complainant to provide appropriate supplementation or additional clarification in writing. Depending on the substance of the supplementation of the statements, a deadline may be set for the customer to supplement the statements, which shall not exceed 15 days. If the customer does not comply with the request, the complaint shall be dismissed, and the customer shall be notified thereof in a clear and understandable manner.

Complaints lodged with the Slovenian Insurance Association (SZZ) or the Insurance Supervision Agency (AZN) and subsequently forwarded to the company shall be treated in the same manner as if they had been lodged directly with the company.

2.4 Decision on complaints and complaints resolution

The responsible person shall distinguish between the handling of simple requests (questions, requests for clarification, petitions, claims etc.) and complaints from customers. Simple requests shall not be maintained in the company's complaints register.

The responsible person may make the following decision regarding customer complaints:

• dismiss the complaint (in cases where the conditions for its processing are not met);
• reject the complaint as unfounded;
• uphold the complaint in part or in full;
• terminate the complaints procedure (in the event that the complaint is withdrawn).

The responsible person must resolve the complaint within a maximum of 30 days from the receipt of the complete complaint by the company. Any breach of this deadline must be notified to the customer in writing before the deadline expires, stating the reasons for the delay. In any case, the customer shall be provided with a response.

The decision must be reasoned. If the complaint is well-founded, the decision must be executed within the shortest possible time. In any case, the decision (status of the complaint) must be appropriately recorded in the company's complaints register.

Complaints within the company's internal complaints resolution procedure shall be resolved in one instance. The customer must receive a written, reasoned response from the responsible person to each complaint.

If the customer lodges a repeated complaint, the company must send the customer the final response in written form by registered mail. The provision concerning the final response also applies in the case of a repeated complaint by email, if the company knows the sender's address. The final response must also include legal information on the possibility of continuing the procedure within the existing out-of-court dispute resolution mechanism.

The customer shall bear any costs of legal advice and representation incurred by their participation in the complaints procedure.

The responsible person shall inform the customer that the decision is final, but the customer, if not satisfied with the decision, may continue the complaints resolution through out-of-court dispute resolution institutions, namely:

• dispute resolution through mediation at the Mediation Centre at the Slovenian Insurance Association, GIZ, where disputes arising from insurance and compensation relationships on the basis of insurance contracts or by law are resolved out of court, namely regarding the rights of policyholders, insureds, injured parties and insurance companies, or
• dispute resolution with the insurance ombudsman due to non-compliance with the Insurance Code, other good business practices and fundamental standards of the insurance profession. The ombudsman does not handle disputes arising from insurance relationships which, by their legal nature and content, would fall within the jurisdiction of the court.

All customer complaints and final complaints decisions shall be recorded in the company's complaints register.

The company shall analyse disputed matters and their manifestations and causes at least once a year. The analysis shall serve as a basis for further activities in ensuring continuous care for customers and improving the company's operations.

Upon request, the company shall provide information to the Insurance Supervision Agency on the number of complaints, the type of insurance to which the complaint relates, the reasons for complaints, the timeliness of the solution and the merits of the complaint.

These rules shall enter into force and apply from 01.07.2024 onwards. They shall be published in the register in the reception office of Findes plus 2 d.o.o., in prominent places in all business premises in which business is conducted with customers and on the company's website.

In Ljubljana, 01.07.2024

Findes plus 2 d.o.o.
Urška Pajnič
Director