Customer Claim Handling Procedure

Approved
by Order No. 31/1-04-26 O/D of the General Director
of MCC “Bailyk Finance”
dated April 13, 2026

1. GENERAL PROVISIONS

1.1. This Customer Complaint Handling Procedure (hereinafter referred to as the “Procedure”) has been developed to protect the rights and legitimate interests of clients of CJSC MCC “Bailyk Finance” (hereinafter referred to as the “Company”), as well as to promote the social responsibility of the Company’s personnel.

1.2. This Procedure is an internal document of the Company and regulates the process of handling customer appeals, registration and record-keeping of complaints; the process of providing feedback and preparing reports for monitoring and analysis purposes; the process of interaction between the Company and its partner organizations; and establishes the procedure for equipping the Company’s offices and official website with information on financial services and customer feedback channels.

1.3. This Procedure has been developed in accordance with the applicable legislation, regulatory legal acts of the National Bank of the Kyrgyz Republic, in particular the Regulation on Minimum Requirements for the Provision of Banking Services and the Handling of Consumer Complaints, the Company’s internal regulatory documents, as well as generally accepted standards and principles of customer service and customer protection.

1.4. A complaint/appeal shall mean an oral, written, or electronic complaint, application, or suggestion submitted by a client containing information about violations of their rights, violations of regulatory legal requirements, requests for banking services, including amendments to contractual terms.

1.5. Complaints/appeals shall be accepted in all Company offices, through the official website, via electronic communication channels, as well as when received through the Company’s partners.

1.6. This Procedure is mandatory for handling complaints and suggestions received from the Company’s clients.

1.7. Complaints/appeals shall be reviewed free of charge.

1.8. When handling customer complaints/appeals, the Company shall be guided by the following key principles:

  • The 7 Client Protection Principles;
  • Legality, honesty, good faith, transparency, reasonableness, and fairness;
  • Respect for and protection of the rights and legitimate interests of clients, and maintaining a partnership-oriented approach toward them;
  • Mandatory review of complaints/appeals and provision of the results of such review;
  • Timeliness, objectivity, and completeness in the review process;
  • Review of customer complaints/appeals based on the principle of parity (equal treatment of clients).

2. INFORMATION AVAILABLE IN OFFICES REGARDING THE PROCEDURE FOR THE PROVISION OF BANKING SERVICES AND CUSTOMER FEEDBACK CHANNELS

2.1. In order to provide clients with the opportunity to submit complaints or suggestions, each Company office shall maintain a Complaints and Suggestions Book, which shall be bound, numbered, certified by the signature of the General Director or Branch Director, and stamped with the seal of the Company or Branch. The Complaints and Suggestions Book shall be prepared in accordance with the template set forth in Appendix 1 to this Procedure and placed in a location clearly visible to clients. The Complaints and Suggestions Book shall be retained for a period of at least five (5) years.

2.2. Information on customer feedback methods and channels shall be displayed in a prominent location accessible to clients in all Company offices.

2.3. The Company provides nine (9) customer feedback channels for communication with clients:

  1. Trust Line – telephone line for receiving calls: +996 (701) 51 17 61;
  2. WhatsApp – communication via the WhatsApp application: +996 (701) 51 17 61;
  3. Complaints and Suggestions Book – a special book available in every Company office, including the Head Office, for recording client complaints and suggestions;
  4. Personal Reception by the Company’s Management in accordance with the schedule specified in Clause 5.5;
  5. kairyluu@bf.kg – for receiving complaints and appeals by e-mail;
  6. Communication via Instagram: https://www.instagram.com/bailykfinance.kg/;
  7. Messages via Facebook: https://www.facebook.com/www.bf.kg;
  8. Telegram Bot – the official Telegram bot: @BailykFinance_bot;
  9. Call Center – Unified Information Center: +996 (220) 99 11 11, +996 (559) 99 11 11, +996 (509) 99 11 11.

2.3.1. The “Submit a Complaint” section of the Company’s website at https://bf.kg/ru/ostavit_zhalobu allows users to submit complaints without providing personal data. Complaints that do not contain information enabling identification of the applicant shall be considered anonymous, shall be registered, and shall be reviewed in accordance with Clause 3.3 of this Procedure.

2.4. An electronic version of this Procedure shall be published on the Company’s official website.

2.5. Upon a client’s request, Company employees shall explain the established procedure for handling complaints and appeals.

3.PROCEDURE FOR RECEIVING AND REGISTERING CUSTOMER COMPLAINTS AND APPEALS

3.1. The Company accepts customer appeals in Kyrgyz and Russian languages in the following forms:
• Oral form (via the hotline; by calling the Contact Center; during personal reception);
• Written form (submitted in person, via postal mail; entries made in the Complaints and Suggestions Book);
• Electronic form (messages received via e-mail, WhatsApp, Telegram, Facebook, Instagram, as well as through the website section “Submit a Complaint”).

3.2. To ensure completeness and quality of complaint review, clients are recommended to provide:
• surname, first name, and patronymic (if applicable);
• name and address of the office where the client was served;
• address and/or contact details for sending a response;
• description of the claim, request, complaint, or suggestion, as well as the date of submission.

3.3. All complaints submitted in the established manner are subject to mandatory registration and review. Refusal to accept complaints or applications, as well as requiring clients to present documents in order to access the Complaints and Suggestions Book, is not permitted.

3.4. Features of handling certain categories of appeals:
• Anonymous complaints are subject to registration and are reviewed based on the stated facts and available information. A substantive response is provided only if contact details or another communication channel is available. If no feedback channel is available, no response is provided.
• Repeated complaints containing issues previously reviewed without new arguments or circumstances are addressed with reference to the previously made decision. Reconsideration is carried out only if new data or facts are provided.
• Complaints outside the Company’s competence are responded to with explanations on how and where to submit the appeal, including the relevant authority or organization.
• Written complaints containing obscene or offensive language, as well as threats to life, health, or property of Company employees and/or their family members, are registered and may be left without substantive review. If information on possible violations is available, the Company conducts an internal review of the stated facts.

3.5. All appeals received by the Company, including those from the Head Office, Company branches, and partner organizations, must be registered in the electronic complaints register (CRM system) in accordance with the template provided in Appendix 2. Employees of the Company and partner organizations receiving customer complaints/suggestions must clarify whether the client agrees to be contacted following the resolution of the complaint/suggestion. If the client agrees, their contact phone number must be requested, except for complaints received via e-mail.

3.6. Registration of customer appeals in the electronic register is carried out by Contact Center Operators.

3.6.1. In case of anonymous appeals, registration and further review are carried out in accordance with Clause 3.3 of this Procedure.

3.7. Registration of appeals received at the Head Office of the Company: the Contact Center Operator receives and registers in the electronic register all appeals received via the communication channels specified in Clause 2.3 of this Procedure, as well as all letters delivered in person or received via postal mail.

3.7.1. At the Head Office, appeals received via the Complaints and Suggestions Book, as well as other written complaints submitted in person, are received by an employee of the Sales Support Department, who scans the relevant page of the Complaints and Suggestions Book and other written materials and sends them to kairyluu@bf.kg or callcenter@bf.kg for subsequent registration in the electronic register.

3.7.2. Upon receipt of complaints via postal mail, the Sales Support Department employee opens the envelope, registers it in the established manner, scans the letter, and sends it to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt.

3.7.3. Upon receipt of appeals sent to office@bf.kg, the Administrative Assistant forwards the appeal to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt.

3.8. Registration of appeals received in Company offices: the Cashier-Operator of the database (hereinafter “COD”) of the office, or the person substituting them, is required to forward information on appeals received in the office (oral, in-person visits, or phone calls to office numbers) to the Contact Center by sending a message to kairyluu@bf.kg or callcenter@bf.kg, including the description of the appeal in accordance with Clause 3.2.

3.8.1. When complaints are submitted via the Complaints and Suggestions Book, the COD scans the relevant page and sends it to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt, with additional comments if available.

3.8.2. Upon receipt of appeals via postal mail, the COD opens the envelope, stamps the letter with the date of receipt, scans it, and sends it to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt.

3.8.3. Control over timely submission of complaint information by the COD to the Contact Center is carried out by the Finance Manager / Deputy Finance Manager of the respective office, or the person substituting them.

3.8.4. In case of incomplete information, the Contact Center Operator must contact the person who submitted the information to clarify all relevant circumstances necessary for proper registration and review.

3.9. Registration of appeals received through Company partners.

3.9.1. When appeals are received by an insurance company, collection agency, or other partner organization under contractual relations with the Company, the partner organization shall send the text of the appeal to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt, including additional comments if available. Further review is carried out in accordance with Section 4 of this Procedure.

3.9.2. If an appeal addressed to a partner organization is received at a Company office, the COD, or in the Head Office by a Sales Support Department employee, shall forward the appeal to kairyluu@bf.kg or callcenter@bf.kg no later than the next working day after receipt, including additional comments if available. The Contact Center Operator receives and registers the appeal and forwards it to the partner organization using the contact details specified in the cooperation agreements.

3.10. When receiving letters from the National Bank containing customer appeals addressed to the Company at office@bf.kg, the Contact Center Operator shall act in accordance with the provisions of Section 4 of this Procedure.

4. PROCEDURE FOR HANDLING CUSTOMER APPEALS

4.1. The Contact Center employee shall register the customer’s appeal in the electronic complaints register in accordance with Appendix 2, and assign a category to the appeal/complaint according to the following types:

4.1.1. Complaints regarding service quality and customer service:

• complaints about queues in Company offices;
• complaints about inconvenient office location;
• complaints about poor cash desk (teller) service;
• complaints about customer discrimination (gender, age, nationality, etc.);
• complaints about rude behavior, unlawful actions and/or inaction of Company employees;
• other complaints related to the Company’s activities and employees.

4.1.2. Complaints regarding violations of loan agreements and Islamic finance agreements:

• complaints regarding violations of contractual terms with clients (incorrect calculations or information in loan agreements, repayment schedules, or credit information);
• complaints about a complex loan application process (document requirements, long processing time for loan issuance);
• complaints about a complex financing process or conditions under Islamic finance principles;
• complaints about incorrect information regarding the Company’s products and services;
• complaints about delays or refusal to issue collateral documentation;
• complaints about the operation of the Company’s information systems and digital services.

4.1.3. Pre-trial complaints and legal disputes:

• appeals containing disputes over the client’s rights (letters challenging the legality of the Company’s actions, validity of contracts, decisions, etc.);
• appeals submitted to the Company as part of pre-trial dispute resolution procedures (claims, settlement proposals, letters indicating the client’s intention to initiate legal proceedings);
• judicial documents (lawsuits and other claims submitted to courts and law enforcement bodies against the Company, court summons and/or notices, court rulings and/or decisions, writs of execution, enforcement orders from the State Enforcement Service, and other related documents).

4.1.4. Complaints regarding partner organizations:

• appeals containing complaints about the actions of employees of collection agencies engaged by the Company for overdue debt recovery;
• complaints about the operations and actions of insurance companies.

4.1.5. Customer requests, inquiries, and acknowledgments:

• requests to change loan agreement terms (deferral, extension, restructuring, debt write-off, etc.);
• suggestions regarding the Company’s operations;
• acknowledgments and expressions of gratitude to Company employees.

 

Type of Customer Appeal Responsible Unit (Employee) Participating Units (Employees)
complaints about rude behavior, unlawful actions and/or inaction of Company employees Branch Director and/or other relevant division Regional Office Director; Head of relevant division; HR Department; Security Department
complaints about discrimination of clients (gender, age, nationality, etc.) Branch Director and/or other relevant division Regional Office Director; HR Department
complaints about inconvenient office location Branch Director Administrative and Economic Department
complaints about poor cash desk service Branch Director Regional Office Director
complaints about queues in offices Branch Director and/or other relevant division Regional Office Director
complaints about delays or refusal to issue collateral documents Branch Director Regional Office Director; Legal Department; Sales Support Department
complaints about violation of loan agreement terms (incorrect calculations or information in loan agreements, repayment schedules, credit information) Branch Director and/or other relevant division Regional Office Director; Legal Department; Portfolio Administration Department
complaints about incorrect information regarding Company products and services Branch Director and/or other relevant division Regional Office Director; Sales Support Department; Head of relevant division
complaints about Islamic finance service process and conditions Branch Director Regional Office Director; Sales Support Department
complaints about complex loan application process (documents, processing time, etc.) Branch Director Regional Office Director; Sales Support Department
complaints about information systems and digital services Information Technology Department Regional Office Director; Information Security Department
pre-trial dispute complaints (claims, settlement proposals, intent to go to court) Legal Department Regional Office Director; Branch Director; Security Department
appeals containing disputes over client rights (challenging legality of Company actions, contracts, decisions, etc.) Legal Department Branch Director; Sales Support Department
court-related documents (lawsuits, court notices, decisions, enforcement documents, etc.) Debt Collection Department Regional Office Director; Sales Support Department; Legal Department
complaints about actions of collection agency employees Debt Collection Department Legal Department; Security Department
complaints about insurance company operations/actions Branch Director Sales Support Department; Regional Office Director
suggestions regarding Company operations Relevant division Regional Office Director; Head of relevant division
acknowledgements and gratitude to Company employees HR Department and/or relevant division Regional Office Director; Branch Director; Head of relevant division
requests for changes to loan terms (deferral, extension, restructuring, write-off, etc.) Branch Director and/or relevant division Regional Office Director
other complaints about Company operations and employees Relevant division Branch Director; Regional Office Director; Head of relevant division

Format of the “Complaints and Suggestions Book”

Date Full name of client Contact details (address, phone, e-mail) Description (essence) of complaint or suggestion Company explanations (actions taken) Date of response Full name of employee who provided the explanation

Appendix 2

Field name in CRM system Description and format of completion
Complaint ID Generated automatically
Date of complaint Date when the complaint, suggestion, or appeal was received
Type of complaint Specified in accordance with Section 4.1 of the Procedure
Source of information Communication channel (feedback channel), selected from the dropdown list in accordance with Section 2.3 of the Procedure
Office where appeal was received Indicated if necessary
Office related to the appeal Indicated if necessary
Full name of applicant Full name of the person submitting the appeal
Contact details of applicant Phone number, e-mail, or postal address (residential address) for providing a response
Description of complaint Summary of the essence of the appeal
Company explanations Brief and clear explanation provided by the responsible unit or employee
Response format Indicates the format in which the response was provided to the applicant
Date of response Date when the response was provided to the applicant
Name of employee who provided explanation Full name of the employee or responsible unit who provided clarification
Customer satisfaction level regarding complaint resolution Level of satisfaction with the received response; filled in last by the Contact Center Operator

 

Appendix 3

to the Customer Complaint Handling Procedure

Customer Complaint Submission Form

Full name of client:

Contact details (phone, address, e-mail):

Description of complaint / appeal:

Date: ___________________________

Client signature: ___________________________

Complaint received by (employee full name):

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