The procedure for considering customer requests Closed Joint Stock Company “MCC “Bailyk Finance”

Customer Claim Handling Procedure

Approved

By the Order of the Director General

No. 46/1-06-24 O/D

dated June 18, 2024

1. GENERAL PROVISIONS
1.1. This Procedure for considering customer requests (hereinafter referred to as the “Procedure”) has been developed in order to protect the rights and legitimate interests of the clients of ZAO MFI “Bailyk Finance” (hereinafter referred to as the “Company”), as well as in order to develop social responsibility of the Company’s personnel.
1.2. This Procedure is an internal document of the Company and regulates the process of considering requests, registering and recording complaints; the process of providing feedback, as well as generating reports for the purpose of accounting and analysis; the process of interaction between the Company and partner organizations; determines the procedure for equipping the offices and the official website of the Company with information on the provision of financial services and feedback channels with clients.
1.3. This Procedure has been developed in accordance with the current legislation, regulatory legal acts of the National Bank of the Kyrgyz Republic, in particular with the Regulation on the minimum requirements for the procedure for the provision of banking services and the consideration of consumer requests, local regulatory acts of the Company, as well as generally accepted standards and principles of servicing and protecting clients.
1.4. An appeal shall be understood as an oral or written (or electronic) complaint, statement or proposal from clients containing information about the violation of their rights, requirements of regulatory legal acts, requests for the provision of banking services, including changes to the terms of the agreement.
1.5. Appeals are accepted without fail in all offices of the Company, on the official website, electronic means of communication, as well as when received through the Company’s partners.
1.6. The procedure is mandatory for execution when working with complaints / suggestions received from the Company’s clients.
1.7. Consideration of appeals is carried out free of charge.
1.8. When considering client appeals, the Company is guided by the following basic principles:

 7 principles of client protection;
 Legality, honesty, good faith, transparency, reasonableness, fairness;
 Respect and ensuring the rights and legitimate interests of clients, a partnership attitude towards them;

 Mandatory consideration of appeals and provision of the results of their consideration;
 Timeliness, objectivity and completeness of consideration of requests;  Consideration of customer requests on the principles of parity (equality of customers).

2. EQUIPPING OFFICES WITH INFORMATION ON THE PROCEDURE FOR PROVIDING BANKING SERVICES AND FEEDBACK CHANNELS

2.1. In order to provide customers with the opportunity to submit a complaint or suggestion, each office of the Company must have a Book of Complaints and Suggestions, laced, numbered, certified by the signature of the General Director or Director of the Branch and the seal of the Company or Branch. The Book of Complaints and Suggestions must be drawn up in accordance with the sample specified in Appendix 1 to this Procedure and placed in a place visible to customers. The Book of Complaints and Suggestions must be stored for at least 5 years.
2.2. Information on feedback methods and channels must be posted in a visible place for customers in all Company offices.
2.3. The Company provides 10 feedback channels for interaction with customers:
1) “Helplines” – a telephone line for receiving calls (0701) 51 17 61;
2) “WhatsApp” – for communication via the WhatsApp application at (0701) 51 17 61;
3) “Book of complaints and suggestions” – a special book for recording complaints and suggestions from customers, available in each office of the Company, including the Head Office, to reflect complaints and suggestions;

4) The “Leave a complaint” section of the website at https://bf.kg/ru/ostavit_zhalobu – for leaving a complaint via the Internet;
5) Personal reception of clients by the Company’s management according to the schedule specified in paragraph 5.5;

6) Email kairyluu@bf.kg – for receiving requests by email;
7) Instagram – For communication via the social network Instagram https://www.instagram.com/bailykfinance.kg/;

8) Facebook – Messages on the social network Facebook https://www.facebook.com/www.bf.kg;
9) Telegram bot – Official auto-reporting bot in the Telegram messenger @BailykFinance_bot;
10) Call Center – Single information center (0220) 99 11 11, (0559) 99 11 11, (0509) 99 11 11.
2.4. The electronic version of this Procedure must be posted on the official website of the Company.
2.5. At the request of the client, the Company’s employees are obliged to explain to him the established procedure for considering requests.

3. PROCEDURE FOR RECEIVING AND REGISTRATION OF APPEALS

3.1. The Company accepts appeals in Kyrgyz and Russian in the following forms:
 orally (by calling the hotline; by calling the Contact Center; in person);
 in writing (received in person, to the postal address; entry in the Book of Complaints and Suggestions);

 in electronic form (messages received by e-mail, via the WhatsApp, Telegram application, on social networks Facebook, Instagram, as well as in the “Leave a complaint” section of the website).
3.2. Appeals are accepted for consideration in accordance with Appendix 3, containing the following

 address, contact details of the client for sending a response;
 the essence of the claim, request, complaint, wish and date of the request.
3.3. All requests submitted in the established manner are subject to mandatory consideration. Refusal to accept complaints and applications, as well as the requirement from the client to present documents for access to the Book of complaints and suggestions, is not allowed.
3.4. Not subject to consideration:
 A written request from the client that does not indicate his personal and contact information (last name, first name, patronymic, client’s telephone number), or the postal address to which the response should be sent (anonymous requests);
 A written request from the client that contains obscene or offensive language; expressions containing a threat to the life, health and property of the Company’s employee, as well as members of his family;
 Repeated consumer requests that do not provide new arguments or circumstances, provided that previous requests have been answered comprehensively and all necessary measures have been taken;
 Requests that contain issues that are not within the Company’s legal competence, provided that the client is explained where and in what order they should contact them.
3.5. All requests received by the Company, including the Head Office, the Company’s offices, and partner organizations must be registered in the electronic request log – the CRM system, in accordance with the sample specified in Appendix 2. Employees of the Company and partner organizations accepting customer requests, when registering a complaint/suggestion, must clarify the possibility of calling the client following the resolution of the client’s complaint/suggestion. In the event of a positive response from the client, it is necessary to ask for the client’s contact phone number, with the exception of requests received by e-mail.
3.6. Registration of customer requests in the electronic registration log is carried out by Contact Center Operators.
3.7. Registration of requests received by the Company’s Head Office. The Contact Center Operator accepts and registers in the electronic log of requests all requests received through the feedback channels specified in paragraph 2.3. of this Procedure and all letters sent in person to the Company’s postal address.
3.1.1. At the Head Office, requests from the Company’s clients are accepted by an employee of the Sales Support Department, who scans the relevant page of the Complaints and Suggestions Book and sends it to the e-mail address kairyluu@bf.kg or callcenter@bf.kg for subsequent registration of the request in the electronic log of requests.
3.1.2. Upon receipt of requests by mail, an employee of the Sales Support Department opens the envelope, registers it in the prescribed manner, scans the letter and sends it to the e-mail address kairyluu@bf.kg or callcenter@bf.kg no later than the next business day from the date of receipt of the letter.
3.1.3. Upon receipt of requests to the email address: office@bf.kg, the Administrative Assistant forwards the request to the email address kairyluu@bf.kg or callcenter@bf.kg no later than the next business day from the date of receipt of the request.
3.8. Registration of requests received at the Company’s offices. The cashier-database operator (hereinafter referred to as “CODB”) of the office or the person replacing him/her is obliged to transfer information about requests received at the office to the Contact Center (orally, during the client’s visit and by calling the office phones), by sending a message to the email address kairyluu@bf.kg or callcenter@bf.kg with a description of the request in accordance with paragraph 3.2.;
3.1.4. When requests are received by recording in the Book of Complaints and Suggestions, the KOBD scans the relevant page of the Book of Complaints and Suggestions and sends it to the e-mail address kairyluu@bf.kg or callcenter@bf.kg no later than the next working day from the moment of receipt of the request with additional comments on the request, if any;
3.1.5. When requests are received by mail, the KOBD opens the envelope, puts the date of receipt on the letter, scans the letter and sends it to the e-mail address kairyluu@bf.kg or callcenter@bf.kg no later than the next working day from the moment of receipt of the letter.
3.1.6. The Financing Manager/Deputy Financing Manager of the relevant office, or a person replacing him/her, monitors the timely transfer of information on requests to the KOBD to the Contact Center;
3.1.7. In case of incomplete information, the Contact Center Operator must contact the person transmitting information about the request to clarify all the circumstances that are important for consideration and registration.
3.9. Registration of requests received through the Company’s partners.
3.1.8. When requests are received by an insurance company, collection agency or other partner organization with which the Company has contractual relations, the partner organization sends the text of the request to the e-mail address kairyluu@bf.kg or callcenter@bf.kg no later than the next business day from the moment of receipt of the request with additional comments about

3.1.9. Upon receipt of requests addressed to a partner organization at the Company’s office, the KOBD or his substitute, at the Head Office – an employee of the Sales Support Department, sends the request to the e-mail address kairyluu@bf.kg or callcenter@bf.kg no later than the next business day from the moment of receipt of the request with additional comments on the request, if any. The Contact Center Operator accepts and registers the request and forwards it to the partner organization using the contacts specified in the Cooperation Agreements.
3.10. Upon receipt of letters from the National Bank with requests from clients addressed to the Company to the e-mail address office@bf.kg, the Contact Center Operator is guided by the provisions of Section 4 of this Procedure.

4. PROCEDURE FOR CONSIDERING APPEALS

4.1. The Contact Center employee registers the client’s request in the electronic request log in accordance with Appendix 2, and assigns a request/complaint category according to the following types:
4.1.1. Complaints about service and quality of service:
• complaints about queues at offices;
• complaints about the inconvenient location of the office;

• complaints about unsatisfactory work of the cash desk;
• complaints about discrimination against the client (gender, age, nationality, etc.);
• complaints about rudeness, illegal actions and/or inaction of the Company’s employees;
• other complaints about the activities of the Company and employees.
4.1.2. Complaints about violation of the terms of the loan agreement and Islamic financing agreements:
• complaints about violation of the terms of the agreement with the client (incorrect calculations or information in the loan agreement, repayment schedule, CIB);

• complaints about the complex loan application process (package of documents, duration of the loan issuance);
• complaints about the complex process of provision, terms of financing according to Islamic principles;
• complaints about incorrect information about the Company’s products and services;
• complaints about delays or refusal to issue collateral documents.
4.1.3. Pre-trial complaints and disputes about rights:
• containing a dispute about the Client’s rights (letters challenging the legality of the Company’s actions, challenging the validity of contracts, decisions, etc.);
• Appeals received by the Company in the course of pre-trial measures to resolve disputes (claims, proposals for settling a dispute out of court, letters indicating the client’s intention to apply to the courts);
• constituting judicial documents (a statement of claim and other statements filed with judicial and other law enforcement agencies against the Company, a summons and/or court notice, a court ruling and/or decision, a writ of execution, a PSSI ruling, other letters, etc.).
4.1.4. Complaints about the work of partner organizations:
• requests containing a complaint about the actions of employees of a collection agency engaged by the Company to work with overdue debts;

• complaints about the work, actions of an insurance company.
4.1.5. Requests, requests and confessions from clients:

• requests to change the terms of a loan agreement (deferral, extension, restructuring, write-off, etc.);
• proposals for the work of the Company;
• confessions, gratitude to an employee of the Company.
4.2. After registering the request, the Contact Center Operator forwards it to the officials and/or structural divisions of the Company, whose competence includes the client’s issue (hereinafter referred to as the “Responsible Division”), in particular:

4.3. A customer complaint received by the Company shall be reviewed within 10 business days from the date of its registration, with the exception of court requests and requests from other law enforcement agencies, requests from the National Bank, the execution period for which may differ. If an additional investigation or other measures are required to review a customer complaint, the complaint review period may be extended by 10 business days, indicating the reason for the extension in the Electronic Journal of Complaints. In the event that the review of a customer complaint is extended, the Contact Center Operator must inform the customer of the extension, indicating the reason.
4.4. When sending a request to the Responsible Division of the Company, the Contact Center Operator notifies the responsible employee of the maximum 10-day period during which the request is subject to review.
4.5. The Responsible Division is obliged to:
• determine a specific executor responsible for reviewing the request on the merits of the issue raised in it;
• if an internal investigation is necessary, send the complaint to the Security Department;
• if necessary, request information from other departments that is necessary to consider the request;
• if necessary, contact the client to clarify his complaint or request;
• initiate an application for consideration by the Credit Committee if the client’s request raises issues within the competence of the Credit Committee;
• if necessary, initiate internal investigations into the facts voiced in the request;

• prepare a draft response on behalf of the Company to the request, arrange for its approval and signing.
4.6. The response must contain a clear justification for satisfying (in full or in part) or refusing to satisfy the request, or an explanation of the rights and obligations of the client. The response must contain information about the responsible executor and his contact details. If necessary, copies of documents are attached to the response.
4.7. The Company’s response to the client based on the results of the request is given in the language of the request: the state or official language of the Kyrgyz Republic.
4.8. If the client’s request is justified and legitimate, the Company takes measures to eliminate violations, restore the rights and legitimate interests of the client, or take other appropriate measures.
4.9. If the request contains questions that are not within the legal competence of the Company, the client is given a written explanation of where and in what order he should contact.
4.10. The Responsible Department is responsible for meeting the deadline for considering the client’s request.
4.11. Except for cases where the draft response is prepared by the Legal Department, the draft response is subject to approval by the Legal Department, which checks the response for legality and ensures compliance with the corporate style of the Company’s office work.
4.12. The Contact Center Operator is obliged to:
4.1.6. Ensure that a response is sent to the client at the addresses specified in the request (if the request is a collective one, the response is sent to the address specified first in the request, unless otherwise specified in the request itself), or that a response is sent to the Financing Manager of the office from which the request was received to enter the client’s response to the complaint in the Book of Complaints and Suggestions;
4.1.7. Fill in the “Company’s Explanations” section in the request card in the electronic journal of requests for registration of measures taken based on the results of the request;
4.1.8. File the request, response and attachments to it in a separate folder and ensure their storage for at least 5 years.
4.13. Based on the results of reviewing the client’s written request, the Financing Manager or his/her substitute is obliged to record the result of the investigation of the client’s complaint/request in the Book of Complaints and Suggestions:

 the Company’s explanation in response to the client’s complaint/request;
 the date of providing the response to the client;
 Full name of the employee who provided the explanation.
4.14. If the request was not reviewed (indicate the reason why the request was left without review).
4.15. Financing managers or their substitutes must send scanned copies of the Complaints and Suggestions Books to the Head of the Contact Center on a monthly basis to check that they have been filled in correctly.

5. PROCEDURE FOR REVIEWING ORAL APPEALS

5.1. All Company employees who have accepted oral requests from clients, received via telephone or in person, are required to provide advice on feedback channels for submitting requests and assist clients in drafting written requests.
5.2. In the event that the consultation is completed by the client drawing up a written request, the Company employee must transfer the information to the Contact Center for its registration to the e-mail address kairyluu@ or callcenter@bf.kg in accordance with Section 4 of this Procedure.
5.3. In the case of an oral request, a Company employee, with the client’s consent, may make an audio recording of the conversation for use in further consideration of the request. In order to provide high-quality feedback, all requests received orally must be transferred to the Contact Center in accordance with Section 3.8. of this Procedure.
5.4. If an oral request does not require additional verification and does not contain information about violations, then a response to the request can be given promptly orally (by telephone or in person).
5.5. The Director of the Regional Office or other authorized persons, as well as the heads of the relevant districts and (or) offices, conduct a personal reception of visitors according to the following schedule:
• Director of the Regional Office — every Tuesday from 10:00 to 11:00 at the Head Office of the Company;

• Director of the District or the Financing Manager of the relevant office — daily from 10:00 to 11:00.
5.6. Following the personal reception, a protocol or a written request is drawn up, and with the client’s consent, audio and video recording may be made. In cases where a written request is drawn up, the procedure for consideration is carried out in accordance with Section 4 of this Procedure.

6. CONTROL AND RESPONSIBILITY

6.1. The Head of the Responsible Unit shall exercise control over the timeliness of consideration of requests and preparation of responses for the Contact Center Operator.
6.2. In cases of violation of the review deadlines without good reason or failure to provide responses to requests, the Head of the Contact Center shall inform the General Director and the Operations Director of such facts.
6.3. Verification of the correctness of the compilation and maintenance of the Book of Complaints and Suggestions, as well as compliance with the requirements of this Procedure by the Company’s employees shall be carried out by the Internal Audit Service during audit checks.
6.4. Employees found guilty of violating the procedure for considering requests established by this Procedure may be subject to disciplinary measures stipulated by the legislation of the Kyrgyz Republic, the Code of Corporate Ethics, the HR Policy and other internal regulations of the Company.
6.5. All information received by the Company’s employees during the consideration of customer requests is and is recognized as confidential and is not subject to disclosure, except in cases where such disclosure is permitted in accordance with the legislation of the Kyrgyz Republic.

7. ANALYTICS AND REPORTING

7.1. The Head of the Contact Center must prepare and submit to the Company’s management a monthly report on complaints received and requests received through all communication channels.
7.2. At the request of other departments, the Head of the Contact Center may provide consolidated statistical data on customer requests and the results of their consideration.
7.3. The Head of the Contact Center shall prepare and submit to the authorized structural division of the National Bank of the Kyrgyz Republic a report on written complaints from consumers on a semi-annual basis. The report shall be drawn up in accordance with the form established by the regulatory acts of the National Bank of the Kyrgyz Republic, signed by the General Director of the Company and submitted before the twentieth day of the month following the reporting half-year.

8. FINAL PROVISIONS

8.1. Additions and amendments to this Procedure shall be made as necessary and approved by the Order of the General Director.
8.2. In the event that individual provisions of this Procedure conflict with the current legislation of the Kyrgyz Republic, they shall lose force and the relevant provisions of the current legislation of the Kyrgyz Republic shall apply. The invalidity of individual provisions of this Procedure shall not entail the invalidity of other provisions and the Procedure as a whole.

9. APPENDICES:

9.1. The following documents are attached to this Procedure:
1. Book of complaints and suggestions;
2. Electronic journal of requests;
3. Form for receiving customer requests.

Customer appeals
Review Procedure
Appendix 1

Format of “Complaints and Suggestions Booklet”

Appendix 2
to the Procedure for Considering
Customer Appeals
Format for Registering Appeals in the Electronic Appeal Log

Appendix 3
to the Procedure for Considering
Customer Appeals
Form for Receiving Customer Appeals

Appendix 3
to the Procedure for Considering
Customer Appeals
Form for Receiving Customer Appeals
Client’s full name: ____________________________________________________________________
Contact details (phone, address):_________________________________________________
The essence of the appeal:_________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
Date________________________ Client’s signature:______________________________________
The request was received by (employee’s full name): ______________________________________________