In order a banking organization to lead to substantial and long-term growth, it must operate with a view to stability, fidelity, solvency, resource utilization, and a clear and practical strategic position. In order the above condition to be realized and for the prosperity to come, it is necessary to constantly adapt to the current regulatory framework. Adaptation under conditions that in turn leads to enhancing the good reputation of the organization, which builds loyalty and ultimately adds value and strengthens the bank brand name.
The Cooperative Bank of Karditsa has set the goal of proper, lawful and effective management of customer inquiries / requests and even more has understood that complaint management is an important element for assessing the quality of the Bank’s services. For this reason, the need to make every effort to serve the requirements and needs of its customers becomes imperative. If this is not achieved, it is obliged to formulate a procedure for dealing with these cases quickly and efficiently with a view to fair and equitable treatment of customers, which must be followed with due diligence.
This foundation issues this Internal Complaint - Policy on “Complaints Management”, which aims to specialize the broader guidelines for the development of the policy and procedures for dealing with complaints from customers - traders.
The Bank’s Management has the overall responsibility for the compliance of all staff with the rules and times for dealing with such complaints, it is responsible for defining and ensuring the observance of the relevant policy. The Bank must communicate this recorded policy to all relevant staff and make it available to it at all times through the appropriate internal route.
The European Union has from time to time published guidelines setting out the following:
Implementation of a CI complaint management policy defined and supported by the business’s senior management, contained in a document and accessible to all staff
Establish a complaint management function for the fair examination, detection and mitigation of potential conflicts of interest
Timely and effective filing of complaints
Providing information to the competent authorities by CI regarding the complaints they receive
Continuous internal following of complaints
Provision of clear, accurate and up-to-date information by CI in relation to the specific requests received or for the procedures applied for their examination or by publication of detailed data
Implementation of procedures for effective examination and response to complaints received - communication in simple and understandable language, if the response is given without undue delay and if in case of a final decision that does not fully satisfy the consumer request a detailed justification of the business’s response and explicit Indication of the possibilities of further appeal of the consumer (Consumer Ombudsman, out-of-court settlement of disputes, to national competent authorities, etc.) is provided
Today, on the occasion of the publication in the Official Gazette 1613/2019 of ECA 157/02.04.2019 on “Adoption of the guidelines of the Joint Committee of European Supervisory Authorities regarding the handling of complaints submitted by traders to supervised institutions”, this policy is updated the from 04-05-2017 customer complaint management policy based on BGGA 2501/2002 “Informing traders with credit institutions about the conditions governing their transactions” (Government Gazette A’ 277). The provisions of ECA 157/2019 are applied by all the Institutions that fall under the definition of par. 1 of Chapter B of the present. However, they do not apply to complaints about services provided by an entity other than the Foundation to which the complaint was lodged, provided that the Foundation is not liable under its legal or regulatory framework for the provision of the relevant service. In this case, the Foundation responds to the complaint by notifying the trader of its non-involvement and, if possible, providing the details of the entity responsible for handling the complaint. Finally, the provisions of the present are applied without prejudice to the provisions of Law 4537/2018 “Incorporation into Greek legislation of Directive 2015/2366/EU on payment services and other provisions”.
The above ECA concerns all traders with financial institutions, whether they are individuals or businesses, and is a key decision for the transparency of transactions and the adequate information of the trader.
The justifying basis for this intervention is:
Removing the information asymmetry that exists between the parties (supplier and consumer) on the terms governing their transactions
Tackling the problem of reduced consumer bargaining power against the supplier
Consumer Protection
Information on the content of the contracts signed
Control of abusive terms of trade and prohibition of unfair commercial practices
Possibility of the consumer appealing to justice
2. BASIC CONCEPTS
Pursuant to ECA 157/2019, a complaint is defined as the oral or written statement of dissatisfaction addressed to an Institution in relation, as the case may be, to the activities of article 11 and article 153 of law 4261/2014, law 1665/1986, law 1905/1990, of par. 1.a of article 1 of law 4354/2015 and of cases a’ to c’ of par. 5 and par. 20 of article 3 of law 4438/2016, while the Complainant is the individual or legal entity that submits a complaint to an Institution.
3. OBJECTIVES
Through this policy, the Cooperative Bank of Karditsa S.A. sets as a goal:
The provision of high quality service to its traders / customers, with reception, examination and settlement service of complaints, documents or oral, regarding actions or possible omissions of the Bank’s services during the provision of banking services or products to individuals and businesses (individual or legal entity).
The immediate resolution of problems by minimizing potential conflicts of interest and the management of disputes that arise, in a fair and impartial manner.
The management of customer inquiries / requests and, even more, the management of complaints is an important element for the evaluation of the quality level of the Bank’s services, for this reason it becomes imperative to make every effort to serve the requirements and needs of customers. If this is not achieved, there is an obligation to set up a process to deal with these cases quickly and efficiently with a view to fair and equitable treatment of customers which must be followed with due diligence.
4. GENERAL INFORMATION OF TRADERS FOR THE COMPLAINT HANDLING PROCEDURE - COMPLAINT OR DISPUTE PROCESS PROCEDURE
The procedure is communicated to the trader in a clear and comprehensible way with forms (distribution of brochures in the trading area, in a visible box and with clear - legible information)
Via the internet on the BoG website (bank complaint services), where the contact details of each institution and the responsible official for their processing are mentioned
Via the website of the credit institution and sending to the mail of the Bank or by fax
The above information shall contain clear, accurate and up-to-date information on the complaint redressal procedure, including at least:
Detailed description of the actions required for the submission of the complaint by the trader (such as, indicatively, the type of information that he/she must provide, the contact details of the competent person or service of the institution that should address the complaint, etc.).
Description of the procedure followed by the Cooperative Bank of Karditsa when handling the complaint (such as, indicatively, when the receipt of the complaint is confirmed, examination schedule) as well as the report of other bodies that have the authority to address (e.g. the Consumer Ombudsman or other alternative / out-of-court dispute resolution mechanism).
The Cooperative Bank of Karditsa provides written information on the applicable procedure for handling complaints either when providing the acknowledgment of receipt or at the request of the trader, referring at least to the general information of the previous paragraphs of the present.
5. PROCEDURE FOR EXAMINATION AND TREATMENT OF COMPLAINTS FROM CI
The Bank is obliged to deal with the examination of customer complaints for all the products and services it offers and to deal with them immediately and effectively.
The examination of these is conducted through a special service (Complaints Service) that has been established by the Cooperative Bank of Karditsa for this purpose with seriousness and consistency in order to implement the policy of complaint management, ensuring the investigation of complaints in an impartial manner, as well as their resolution by minimizing potential conflicts of interest.
The procedure is activated upon receipt of a written request from the Bank
By direct letter to the Bank, either at the address “Taliadourou and Kolokotroni 1, Karditsa, P.C. 43100” (or at any branch of the Prefecture)
Fax letter to the Bank at +302441080883, marked as “Complaint”
E-mail to This email address is being protected from spambots. You need JavaScript enabled to view it., with the subject “Complaint”, adding the customer’s VAT number
On the Bank’s website www.bankofkarditsa.com, by filling in the relevant electronic complaint form
Through the Consumer Ombudsman or other competent bodies in case the trader has addressed to them.
Necessary information for submitting a complaint:
Identification of the complainant (name, father’s name, VAT number, address and contact phone number)
incident description - cause of complaint
any persons involved.
The Bank then sends immediate information on the receipt of the request (confirmation or reply message in case of electronic sending) and the deadline set for the settlement or communication regarding the arrangement / settlement.
The result of the examination and the relevant answer of the Bank are notified to the traders within 45 days from the receipt of the complaints.
Throughout the final settlement or response of the bank, the customer has the opportunity to learn about all the information and documents used in the documentation of the response by the Bank.
For any information regarding the progress of his/her request, the customer can contact the Bank’s customer service staff and its Complaints Service through the RCU. The Bank processes the personal data of the complainants in order to resolve / settle their case and in accordance with the General Data Protection Regulation (2016/679), the terms of which are posted on the Bank’s website.
6. RESPONSE IN CASE OF COMPLAINT
Upon receipt of each complaint, the Bank provides the complainant with a receipt.
The Bank provides information on the progress of the examination of his case, upon the complainant’s request.
The Bank also provides the complainant with a written response within a maximum of forty-five (45) calendar days from the submission of the complaint. When, for a significant reason, it is not possible to provide an answer within the above defined time period, the Bank must inform on its own initiative the complainant about the reason for the delay and the indicate the time period within which the examination is expected to be completed and provide a written response. During this period, the Bank provides information on the progress of the examination of the case, upon the complainant’s request.
In case the final response given in accordance with the previous sub-paragraph 3 does not fully satisfy the complainant, the Bank includes a detailed justification and explicit reference to the possibility of the complainant to address an alternative / out-of-court dispute resolution mechanism and/or, as the case may be, the competent Authority, if he/she insists on his/her complaint.
Internally, in case of inability to deal with / manage the complaint, the RCU undertakes the further examination of the complaint, the reasons for which it was not satisfied and undertakes the communication with the body or the Consumers’ Union, in case the customer addresses his complaint there.
Maintains - with the assistance of the first line of reference - an excel record of all the details of the complaints:
Date of receipt
Discrimination in written or oral complaint
Complaint category
Way of settlement
Interim response date (if further inquiry is required for a final response)
Date of final response
Indication if the complaint has escalated to another body or Consumer Association
Description of how to resolve a complaint
Indication if it is a systemic problem and actions to address it
Indication if there is a financial loss for CI (e.g. incorrect registration, compensation to the customer, etc.).
7. PRINCIPLES FOR HANDLING COMPLAINTS
The Bank undertakes to collect and investigate all evidence and information related to each submitted complaint in order to provide a reasonably substantiated response. That is why every communication with the complainant is conducted in simple and understandable language.
The Bank analyzes, on an ongoing basis, the data related to the handling of complaints, in order to ensure that any recurring problems or weaknesses of its internal systems are identified and addressed, as well as possible legal and operational risks, in order to take appropriate corrective measures. During the analysis is performed, indicatively:
examination of each complaint separately and grouping by type of complaint to identify any common root cause
to investigate whether the aforementioned operational causes may affect other processes or products - services, including those to which no complaint has been made directly.
8. RECORD KEEPING
The Bank keeps, either in electronic or on paper form, a file with the necessary security specifications, which includes all the complaints it receives, as well as the documents related to each case, from the time of their submission and for a minimum period of five (5) years from the date on which each item came into its possession, unless otherwise specified by other provisions.
9. SUBMISSION OF DATA AND REPORTS TO THE BANK OF GREECE
The Cooperative Bank of Karditsa notifies the Bank of Greece within thirty (30) calendar days from the end of each year, the information of the Annex of ECA 157/2019.
In case the data and information that have been submitted change during the year, the respective change is notified to the Bank of Greece within one month at the latest.
10. COMPLIANCE
The implementation of the policy of complaint management as well as its electronic processing allows the Bank to be consistent in its obligations towards the Supervisory Authorities but also to its traders as well as to have a complete picture through which bigger problems can be identified but also opportunities for improvement can emerge.
More specifically, the Bank, through the procedure it applies, achieves the following:
Helps to draw conclusions about problem areas and to reduce the impact they have on the quality of service and customer service.
Supports on an ongoing basis the overall image of the Bank with reference to its dynamic position in the market and its comparative advantages.
Restores the image of the Bank from actions or omissions of its instruments.
It strengthens the prestige and promotes the social face of the Bank through the positive handling of every problem.
Evaluates statistical data related to complaints and communicates to the Administration and the Central Directorates.
The Bank, through its Competent Audit Units, verifies the faithful implementation of the policy and procedures it has established regarding its compliance with the above mentioned Executive Committee Act.
