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1 INTRODUCTION

AFI Microfinance SA (hereinafter AFI) implements and maintains effective and transparent
procedures for the reasonable and prompt handling of complaints received from clients. The
company fully abides by the Bank of Greece Executive Committee Act No. 157/1/2.4.2019 and
complementary 187/8.4.2021.

2 PURPOSE OF THE MANUAL

The purpose of the Complaints Policy and Process manual is to ensure that all complaints are dealt
promptly and consistently and are handled with courtesy and fairness. Following a complaint, AFI
aims to rectify the issue and improve its services. Handled well, complaints give to customers redress
when things go wrong and help AFI to continuously improve its services.

3 DEFINITION OF COMPLAINT

Any expression (oral or written) of dissatisfaction addressed to AFI that relates to the quality of its
services to a prospect or a client is considered a complaint. A complaint can be received directly from
the person indicating dissatisfaction or indirectly, through a third party. A complaint can be received
from either an individual or a legal entity.
In case no appropriate solution was found to his/her demand or request, a complainant can ask for
mediation.

A complaint may relate, but not limited, to:

a failure to provide a service or inadequate quality or standard of services provided;
a request for a service or for information which has not been answered;
misleading information about services provided;
accessibility of buildings or services;
treatment by or attitude of a member of staff;
lack of or insufficient company safety and security measures.

4 ORGANIZATIONAL REQUIREMENTS

Complaints’ Management Policy

AFI establishes a detailed Complaints Management Policy defined and adopted by the Board of
Directors, which has the responsibility for its implementation and the general monitoring of
compliance with it.
AFI discloses the above policy to all staff and makes it readily available to it through the appropriate
intranet/inter-company communication channels.

Complaints Management Procedure

(a) AFI establishes a complaints management procedure in order to implement the complaints
management policy, ensuring that complaints are managed in a non-discriminatory manner, as well
as to resolve them by minimizing potential conflicts of interest.

(b) AFI designates the company’s Internal Auditor as its CMPO

Principles for handling complaints

(a) AFI arranges for the collection and investigation of all evidence and information related to any
complaint registered to provide a reasonably substantiated answer.

(b) All communication with the complainant is conducted in simple and understandable language.
Maximum effort will be placed to communicate with the applicant in his/her mother tongue, in case
this is not Greek, given the restrictions /limitations of any translation.

(c) AFI analyzes the data on a semi-annually basis related to the handling of complaints, so that any
recurring problems or weaknesses are identified and addressed of: internal systems, potential legal
and/or operational risks, in order for appropriate remedies to be taken. During the analysis:

(i) AFI examines each complaint separately and groups it by type of complaint to identify any
common root-causes

(ii) AFI investigates whether the above-mentioned root-cause affects other processes or products –
services, including those to which no one has ever directly complained.
Should any pattern or culprit occurs, the issue is addressed and discussed in the following Board of
Directors meeting and procedures/policies are updated accordingly.

5 PROCEDURES

5.1 COMPLAINTS SUBMISSION

There are different ways of filling a complaint to AFI:

By mail [to: Action Finance Initiative (AFI), Louizis Riankour 64, Apollon Tower 10B3, 11523,
Athens, Greece, Attention: CMPO] regardless of the location of the complainant;
By email (complaints@afi.org.gr);
On AFI’s website, on the footer of the front page, by pressing the «Submit your complaint» link;
By filling a physical form at the Headquarters’ office [Action Finance Initiative (AFI), Louizis Riankour 64, Apollon Tower 10B3, 11523, Athens, Greece,] and submitting it to the Complaints Box, to which only the CMPO has access.

The claimant is strongly advised to read carefully the Complaints Policy before drafting the
complaint, which is available on AFI’s website.

5.2 RECEIVING COMPLAINTS

Each working day the CMPO checks if there are new complaints submitted, and registers the
claim in the CRM system. Any complaint received by AFI is assigned a protocol number.
Each complaint should include the following data:

Name/Surname of the individual
Name the legal entity (if applicable)
The Greek ID number or Tax Number of the individual or the legal entity
Email of the individual
Phone number of the individual
Category of the complaint (drop-down menu with specified options to choose from (in case
of Other, a short label of the category should be filled-in by the complainant)
Free text to describe the complaint with the option to upload documents

By the end of the next working day of receiving the complaint, a confirmation message is sent to the
complainant acknowledging the receipt of the complaint and containing a copy of the complaint
details. A deadline of 10 working days after the acknowledgement of the complaint receipt is
communicated to the complainant to have the complaint investigated and the response
communicated.

5.3 HANDLING PROCESS

– The CMPO communicates and assigns the complaint to the relevant department within the
CRM system and starts to collect and investigate all evidence and information related to any
complaint registered to provide a reasonably substantiated answer. This information can be
derived from the Customer Relationship Management system the company uses, interviews
with the staff involved throughout the interaction with the complainant, physical information
submitted by the complainant to AFI or possible communication via other means [text
messages (SMS/MMS), social media, voicemail messages, etc].
– Should the CMPO need further clarifications, he/she may need to reach out to the
complainant for more details.
– A written reply will be communicated to the complainant with a proposed solution, ten (10)
working days upon the acknowledgment receipt of the complaint.
– If the case requires more time, the CMPO notifies the complainant in a timely manner and
provides reasoning behind the delay and informs the complainant of a new deadline by which
the complaint will be resolved in written.
– Should the complainant contact AFI before the ten (10) working days’ deadline or before any
subsequent, well-substantiated extended date, the CMPO informs the complainant about the
progress of the complaint handling process.
– If the applicant wishes to have his/her case re-examined, the CMPO escalates the case and
assigns the complaint to the General Manager withing the end of the next working day, who
in turn takes over the complaint resolution process, and the CMPO informs the complainant
accordingly. A resolution/proposal is then communicated to the complainant within 5 days of
the assignment to the General Manager.
– If the applicant is still not satisfied with the resolution process, AFI informs the complainant
in written a detailed justification and an explicit reference to the complainant’s ability to
escalate to an alternative/out-of-court dispute resolution mechanism and/or where
appropriate to the regulatory authority.
– Once a solution is agreed upon, the CMPO updates and resolves the case in the CRM system.
In case a complaint has been made in bad faith and is not justified, the CMPO will provide the
complainant in writing with an explanation of why the complaint will not be taken further.
Depending on the nature and the possible claims arising thereof, a briefing or an opinion may be
sought from the Legal Advisor of AFI. This is the case, in particular, in the events of meditation.

5.4 GENERAL INFORMATION TO INTERLOCUTORS FOR THE COMPLAINTS MANAGEMENT PROCEDURE

AFI informs all involved parties about its complaint management procedure, in plausible form, in
electronic form by posting it on its website. This procedure includes

(a) a detailed description of the actions required to make a complaint

(b) a description of the procedure followed by AFI in handling the complaint (such as, for example,
when the receipt of the complaint is confirmed, examination schedule) as well as the reporting of
other bodies that have the power to address (e.g. Issue B '1613 / 10.05.2019 GOVERNMENT
GAZETTE 18875 Consumer Advocate or other alternative / out-of-court dispute resolution
mechanism).

AFI provides written information to the complaint about the complaints’ handling procedure upon
providing the acknowledgment of receipt.

5.5 RECORD KEEPING

AFI maintains effective and transparent procedures for the appropriate handling of complaints
received from clients. AFI keeps in electronic form, a report, with all necessary security
specifications, which includes all complaints received, as well as related documents with each case,
from the time of their submission and for a minimum period of five (5) years from the date that each
complaint was registered.

5.6 REPORTING

AFI notifies Bank of Greece within two (2) months from the start of the Complaints Management
Policy and Procedure implementation and subsequently within thirty (30) calendar days from the
end of each year.
2. Where data and information provided have been subject to change during a calendar year, Bank
of Greece is notified, no later than a month.