Amending Resolution No 03-105 on the Rules for Handling Complaints Received by Financial Market Participants

BOARD OF LIETUVOS BANKAS RESOLUTION AMENDING RESOLUTION NO 03-105 OF THE BOARD OF THE BANK OF LITHUANIA OF 6 JUNE 2013 ON THE APPROVAL OF THE RULES FOR THE HANDLING OF COMPLAINTS RECEIVED BY THE FINANCIAL MARKET PARTICIPANTS 16 December 2025 No 2025/03-169 Vilnius The Board of Lietuvos bankas has resolved: 1. To amend Resolution No 03-105 of the Board of the Bank of Lithuania of 6 June 2013 on the approval of the rules for the handling of complaints received by the financial market participants and set forth to read as follows: “ BOARD OF LIETUVOS BANKAS RESOLUTION ON THE APPROVAL OF THE RULES FOR THE HANDLING OF COMPLAINTS RECEIVED BY THE FINANCIAL MARKET PARTICIPANTS Acting in accordance with Article 42(4)(1) of the Republic of Lithuania Law on the Bank of Lithuania, Article 56(4) of the Republic of Lithuania Law on Banks, Article 40(4) of the Republic of Lithuania Law on the Central Credit Unions, Article 49(3) of the Republic of Lithuania Law on Credit Unions, Article 29(18) of the Republic of Lithuania Law on Markets in Financial Instruments, Article 13(1) of the Republic of Lithuania Law on Collective Investment Undertakings, Article 14(1) of the Republic of Lithuania Law on Collective Investment Undertakings Intended for Informed Investors, Article 39 1 (1) of the Republic of Lithuania Law on the Supplementary Voluntary Accumulation of Pensions, Article 23(1) of the Republic of Lithuania Law on Payment Institutions, Article 29(1) of the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions, Article 36 1 (1) of the Republic of Lithuania Law on Real Estate Related Credit, Article 21 2 (1) of the Republic of Lithuania Law on Consumer Credit, Article 22(6) of the Republic of Lithuania Law on Insurance, Article 6(4) of the Republic of Lithuania Law on Currency Exchange Operators, Article 32(1) of the Republic of Lithuania Law on Credit Servicers and Credit Purchasers, Article 9(2) of the Republic of Lithuania Law on Markets in Crypto-Assets, the Board of Lietuvos bankas has resolved: To approve the Rules for the Handling of Complaints Received by the Financial Market Participants (attached).” 2. To establish that: 2.1. in accordance with the Rules for the Handling of Complaints Received by the Financial Market Participants approved by this Resolution, data shall be provided for the second half of 2026 and subsequent reporting periods; 2.2. the information on complaints received for reporting periods ending before 31 December 2025, specified in paragraph 23 of the Rules for the Handling of Complaints Received by the Financial Market Participants, which were in force until 31 December 2025, shall be provided in accordance with the legislation in force until 31 December 2025; 2.3. this Resolution shall enter into force on 1 January 2026. Chair of the Board APPROVED by Resolution No 03-105 of the Board of the Bank of Lithuania of 6 June 2013 (Amended by Resolution No 2025/03-169 of the Board of Lietuvos bankas of 16 December 2025) RULES FOR THE HANDLING OF COMPLAINTS RECEIVED BY THE FINANCIAL MARKET PARTICIPANTS CHAPTER I GENERAL PROVISIONS

1. The Rules for the Handling of Complaints Received by the Financial Market Participants (hereinafter, the Rules) lay down the requirements that must be complied with by the financial market participants in accepting, registering and handling the complaints related to services provided by them and/or contracts concluded with customers and in making decisions on these complaints.
2. The Rules have been drawn up taking into account the Guidelines on Complaints-Handling for the Securities (European Securities and Markets Authority – ESMA) and Banking (European Banking Authority – EBA) Sectors (JC 2018 35), as amended and supplemented, as well as the European Insurance and Occupational Pensions Authority (EIOPA) Guidelines on Complaints-Handling by Insurance Undertakings (EIOPA-BoS-12/069).
3. The terms used in the Rules: 3.1. Financial market participants : 3.1.1. banks or foreign bank branches established in the Republic of Lithuania; 3.1.2. insurance undertakings, branches of foreign insurance undertakings established in the Republic of Lithuania, insurance brokerage undertakings and branches of foreign insurance intermediaries established in the Republic of Lithuania; 3.1.3. financial brokerage firms and branches of foreign financial brokerage firms established in the Republic of Lithuania; 3.1.4. management companies, investment companies, pension associations and branches of foreign management companies established in the Republic of Lithuania; 3.1.5. financial advisory companies; 3.1.6. credit unions; 3.1.7. central credit unions; 3.1.8. payment institutions; 3.1.9. electronic money institutions and branches of foreign electronic money institutions established in the Republic of Lithuania; 3.1.10. consumer credit providers; 3.1.11. peer-to-peer lending platform operators; 3.1.12. creditors and credit intermediaries; 3.1.13. currency exchange operators; 3.1.14. credit servicers; 3.1.15. issuers of asset-referenced tokens; 3.1.16. crypto-asset service providers; 3.1.17. crowdfunding service providers; 3.2. Managers of a financial market participant – the person or persons who direct the activities of the financial market participant: 3.2.1. the head of the administration; 3.2.2. members of the board; or 3.2.3. members of the supervisory board; 3.3. Customer – a natural or legal person, to whom the financial market participant provides financial and/or insurance services, as well as credit administration services; 3.4. Applicant – a person lodging a complaint concerning the services provided by the financial market participant and/or the contracts concluded with the financial market participant, i. e. the existing or potential policyholder, the insured person, the beneficiary, the injured third party, the existing or potential customer of other financial market participant, or their representative; 3.5. Complaint –

the applicant’s appeal submitted in writing to the financial market participant stating that the person’s rights or lawful interests arising from or related to the services provided by the financial market participant or the contracts concluded with the financial market participant have been infringed. An application shall also be considered written if submitted by email or other means of distance communication that allow the applicant to be properly identified and the fact of submission of information to be proven; 3.6. Complaint handling policy – a document, which, regardless of its title (policy, instructions, rules, etc.), contains the information on the complaint management process of the financial market participant; 3.7. Register of complaints – register or equivalent computerised document registration system that records the applicants’ complaints received directly from the applicants or via post offices, in any unit or division of the financial market participant, as well as by email or other means of distance communication; 3.8. Complaint management process –

actions of employees of the financial market participant related to the receipt, registration, handling of the complaint, informing the applicant, etc. The complaint management process must be separated from other processes: from processes of management (handling) of actions and from processes of management (handling) of enquiries; 3.9. Persons responsible for control functions – persons responsible for risk management, compliance with legal requirements and the requirements of internal documents of the financial market participant, or the organisation of internal audit; 3.10. Foreign country – all Member States and non-Member States of the European Union or member and non-member countries of the European Economic Area, except for the Republic of Lithuania. 4. Other terms used in the Rules shall be understood as they are defined in the Republic of Lithuania Law on Banks, the Republic of Lithuania Law on Consumer Credit, the Republic of Lithuania Law on Insurance, the Republic of Lithuania Law on Markets in Financial Instruments, the Republic of Lithuania Law on Collective Investment Undertakings, the Republic of Lithuania Law on Collective Investment Undertakings Intended for Informed Investors, the Republic of Lithuania Law on the Accumulation of Pensions, the Republic of Lithuania Law on the Supplementary Voluntary Accumulation of Pensions, the Republic of Lithuania Law on Financial Institutions, the Republic of Lithuania Law on Credit Unions, the Republic of Lithuania Law on Payment Institutions, the Republic of Lithuania Law on Electronic Money and Electronic Money Institutions, the Republic of Lithuania Law on the Central Credit Unions, the Republic of Lithuania Law on Real Estate Related Credit, the Republic of Lithuania Law on Insurance, the Republic of Lithuania Law on Currency Exchange Operators, the Republic of Lithuania Law on Credit Servicers and Credit Purchasers, the Republic of Lithuania Law on Markets in Crypto-Assets and other legal acts. 5. The provisions of the Rules do not apply where: 5.1. the activities of the financial market participant indicated in the applicant’s complaints are not regulated by special laws and are not supervised by Lietuvos bankas; or 5.2. the financial market participant is not responsible for the pursuit of the activities indicated in the applicant’s complaint. 6. In the case indicated in subparagraph 5.2 of the Rules, the financial market participant receiving the complaint must respond to the applicant, specifying the reasons for the refusal to accept and handle the complaint, and, if possible, indicating the financial market participant responsible for the handling of the complaint to the applicant. 7. Complaints related to the intermediaries of payment institutions, dependent consumer credit intermediaries, dependent credit intermediaries, intermediaries of electronic money institutions, insurance agents and ancillary insurance intermediaries shall be handled respectively by the payment institutions, consumer credit providers, creditors or peer-to-peer lending platform operators, electronic money institutions or branches of foreign electronic money institutions established in the Republic of Lithuania, insurance undertakings or branches of foreign insurance undertakings established in the Republic of Lithuania (except in cases where responsibility for the actions of intermediaries is borne by the intermediaries themselves in accordance with the requirements of applicable legislation) by ensuring that their intermediaries will properly fulfil the requirement specified in paragraph 6 of the Rules. 8. The provisions of the Rules shall apply to the out-of-court consumer dispute settlement procedures for financial services to the extent they do not contradict the provisions of other legal acts regulating the procedure of the out-of-court consumer dispute settlement procedures initiated by a consumer against a seller or service provider. CHAPTER II COMPLAINT HANDLING POLICY 9. The financial market participant must approve, implement and maintain an effective complaint handling policy to ensure that the financial market participant: 9.1. organises the process of management of the applicants’ complaints in a prompt, fair, effective and proper manner; 9.2. avoids the conflicts of interests, takes all necessary measures to identify and eliminate the conflicts of interests, in particular by ensuring that the complaint is not referred to an employee or subdivision whose actions or omissions are the subject of the complaint. Where the actions or omissions of an employee or subdivision responsible for handling complaints are the subject of the complaint, the institution shall ensure that the complaint is handled impartially; 9.3. allocates sufficient human resources to ensure the proper handling of complaints; 9.4. ensures that the applicants’ complaints are handled by the employees who have adequate skills, knowledge and experience to perform this function, grants them access to all information necessary for the handling of complaints; 9.5. ensures regular training for employees who handle complaints; 9.6. registers and stores the received complaints and information on the measures taken to resolve the complaint in a proper and organised manner; 9.7. monitors that the complaint management process is effective and, if necessary, updated; 9.8. develops, maintains and uses the internal information system ensuring the effective complaint management process. 10. The complaint handling policy shall be approved by any of the managers of the financial market participant specified in subparagraph 3.2 of the Rules. The complaint handling policy may be incorporated in the general customer service policy of the financial market participant. 11. The managers of the financial market participant shall be responsible for the implementation and regular review of the complaint handling policy and for the assessment of its effectiveness, take the appropriate measures to rectify the identified weaknesses. The implementation of requirements of the complaint handling policy and the provision of information, as provided for in subparagraph 23.5 of the Rules, may be assigned to the employee or subdivision of the financial market participant. 12. The complaint handling policy shall be introduced to all employees of the financial market participant to whom it may be relevant. 13. The financial market participant must ensure the effective control of the complaint management process. CHAPTER III INFORMATION PROVIDED TO THE PUBLIC AND APPLICANTS 14. The financial market participant must publish the information on the complaint management process in a visible and easily accessible place on its website and, where possible, in other means used for providing remote services (e.g. a mobile app). If the financial market participant has no website or does not provide services by means of distance communication, the information shall be provided in other ways easily accessible to the public (brochures, leaflets, contracts with customers, etc.). 15. The financial market participant must, on the applicant’s request, provide the latter in writing on paper or using another durable medium, if agreed between the applicant and the financial market participant, with information indicated in paragraph 14 of the Rules and other information necessary for the applicant that is related to the complaint management process. 16. The information indicated in paragraph 14 of the Rules that is published and provided to applicants by the financial market participant must be clear, accurate, up-to-date and comprise: 16.1. information to be specified by the applicant in the complaint; 16.2. contact details of the person or subdivision to which the complaint should be submitted, or a link to the complaint submission channel; 16.3. the time limit during which the financial market participant shall examine the complaint; 16.4. information on the possibility for the applicant to address the complaint to a competent authority handling complaints. CHAPTER IV REGISTRATION AND HANDLING OF COMPLAINTS 17. The complaint handling policy shall be followed by all employees of the financial market participant involved in the complaint management process. 18. In managing complaints, employees of the financial market participant must abide by the principles of respect for human rights, justice, fairness, rationality, objectivity, impartiality, and expeditiousness. 19. The financial market participant must ensure the registration of received complaints in the register. Complaints shall be registered in accordance with the procedure laid down by the financial market participant. 20. The register of complaints shall contain the following data supporting the complaint: 20.1. the applicant’s forename and surname or name; 20.2. the applicant’s contact details; 20.3. the date and method of receipt of the complaint; 20.4. merits of the complaint (brief content); 20.5. products or services of the financial market participant subject to the complaint, their types; 20.6. the date of submission of the response to the applicant; 20.7. the final result of handling the complaint; 20.8. the forename, surname, and position of the employee of the financial market participant who handled the complaint and provided the response to the applicant. 21. The financial market participant must ensure that: 21.1. the applicant can submit the complaint directly or via post offices, in any unit or division of the financial market participant, as well as by email or other means of distance communication; 21.2. the applicant is confirmed receipt of the complaint as soon as possible. If the applicant has not provided their email address to the financial market participant, confirmation of receipt of the complaint will not be sent to the applicant (unless it is indicated that such confirmation is requested and other contact details are provided); 21.3. all documents and data related to the complaint being handled that are necessary for a thorough and objective examination of the complaint are collected and assessed; 21.4. the communication with the applicant is clear and understandable; 21.5. the applicant’s complaint is examined and a detailed, reasoned and documented response is submitted as soon as possible, but no later than within 15 working days of the day of receipt of the complaint. In exceptional cases, where the response cannot be given within 15 working days for reasons beyond the control of the financial market participant, it must send a holding response, clearly stating the reasons for the delay in responding to the complaint and the deadline by which the applicant will receive the final response. In any event, the deadline for submitting the final response shall not exceed 35 working days from the date of receipt of the complaint; 21.6. where the complaint is not satisfied or satisfied in part, the response provided to the applicant shall state the reasons for the refusal to satisfy the complaint (justification based on established facts and legal norms and/or contractual provisions), other measures of protection of the applicant’s interests, including, but not limited to, possible dispute settlement measures and courts; 21.7. the applicant is always provided with a written response on paper or using another durable medium, if agreed between the applicant and the financial market participant; 21.8. the applicants’ complaints are examined free of charge; 21.9. the applicants’ complaints are examined in Lithuanian or another language, if agreed between the financial market participant and the applicant. 22. The financial market participant must retain the applicants’ complaints, the material related to their handling, and the response provided to the applicant for at least 3 years of the day of providing the final response to the applicant. CHAPTER V ASSESSMENT OF COMPLAINT HANDLING RESULTS 23. With a view to identifying its weaknesses and potential legal or operational risk, the financial market participant must periodically assess the results of handling the complaints. During the assessment, the financial market participant must: 23.1. collect information on similar complaints related to a certain service or product, carry out the analysis of this information in order to identify the underlying cause of complaints and the priorities of elimination of causes; 23.2. assess, whether the underlying cause of certain complaints can lead to the occurrence of complaints concerning other services or products; 23.3. assess, whether the underlying causes of complaints can be eliminated and identify the ways to eliminate them; 23.4. if necessary, eliminate the identified underlying causes of complaints; 23.5. ensure that information on recurring or systemic causes of complaints is regularly, at least once a year, provided to managers of the financial market participant so that they can effectively perform their functions. 24. The financial market participant must retain for at least 3 years the information on the managers’ decisions on the elimination of the operational weaknesses identified on the basis of the complaints and on the management of risk. CHAPTER VI FINAL PROVISIONS 25. The financial market participants indicated in subparagraphs 3.1.1–3.1.4, 3.1.8–3.1.9 and 3.1.16–3.1.17 of the Rules (with the exception of the insurance brokerage undertakings and branches of foreign independent insurance intermediaries established in the Republic of Lithuania) must, by 1 March of the following year after the end of the calendar year, communicate by electronic means the information on received complaints and on the assessment of results of handling complaints to Lietuvos bankas, in accordance with the requirements set out in the Description of the Procedure for Reporting Complaints Received by the Financial Market Participants (Annex). 26. Financial market participants who, before the deadline for submitting reports set out in the Rules, identify (learn) that the data in the reports submitted to Lietuvos bankas are inaccurate, incomplete, incorrect, etc. (hereinafter, inaccuracies) shall revise the data in these reports and resubmit them to Lietuvos bankas before the deadline for submission of these reports specified in the Rules. 27. Financial market participants who, after the deadline for submitting reports set out in the Rules, identify (learn) that the reports submitted to Lietuvos bankas contain inaccuracies, shall, within 5 working days of the date of such identification (learning), notify Lietuvos bankas thereof in writing and submit reports with revised data to Lietuvos bankas in accordance with the procedure set out in the Rules. Financial market participants shall indicate the following information in the notification referred to herein: 27.1. the reasons for inaccuracies; 27.2. the lines of the reports in which inaccuracies were identified; 27.3. the reporting period(s) for which the report data are to be revised. 28. The notification referred to in paragraph 27 of the Rules shall be submitted to Lietuvos bankas in the manner specified in subparagraph 19.1 of the Rules for the Examination of Requests and Complaints of Individuals and the Provision of Services to Them at the Bank of Lithuania approved by Resolution No 03-76 of the Board of the Bank of Lithuania of 8 May 2014 on the approval of the rules for the examination of requests and complaints of individuals and the provision of services to them at the Bank of Lithuania. 29. Financial market participants must collect and, on request of Lietuvos bankas, submit the information on the number of received complaints broken down by causes of submission of complaints and results of their handling (complaint claims satisfied, partially satisfied, or not satisfied). 30. The manager of the financial market participant shall be responsible for the correctness of the information submitted to Lietuvos bankas.

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Annex to the Rules for the Handling of Complaints Received by the Financial Market Participants DESCRIPTION OF THE PROCEDURE FOR REPORTING COMPLAINTS RECEIVED BY THE FINANCIAL MARKET PARTICIPANTS Reports on complaints received by the financial market participants are submitted in JSON format via the REGATA information system of Lietuvos bankas (hereinafter, the Information System). The Information System manual and technical information on reporting are published on the website of Lietuvos bankas. Form SKND_01. This form specifies the number of complaints received during the reporting period, broken down by the services provided by the financial market participant and the type of complaint. Column title Instructions for completion Received (R) / satisfied or partially satisfied (S) complaints The status of the complaint is assigned by selecting one of the following options: Received. This selection is mandatory. Satisfied or partially satisfied complaints. This selection is mandatory when the complaint is satisfied or partially satisfied. Type of service or financial instrument Complaints are grouped by type of service or financial instrument provided by the financial market participant, by selecting one of the following options: Life insurance With-profit insurance Index-linked and unit-linked insurance Other life insurance Non-life insurance Medical expenses insurance Income protection insurance Motor third party liability insurance Insurance of land vehicles other than railway rolling stock Property insurance against fire and other damage General liability insurance Other non-life insurance Financial instruments and crypto-assets Financial instruments Crypto-assets Credit services provided by the bank Real estate related credits Consumer credits Pension funds Pillar II Pillar III Crowdfunding services Loan brokerage Distribution of transferable securities and instruments used for crowdfunding purposes Payment services Payment accounts Non-cash operations Cash operations Payment cards Other payment instruments Other payment services Other services Acceptance of deposits and other repayable funds Issuance and redemption of electronic money Other services Type of complaint Complaints are grouped by nature: Insurance products Sales process Pre-contractual and contractual information Deductions, insurance premium, excess, interest Performance of the insurance contract Administration of claims Refusal to pay insurance benefit, recognition of an event as non-insured Time limits of payment of benefit, delay in payment Termination of a contract Other causes Services of financial instruments and crypto-assets Acceptance, transfer and execution of customer orders Disclosure of information Financial instrument or crypto-asset portfolio management Provision of investment recommendations Administration of transactions – payments, custody of assets, etc. Compliance with contractual terms and applicable taxes Management of the conflicts of interests Application of measures to prevent money laundering (ML) and terrorist financing (TF) Distribution of financial instruments or crypto-assets Operating a multilateral trading facility Exchange of crypto-assets for funds and/or other crypto-assets Other causes Credit services provided by the bank Disclosure of information Creditworthiness assessment Application of taxes, fees, penalties, and interest Early repayment Delay in contract performance and contractual penalties Termination of a contract Fraud Other causes Pension funds Sales process Terms and conditions of pension fund rules and/or pension accumulation agreement Suspension and/or termination of accumulation Change of pension fund Pension contributions Management and administration of pension funds Advertising of pension funds and disclosure of information Fees and deductions Pension fund payments Other causes Payment and other services Pre-contractual relationship: refusal to provide a service due to ML/TF risk management Pre-contractual relationship: refusal to provide a service for reasons other than ML/TF risk management Contractual relationship: non-provision, improper provision or restrictions on the use of a service due to ML/TF risk management Contractual relationship: non-provision, improper provision or restrictions on the use of a service for reasons other than ML/TF risk management Contractual relationship: fraud Termination of contractual relationship: termination of a contract on the initiative of the FMP Termination of contractual relationship: return of customer funds upon termination of a contract Application of taxes, fees, penalties, and interest. Communication/service/handling of complaints Information about service terms and conditions or changes thereto Operation of ATMs Other causes Crowdfunding services Disclosure of information Application of credit scores to crowdfunding projects Crowdfunding offering prices and/or interest rates Administration of bulletin board Compliance with contractual terms and applicable taxes Management of the conflicts of interests Other causes

Form SKND_02. This form provides an assessment of the results of the handling of complaints received by the financial market participant and a description of the causes for complaints other than those specified in Form SKND_01.

Column title Type Instructions for completion Filling option Assessment of the results of the handling of complaints received Textual Information on the assessment of the results of the handling of complaints received by the financial market participant carried out in accordance with paragraph 23 of the Rules and/or a copy of the material provided to the managers of the financial market participant on the analysis of complaints received during the reporting period carried out on the basis of subparagraph 23.5 of the Rules is provided. This information should include decisions taken (planned) to remedy operational deficiencies identified on the basis of complaints and to manage risks. If no operational deficiencies were identified after the assessment of the results of the handling of complaints, this should also be indicated. Mandatory Document title Textual If information on the assessment of the results of the handling of complaints received has already been provided to Lietuvos bankas by the date of submission of the report, the titles of documents containing this information are indicated. Mandatory Date of document submission Date If information on the assessment of the results of the handling of complaints received has already been provided to Lietuvos bankas by the date of submission of the report, the date of submission of documents containing this information in the system is indicated. Mandatory Description of other complaint causes Textual The number of complaints received and satisfied is indicated and the causes for these complaints are described. Mandatory if the proportion of complaints attributed to other causes is 10% higher than the total number of complaints Total number of complaints received (units) Numerical The number of all complaints received during the reporting period is indicated. Mandatory

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