Chapter Two: Instructions Regulating the Mechanism for Dealing with Complaints in Banks

1. Introduction

These Instructions complement the Instructions for Protecting Customer Rights issued on February 19, 2019, and aim to establish regulatory rules for dealing with complaints in banks, and provide a mechanism characterized by effectiveness, fairness, transparency, and independence during customers' banking transactions. This aims to enhance the level of service provision, thereby strengthening customer trust in the banking system and supporting competition, which leads to an increase in financial inclusion rates. This comes in light of the authorities of the Central Bank stipulated in Articles numbers 7, 83, 216, and 217 of Law No. 194 of 2020 issuing the Central Bank and Banking System Law. These Instructions include the minimum requirements that must be met to ensure the efficiency of the complaint regulation mechanism in banks.

2. Definitions

Complaint: Any verbal or written expression or by any possible means - including sign language for persons with disabilities - (excluding inquiries or requests for information) indicating dissatisfaction of the complainant with the banks, outsourcing service providers, payment service providers, or the bank's contracted agents, due to their causing them actual or potential financial loss or moral damage. This includes, by way of example:

• Quality of service or product.
• Refusal to provide the service or product.
• Negligence, error, or any unsatisfactory behavior when dealing with complainants.
• Disclosure problems regarding actual yield rates, fees, or penalties imposed on providing or canceling any service or product.
• Terms and conditions for providing the service or product.
• The time required to receive any services or products or cancel them.
• The mechanism for dealing with the complaint.
• Product or service informational or marketing materials.
• Any procedures or decisions that the complainant believes contradict relevant laws or instructions and controls issued by the Central Bank.

Complainant: Includes bank customers, as well as potential and/or prospective customers of the bank or outsourcing service providers, payment service providers, or the bank's contracted agents.

Customer Contact Channels: Are the places or points where transactions are conducted between the customer and the bank, outsourcing service providers, payment service providers, or the bank's contracted agents. This includes, as a minimum, branches, electronic and virtual points, and call centers.

Customer Rights Protection Unit: Is the unit established in banks in accordance with Item 1-3-4 of the Instructions for Protecting Bank Customers' Rights issued by the Central Bank in February 2019, among whose responsibilities is dealing with complaints.

Basic Cost of Contacting the Bank: Is the actual cost borne by the complainant to contact the bank, including, by way of example, telephone call costs and written correspondence. It does not include any additional costs, fees, or other expenses.

Systemic Problems: Are problems related to the bank's systems, including, by way of example, technical problems, internal system problems, or the bank's automated systems.

3. Scope of Application

These Instructions apply to all banks registered with the Central Bank, including branches of foreign banks. The bank bears full responsibility for any damage that may be caused to the complainant as a result of dealing with its employees, outsourcing service providers, payment service providers, or the bank's contracted agents for the purpose of obtaining a service or product, or in case of violating the requirements contained in these Instructions.

4. General Provisions

1-4 Banks are committed to putting in place fair, clear, effective, and independent mechanisms for dealing with complaints.

2-4 Banks are committed to making the complaint reception and handling service free at all stages, with the complainant bearing the basic cost of contacting the bank.

3-4 Banks are committed to providing the Customer Rights Protection Unit and other relevant departments dealing with complaints with appropriate and sufficient resources - commensurate with the nature and size of the bank's business - enabling them to process complaints. These resources include, in particular:
1-3-4 Providing trained and qualified human resources with the necessary experience to receive, examine, study, and process complaints.
2-3-4 Designating the authorities responsible for making the necessary decisions to process complaints - including financial settlements, if any - or referring them to the relevant departments.
3-3-4 Providing effective automated systems and electronic infrastructure to deal with complaints quickly, fairly, and efficiently, including all technical support means, resources, devices, and tools.
4-3-4 The right to access and obtain all files, records, transactions, contracts, and other information, data, and documents related to complaints throughout the examination process.
5-3-4 Providing necessary programs for periodic and continuous training of employees.

4-4 Decisions of the Customer Rights Protection Unit in the bank are binding on outsourcing service providers, payment service providers, and the bank's contracted agents. This must be stipulated in all contracts concluded - including automatically renewed contracts - with these entities upon the issuance of the Instructions.

5-4 The bank's Compliance Department must ensure the adoption and implementation of all policies and procedures that ensure compliance with the provisions of these Instructions.

6-4 The bank must pay special attention to humanitarian cases and the most vulnerable customers, as well as providing specialized staff to enable complainants with disabilities to submit their complaints easily and effectively in accordance with the Instructions on Facilitating Access to Banking Services for Persons with Disabilities issued in September 2021.

5. Rules for Informing Customers about Submitting Complaints

1-5 Banks are committed to informing customers of their rights in accordance with these Instructions, including, in particular:
1-1-5 Publishing and distributing informational brochures about complaint submission procedures and handling mechanisms, in writing or electronically, free of charge; and making them available in prominent and easily accessible places upon request or during complaint submission. These must include, as a minimum, information and data regarding the bank's complaint submission channels, the submission and tracking mechanism, and a simplified explanation of the bank's obligations at the complaint examination stages and the specified timeframe. This must be done through, at a minimum, the following channels:

• The bank's website.
• Contract forms for banking services and products provided by the bank, outsourcing service providers, payment service providers, or the bank's contracted agents.
• Customer contact channels, including branches and bank units, through written or electronic boards and posters.
• Email, SMS via mobile phones, correspondence, and account statements.
• The bank's social media channels (if possible).
• Call centers.

2-5 The bank is committed to providing a unified internal form in Arabic and English for submitting complaints (reference model attached - Annex No. 1). It must be made available through all customer communication channels. The form must include, as a minimum:

• Date of complaint submission.
• Complainant's data, including ID verification number.
• Complainant's contact data.
• The complainant's preferred communication method for tracking the complaint.
• Summary of the complaint.
• The branch/department concerned with the complaint.
• The product/service subject to the complaint.
• The ability of the complainant to attach any documents related to the complaint.
• The mechanism for submitting, tracking, and responding to the complaint according to the timeframe specified by the bank.

3-5 The bank is committed to informing illiterate complainants of their right to submit complaints and assisting them in doing so, and explaining the handling mechanism and the specified timeframes for examination and response, all verbally if necessary.

6. Mechanism for Dealing with Complaints

1-6 The bank must put in place the necessary internal policies and procedures for dealing with complaints fairly, transparently, and without discrimination, while committing to informing the executive management. These policies must be approved by the Board of Directors and applied to ensure:
1-1-6 Allowing complaints to be submitted by any possible means - even if the bank's dedicated complaint form is not used - and the bank is committed to not imposing any restrictions or conditions that hinder the complainant's right to submit a complaint. 2-1-6 The necessity of having multiple channels for receiving complaints, including, as a minimum:

• Bank branches, agents, or their branches.
• Telephone through the bank's call center, with the necessity of designating a code for complaint submission and informing the complainant that the complaint will be recorded.
• All other electronic means available to the bank, such as fax, email, and website.
• Direct communication with the Customer Rights Protection Unit.
• Social media channels (if possible), limited to receiving the complaint only. The bank must track it through any of the other approved channels above.
  3-1-6 Making every effort and taking all necessary procedures to process complaints submitted to the bank before directing complainants to escalate their complaints to the Central Bank.
  4-1-6 Setting timeframes for processing complaints according to the type of product or service provided, without contradicting Item 9 of these Instructions.

2-6 The bank's Customer Rights Protection Unit is committed to analyzing complaints and reporting on them, informing the executive management through the bank's Compliance Department to the Audit Committee and Board of Directors. This includes procedures ensuring the bank's compliance with instructions issued in this regard, or any other relevant laws or guidelines, as follows:
1-2-6 Analyzing individual complaints to determine the causes of their emergence, to ensure they do not affect any other procedures, services, or products, whether complaints have been submitted by other customers or not. 2-2-6 Working to take all possible corrective procedures regarding those causes. 3-6 Determining systemic and recurring problems and taking corrective procedures regarding them by considering the following:

• The number of complaints received by the bank.
• Collecting information about the causes of complaints, the services and products related to them, and putting in place mechanisms to prioritize handling those complaints.
• The total cost of financial settlements for complaints (if any).
• Putting in place a mechanism to determine the impact of those complaints on any other procedures, products, or services.
• Putting in place a mechanism to determine the corrective procedures for the causes of the complaints and how to apply them.
• Submitting periodic reports to the Audit Committee and Board of Directors on systemic and recurring problems, their causes, and the necessary corrective procedures, as stated in these Instructions.

4-6 When discovering systemic or recurring problems, the bank must consider subsequent or potential damages to customers who did not submit complaints regarding them, as well as taking necessary and appropriate corrective and proactive procedures to address them and informing customers thereof.

7. Monitoring and Evaluating the Complaint Handling Mechanism

The bank is committed to putting in place a periodic monitoring system to measure customer satisfaction with the complaint handling mechanism, as well as a system to measure the quality of handling and processing complaints submitted to the bank, according to a periodic monitoring system for quality standards and related work procedures. The monitoring system includes:
1-7 Conducting surveys via (branches, telephone, email...) to random samples of customers.
2-7 Examining random samples of closed complaints to ensure compliance with quality standards.
3-7 Subjecting branches, call centers, banking operations management, and departments concerned with handling complaints to continuous supervision and control, including monitoring methods or mystery shopping.
4-7 Conducting a periodic evaluation of internal procedures for handling and processing complaints at least every two years.

8. Rules for Processing Complaints

The bank must, upon receiving a complaint, do the following:
1-8 Examine the complaint efficiently, seriously, and neutrally, and exercise due care in processing it.
2-8 Obtain any additional information necessary to examine the complaint.
3-8 Follow the principle of good faith in dealing with the complaint and refrain from requesting any documents or information not directly related to the subject of the complaint.
4-8 Evaluate the complaint fairly and quickly, considering the following factors:

• The nature of the complaint.
• The appropriate corrective procedure to process the complaint.
• The existence of reasonable grounds indicating responsibility of another party - sole or joint with the bank - for the complaint under examination.
• All available evidence and circumstances surrounding the complaint.
• Similarities with other complaints previously received by the bank.
• Instructions and rules issued by the Central Bank and any other relevant rules and regulations.
  5-8 Present suitable and appropriate solutions and corrective procedures to the complainant according to the nature of the complaint, to process it if possible.
  6-8 Clarify the basis for evaluating the complaint to the complainant, as well as the bank's decision regarding it, and clarify the corrective procedures taken to process it; transparently, clearly, and fairly.
  7-8 Apply the solutions or corrective procedures for processing the complaint that the bank presented to the complainant and agreed upon, quickly and fairly.
  8-8 The complaint is considered closed by the bank in the following cases:
• The bank sends a final response regarding it.
• The complainant explicitly or implicitly accepts the bank's response.

9. Special Rules for Timeframes for Dealing with Complaints

1-9 The bank must, upon receiving a complaint, do the following:
1-1-9 Immediately acknowledge receipt of the complaint by providing the complainant with its reference number. If this is not possible, the complainant must be provided with the reference number within a maximum of two working days from the date of receipt of the complaint. 2-1-9 Providing the complainant with the complaint reference number - in writing or electronically - according to the communication method specified by the complainant, which may include any of the following means:

• Correspondence, recorded phone calls, and SMS via mobile phones.
• Any other electronic channels; such as fax, email, and website.
• Personal presence in front of bank employees or their agents at any customer contact channels.
  3-1-9 Warning the complainant of the importance of keeping the reference number to track the complaint.
  4-1-9 Informing the complainant of the time required to examine the complaint according to the bank's internal work procedures.
  5-1-9 When the complainant tracks the complaint, the bank must inform them of the status of the complaint until a decision is made, according to its nature (if possible).

2-9 The bank must respond - in writing or electronically - to the complaint within a maximum of 15 working days from the date of receipt, in a manner that allows the complainant to keep the response. The response must include:

• Acceptance of the complaint with presenting suitable solutions or corrective procedures to the complainant to process it, or rejection with stating reasons, or presenting solutions to process the complaint without acceptance in case of no error on the bank's part.
• Attaching a copy of the bank's explanatory brochure on the complaint processing mechanism.
• Informing the complainant of all their rights in case of not accepting the bank's response and the procedures to be followed in this case, as well as the consequences of not following these procedures.

3-9 Regarding complaints involving transactions with third parties (another bank, outsourcing service providers, or the bank's contracted agents), the condition of responding within 15 working days does not apply.

4-9 In case the complainant does not accept the bank's response, they must inform the bank of this - in writing or electronically - within a maximum of 15 working days from the date of receiving the response, stating the reasons for non-acceptance. 5-9 The complainant's failure to object for a period of 15 working days from the date of receiving the bank's response is considered implicit acceptance of the response received from the bank. The bank may accept the complainant's objection after the mentioned period if acceptable justifications are provided.

6-9 In case the complainant informs the bank of non-acceptance of the response, the bank must do the following:
1-6-9 Inform the complainant - in writing or electronically - of receiving this notification and re-examining the complaint with the same reference number and date of the notification.
2-6-9 Re-examine the complaint through a higher administrative level than the one that examined it the first time, with no member of that level having participated in the previous examination.

7-9 The complainant must be warned of the importance of keeping the bank's notification mentioned in Item (1-6-9) to track the complaint and refer to it when needed.

8-9 The bank must send the final response - in writing or electronically - to the complainant within 15 working days from the date of receiving the notification, except for the third parties mentioned in Item (3-9). This must be done in a manner that enables the complainant to keep the response.

9-9 In all cases, the final response must include:

• Expressing sufficient and clear reasons and causes for the response.
• Providing supporting evidence (if possible).
• Referring to the regulations, systems, and legislative texts related to the complaint under examination.

10. Complaints Related to Outsourcing Service Providers, Payment Service Providers, or the Bank's Contracted Agents

1-10 The bank is committed, upon receiving a complaint related to transactions involving outsourcing service providers, payment service providers, or the bank's contracted agents, to immediately acknowledge receipt of the complaint in writing or electronically, and providing the complainant with a reference number for their complaint.

2-10 If this is not possible, the complainant must be provided with the reference number within a maximum of two working days from the date of receipt of the complaint, accompanied by:

• Acknowledgment of receipt of the complaint.
• Informing the complainant that their complaint relates to transactions with outsourcing service providers, payment service providers, or the bank's contracted agents.
• Informing the complainant of the time required to examine their complaint.

3-10 The bank must immediately communicate with the entity concerned with the complaint and bind it to a timeframe for processing it according to what was stated to the complainant, including the contracts concluded with the bank.

4-10 Contracts concluded between the bank and outsourcing service providers, payment service providers, and the bank's contracted agents must include binding clauses regarding specific mechanisms for dealing with complaints, the role of both the bank and the contracted entity in examining and processing referred complaints, as well as the timeframes necessary to respond to the bank regarding referred complaints.

5-10 In all cases, when the complainant tracks their complaint, the bank must inform them of the status of their complaint until a decision is made, according to its nature (if possible).

6-10 The rules stipulated in Items 2-9 to 9-9 apply to transactions with outsourcing service providers, payment service providers, or the bank's contracted agents, except regarding timeframes, including responding to the complainant within the timeframes mentioned in Items 3-10 and 4-10, with continuous monitoring by the bank.

11. Rules for Referring Complaints

1-11 The Customer Rights Protection Unit may refer all or part of a complaint to its counterpart in another bank if the bank has serious grounds that the subject of the complaint falls under the total or joint responsibility of the referred bank. The complaint must be referred within the scope of the part concerning the bank, in accordance with the confidentiality of customer accounts according to Law No. 194 of 2020 issuing the Central Bank and Banking System Law, while committing to the following:
1-1-11 The referral must be done within a maximum of two working days from the date of receipt of the complaint.
2-1-11 Informing the customer - in writing or electronically - before the referral that all or part of their complaint concerns another bank, and the reasons for that.
3-1-11 Informing the customer within a maximum of two working days from the date of referral and informing them of the name of the referred bank, contact means, including the complaint reference number.
4-1-11 Informing the complainant of the time required to study the complaint.

2-11 The referred bank must inform the bank receiving the complaint of the time required to study it; to inform the complainant thereof.

3-11 The bank referred to is committed to dealing with, examining, and considering the complaint with the same care and procedures followed in examining complaints submitted directly to the bank.

4-11 The bank referred to must send its response - in writing or electronically - to the bank receiving the complaint within a maximum of 15 working days from the date of referral. This does not apply to complaints related to third parties.

5-11 In case the bank receiving the complaint refers all or part of the customer's complaint to another bank, the bank receiving the complaint is committed to responding to the customer with the responses of both banks.

6-11 In case the customer does not accept any of the notified responses, they must inform the bank receiving the complaint of their objection, according to the rules and timeframes stipulated in the Instructions in Items (4-9) to (9-9). Both the bank receiving and the bank referred to are committed to re-examining the complaint, in accordance with Items (1-11) to (4-11).

7-11 The bank referred to is committed to sending the final response - in writing or electronically - to the bank receiving the complaint, all in accordance with the procedures, controls, and timeframes stipulated in these Instructions.

8-11 Banks must, through the Banks Union, cooperate to activate the complaint referral rules stipulated in these Instructions by exchanging contact points and working to coordinate referral procedures.

9-11 The bank has the right not to mention in its reports any complaint that was fully referred to another bank. In case of joint responsibility for the complaint, both banks must include the complaint in their reports such that the referral to each bank is only for the part concerning that bank.

12. Rules for Registering Complaints

1-12 The bank is committed to creating a database to store data related to complaints in a classified manner according to what will be mentioned in Item 3-12 below, while maintaining the integrity and confidentiality of information provided by customers. The database must include:
1-1-12 A register of complaints submitted to the bank and the data and documents related to them, as well as all procedures and decisions taken regarding them.
2-1-12 A register of all complaint analysis reports, the causes of their emergence, and decisions taken, including corrective procedures.

2-12 The bank must retain the data mentioned in the bank's complaint database for a minimum of five years from the date of receipt of the complaint.

3-12 Complaints mentioned in the database are classified as follows:
A) Individual Complaints:

• Name of the complainant.
• Type of complainant (Male/Female).
• Age/Date of birth of the complainant.
• National ID/Passport number (for foreigners) of the complainant, and a copy of the ID verification document.
• Residence of the complainant.
• Data regarding communication means with the complainant.
• The complainant's preferred communication method specified for tracking the complaint.
• Whether the complainant is a person with a disability or not.

B) Corporate Complaints:

• Company name.
• Nature of activity.
• Commercial registration number and a copy thereof.
• Company address.
• Name of the company representative/authorized person to submit the complaint.
• National ID/Passport number (for foreigners) of the company representative/authorized person to submit the complaint, and a copy of ID verification documents.
• Data regarding communication means with the company representative/authorized person to submit the complaint.
• The preferred communication method of the company representative/authorized person to submit the complaint specified for tracking the complaint.

C) General Data for Corporate and Individual Complaints:

• Account number (if available).
• The branch the complainant belongs to (if possible).
• The service/product subject to the complaint.
• The department concerned with the complaint.
• Type of complaint (e.g., delay in providing service, refusal to provide service, system error, etc.).
• Date the complaint occurred.
• The means the complainant followed to submit their complaint.
• Date the complaint was received by the bank.
• The branch/department receiving the complaint.
• The complaint reference number.
• The result/corrective procedure sought by the complainant.
• Any documents submitted by the complainant.
• The procedures taken based on the bank's examination of the complaint.
• Responses sent to the complainant.
• The bank's decision regarding the complaint and its date, whether implemented or not.

13. Complaint Reports

1-13 Internal Reports:
1-1-13 The Customer Rights Protection Unit in the bank must submit quarterly reports at a minimum on its activities - informing the executive management - through the Compliance Department to the Audit Committee and Board of Directors for information and taking necessary corrective procedures if required.

2-1-13 The mentioned reports must include, as a minimum, the following information:

• Number of complaints, their nature, and classification according to the nature of the complainant (individual/corporate), type (male/female), age, and geographical location (the branch the customer belongs to).
• Branches or departments where a large number of complaints were submitted.
• Recurrence of the complaint.
• Procedures taken to deal with the complaints.
• Number of complaints processed.
• Average time taken to process complaints.
• Number of complaints processed within a period exceeding 15 working days and the reasons for that, to identify the causes of delay in processing complaints and work to prevent recurrence.
• Number of complaints not processed and the reasons for that.
• The causes and systemic problems that led to the emergence of complaints, and what was taken to process them.
• The total cost of financial settlements for complaints (if any).

3-1-13 The Customer Rights Protection Unit must analyze these reports to determine the causes that led to the emergence of those complaints.

4-1-13 The Unit must take all corrective procedures and study the status of other customers to verify that no violations or similar problems occur, as well as providing recommendations to relevant departments (if required) to modify product design, and/or marketing, and/or customer communication procedures, or any other procedures.

5-1-13 Information resulting from the preparation and analysis of these reports must be used to enhance the efficiency and expertise of bank employees, and strengthen the training plans and programs of the Customer Rights Protection Unit.

6-1-13 The bank is committed to submitting reports on the results of the surveys and evaluations mentioned in Item 7, through the Compliance Department to the Audit Committee and Board of Directors, as well as the necessary recommendations to develop complaint handling mechanisms to ensure their continuity and effectiveness, and to ensure compliance with their quality standards.

2-13 External Reports:
The Customer Rights Protection Unit must provide the Customer Rights and Competition Sector at the Central Bank with quarterly reports on complaints according to the model provided, within 30 days from the end of each quarter.

14. Compliance Period:

Banks are granted a compliance period of six months from the date of issuance of these Instructions.

Annex (1)

Reference Model for Complaints

We apologize for any difficulty in obtaining any of the services provided by the bank or with any of its employees or through the procedures followed. We request that you fill out the following form and submit it to the bank. We will look into your complaint and respond as soon as possible, as outlined in this form. The complaint will be handled with utmost confidentiality and credibility.

Complaint Reference Number:

Name of the Company (if the complainant is a company):
Commercial Registration Number:
Address (if available):

ID Verification (National ID/Passport):

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