Dear Sir / Chairman of the Board of Directors,

Greetings,

In the context of the interest the Central Bank of Egypt attaches to developing the banking sector through the application of best international practices, which have emphasized the importance of caring for protecting the rights of bank customers to consolidate the trust of users in the banking sector and enhance competition among banks, thereby raising the efficiency of the banking sector as a whole. The concept of protecting customer rights includes having clear foundations and rules governing the relationship between banks and their customers at all stages of dealing, which achieves justice and transparency, and ensures the protection of customer data, in addition to determining a clear mechanism for dealing with complaints, as well as spreading banking and financial culture and awareness among customers.

And given that protecting the rights of customers is considered one of the main elements for achieving financial inclusion, which is one of the pillars in enhancing financial stability and achieving the priorities of the Central Bank of Egypt at the present time, due to its effective role in sustainable development, it has become necessary to issue instructions for protecting the rights of bank customers aimed at establishing the internal policies and procedures that must be available at banks, and the basis for dealing with customers while taking into account providing suitable products and services for them that match their requirements and their ability to fulfill the resulting obligations, which leads to encouraging individuals and increasing their inclination to use banking services.

This, and with reference to our letter dated August 2, 2018, by which banks were provided with the draft instructions for protecting the rights of bank customers for consultation purposes, and after studying the comments and proposals received from banks, the decision of the Board of Directors of the Central Bank of Egypt was issued in its meeting held on February 13, 2019 regarding Instructions for protecting the rights of bank customers (a copy is attached), taking into account granting banks a period of adjustment for one year from the date of issuance of the instructions.

Please accept our highest respect, Tarek Amer

Instructions for protecting the rights of bank customers

Table of Contents

Page	Description
	Definitions
	Scope of Application
	General Rules
	Customer Rights Protection Rules
	1-4 Dealing with customers on the principle of justice and fairness
	2-4 Disclosure and Transparency
	3-4 Mechanism for dealing with customer complaints
	4-4 Spreading banking culture and awareness
	Protection of customer data and preservation of confidentiality
	Customer rights protection in relation to the use of electronic banking services

-1 Concept of protecting the rights of bank customers and important definitions:

According to the general concept of protecting the rights of bank customers, there is a clear regulatory framework based on international best practices that defines the relationship between banking service providers and their users, in order to ensure that customers receive their rights in terms of justice, transparency, and maintaining data confidentiality, with ensuring the existence of a mechanism for dealing with complaints. In addition to raising banking awareness among customers, enabling them to make sound decisions.

We list below the definitions of the most important terms mentioned in the instructions:

Customers: Natural and legal persons who deal with the banking sector directly or through payment service providers and their agents or their representatives from support companies.

External Support Companies: Establishments with which the bank contracts and entrusts them to provide any service or product on its behalf.

Service Providers: Entities with which the bank contracts to provide a payment service using mobile phones in accordance with the controls issued by the Central Bank of Egypt in this regard.

Loans and Credit Facilities: Loans and facilities granted to natural and legal persons.

Interest Rate: It is the actual annual interest rate according to the rules of the Central Bank Law.

Financially Excluded Categories:

• Customers outside the scope of banking sector services.
• Customers registered in the banking sector but who do not use the service or product offered to them.

Guarantor: The person (natural/legal) who provides a guarantee (personal/physical) in exchange for a credit facility granted to a customer.

Customer Rights Protection Unit: A separate unit in the bank or with the service provider specialized in dealing with customer complaints, which is subordinate to and reports to the Compliance Department.

-2 Scope of Application

These instructions apply to all banking services and products provided by all banks registered with the Central Bank of Egypt, including branches of foreign banks.

-3 General Rules:

The Board of Directors of the Bank must ensure that the policies, procedures, and systems in force are fully consistent with the instructions for protecting customer rights, and ensure that all bank employees comply with them, and that the policies and procedures of payment service providers or their agents or their representatives from external support companies are consistent with the instructions through contracts concluded with them, to include at least the following:

• Designing products and services and pricing them taking into consideration the following:
  • Determining the target categories of customers and the suitable products and services for each category.
  • Dividing customers into categories and segments, based on income, educational level, geographical distribution, and age groups, and paying due attention to the needs of excluded financial categories, the elderly, and those with special needs, with innovating and designing various products and services to match all customer segments.
• Ensuring that employees specialized in the bank - as well as employees of payment service providers or their agents or their representatives from external support companies - understand the characteristics, terms, and costs of products and services, enabling them to explain them and answer customer inquiries.
• Ensuring that the terms and conditions of products and services are drafted clearly and understandably for all categories and segments of customers.

The Compliance Department of the Bank must ensure the implementation of the systems and work procedures that ensure compliance with what is stated in these instructions and prepare periodic follow-up reports on this matter and submit them to the Audit Committee for presentation to the Board of Directors.

In the event that payment service providers or their agents or their representatives from external support companies provide any product or service on behalf of the bank, whether directly or indirectly, customers must be treated with justice and transparency, and the bank bears full responsibility for the results of providing that service and for any damage that may be caused to the customer as a result thereof.

Strengthening the role of the Customer Rights Protection Unit by the Board of Directors of the Bank, through providing the necessary mechanisms and means to resolve complaints as quickly as possible.

-4 Customer Rights Protection Rules

1-4 Dealing with customers on the principle of justice and fairness

• Emphasizing that the culture of the bank and payment service providers and their agents or their representatives from support companies should deal with customers with high professionalism characterized by justice and transparency.
• The bank and payment service providers and their agents or their representatives from support companies must treat all customers at all stages of banking transactions without discrimination and on the principle of justice, fairness, and honesty.
• Providing the terms and conditions of products and services when marketing them transparently, in accordance with the bank's presentation of the product or service to the customer before or at the time of purchase.
• Measuring the customer's financial ability to fulfill all obligations, including installments, commissions, and any other additional expenses the customer may incur.
• The bank and payment service providers and their agents or their representatives from support companies must assist the customer in choosing the suitable service or product that matches their needs and their ability to fulfill the resulting obligations, without forcing the customer to buy a group of products to obtain a specific product.
• In the event that a product or service cannot be provided to the customer, he has the right to know the reasons for rejection - if possible - and in a manner that does not conflict with relevant laws, and he has the right to retrieve the original documents he submitted when requesting the product or banking service.
• The bank and payment service providers and their agents or their representatives from support companies must clarify the method of canceling the service or product, the time required for that, and the expenses and deductions resulting from that.
• The bank and payment service providers and their agents or their representatives must use fair and non-complex contracts/forms, with readable and clear wording that specifies the rights and obligations of the bank, the service provider, and the customer, to include all terms and conditions of the product or service, using simplified banking terminology, and committing to including the following clauses at a minimum:
  • Data of the bank, or payment service providers and their agents or their representatives (in case of signing directly with the customer), and the customer.
  • Contract duration.
  • The interest rate used with specifying whether it is variable or fixed.
  • All expenses and commissions applied to the product, taking into account determining a suitable mechanism that ensures the customer is informed in advance in case of any amendments to them.
  • Expenses and deductions applied by the bank in case the customer wishes to transfer the account or close it, or stop dealing with the product or service subject to the contract.
  • The procedures that the customer must follow in the event of tampering with his accounts, theft, or loss of banking cards, with specifying the responsibility of each party in these cases.
  • The language and means of communication through which communication with the customer will be conducted.
  • A summary of the procedures taken by the bank in the event of non-compliance with payment in the specified dates or breach of any clause of the concluded contract, and the consequences thereof, as well as all additional costs associated with them, including commissions, interest, and fees.
  • Reference to the possibility of escalating the complaint to the Central Bank of Egypt in case it is not resolved by the bank.
• In all cases, contracts/forms must not include clauses that may cause unfair harm to the customer, such as:
  • Omitting or modifying any of the obligations stipulated in these instructions.
  • Obliging the customer to any conditions not included in the contract clauses.
  • Excluding any condition that was mentioned or promoted to the customer, including advertisements and conversations with customer service.
  • Renewing the contract automatically without obtaining prior consent from the customer or without notifying him in advance and giving him a reasonable time period to cancel the renewal (except for products that require automatic renewal due to their nature).
  • Preventing the customer from canceling the product or service, while retaining the bank's right to obtain any dues owed to the bank according to the contract terms.
  • Limiting the customer's right to set off or settle his accounts, except in cases where the product terms require not disposing of the amounts related to it for a specific period.
• The customer also has the right to view the contract before contracting and obtain a copy of it at any time before contracting.
• In the event of card theft or account tampering and after notifying the bank thereof, the bank must refund any amounts/expenses that were deducted, unless it is proven from the bank's or service provider's systems and records that the transaction was carried out with the customer's consent or through his fraud.
• In the event that the customer is asked to provide guarantees for granted facilities, the size of the required guarantees must be proportional to the size of the granted facilities.
• In the event that there is a guarantor for the customer, the following must be followed:
  • Informing the guarantor of the obligations resulting from providing the guarantee, including the size of the financial obligation.
  • Obtaining a commitment from the guarantor to maintain the confidentiality of the customer's information and obtaining the customer's consent to disclose that information to the guarantor.
  • Providing the guarantor with a copy of the contract upon request.
  • Informing the guarantor in a timely manner in the event of any signs of default or breach by the customer regarding the guaranteed facility only and the consequences thereof.
  • Informing the guarantor before listing him as an irregular customer with both the Central Bank and the Egyptian Credit Bureau (Score-I).
• The customer shall not be asked for expenses or commissions (including expenses and commissions of support companies) that apply to any of the following conditions:
  • They were not included in the contract clauses.
  • Expenses or commissions for banking services or products that were not activated.
  • Expenses resulting from electronic services if the customer was not notified of them before executing the transaction, allowing him the freedom to choose whether to complete them or not. (For example: ATM transactions).
• The customer has the right to cancel his request for a banking product/service that has not been activated within two working days from the date of signing the contract without imposing any expenses or penalties.
• In the event of canceling any product or service, the bank and payment service providers and their agents or their representatives must do the following:
  • Paying the amounts due to the customer - including accrued returns, if any.
  • Not retaining any amounts previously collected in exchange for a product/service that the bank did not provide - if any.
  • Canceling any standing instructions made through direct debit from the account to fulfill obligations resulting from the product or service that was discontinued.
• In the event of payment (whether full or partial), the bank must not exaggerate in imposing expenses or penalties and determine them based on the actual cost incurred by the bank resulting from the cancellation of the contract.
• In the event that the customer pays off his debts in full, the bank must notify the Egyptian Credit Bureau (Score-I) that the debt has ended, as well as provide the customer with checks signed by him - if any - and a clearance from the bank, to include at a minimum the following data:
  • Customer data.
  • Account number of the granted facility at the bank.
  • Type of facility.
  • Payment date.
  • Nature of payment. (Full payment / Payment within the framework of settlement / Settlement with the bank and the bank's waiver of part of its dues).

2-4 Disclosure and Transparency

• The bank must disclose the actual annual interest rate and banking service prices in customer reception halls at its headquarters and branches or on its electronic website, or in various media or in correspondence and bulletins sent to customers, in accordance with what is stated in the Central Bank Law, the Banking and Monetary Authority Law in this regard.
• All rules and regulations related to all banking services must be available on the bank's electronic website.
• When the bank markets or advertises its products, it must use simple and understandable language for the general public and avoid complex or unclear terminology.
• The bank and payment service providers and their agents must provide the customer with sufficient, clear, and non-misleading information before contracting, making him fully aware of the terms, characteristics, and costs of the product or service.
• In the event that the bank deals with external support companies or payment service providers or their agents regarding products or services provided to the customer, the bank must inform the customer that the bank is fully responsible for all services provided by those companies.
• In the case of a fixed interest rate for credit facilities, the bank is not allowed to modify it without obtaining the customer's consent.
• The customer must be informed according to the mechanism agreed upon in the contract of any changes in the interest rate - in the case of a variable interest rate for credit facilities - or fees or expenses agreed upon and the impact of that on the terms of the granted facility.
• The bank and payment service providers and their agents or their representatives must inform the customer of an account balance statement according to the rules of the law, and the account statement must include at a minimum the following:
  • All customer transactions that took place during the period, including the balance at the beginning and end of the statement period.
  • What was credited to the account in terms of returns, expenses, and fees (if any).
  • The deadline required to authenticate the account statement.
• In addition to the above, the bank must commit to disclosing the following clauses in the event of issuing account statements for credit cards:
  • The granted credit limit.
  • The current balance.
  • The minimum payment limit.
  • The payment due date.
  • Total interest due.
  • Number of days of delay.
• In the event that the customer objects to the data sent by the bank, before the end of the period stipulated according to the Central Bank Law, the Banking and Monetary Authority Law, the matter must be investigated and corrective measures taken if necessary within a period not exceeding fifteen working days from the date of the customer's objection, except for objections related to transactions with external parties where investigating them may take a longer period.
• In the event that the customer requests any detailed data about his accounts or about any transactions that took place during the last five years at the latest or according to the bank's procedures in this regard, the bank must provide the customer with his request within ten working days at the latest, and this applies to customers who have stopped dealing with the bank or the service provider.
• In the event that the customer defaults according to the conditions in the contract, the bank or service provider must take the following:
  • Providing the customer with the necessary advice and counseling at this stage.
  • Giving the customer sufficient information about his rights and obligations.
  • Ensuring that the payment period is suitable for the customer's circumstances in light of the study prepared for him in the event of rescheduling or settlement.
  • Informing the customer of all procedures that will be taken in the event of his non-compliance with payment.
• The bank should announce in advance plans related to the flow of work and alternatives available to customers, for example:
  • Procedures that may lead to the disruption of providing any services.
  • Terminating some banking services.
  • Closing or relocating any branch.

3-4 Mechanism for dealing with customer complaints

The bank must apply policies and procedures that ensure the provision of a fast and free mechanism for dealing with customer complaints fairly, transparently, and effectively, to include at a minimum the following procedures:

• Creating a separate unit in the bank specialized in dealing with customer complaints under the name "Customer Rights Protection Unit", equipped with suitable human resources (for example, banking, legal expertise...), which is subordinate to and reports to the Bank's Compliance Department, with including in the bank's internal policy and the unit's work procedures the right to access files, records, and transactions of customers with complaints.
• The decisions of the Customer Rights Protection Unit in the bank are binding on electronic payment service providers and external support companies, and this must be stipulated in the contracts concluded with them.
• Preparing a unified internal model for customer complaints to be made available at branches or with agents or through the bank's and payment service providers' electronic website, to include at a minimum the following:
  • Date of submitting the complaint.
  • Customer data, including identity verification number and means of contact.
  • Summary of the complaint.
  • The department concerned with the complaint.
  • Attaching any documents related to the complaint.
• In all cases, the bank and payment service providers must consider any complaint submitted even in the event that the aforementioned model is not used or in the event that it is submitted directly to the bank.
• Informing customers about the mechanism for submitting and following up on complaints, through printed materials, informational boards, or electronic messages via email or mobile phone, or including correspondence and account statements addressed to customers with contact methods with the Customer Rights Protection Unit in the bank.
• Providing means for submitting complaints as a minimum as follows:
  • A complaint box at branches, and the compliance officer or his representative at the branch opens the box daily and sends complaints to the specialized unit for customer rights protection to register and examine the complaint.
  • Electronic means via fax, email, or website, with the complaint submitted to be registered by the next working day at the latest.
  • A phone number, with the complaint registered on a recorded line or in writing, with notifying the customer thereof.
  • Through the customer's direct contact with the Customer Rights Protection Unit.
• Providing the customer with a reference number within two working days from the date of registering the complaint to enable him to follow it up easily, with the possibility of following it up through the bank's or payment service provider's website or by phone.
• Banks must inform their customers that they cannot submit their complaints directly to the Central Bank of Egypt before referring to the concerned bank first.
• The customer's complaint must be responded to within a period not exceeding fifteen working days from the date of receipt (except for complaints related to transactions with external parties, with the customer must be informed of the time required to study the complaint).
• The unit responds to the complaint in writing or electronically, including appropriate justifications or corrective measures, if any.
• The concerned departments must take corrective measures and verify that there are no similar cases.
• The customer may escalate the complaint to the Central Bank in the event that his complaint is not responded to within the stipulated period.
• In the event that the customer does not accept the bank's or service provider's response, he must notify the bank or service provider in writing within fifteen working days from the date of receiving the response, including reasons for non-acceptance, and in the event that he does not do so, it is considered an implicit acceptance of the response.
• In the event that the bank or service provider notifies of non-acceptance of the response, the bank must reconsider and examine the complaint again, and respond to the customer finally within fifteen working days, accompanied by appropriate and clear justifications, especially if the response has not changed, with notifying the customer of his right to escalate the complaint to the Central Bank of Egypt in the event that the customer does not accept the bank's second response.
• The Customer Rights Protection Unit in the bank submits periodic reports about its work through the Compliance Department to the Audit Committee and the Board of Directors, such that these reports are considered a means to access the customer's opinion and work to improve performance, and the reports must include at a minimum the following:
  • The number of complaints, their nature, and their classification according to the nature of the customer (individual/company), type (male/female), age, and geographical location.
  • Measures taken regarding complaints.
  • Complaints that have been concluded.
  • Reasons or systemic problems that led to the appearance of complaints, and measures taken regarding them.
• The unit must analyze the submitted reports to determine the reasons and problems that led to the appearance of complaints, and take corrective measures regarding them, and recommend studying the situations of other customers to verify the absence of similar violations or problems.
• The Audit Committee and the Board of Directors of the Bank must consider the measures proposed by the complaints unit and supervise their implementation in the event of approval.
• The bank must provide the Central Bank of Egypt with a quarterly report on customer complaints according to the model prepared by the Central Bank of Egypt for this purpose, to include at a minimum:
  • The number of complaints, measures taken regarding them, and the consequences thereof.
  • Analysis of the nature of the submitted complaints.
• The bank must keep records of all complaints so that they are easy to refer to if necessary, for a period of five years from their submission at a minimum.

4-4 Spreading banking culture and awareness

• The bank and payment service providers must pay attention to spreading banking culture among customers, through simplified informational bulletins and communication with customers to introduce banking services and products. The bank must also inform the customer of his rights and obligations, which include at a minimum the following:
  • Clarifying how to use the bank's services and products, and informing about how to use debit cards and bank accounts according to the terms and regulations.
  • Clarifying the consequences of irregularity in payment for credit customers and what may result from it of negative effects on their dealings with banks and payment service providers (for example: being listed on negative lists).
  • Informing about fraud and forgery operations that accounts may be exposed to and how to deal with them.
  • The importance of reading contracts.
  • The importance of providing accurate and clear information to the bank or payment service providers that enables them to provide suitable services and products for the customer.
  • Not disclosing any confidential information about accounts to any other party, and taking all necessary measures to maintain debit or credit cards as well as the username and password.
  • The importance of updating personal data with dealing banks, including residential and work addresses, email, and phone number.
  • The necessity of notifying the bank or service provider immediately and without delay upon realizing any transaction involving theft, embezzlement, tampering with accounts, or unauthorized deduction of transactions from the customer on debit or credit cards.
• In the event that the customer does not comply with what is stated in the previous clauses, the customer bears full responsibility for any transactions carried out without his consent and what results from them of commissions and expenses.
• The bank and payment service providers must work on developing the professional performance of their employees, especially those who have direct contact with customers, to include strengthening the principles of protecting customer rights that:
  • Training employees on customer rights protection rules, and following up on their effective and continuous implementation.
  • Training employees on providing banking products and services, including evaluating the suitability of their needs and the ability to fulfill all resulting obligations.
  • Providing specialized training programs, whether internal or external, for employees.

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