Circular dated May 7, 2024 regarding the instructions regulating the mechanism for dealing with complaints in banks

Cairo on: 7 May 2024

Dear Sir / Chairman of the Board of Directors of Bank,

Greetings,

With reference to the instructions for the protection of bank customers' rights issued under Circular Letter dated 19 February 2019, and specifically regarding the enhancement of regulatory frameworks related to complaint examination to ensure fair, transparent, and non-discriminatory treatment, and in order to define a comprehensive framework that enhances customer trust in the banking system and contributes to increasing financial inclusion rates,

A clear mechanism for dealing with complaints has been decided by the Board of Directors of the Central Bank at its meeting held on 30 April 2024 as follows:

"Banks must comply with all requirements regarding the mechanism for dealing with complaints in banks as set out in the attached instructions, completing what was stated in the instructions for the protection of customers' rights issued under Circular Letter dated 19 February 2019."

Please be so kind as to alert regarding full compliance with the attached instructions.

And please accept our highest regards,

Hassan Abdallah

Instructions Regulating the Mechanism for Dealing with Complaints in Banks

Table of Contents	Page
1. Introduction	3
2. Definitions	3
3. Scope of Application	3
4. General Provisions	4
5. Rules for Raising Customer Awareness Regarding Complaint Submission	5
6. Mechanism for Dealing with Complaints	6
7. Monitoring and Evaluating the Mechanism for Dealing with Complaints	7
8. Rules for Processing Complaints	8
9. Specific Rules for Time Periods for Dealing with Complaints	9
10. Complaints Related to Outsourcing Service Providers, Payment Service Providers, or Agents Contracted with the Bank	11
11. Rules for Referring Complaints	12
12. Rules for Recording Complaints	13
13. Complaint Reports	14

1. Introduction

These instructions complement the instructions for the protection of customers' rights issued on 19 February 2019 and aim to establish regulatory rules for dealing with complaints in banks, and provide a mechanism characterized by effectiveness, justice, transparency, and independence during customers' banking transactions and to elevate the level of service provision to enhance customer trust in the banking system and support competition, which leads to an increase in financial inclusion rates. This comes in light of the competencies 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, where these instructions include the minimum requirements that must be met to ensure the efficiency of the regulatory mechanism for complaints in banks.

2. Definitions

Complaint: Any verbal or written expression or by any possible means - including sign language for the disabled - (excluding inquiries or requests for information) that indicates dissatisfaction of the complainant with the banks, outsourcing service providers, payment service providers, and agents contracted with the Bank, due to their suffering actual or potential financial loss or moral harm, and includes as follows 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 the complainant.
• Disclosure problems regarding actual return rates, fees, or fines imposed on providing or canceling any service or product.
• Terms and conditions for providing the service or product.
• The time required to receive any of the 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 in addition to potential customers and/or customers intended to be dealt with by the bank or outsourcing service providers, payment service providers, or agents contracted with the Bank.

Customer Contact Channels: Are the places or points through which or at which the transaction between the customer and the bank or outsourcing service providers, payment service providers, or agents contracted with the Bank takes place, including branches, electronic and virtual points, and call centers as a minimum.

Customer Rights Protection Unit: Is the unit established in banks in accordance with Clause 1-3-4 of the instructions for the protection of bank customers' rights issued by the Central Bank in February 2019, which among its competencies is dealing with complaints.

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

Systemic Problems: Are problems related to the bank's systems, including for 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, and the bank bears full responsibility for any damage that may be caused to the complainant as a result of dealing with its employees or outsourcing service providers, payment service providers, or agents contracted with the Bank 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 must establish fair, clear, effective, and independent mechanisms for dealing with complaints.

2-4 Banks must make the complaint reception and handling service available free of charge at all stages, provided that the complainant bears the basic cost of contacting the bank.

3-4 Banks must provide the Customer Rights Protection Unit and other competent departments dealing with complaints with appropriate and sufficient resources - commensurate with the nature and size of the bank's business and enabling them to process complaints - including, in particular, the following: 1-3-4 Providing trained and qualified human resources with the necessary experience to receive, examine, study, and process complaints. 2-3-4 Determining the authorities concerned with making the necessary decisions to process complaints - including financial settlements if any - or referring them to the departments concerned with that. 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 the necessary programs for periodic and continuous training of employees.

4-4 The decisions of the Customer Rights Protection Unit in the bank are binding on outsourcing service providers, payment service providers, and agents, including contracts that are automatically renewed - with the bank contracted with them, and this must be stipulated in all contracts concluded by these entities upon the issuance of the instructions.

5-4 The compliance department in the bank must ensure the adoption and application 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 affected customers, as well as providing specialized staff easily and effectively in accordance with the instructions issued regarding facilitating access to banking services for persons with disabilities issued in September 2021.

5. Rules for Raising Customer Awareness Regarding Complaint Submission

1-5 Banks must raise customer awareness of their rights in accordance with these instructions, which includes, in particular, the following: 1-1-5 Publishing and distributing awareness leaflets about complaint submission procedures and the mechanism for dealing with them in writing or electronically free of charge; and making them available in prominent and easily accessible places upon request or during complaint submission; including at least the minimum information and data regarding the bank's complaint submission channels, the submission mechanism, the bank's obligations in the stages of complaint examination and the specified time frame for that, through the following channels at a minimum:

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

2-5 The bank must provide a unified internal form in Arabic and English for submitting complaints (a sample form is attached - Annex No. 1), to be made available through all customer communication channels. The form must include at least the following:

• Date of complaint submission.
• Complainant's data, including identity verification number.
• Contact data of the complainant.
• The complainant's preferred communication method to follow up on their 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, following up, and responding to the complaint according to the time frame specified by the bank.

3-5 The bank must inform illiterate complainants of their right to submit a complaint and assist them in doing so, and clarify the mechanism for dealing with it and the specified time frames for its examination and response, all verbally if necessary.

6. Mechanism for Dealing with Complaints

1-6 The bank must put in place the internal policies and procedures necessary for dealing with complaints fairly, transparently, and without discrimination, while ensuring informing the executive management of them. These policies must also be approved by the bank's board of directors and applied to ensure the following: 1-1-6 Allowing complaints to be submitted by any possible means - even in the absence of using the bank's dedicated complaint form - and the bank must not impose any restrictions or conditions that hinder the complainant's right to submit it. 2-1-6 The necessity of having multiple channels for receiving complaints, including at least the following:

• Bank headquarters, agents, or their branches.
• Telephone through the bank's call center, with the necessity of designating a code for submitting complaints and informing the complainant in advance that the complaint will be registered.
• All other available electronic means at the bank such as: fax, email, website.
• Direct communication with the Customer Rights Protection Unit.
• Social media channels (if possible), limited to receiving complaints only, and the bank must follow them up 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 time periods for processing complaints according to the type of product or service provided, so as not to conflict with what is stated in Clause (9) of these instructions.

2-6 The bank's Customer Rights Protection Unit must - by analyzing complaints and reporting on them while informing the executive management of them - through the bank's compliance department to the audit committee and board of directors, including the procedures that ensure the bank's compliance with the instructions issued in this regard, or any other relevant laws or guidelines, as follows: 1-2-6 Analyzing individual complaints to determine the causes that led to their emergence, to ensure they do not affect any other procedures, services, or products, whether complaints have been submitted about them 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 the emergence of complaints, the services and products related to them, and setting mechanisms to prioritize dealing with those complaints.
• The total cost of financial settlements for complaints - if any.
• Setting a mechanism to determine the impact of those complaints on any other procedures, products, or services.
• Setting a mechanism to determine the corrective procedures for the causes that led to the emergence of complaints, and how to apply them.
• Raising periodic reports to the audit committee and board of directors about systemic and recurring problems, their causes, and the necessary corrective procedures regarding them, as stated in these instructions.

4-6 When discovering the existence of systemic or recurring problems, the bank must look into the subsequent or potential damages resulting from those problems for customers who did not submit complaints about them, as well as taking the necessary and appropriate corrective and proactive procedures to deal with them and informing customers of that.

7. Monitoring and Evaluating the Mechanism for Dealing with Complaints

The bank must put in place a periodic monitoring system to measure the level of customer satisfaction with the mechanism for dealing with complaints, as well as a periodic monitoring system according to quality standards and work procedures for that. The monitoring system for measuring the quality of dealing with complaints submitted to the bank and processing them includes the following: 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 each of the branches, call center, banking operations department, and departments concerned with dealing with complaints to continuous supervision and control, including monitoring methods or mystery shopping. 4-7 Conducting a periodic evaluation of internal procedures for dealing with and processing complaints at least every two years.

8. Rules for Processing Complaints

The bank must, upon receiving the 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 that are not directly related to the subject of the complaint. 4-8 Evaluate the complaint fairly and quickly by considering the following factors:

• The nature of the complaint.
• The appropriate corrective procedure to process the complaint.
• The existence of reasonable reasons indicating the responsibility of another party - sole responsibility - or joint responsibility 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, in addition to clarifying 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 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. Specific Rules for Time Periods 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. In case this is not possible, the complainant must be provided with the reference number within a maximum of 2 working days from the date of receiving 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 submitter, which may include any of the following means:

• Correspondence, recorded phone calls, and text messages via mobile phone.
• Any other electronic channels; such as fax, email, and website.
• Personal presence before bank employees or their agents at any customer contact channels. 3-1-9 Alerting the complainant to the importance of keeping the reference number to follow up on their complaint. 4-1-9 Informing the complainant of the period necessary to examine the complaint according to the bank's internal work procedures. 5-1-9 When the complainant follows up on their complaint, the bank must inform them of the status of the complaint until it is resolved, according to its nature - if possible.

2-9 The bank must respond - in writing or electronically - allowing the submitter to keep the response, which must include the following, within a maximum of 15 working days from the date of receiving it:

• Accepting the complaint with presenting suitable solutions or corrective procedures to the complainant to process their complaint, or rejecting it with stating the reasons, or presenting solutions to process the complaint without accepting it in case of no error on the part of the bank.
• Attaching a copy of the bank's explanatory brochure on the mechanism for processing complaints.
• Informing the complainant of all their rights in case they do not accept 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 external parties (another bank, outsourcing service providers, or agents contracted with the Bank, others), 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 that - in writing or electronically - within a maximum of 15 working days from the date of receiving the response, stating the reasons for non-acceptance of the response received.

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 an implicit acceptance by the bank, and the bank may accept the complainant's objection after the mentioned period if they provide acceptable justifications.

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 - upon receiving this notification and re-examining the complaint with the same reference number and date of notification. 2-6-9 Re-examine the complaint through a higher administrative level than the level that examined it the first time, with no member of that level having previously participated in its examination.

7-9 The complainant must be alerted to the importance of keeping the bank's notification mentioned in Clause (1-6-9) to follow up on their complaint and refer to it when needed.

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

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

• Expressing sufficient and clear justifications and reasons for the response.
• Providing supporting evidence - when 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 Agents Contracted with the Bank

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

2-10 The bank must - in case this is not possible - provide the complainant with the reference number within a maximum of 2 working days from the date of receiving the complaint, accompanied by the following:

• Acknowledgment of receiving the complaint.
• Informing the complainant that their complaint relates to transactions with outsourcing service providers, payment service providers, or agents contracted with the Bank.
• Informing the complainant of the period necessary to examine their complaint.

3-10 The bank must immediately communicate with the party concerned with the complaint and bind them to a time frame for processing it according to what was stipulated in the contracts concluded with the bank and what was communicated to the complainant.

4-10 Contracts concluded between the bank and outsourcing service providers, payment service providers, and agents must include clauses related to a specific mechanism for dealing with complaints, the role of both the bank and the contracted party in examining and processing referred complaints, as well as the time periods necessary to respond to the bank regarding the referred complaints.

5-10 In all cases, when the complainant follows up on their complaint, the bank must inform them of the status of their complaint until it is resolved, according to its nature - if possible.

6-10 The rules stipulated in Clauses 2-9 to 9-9 apply to transactions with outsourcing service providers, payment service providers, or agents contracted with the Bank, except regarding time limits, including responding to the complainant within the time periods mentioned in Clauses 3-10 and 4-10, while ensuring 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 reasons that the subject of the complaint falls under the total or joint responsibility with another bank, provided that the complaint is referred within the scope of the part concerning the referred bank, while adhering to the confidentiality of customers' correspondence in accordance with Law No. 194 of 2020 issuing the Central Bank and Banking System Law, and adhering to the following: 1-1-11 That the referral takes place within a maximum of 2 working days from the date of receiving 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 2 working days from the date of referral and informing them of the name of the bank to which the complaint is referred, and contact means with it, including the reference number of the complaint. 4-1-11 Informing the complainant of the time period necessary to study the complaint.

2-11 The bank to which the complaint is referred must, upon receiving it, immediately inform the bank receiving the complaint of the time period necessary to study it; to be communicated to the complainant.

3-11 The bank to which the complaint is referred must deal with it, examine it, and consider it with the same care and same procedures followed in examining complaints submitted directly to the bank.

4-11 The bank to which the complaint is referred 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 its referral, and this does not apply to complaints related to external 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 must respond to the customer with the responses of both banks.

6-11 In case the customer does not accept any of the responses communicated, they should inform the bank receiving the complaint of their objection, in accordance with the rules and time frames stipulated in the instructions in Clauses (4-9) to (9-9), and both the bank receiving and the bank to which the complaint is referred must re-examine it, in accordance with Clauses (1-11) to (4-11).

7-11 The bank to which the complaint is referred must send the final response - in writing or electronically - to the bank receiving the complaint, all in accordance with the procedures, controls, and time frames stipulated in these instructions.

8-11 Banks must - through the banks' union - cooperate to activate the rules for referring complaints 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 referred in full to another bank, and in case of joint responsibility for the complaint, both banks must include the complaint in their reports such that the referral is for the part concerning each bank only from the complaint.

12. Rules for Recording Complaints

1-12 The bank must establish a database to save data related to complaints in a classified manner according to what will be mentioned later in Clause (3-12) below, while maintaining the integrity and confidentiality of information provided by customers. The database must include the following: 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 and the causes that led to their emergence and the decisions taken, including corrective procedures.

2-12 The bank should keep the data mentioned in the bank's complaint database for a period of five years - as a minimum - from the date of receiving the complaint.

3-12 Complaints in the mentioned database are classified; and the information included includes at least the following data: 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 identity verification document
• Place of residence of the complainant
• Data regarding communication means with the complainant
• The complainant's preferred communication method specified by them to follow up on their 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 of it
• 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 identity 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 by them to follow up on 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, error in the automated system... 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 reference number of the complaint
• The result/corrective procedure sought by the complainant
• Any documents submitted by the complainant
• The procedures taken in light of 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 bank's Customer Rights Protection Unit must raise quarterly reports at a minimum about its work - while informing the executive management of them - through the compliance department to the audit committee and board of directors to be informed and take the necessary corrective procedures - if the matter requires.

2-1-13 The mentioned reports must include at least 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 complaints.
• Procedures taken to deal with complaints.
• Number of complaints processed.
• Average time taken...

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