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Office complaints procedure

In our office complaints procedure, the following terms are defined as stated below:

client: the client of BANNING N.V. in relation to the assignment agreement;
complaint: every written manifestation of dissatisfaction from or on behalf of the client against the lawyer or those working under his responsibility, about the formation and performance of a letter of engagement, the quality of the service provision or the extent of the invoice, not being a complaint as referred to in paragraph 4 of the Counsel Act [Dutch Lawyers Act / Advocatenwet];
BANNING: BANNING N.V.;
complainant: the client or its representative that submits the complaint;
complaints officer: the director of BANNING commissioned with handling the complaint, namely Mr J.W. de Tombe or Mr M.W. Steenpoorte.

This office complaints procedure applies to every letter of engagement between BANNING and the client.
Every BANNING lawyer will handle complaints in accordance with this complaints procedure.

This office complaints procedure serves:

to document a procedure of processing complaints from clients constructively, within a reasonable period of time;
to document a procedure to establish the cause of the client’s complaint;
to preserve and improve existing relationships by means of correct complaints handling;
to train employees to respond to complaints with the client in mind;
to improve the quality of the service provision by means of complaints handling and complaints analyses.

This office complaints procedure has been published on our website. Before or when entering into a letter of engagement, the lawyer makes the client, through the general terms and conditions or through a confirmation of engagement letter, aware of the fact that BANNING uses an office complaints procedure and that this procedure applies to the service.
Complaints as referred to in Article 1 of this office complaints procedure that are not resolved after being dealt with will be submitted to the competent court.

If a client approaches BANNING with a complaint, the compliant will be forwarded to the complaints officer.
The complaints officer notifies the person against whom a complaint has been made of the filing of the complaint and gives the complainant and the person against whom a complaint has been made the opportunity to provide an explanation to the complaint
The person against whom a complaint has been submitted will try to reach a solution with the client, with or without the intervention of the complaints officer.
The complaints officer processes the complaint within four weeks of receiving it or, when this rule is deviated from, notifies the complainant thereof, stating the reasons and giving a new term within which an opinion about the complaint will be given.
The complaints officer notifies the complainant and the person against whom a complaint has been made in writing about its opinion regarding the validity of the complaint, along with recommendations if applicable.

The complaints officer and the person against whom a complaint has been made shall observe confidentiality during the complaints handling process.
The complainant shall not be charged for the costs of handling the complaint.

The complaints officer is responsible for the prompt processing of the complaint.
The person against whom a complaint has been made will keep the complaints officer informed about any contact and a possible resolution.
The complaint officer shall keep the complainant informed about the processing of the complaint.
The complaints officer shall keep the complaints file up to date.

The complaints officer registers the complaint and the subject of the complaint.
The complaints officer reports periodically within BANNING on the handling of complaints and, where possible, makes recommendations to prevent new complaints and to improve procedures.
The reports and recommendations are discussed withing BANNING and submitted for a decision at least once a year.

March 26, 2020