1. Background and purpose
The Board has adopted this procedure for complaint handling (the "Procedure") and has herein defined and outlined the guidelines for Crowdlending Europe AB (the "Company" or "Crowdster", Org-Nr: 559521-5350) in relation to the Company's handling of complaints, including description of roles and responsibilities, information and guidance to the customer, and appointment of a complaint officer.
The procedure applies to:
- Private customer relationships
- Business customer relationships that do not differ from private customer relationships (e.g., private holding companies)
The CEO is responsible for ensuring that:
- The procedure is implemented and complied with
- Employees are familiar with the content
- Employees can refer to relevant information and the Complaints Officer
2. Responsible parties
The Legal Officer is designated as the Complaints Officer and has overall responsibility for:
- Compliance with this Procedure
- Managing and processing customer complaints
- Maintaining the complaint handling process
3. Definition of complaints
A complaint is defined as:
- An enquiry to the Company's Complaints Officer
- An enquiry to the Company handled by the Complaints Officer
- An expression of dissatisfaction with the service or product provided
3.1 Complaint handling criteria
- Complaints must be received in writing
- Immediate, non-specific dissatisfactions that can be quickly remedied do not require formal registration
- Persistent dissatisfaction requires formal complaint guidance
4. Complaint handling procedure
4.1 Initial processing
- All complaints must be received in writing
- Complaints must be forwarded to the Complaints Officer without delay
- The Complaints Officer will acknowledge receipt within 10 working days
- Acknowledgement includes:
- Confirmation of complaint admissibility
- Contact details of the responsible person (name, email, telephone)
4.2 Investigation process
- Assess complaint intelligibility and completeness
- Request additional information if necessary
- Investigate circumstances and background
- Involve relevant Company personnel
- Obtain necessary information
4.3 Decision and response
- Investigate and make a decision to accept or reject the complaint
- Inform Executive Board of recommended decision
- Aim to respond within 14 working days
- Provide explanation if response is delayed
- Address all points raised in the complaint
- Provide reasons for investigation outcome
4.4 Additional guidance
- If complaint is not granted, inform customer of appeal options:
- Allmänna Reklamationsnämnden (www.arn.se)
- Public court actions
- Company lawyer may be involved depending on complaint complexity
5. Communication guidelines
- Complaints can be submitted electronically via email
- Communication in the same language as Key Investor Information Document
- Use clear and plain language
- Option for electronic or paper communication
6. Complaint guidance website information
The website complaint guide will include:
- Conditions for complaint admissibility
- Confirmation that complaints are free of charge
- Submission methods and contact information
- Required information and evidence
- Supported languages
- Complaint responsibility and contact details
- Expected timeframe for complaint resolution
7. Complaint Registration
The Complaints Officer maintains an excel complaint register documenting:
- All received complaints
- Complaints about the Company
- Complaints related to business or projects
- Ensures easy extraction and reporting to Danish FSA
8. Procedure Review
This procedure will be reviewed:
- When deemed necessary by the Executive Board
- At minimum, once per year
Contact Information:
- Email: hello@crowdster.eu
- Address: Drottvägen 7a, 182 64 Djursholm, Sweden
- Organization Number: 559521-5350