Grupo Binternational’s Customer Defence Policy

First edition, September 2022.

Scope of application and compliance
This Customer Defence Policy regulates the requirements and procedures of the Customer Service Department (SAC) of Grupo Binternational, S.L., and its purpose is to attend to and resolve complaints and claims submitted by all those who receive services from the company, related to their legally recognised interests and rights.

This obligation refers to complaints and claims presented, directly or through representation, by all natural or legal persons, Spanish or foreign.

Complaints are considered to be delays, inattention or any other type of deficient performance in the provision of the company’s services.

Complaints are considered to be those submitted with the aim of restoring an interest or right, and which derive from alleged breaches of contracts, transparency and customer protection regulations or good practices.

Approval of the Policy
This Customer Protection Policy is approved by the administrative body and any modification and/or update must also be approved by the same, being recorded in writing in Annexes to the same.

Designation of the Customer Service Manager
The Customer Service Manager is appointed by the administrative body, and shall be a person of good repute, knowledge and proven professional experience to perform his or her duties.

The person in charge of the Customer Service Department may be relieved of his or her duties and delegate them to another person of equal honour and professional experience in the company when circumstances arise that undermine his or her impartiality and objectivity.

This is currently delegated to Sandra Manso Núñez.

The term of office is indefinite and shall cease, in addition to death, in the event of supervening incapacity, termination of the relationship with the company and resignation.

Postal address: address of the company’s head office, C/ Diego de León nº 57, 28006, Madrid.

E-mail address: sac@grupobinternational.com

Functions
The functions of the CCS are:

  • To receive the complaints or claims presented.
  • To process such complaints or claims in accordance with the procedure established in this Policy within the deadlines required therein.
  • To make recommendations and suggestions to the management body on all those aspects that, in its opinion, strengthen the good relations and mutual trust that should exist between GB and its customers.

GB will ensure and adopt the necessary measures so that all its departments provide the CCS as soon as possible with all information requested by the latter and necessary in relation to the exercise of its functions.

Communication to customers
Grupo Binternational will inform all its customers of the existence of this Policy, the Customer Service Department (SAC), its postal address and e-mail address.

The maximum period for attention and resolution of complaints and claims will be one month.

Procedure, form and deadline
First phase

Firstly, the customer must submit complaints or claims directly to the person responsible for providing the contracted service for resolution.

The customer may submit their complaint or claim in person or by proxy, on paper directly at the office or by computer, electronic or telematic means to the e-mail address of the person responsible for providing the service, provided that they can be read, printed and stored correctly and in accordance at all times with current legislation on electronic signatures.

Complaints must be submitted within a maximum period of two years from the date on which the customer became aware of the event or situation giving rise to the complaint or claim.

Second phase

If the complaint or claim is not resolved in favour of the customer, it will be sent to the Customer Service Department (SAC) by e-mail sac@grupobinternational.com or by post to the company’s headquarters at C/ Diego de León nº 57, 28006, Madrid.

The Customer Service Department will send the customer a written acknowledgement of receipt, which must state the date of submission to the Customer Service Department for the purposes of calculating the deadline and will proceed to open the file.

The content must be as follows:

  • Name, surname, address and NIF of the interested party and, if applicable, of their representative, for natural persons, and details of powers of attorney and registration details for legal persons.
  • Details of the reasons for the complaint or claim.
  • Documentation supporting the complaint or claim.
  • Proof that the complaining customer is not aware that the matter that is the subject of the complaint or claim is being dealt with through administrative, arbitration or judicial proceedings.
  • Place, date and signature.

In order to be admitted for processing, the CCS Manager must first check that the identity of the customer making the complaint is accredited and that the content of the document detailing the reason for the complaint or claim is clearly presented.

If this is not the case, the complainant will be asked to provide the necessary documentation or to rectify the material errors within a period of ten calendar days (a period that is not included in the calculation of the one-month period that the CCS must comply with).

If no response is received within this period, i.e. if the requested documentation is not provided or the material errors are not corrected, the file will be closed and the customer will be notified in writing. The file will remain open as long as the material errors identified are rectified.

The CCS may not admit the following complaints and claims for processing:

  • When the reasons are not specified or important information is missing.
  • When the facts on which the grounds for the complaint or claim are based are not related to the interests and rights legally recognised to customers by contract or by the corresponding regulations in force applicable to GB.
    Complaints and claims already resolved previously concerning the same facts.
  • When they are presented as complaints or claims, appeals or different actions, whose knowledge is the competence of administrative, arbitration or judicial bodies, or are pending resolution or litigation, or have already been resolved by them.
  • When the aforementioned two-year period has elapsed.
  • When the complaint or claim is not admitted for processing for any of the above reasons, the customer shall be notified in writing, explaining the reasons for the decision, giving him/her a period of ten calendar days in which to present allegations.

Once the allegations have been received, if we determine that the reasons for non-admission continue to exist, you must inform the customer of your final decision.

When a complaint or claim has been rejected for processing, it may be resubmitted to the CCS provided that the reasons communicated to the customer have been rectified within the stipulated period.

Cancellation and withdrawal
When the person responsible for providing the service, having received the complaint or claim, resolves it to the customer’s satisfaction, he/she shall notify the CCS, providing documentary justification, unless the customer expressly withdraws the complaint or claim. In such cases, the complaint or claim shall be filed, with no need for further action.

Customers may withdraw their complaints and claims at any time, which will result in the immediate termination of the procedure.

Completion and notification
The CCS shall finalise the processing of the file by notifying the customer in writing of its reasoned decision, with clear conclusions, based on the contractual clauses, transparency and customer protection regulations, as well as on good practices.

The communication to the customer shall be within a maximum of ten calendar days from the date of the issuance of the decision. The means shall be the same as those indicated above for the receipt of complaints and claims.

The decisions taken by the CCS must be complied with by the company. In the event that the customer accepts the decision, this does not imply waiver of his rights for the legitimate defence of his interests.

Annual report
The CCS shall submit an annual report on the performance of its functions to the company’s management body within the first quarter of the following financial year.

The report shall contain:

  • Statistical summary of complaints and claims received, admitted or not, reasons for their admission and/or inadmissibility, reasons given by customers and the type of service provided and/or project to which they are related.
  • Summary of decisions, whether favourable or unfavourable to the client.
  • General criteria of the decisions.
  • Recommendations or suggestions.

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