Complaint Handling Policy

1. GENERAL

1.1 Purpose

CC Real is committed to promoting customer satisfaction by encouraging feedback, including complaints. This complaint handling policy (hereinafter “the Policy”) sets out how CC Real deals with complaints in an efficient and transparent manner and provides a systematic approach to reviewing complaints to identify and resolve issues before they become recurring.

1.2 Objectives

This Policy serves to provide a clear framework for handling complaints through effective and efficient procedures. CC Real analyses customer complaints, considering their needs and concerns, focusing on the opportunity to constantly improve the quality of its services.

1.3 Principals of effective complaint handling

1.3.1 Visibility and transparency

The Complaint Handling Policy is available on the CC Real website: www.cc-real.com

1.3.2 Making a Complaint

Any Client / Investor of the CC Real is allowed to file a complaint by:
a. Sending an e-mail to: complaint@cc-real.com
b. In writing addressed to CC Real:

CC Real
Handelskai 94-96
A-1200 Vienna

1.3.3 No charges

Filing complaints with the CC Real and the internal handling of complaints is free of charge.

1.3.4 Ensuring no detriment to complainant

We take all measures to ensure that complainants are not adversely affected due to the fact of filing a complaint.

1.3.5 Objectivity and equity

Each complaint is managed in a fair, objective and unbiased manner by the CC Real.

1.3.6 Confidentiality and disclosure

CC Real ensures that the processing of personal data complies with the applicable rules on personal data protection.

1.3.7 Responsiveness

All complaints will be treated in an efficient manner. CC Real endeavours to resolve complaints within one month after receiving it.
If we assess the processing of the complaint will takes longer, or there are delays in processing the complaint we will inform the complainant of the reason for the delay and likely time for resolution.

1.3.8 Review

This Policy will be reviewed periodically and improved as appropriate.

2 DEFINITION AND RESPONSIBILITIES

2.1 Definition

2.1.1 Complaint

A complaint is any kind of expressed discontent, raised in connection with a specified business matter. The complaint should be in writing.

2.1.2 Complainant

Any client or partner of CC Real can be a complainant.

2.2 Responsibilities

Within the CC Real the Risk and Compliance Manager (RCM) is:

  1. Appointed as Complaints Handling Officer
  2. Responsible for managing and handling all complaints sent to the CC Real and
  3. Responsible for the implementation of the Policy.

All employees are required to refer, any complaints received, to the RCM immediately (in writing).

3. PROCESS

3.1 Complaint Handling Procedure

3.1.1 Receipt

CC Real will confirm receipt by email. It is expected this will be done within two working days (unless there are exceptional circumstances).
All complaints are managed centrally through RCM and fully recorded.

3.1.2 Investigation

Complaints will be handled independently of the business unit which is the subject of the complaint.
The information provided by the complainant will be used to investigate and assess the complaint.
As a minimum, the following information is required to be provided by the complainant:

  • Complainant’s name and contact details
  • If acting on behalf of another party, the Complainants role and authority to act on their behalf
  • Details and reason of the complaint
  • Copies of any documentation supporting the complaint

Following an initial assessment of the complaint, a request for further information will be sent to the complainant if required.

CC Real will assess in a fair and consistent manner:

  • The subject matter of the complaint
  • What remedial action may be appropriate
  • Whether any other party may be solely or jointly responsible for the subject matter
3.1.3 Third Party Involvement

If CC Real has reasonable grounds to assume that another party may be solely or jointly responsible for the matter, it will forward the complaint to the party. Subsequently, the complainant will be informed of the referral.

3.1.4 Closing of Complaint

CC Real will endeavor to resolve the complaint within a period of one month, of receiving full details of the complaint. The complainant will be informed If the complaint cannot be resolved within this period.

In other cases, the complainant will receive a written statement from CC Real for the closing of the complaint assessment process.

3.1.5 External Complaint Resolution

If complainant is not satisfied with the handling of the compliant or the outcome, the complainant has the right to escalate the complaint to an external dispute resolution body or the appropriate supervisory authority.

3.2 Documentation and Records

Details of the process including:

  • Date of the complaint
  • Complainant’s name and contact details
  • Status of the complaint
  • Assessment
  • Summary of the corrective measures
  • Complaint closing statement
  • Possible process improvements for future complaint handling will be recorded.

CC Real will keep the record of each complaint for seven years.