Excerpt from the Regulations on Handling Client Complaints as of February 14, 2024

GENERAL PROVISIONS

The Regulations on Handling Client Complaints (hereinafter referred to as the "Regulations") have been developed in accordance with the legislation of the Kyrgyz Republic and the regulatory legal acts of the National Bank of the Kyrgyz Republic.

These Regulations establish the procedure for receiving and reviewing client complaints, including applications, grievances, and suggestions (hereinafter referred to as "Complaints"), in CJSC Microfinance Company "Elet-Capital" (hereinafter referred to as the "Company"). They aim to ensure the protection of clients' rights, deliver their suggestions, remarks, and comments to the Company's management, and provide for their review and the implementation of appropriate measures.

For the purposes of these Regulations, the following terms are used:

• Banking services – operations and services conducted and provided by the Company in accordance with the legislation of the Kyrgyz Republic;
• Complaint – an oral or written grievance or statement (dispute) from a client, containing information about violations and/or the restoration of their rights, violations of the requirements of regulatory legal acts, as well as messages regarding banking services, including changes to contract terms;
• Book of complaints and suggestions – a special book for recording client complaints and suggestions for their subsequent review in the prescribed manner.

In providing banking services and reviewing client complaints, the Company adheres to the following key principles:

• Legality, honesty, integrity, transparency, reasonableness, fairness, and social responsibility;
• Respect for and protection of clients' rights and legitimate interests, maintaining a partnership-based approach toward them;
• Mandatory review of complaints and provision of the outcomes of such reviews;
• Timely, objective, and comprehensive review of complaints;
• Equal treatment of clients in the review process;
• Ensuring confidentiality and non-disclosure of information constituting banking secrecy.

AIMS AND OBJECTIVES OF THE REGULATIONS

• To provide clients with tools and opportunities to protect their rights, convey their suggestions and comments on the Company's activities and the performance of its employees by directly contacting the Company's management and/or branch management.
• To eliminate deficiencies and violations that prompted clients' complaints, improve service quality, and increase employee accountability for fulfilling their duties.
• To establish procedures and deadlines for receiving, reviewing, and responding to client complaints.
• To set requirements for providing clients with comprehensive information about the Company's services and clarifying clients' rights and obligations when obtaining loans.

PROCEDURES FOR HANDLING COMPLAINTS<

Receiving Complaints:
Clients’ complaints may be submitted orally (via telephone or in-person meetings) or in writing, delivered personally, by mail, via email (This email address is being protected from spambots. You need JavaScript enabled to view it.), through the book of complaints and suggestions, or the Company’s official website. Complaints can be submitted in either the state or official language of the Kyrgyz Republic.

• The book of complaints and suggestions must be placed in a visible and accessible location for clients (e.g., information stands).
• An electronic version of the complaint handling procedure (the section concerning clients) must also be available on the Company’s official website, , and the link should be posted on the homepage..
• Upon the client’s request, the Company must explain the established procedure for handling complaints.
• The maximum review period for client complaints is 30 (thirty) calendar days.
• If additional verification or other measures are required to review a complaint, the review period may be extended by the Company’s Chief Operations Officer, with the client being notified.

Clients may submit complaints through the following channels:

• Personal visits to a branch or the Head Office;
• By e-mail (This email address is being protected from spambots. You need JavaScript enabled to view it.);
• Through the official website of the Company in the “Questions and Suggestions” section;
• By recording it in the book of complaints and suggestions;
• By calling the telephone number displayed on the information stand at each branch and listed on the Company’s website.

Anonymous complaints (those without personal and contact information or a mailing address for responses) do not require a response to the complainant.

Procedure for Reviewing Written Complaints and Providing Responses to Clients:

• Written complaints submitted to the Company must be reviewed within 30 (thirty) calendar days, with a written response provided to the client.
• The Company's response to the client will be provided in the language of the complaint—either the state or official language of the Kyrgyz Republic.
• For complaints submitted by multiple clients (collective complaints), the response will be sent to the first address listed in the complaint unless otherwise specified in the submission.

Procedures for Handling the Book of Complaints and Suggestions:

• Each branch of the Company must have a book of complaints and suggestions in client service areas where clients can record their remarks, complaints, and suggestions.
• Complaints must be reviewed within 30 (thirty) calendar days, with a written response provided.

The procedure for handling inquiries received by the Head Office phone of the Company:

• Each branch must display information about the option to contact the Head Office, including the telephone number of the Chief Operations Officer.
• If the issue requires a written response, the response must be provided within 30 (thirty) calendar days.

Procedure for Handling Inquiries Submitted via the Company's Official Website
Inquiries submitted via the Company's official website are automatically forwarded to the company's email address. The inquiry must be reviewed within 30 (thirty) calendar days, with a written response provided.

Procedure for Personal Client Reception at Branches or the Head Office
Branch managers approve the schedule for personal visits, which must be held at least twice a week for no less than one hour.
The Operational Director at the Head Office also approves the schedule for personal visits, which must occur at least once a week.
The schedule for personal visits by both the Branch Manager and the Operational Director is posted on the information board at the branch.
If time and opportunities allow, the Branch Managers and the Operational Director are obligated to accept clients at any other working hours. When visiting in person, the client must present an identification document.
In the case of a verbal inquiry by phone, with prior notification to the client, the conversation may be recorded for use in the inquiry review process.
Responsible employees (Chief Loan Specialist, Senior Loan Specialist, Loan Specialist) will conduct personal receptions of visitors regularly within working hours.

Procedure for Client Consultations on Loans
When a potential borrower initially contacts the branch for a loan, the Loan Specialist is required to fill out the Key Data Sheet on the potential loan with the client, free of charge, and provide it to the client. This inquiry is not considered a loan application.
The client has the right to keep the completed Key Data Sheet for comparison with services from other financial institutions.
If the loan is approved, and before the loan agreement is signed, the Loan Specialist must provide the client orally with the following information:

• Loan term;
• Loan amount;
• Interest rate (nominal annual rate), as well as the effective annual percentage rate at the time of providing the information;
• A comprehensive list and amounts of fees, commissions, and other charges related to obtaining and servicing the loan;
• The consumer’s responsibilities and risks in case of non-compliance with the loan agreement;
• The responsibility of the collateral provider, guarantor, or any other party to the loan agreement;
• The amounts of one-time or regular payments (usually monthly);
• The total cost of the loan, showing separately the principal amount, interest, commissions, and other payments associated with the conclusion and execution of the agreement;
• The consumer's rights as stated in the Key Data Sheet on the potential loan.
  During the loan servicing period, Loan Specialists must, upon verbal or written request from the client, provide oral or written information free of charge on the following:
• The amount of funds repaid on the loan;
• The size and schedule of regular payments;
• The amount of overdue debt;
• The allocation of incoming funds for loan repayment;
• The amount due in case of partial or full early repayment of the loan;
• The outstanding principal balance;
• The credit limit.
  When dealing with overdue loans, employees/Company will pursue debt recovery in accordance with the law and the loan agreement.
  To recover the loan debt, employees properly notify clients of the need to repay the debt and the consequences of non-compliance with the loan obligations.
  Debt notices must include a brief summary of the debt, specifying the principal amount, accrued interest, and penalties.
  Notices must not be delivered, nor reminders made via phone calls, or field visits conducted from 10 PM to 6 AM local time.