Complaint Handling Policy

1. Purpose

This Complaint Handling Policy (“Policy”) describes how Romania for Business (“the Company”, “we”, “us”) receives, records, investigates, and resolves complaints raised by clients and other stakeholders. The Policy is designed to ensure complaints are handled fairly, promptly, and consistently, in accordance with:

• Government Ordinance No. 21/1992 on consumer protection, republished and as subsequently amended;
• Law No. 296/2004 on the Consumer Code, as amended;
• Government Ordinance No. 38/2015 on the alternative resolution of disputes between consumers and traders (transposing Directive 2013/11/EU on ADR for consumer disputes);
• Regulation (EU) No. 524/2013 on online dispute resolution for consumer disputes (“ODR Regulation”);
• Regulation (EU) 2016/679 (GDPR) and Law No. 190/2018, insofar as a complaint concerns the processing of personal data;
• General principles of the Romanian Civil Code governing contractual liability and good faith in contractual relationships;
• Where applicable, rules of the professional body under which associated professionals operate (e.g., the Romanian Bar Association’s Statute of the Legal Profession, for complaints concerning services rendered by licensed attorneys).

2. Scope

This Policy applies to all complaints submitted by:

• Clients and prospective clients of the Company;
• Beneficial owners or authorized representatives of corporate clients;
• Any other person directly affected by services provided by the Company.

A complaint is any expression of dissatisfaction, whether justified or not, relating to the Company’s services, conduct, fees, communications, or handling of personal data, where a response or resolution is explicitly or implicitly expected.

This Policy does not cover general feedback, pre-contractual inquiries, or requests for information that do not express dissatisfaction — these are handled through ordinary client service channels.

3. Principles

The Company handles complaints in accordance with the following principles:

• Accessibility — complaints can be submitted free of charge, through multiple channels, without unnecessary formality.
• Fairness and objectivity — complaints are investigated impartially, without prejudging the outcome and without conflict of interest on the part of the person handling the complaint.
• Transparency — complainants are kept informed of the process, timelines, and outcome.
• Timeliness — complaints are acknowledged and resolved within the timeframes set out in this Policy.
• Confidentiality — complaint-related data is processed strictly in accordance with the Company’s Privacy Policy and applicable data protection law.
• Non-retaliation — submitting a complaint in good faith will not adversely affect the complainant’s relationship with the Company.

4. How to Submit a Complaint

Complaints may be submitted through any of the following channels:

• Email: info@romania-for-business.com

To help us investigate efficiently, complainants are encouraged to include:

1. Full name and contact details;
2. Nature of the service or engagement concerned (including any reference/file number, if known);
3. A clear description of the issue and, where relevant, the outcome sought;
4. Any supporting documents (contracts, correspondence, invoices, etc.).

Complaints may be submitted in Romanian or English.

5. Complaint Handling Process

5.1 Acknowledgement

The Company acknowledges receipt of a complaint within 5 (five) business days, confirming:

• That the complaint has been logged;
• A reference number, where applicable;
• The name/role of the person handling the complaint;
• The expected timeframe for a substantive response.

5.2 Investigation

The assigned reviewer will:

• Examine the relevant file, correspondence, contractual terms, and any applicable internal policy;
• Where necessary, request additional information or clarification from the complainant;
• Consult with relevant staff, partners, or associated professionals involved in the underlying engagement;
• Assess the complaint objectively against the Company’s contractual obligations, applicable law, and professional standards.

5.3 Resolution and Response

The Company aims to provide a substantive written response within 30 (thirty) calendar days of acknowledging the complaint, consistent with general consumer-protection practice in Romania and, where the complaint concerns personal data processing, the one-month response period under Article 12(3) GDPR (extendable by a further two months for complex requests, with notice to the complainant).

The response will set out:

• The outcome of the investigation;
• The reasoning behind the decision;
• Any corrective action taken or proposed;
• Information on further escalation options, where the complainant is not satisfied (see Section 6).

Where a complaint cannot be resolved within 30 days due to its complexity, the Company will inform the complainant in writing of the delay, the reasons for it, and the revised expected timeframe.

5.4 Record-Keeping

All complaints, related correspondence, and outcomes are logged in the Company’s complaints register and retained for a minimum of 3 (three) years, or longer where required for the defense of legal claims or under sector-specific retention obligations (e.g., AML record-keeping rules, where applicable — see the Company’s AML Policy).

6. Escalation and Alternative Dispute Resolution

If a complainant is not satisfied with the Company’s response, or if no response is received within the applicable timeframe, the following escalation avenues are available:

6.1 Internal Escalation

The complainant may request that the matter be reviewed by senior management, by replying to the original response or contacting info@romania-for-business.com with the reference “Escalation – [complaint reference]”.

6.2 National Authority for Consumer Protection (ANPC)

Where the complainant qualifies as a consumer under Romanian law, they may refer the matter to the National Authority for Consumer Protection (Autoritatea Națională pentru Protecția Consumatorilor — ANPC):

• Website: https://anpc.ro/
• The ANPC also operates the SAL-Fin and related alternative dispute resolution (ADR) entities for out-of-court settlement of consumer disputes, in accordance with GO 38/2015.

6.3 EU Online Dispute Resolution (ODR) Platform

For disputes arising from services purchased online, EU-based consumers may also use the European Commission’s Online Dispute Resolution platform:

• https://ec.europa.eu/consumers/odr/

6.4 Data Protection Complaints

Where a complaint concerns the processing of personal data, the complainant has the right, independent of any internal escalation, to lodge a complaint with:

• The Romanian National Supervisory Authority for Personal Data Processing (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal — ANSPDCP): https://www.dataprotection.ro/

6.5 Professional Body Complaints

Where the complaint concerns professional conduct of a licensed attorney or other regulated professional engaged in the delivery of services, the complainant retains the right to refer the matter to the relevant professional body (e.g., the competent Bar Association), independent of this Policy.

6.6 Judicial Remedies

Nothing in this Policy limits the complainant’s right to pursue remedies before the competent Romanian courts, in accordance with the Romanian Civil Code and Code of Civil Procedure.

7. Data Protection

Personal data submitted as part of a complaint is processed by the Company solely for the purposes of investigating and resolving the complaint, maintaining records, and complying with legal obligations, in accordance with the Company’s Privacy Policy and applicable data protection legislation (GDPR and Law No. 190/2018).

8. Governance and Continuous Improvement

The Company periodically reviews complaint trends and root causes as part of its internal quality control process, with the aim of:

• Identifying recurring issues in service delivery or communication;
• Implementing corrective and preventive measures;
• Updating internal procedures, training, or this Policy where warranted.

This Policy is reviewed at least annually, or upon material change in applicable legislation.

9. Contact