As a regulated financial services firm, Floodlight (the trading name of Ela Expeditions UK Limited in the UK and of Ela Expeditions IE Limited in the EU) is required to have a policy and procedure whereby clients can formally complain about the services that have been provided (or not provided) to them. This policy must ensure that, in all cases where a client is dissatisfied with the way we have dealt with them or the services we have offered, there is a formal process for them to express this, and for Floodlight to take appropriate actions to resolve the issue.
Where Floodlight fails to resolve the issue, clients may also have additional redress options through a third party, or recourse to legal action.
This policy provides Floodlight employees and any parties who may interact with clients on behalf of Floodlight with the formal process that we will follow to ensure that its clients have access to the relevant redress process. Individuals who do not follow this process, or who are found to be circumventing this policy, will be liable to HR action. Individuals could potentially be personally liable to our clients in these circumstances.


Floodlight defines a complaint as any verbal or written expression of dissatisfaction, whether justified ornot, from, or on behalf of, a person about the provision of, or failure to provide, a financial service ora redress determination, which:

(a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and

(b) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service.

This definition aligns with FCA handbook (DISP).

This is a deliberately broad definition of a complaint and will require that employees pay close attention to the conversations and correspondence that they have with clients, as not all clients will use the word “complaint” explicitly. They may use other less formal language such as dissatisfied, upset, annoyed, agitated or gripe, and so employees should listen to the general tone of the client as well as specific language used.

It should also be noted that the definition of a complaint may allow an individual or entity to object to our processes, even where they have been followed appropriately and the client has suffered little more than an annoyance at having to provide documentation. The FCA has worded this intentionally, so that financial institutions are required to be diligent and to log all instances of customer dissatisfaction and resolve them appropriately as opposed to dismissing them out of hand.
It should also be noted that the phrase “has some connection in marketing or providing financial services or products” results in Floodlight potentially being responsible for the failings of our counterparties, even if such failings or complaints were outside of the control of Floodlight. Employees should be aware that a payment being delayed by a third party connected to Floodlight (such as our banking partners or software providers) must still be considered, irrespective of blame or fault.

Fault, where this is outside of the scope of Floodlight (for example, if it lies with the client’s bank) will not result in a viable complaint. However, where the client insists that this be reviewed it may be prudent for staff to follow the complaints process to ensure a formal response is issued to the client.


Any and all clients are able to submit a complaint to us, and to access our complaints and redress process. However, a distinction can be made between those clients who are eligible to have their complaint considered by the Financial Ombudsman Service, and those who are not.

Floodlight’s definition of an eligible complainant aligns with DISP 2.7.3 of the FCA Handbook, as a person that is:

1. a consumer;

2. a micro-enterprise ;

(a) in relation to a complaint relating wholly or partly to payment services, either at the time of the conclusion of thepayment servicecontract or at the time the complainant refers the complaint to the respondent; or

(b) otherwise, at the time the complainant refers the complaint to the respondent;

3. a charity which has an annual income of less than £6.5 million at the time the complainant refers the complaint to the respondent;

4. a trustee of a trust which has a net asset value of less than £5 million at the time the complainant refers the complaint to the respondent;

5. (in relation to CBTL business) a CBTL consumer;

6. a small business at the time the complainant refers the complaint to the respondent; or

7. A guarantor

A micro-enterprise meets the following criteria:
- Employs fewer than 10 people; and
- Has a turnover or annual balance sheet that does not exceed €2 million.

Note: In determining whether an enterprise meets the tests for being a micro-enterprise or a small business, account should be taken of the enterprise’s 'partner enterprises' or 'linked enterprises' (as those terms are defined in the Micro-enterprise Recommendation). For example, where a parent company holds a majority shareholding in a complainant, if the parent company does not meet the tests for being a micro- enterprise or a small business then neither will the complainant (DISP 2.7.4).

A small business meets the following criteria:
- Is not a micro-enterprise; and
- Has an annual turnover of less than £6.5 million (or its equivalent in any other currency); and

● Employs fewer than 50 people; or
● Has a balance sheet total of less than £5million(or its equivalent in any other currency).

To fall within the firm’s definition of an eligible complainant, the complainant must also have a complaint which arises from either:
- being, (or was) customer, payment service user or electronic money holder of the firm, or;
- a (or was) potential customer payment service user, or electronic money holder of the respondent.

In the case of eligible complainants (as per DIPS 1.6.4), Floodlight will, in its final written response to the complaint, refer the complainant to the Financial Ombudsman Service (‘FOS’).

Whilst any client may complain to us, the FCA recognises that larger firms, corporations and other regulated entities are in a position to review their own interactions with financial services firms more closely. As a result, the FCA has decided that they should be offered fewer protections than retail consumers or small corporations. As such the following have been identified as not eligible complaints:

(1) (in all jurisdictions) a firm, payment service provider, electronic money issuer, CBTL firm, designated credit reference agency, designated finance platform or VJ participant whose complaint relates in any way to an activity which:
(a) the firm itself has permission to carry on; or
(ab) the firm, payment service provider, electronic money issuer, CBTL firm, designated credit reference agency, or designated finance platform itself, is entitled to carry on under the Payment Services Regulations, the Electronic Money Regulations, the MCD Order, the Small and Medium Sized Business (Credit Information) Regulations or the Small and Medium Sized Business (Finance Platforms) Regulations; or
(b) the VJ participant itself conducts; and which is subject to the Compulsory Jurisdiction or the Voluntary Jurisdiction;

(2) (in the Compulsory Jurisdiction) a complainant, other than a trustee of a pension scheme trust, who was:
(a) a professional client; or (b) an eligible counterparty;

in relation to the firm and activity in question at the time of the act or omission which is the subject of the complaint (DISP 2.7.9).

Note: Additional information can be found in the section of the FCA Handbook relating to Dispute Resolution and Complaints: https://www.handbook.fca.org.uk/handbook/DISP/

This should not inform or change the standard of the interactions which Floodlight have with its clients, as any entity not listed above will still have recourse to take direct legal action where Floodlight fails to fulfil its contractual obligations. Whilst clients may not be able to refer their complaints to an ombudsman for review, their concerns should be handled appropriately.

To this end, Floodlight will handle all complaints, regardless of the size of the client in line with the following process, however will not make a referral to the FOS for ineligible clients.


Floodlight has established, implemented, and maintains effective and transparent procedures for the reasonable and prompt handling of any complaint.

These procedures:
● allow complaints to be made free of charge by eligible and ineligible complainants by any reasonable means; and
● recognise complaints as requiring resolution.

This may involve the employee further explaining the reason for our processes being as they are, offering refunds or reductions in further fees, or through good client management.

Where the firm can resolve an eligible complaint payment service user complaint within three business days, in addition to sending the complainant a ‘summary resolution communication’, the firm should record the resolved complaint within their complaints register as a complaint resolved within 3 business days.
Once a complaint has been identified, an employee will have three days to resolve the complaint with the client so that the person making the complaint has clearly expressed that their issue is resolved. However if, after three days, the client is still dissatisfied with the issue or has expressed that they wish for a complaint to be formally investigated, employees must escalate that complaint to the Complaints team by the close of business on the third day. This allows the Complaints team to record the complaint and follow the relevant and appropriate steps to ensure that the complaint is handled correctly.

Once a complaint has been received by the Complaints team, the following process will be followed:

Initial Response
An initial response will be sent to the complainant providing a written acknowledgement and reassurance that it has received the complaint and that the Complaints team is dealing with it. The Complaints team will liaise with any additional teams on your behalf as required.

Formal Response to Complaint
Within 15 business days of the original complaint being received, Floodlight must issue a formal response to the complainant. This response will include details of our understanding of the complaint, a timeline of the activities which have taken place, the details of any resolution which we intend to offer, or an explanation as to what steps we intend to take to resolve the issue.

Holding Response
Where Floodlight has been unable to provide a resolution or has been unable to investigate the issue fully during this time, we may write to the client and provide details of the reason for a lack of response. Where clear provisions and explanations can be provided relating to the lack of a response, Floodlight will then allow a further 20 business days to respond.

This pushes the total response time to 35 business days from the receipt of a complaint.

Final Response
A final response and formal response may be the same document (where the issue has been resolved), however Floodlight must issue a formal final response which addresses the issues that have been raised and provides the formal options or redress (where such options exist) for resolving the issue with the client.
Such a response letter will be sent, even where there is no action to be taken on the part of Floodlight, or where the only response is by way of apology or explanation.
A final response letter will be sent to the email from which the complaint has been sent and/or the email address registered to the relevant user/account, or if agreed between the respondent and the complainant, on another durable medium.

A final response to the complainant will:
(a) accept the complaint and, where appropriate, offers redress or remedial action; or (b) offer redress or remedial action without accepting the complaint; or
(c) reject the complaint and gives reasons for doing so;

The final response will also:
(a) encloses a copy of the Financial Ombudsman Service's standard explanatory leaflet;
(b) provides the website address of the Financial Ombudsman Service;
(c) informs the complainant that if he remains dissatisfied with the respondent's response, he may now refer his complaint to the Financial Ombudsman Service; and
(d) Inform the complainant that the firm does not have an agreement with an alternate dispute resolution provider (in the case of non-eligible complainants).

Where the firm can resolve an eligible complaints payment service user complaint within three business days, the firm will send the complainant a ‘summary resolution communication’, being a written communication from the respondent which:

● refers to the fact that the complainant has made a complaint and informs the complainant that the respondent now considers the complaint to have been resolved;
● tells the complainant that if he subsequently decides that he is dissatisfied with the resolution of the complaint they may be able to refer the complaint to the Financial Ombudsman Service;
● indicates whether or not the respondent consents to waive the relevant time limits in DISP 2.8.2R or DISP 2.8.7R (Was the complaint referred to the Financial Ombudsman Service in time?) by including the appropriate wording set out in DISP 1 Annex 3R;
● provides the website address of the Financial Ombudsman Service; and
● refers to the availability of further information on the website of the Financial Ombudsman Service.

Acceptance or Confirmation of Redress
Where any form of redress, compensation or offer is made to the client in order to settle the complaint, the Complaints Team will follow-up with the client within five working days of the final response being sent, to confirm with the client that the issue is resolved and that the client is agreeable to the outcome provided.

Where the client has replied, confirming acceptance of the offer or making their satisfaction of the resolution clear, this step is not needed.


Where Floodlight fails to resolve a client’s complaint within the 15 day time frame, or where the client feels that the complaint was not handled appropriately, (including cases where the complaint was not properly identified as a complaint), the client have the right to file a complaint to PayrNet if they believe that we provide our services improperly or our operations breach customers’ rights or legitimate interests. The filing of complaints and complaint handling process is free of charge at PayrNet.

PayrNet shall accept complaints submitted in person (directly to Customer Service employee, verbally or in writing), by regular or registered mail (sending it to PayrNet’s registered office or actual place of business), email (at the address complaints@payr.net) or through the digital channels provided by PayrNet’s online and mobile platforms.

Financial Ombudsman
Where Floodlight fails to resolve a client’s complaint within the 15 day time frame, or where the client feels that the complaint was not handled appropriately, (including cases where the complaint was not properly identified as a complaint), the client may be able to approach the Ombudsman directly for a resolution.

It should be noted that an individual is able to complain to the Ombudsman about the nature and handling of our complaints process, even where the original complaint is not eligible or relevant. The Ombudsman may find in favour of the client due to the poor handling of the complaint where we fail to identify it as a complaint.

It should be noted by all employees that a complaint handled by the Ombudsman can result in a punitive or monetary award to the client which may outweigh any revenue made on the trade, or any actual losses made by the client. This may include an award for:

1. financial loss (including consequential or prospective loss); or
2. pain and suffering; or
3. damage to reputation; or
4. distress or inconvenience.

The Ombudsman will also charge a fee of £550 for the handling of high volumes of complaints and may also require that Floodlight provides all relevant documents, call recordings and letters to the client resulting in a significant time cost to Floodlight in preparing a response.

It should also be noted, more importantly, that reputational damage to Floodlight may result where we are unable or unwilling to resolve complaints in a satisfactory way with our clients, or where a high volume of complaints is noted. Employees should try, wherever possible, to escalate complaints to the Compliance team for resolution as quickly as possible.

Contact information
Address: Financial Ombudsman Service, Exchange Tower, London, E14 9SR Phone : 0800 023 4567 or 0300 123 9123
Email: complaint.info@financial-ombudsman.org.uk
Website: financial-ombudsman.org.uk

Complaints’ Handling Policy

Ela Expeditions IE


This Policy outlines how Floodlight (which is the trading name of Ela Expeditions IE), (the “Company”) approach to complaints handling, to ensure client concerns are treated adequately and that complaints are addressed promptly and in a fair and transparent manner. It details the requirements to ensure full compliance with our regulatory obligations and the highest possible standards of customer service to which the Company is committed in order to accomplish the above and therefore, adopts a comprehensive Complaints’ Handling Policy.

This Policy is subject to the review and approval by the CEO.

The Company is being enrolled as a distributor of an Electronic Money Institution UAB “PAYRNET”, incorporated and registered in the Republic of Lithuania with company number 305264430, whose registered office is at Islandijos str. 6, 01117, Vilnius, Republic of Lithuania authorized by the Bank of Lithuania with a license number 72, authorisation number LB001994 (“Payrnet”). Accordingly, the Company is serving customers of Payrnet as its agent and may be addressed with customer complaints as a result of its agent activities.

This Policy sets out how the Company will comply with (i) the Law on Payments of the Republic of Lithuania; (ii) Law on Electronic Money Institutions of the Republic of Lithuania; and (iii) the Resolution of the Bank of Lithuania of 6 June 2013 "On the adoption of the rules for the handling of complaints by financial market participants", No. 03-105.


The objective of this Policy is to embed an effective and efficient complaints management process within the Company. This Policy sets out Company’s requirements to support the Company’s commitment in providing products and services of high quality, as well as responsible and efficient service to its customers.

The Company seeks to maintain a reputation as a company delivering high quality professional services which is committed to maintaining its responsiveness to the needs and concerns of our clients.

The Policy is designed to provide guidance on the way in which the Company receives and handles complaints.
The objective of the Policy is to outline how the Company resolves complaints in an efficient, effective and professional manner to ensure we maintain our reputation as a professional firm responsive to client needs and concerns.

Efficient management of complaints enables us to identify problems and continuously improve our standards, services, and delivery.


In this Policy, a complaint is defined as any written or oral expression of dissatisfaction in relation to the Company’s products and services or agreements concluded with the Company, addressed to any employee of the Company, claiming that the rights and / or legitimate interests of the person filing the complaint have been violated and asking for satisfaction of the claims.

Any person or organisation (the complainant) who is dissatisfied with a product or service provided by the Company or agreements concluded with the Company, for any reason, may contact the Company to complain. At times, complaints can be by way of negative feedback, which may not require a resolution or formal follow-up. While this type of feedback is valuable to the Company, the Policy does not apply to feedback of this nature.

Indicatively, the following can be a cause for complaint:
• Inconsistency of terms between pre-contractual information and the actual execution of a transaction; • Insufficient, incomplete or incorrect information of the customer and creation of false expectations;
• Possible errors in processing transactions or executing customer orders and other handling errors;
• Delays or lower than expected level of service;
• Disagreement over the legality of terms of transactions or contracts;
• Absence of professional behaviour of staff.

Adherence to this Policy

This Policy applies to all functions of the Company. All units of the Company must comply with the requirements outlined in this Policy. The Company has adopted an effective control framework to ensure compliance with this Policy and respective procedures.
The Policy should be reviewed at least on an annual basis by the CEO.


The Managing Directors are responsible to communicate the business strategies and expectations. The functions / employees involved in complaints management are responsible to act on the aforementioned expectations and their efforts should be led by enterprise governance and oversight.

The Operations function shall be responsible for the implementation of this Policy, in terms of resolving complaints occurring as part of the Company’s business activity. The Policy should be reviewed on an annual basis or more frequently, if required.

This Policy should be posted on the Company’s internal and private shared document space. This Policy or summary thereof, shall be posted on the Company’s website joinela.com.

The Managing Directors and Senior Management should continually convey the importance of resolving complaints proactively and nurture a corporate culture that encourages employees to treat each complaint as an opportunity for improvement. All the units and branches of the Company must be aware of and comply with the requirements outlined in this Policy.

Role of CEO

The CEO shall be the owner of this Policy. All inquiries and requests for revisions relating to any of the matters specified in the Policy should be addressed to the CEO.
The Policy is intended to be an evolving document. As the Company and its operations evolve, it is anticipated that existing policies may require amendment, and new policies will need to be introduced. The Policy should be reviewed on an annual basis or more frequently, if required, to ensure it is kept up to date. All amendments, additions or deletions to the Policy should be properly documented and approved prior to implementation.
Compliance issues and risk derived from complaints analysis should be factored into the overall Annual Compliance Report provided to the Managing Directors.
The CEO:

● Authorizes the complaints handling program and oversees appropriate adherence by the operations function

The Operations function
● Identify trends and focuses on regulatory requirements;
● Report key complaints findings to the Managing Directors, if required;
● Lead and / or contributes to remediation efforts;
● Track, reviews, and signoff on escalated complaints;
● Oversee and ensure delivery of complaint training suitable for business and operational activities throughout the organisation;
● Review and approves complaint staffing, processes, procedures;
● Review the Company’s responses to customers, when needed;
● Ensure the involvement of legal staff when deemed necessary depending on the nature of the complaint;
● Monitor the timely reaction of the Company to customers’ complaints / requests.


The Company must ensure that the following principles are followed when dealing with complaints:

● Human rights shall be respected, and principles of fairness, reasonableness, objectivity and impartiality shall always be followed when dealing with complaints;

● Complaints shall be handled by a sufficiently competent employee who was not involved in the subject of the complaint;
● The complaints’ handling process shall be reasonably documented, and the Company shall at all times be able to demonstrate the scope and contents of the investigation if needed;
● The Company must avoid any conflicts of interest when handling the complaints and shall take all necessary measures to identify and solve any conflicts of interest.

The following cases shall not be considered as complaints and this Policy shall not be applied to:

● Complaints concerning activity for the performance of which the Company is not responsible;
● Complaints concerning the Company’s activity which is not regulated by the financial services’ laws and is not supervised by the supervisory authority (i.e., is not related to the provision of financial services).

In case the Company is not responsible for the performance of the activity indicated in the complaint, the Company shall still respond to the client within 3 (three) business days by indicating reasons for a refusal to accept and examine the complaint, as well as, if possible, specifying the institution responsible for dealing with such complaint.

Filing of Complaints

The filling of complaints and complaint handling is free of charge at the Company. Complaints shall be filed in Lithuanian language or English language.

Complaints may be filed through any of the following channels:
● Live meeting or recorded phone conversation with the Company’s employee or other representative. Where a conversation is not recorded, the client shall be suggested to file the complaint in one of the other ways;
● E-mail: contact@floodlight.eu
● In writing by submitting a complaint directly to the Company’s employee or by sending it to the Company’s registered office by regular or registered mail.

The complaint shall include the following information:
● Name of the client;
● Client’s contact details;
● Date of the complaint;
● Dispute matter;
● Other circumstances related to the complaint.

The Company shall in each case confirm to the client the receipt of the complaint.

Registration of Complaints

Effective system of controls and structure are the foundation for the safe, sound and compliant operation of the Company and are critical to the effectiveness of any enterprise compliance management program. Complaint data shall be analysed to identify weaknesses in controls, compliance violations, and the need for enhanced targeted testing. Complaints shall be identified, categorised, and recorded to evidence the Company’s remediation efforts. The Company should determine the root causes of a complaint and remedy ineffective controls.

The Company shall dispose an IT solution to monitor the received complaints and the remediation actions. Ideally, this solution would proactively identify potential complaints through predictive analytics.

All complaints received by the Company (including those received orally) shall be registered in the complaints log. Complaints shall be registered on their receipt date or the first following business day if the complaint was submitted at a non-business day or after the Company’s working hours. Complaints shall be recorded on electronic registers / archives. For each complaint, at least the following information shall be stored on the complaints log:

● Name or legal name of the client;
● Address of the client indicated in the complaint or otherwise available to the Company;
● Date and manner of receipt of the complaint. In case of a recorded telephone conversation, the log shall give reference to the date and time of the call so that it was possible for the person assigned responsible for the handling of the complaint to access the relevant recording;
● Complaint registration number;
● Brief description of the substance of the complaint;
● Services or products complained about;
● Company’s employee appointed to handle the complaint;
● Date and for of the reply;
● Final result of the complaint investigation (resolution).

Registration of complaints in the complaints log and maintenance of the log shall be the responsibility of the Operations function. The log shall be maintained in electronic form.

Handling a Complaint

All complaints accepted by the Company shall be forwarded to a respondent, who will be responsible for the investigation of the complaints and preparation of the reply. Reply must be provided in a written form, i.e. in a paper form or any other durable medium (durable medium means a medium which allows the client to keep information addressed to them personally in a way so that for a certain period of time necessary for its use it could be accessed and recovered without modifications. For example, printed paper documents, USB keys, CD-ROMs, DVDs, memory cards or computer hard disks, e-mails.), where so agreed by the Company and the client.
In the investigation, the respondent has the following rights:

● To collect and assess all documents / information needed;
● Analyse the historical data related to the client;
● Communicate with the client and ask for additional information if needed;
● Consult with other Company’s employees or, if needed and approved by the Company’s CEO – external lawyers.

Once a complaint has been received by a respondent, it must:

1. Investigate the complaint competently, diligently and impartially, obtaining additional information as necessary;
2. Assess fairly, consistently, and promptly;
3. Offer redress or remedial action when it decides this is appropriate;
4. Explain to the complainant promptly and, in a way that is fair, clear and not misleading, its assessment of the complaint, its decision on it, and any offer of remedial action or redress; and
5. Comply promptly with any offer of remedial action or redress accepted by the complainant.

Reply to the client

In case a complaint is submitted, the respondent must:

1. Send a final response in writing or using durable medium to the complainant by the end of 15 business days after the day on which it received the complaint; or
2. In exceptional circumstances, if a final response cannot be given for reasons beyond the control of the respondent:
a. send a holding response to the complainant by the end of 15 business days after the day on which it received the complaint, clearly indicating the reasons for the delay in answering the complaint and specifying the deadline by which it will send the final response; and
b. send a final response to the complainant by the end of 35 business days after the day on which it received the complaint.

Reply must include:

1. The outcome of the investigation;
2. Where applicable, terms of the redress or remedial action;
3. Where the complaint is not solved to the satisfaction of the client, motives and reasons for refusal to satisfy the claim;
4. Further remedies available for the client.

Where the complaint is submitted by a consumer, the reply shall also inform the consumer that if they remain dissatisfied with the final response, they shall have a right to apply to Payrnet directly. If the outcome of the complaint is not satisfactory to the consumer, they have a right to afterwards apply to the Bank of Lithuania, in the official language of the country, i.e., Lithuanian. The consumers have the rights described under this clause also when Payrnet fails to respond to the consumer within 15 (fifteen) business days from receiving the complaint.

The Company shall provide the client with the following details of the Bank of Lithuania:

1. The official address of the Bank of Lithuania: Gedimino ave. 6, LT-01103 Vilnius, Lithuania;
2. Address for correspondence: Totorių str. 4, LT-01121 Vilnius, Lithuania, e-mail: info@lb.lt;
3. Address for submitting consumer claims: Žalgirio str. 90, LT-09303 Vilnius, Lithuania, e-mail: prieziura@lb.lt.

The address of the website of the Bank of Lithuania: https://www.lb.lt (or, more specifically, link to information about the Bank of Lithuania settling consumer disputes - https://www.lb.lt/en/dbc-settle-a- dispute-with-a-financial-service-provider).

The consumers may only apply to the Bank of Lithuania within 1 (one) year after they received from Payrnet a response that is not satisfactory to them, or after expiry of the 15 (fifteen) business days term for Payrnet to respond where Payrnet did not respond to the complaint.

Addressing the Company and Payrnet first is a precondition for the consumer applying to the Bank of Lithuania. The decision of the Bank of Lithuania is not mandatory for the Company, Payrnet and the consumer, and either party even after the dispute has been solved by the Bank of Lithuania, has a right to apply to the court.

In case of provision of the Company’s services in another EU Member State than the Republic of Lithuania, the clients which are not consumers have the right to submit their complaints via FIN-NET network (accessible: ps://ec.europa.eu/info/business-economy-euro/banking-and-finance/consumer-finance- and-payments/consumer-financial-services/financial-dispute-resolution-network-fin-net_en).

The client that is not a consumer may still approach the Bank of Lithuania by submitting a claim to the Bank of Lithuania at Totorių str. 4, 01121 Vilnius, e-mail: info@lb.lt, or to the Legal and Licensing of the Bank of Lithuania, Žalgirio str. 90, 09303 Vilnius, e-mail: prieziura@lb.lt.

The clients must be informed of their rights under this Section of the Policy by the Company publishing this Policy or summary thereof on its website, as well as by including relevant provisions in the agreements concluded with the clients. Information about the competence of the Bank of Lithuania to settle disputes between the Company (or Payrnet, as applicable) and the clients who are consumers, as well as the address of the Bank of Lithuania and the address of the website of the Bank of Lithuania shall also be provided on the website of the Company.

Below is a step-by-step procedure of handling of complaints:

1. A complaint is filled by a client through the available channels: orally, by telephone, by post, by e-mail

2. Distribution
The complaint is received by the Company’s employees categorised and distributed to the responsible unit based on its subject.
Complaints may be relevant to quality of products and services, transactions processing, company policies among others.

3. Research/ analysis
The responsible unit conduct investigation and root case analysis in order to identify the cause of the complaint.

4. Resolution/ response
The responsible unit resolve the underlined issue and inform the client regarding the result of the investigation and the final position of the Company within 15 days of the date the complaint was submitted to the Company.

5. Recording
All complaints and remedy actions are recorded and stored by the complaint unit in the complaints log. For each complaint, at least the following information shall be stored:

  • Name or legal name of the client; Address of the client; Date and manner of receipt of the complaint; Complaint registration number; Brief description of the substance of the complaint;
  • Services or products complained about;
  • Company’s employee appointed to handle the complaint;
  • Date and for of the reply;

6. Reporting
The Company shall keep a report on complaints received and submit such information to Payrnet upon request.

7. A complaint is filed by a client
The Company shall provide written responses to complainants within 15 business days following the date that the complaint has been received by the Company

If the customer (who is a consumer) remains dissatisfied with the final response of the Company, they shall have a right to apply to Payrnet directly. If the outcome of the complaint is not satisfactory to the consumer, they have a right to afterwards apply to the Bank of Lithuania. The consumers have the right to apply to the Bank of Lithuania also when Payrnet fails to respond to the consumer within 15 (fifteen) business days from receiving the complaint.

The client that is not a consumer may also approach the Bank of Lithuania by submitting a claim to the Bank of Lithuania directly.


Comprehensive policies, procedures, and training shall be established to ensure that all employees and third-party providers are aware of consumer protection laws and regulations and to deter or prevent compliance violations. The aforementioned policies, procedures, and training shall be routinely updated to incorporate new laws and regulations.

Operations function will be responsible for handling the complaints or at least monitor the actions of other responsible Units towards handling the complaints. All business units and employees shall be obligated to assist timely the Operations function regarding complaints within their field of expertise and responsibility.

The Company shall inform its customers on the established procedures and channels through which complaints may be filed, in accordance with the effective legal framework.

The frontline shall be trained sufficiently and follow specific guidelines regarding the types of complaints which need to be handled at the point of service and the types of complaints which need to be escalated to the CEO.

Specific procedures shall be created for complaints management, indicatively:

● Available channels for filing complaints;
● Recording of complaints and responsibilities of the Company’s employees;
● Distribution of complaints to the responsible unit(s);
● Internal actions and skills for performing checks and collecting evidence;
● Collaboration and coordination between the different units, engaged in the process of handling complaints;
● Consultation with CEO in view of response preparation;
● Involvement of legal staff, when needed;
● Preparation and timely response to customers that filed complaints;
● Remediation actions (if necessary);
● Communication with Payrnet on complaints handling procedures.

The complaints shall also be categorised according to the manner they were submitted (oral complaints, complaints over the phone, written complaints by post, written complaints by e-mail and complaints through lawyers, mediators, regulatory or official bodies), and their subject (quality of products and services, transactions processing, policies / practices).

In case the complaint regards the processing of personal data by the Company, or the customer exercises any right provided by the General Data Protection Regulation, the Company shall provide any response within one (1) month of the request receipt. That period may be extended by two (2) further months where necessary, taking into account the complexity and the requests volume. The Company shall inform the customer of any such extension within one (1) month of receipt of the request, together with the reasons for the delay.


The Company shall establish and maintain an internal single electronic database in which all complaints shall be recorded and kept under a unique tracking number.

The unique tracking number shall be referred to in all communication regarding the complaint from the financial institution to the complainant. All communication and other materials related to each complaint (including analysis and decisions taken by the Managing Directors relating to the elimination of the operational deficiencies identified in handling of complaints procedures) will be kept in the database for five (5) years.

All the accompanying documents and materials, if not part of the database itself, shall be kept with the database and shall be easily accessible when requested by an authorised staff of the Company.

Monitoring is a proactive approach to identify procedural or training weaknesses and reporting of issues is essential to maintaining an effective oversight. Emphasis should be laid on the preparation of reports analysing the causes of complaints so that they can be avoided in the future. Complaint data shall be tracked, analysed, and reported at least annually to communicate potential areas of concern or non- compliance to the Managing Directors and all business lines. Potential regulatory complaints shall be appropriately escalated and monitored. All critical elements of customer relationships shall be connected in complaint tracking, thus creating a more holistic view. For this purpose, a tool that tracks cases shall be developed or purchased, creating centricities between systems of records.

The Operations function shall monitor adherence to this Policy through regular monitoring and:

● Collect information on similar complaints relating to the same product or service, analyse this information in order to establish the main reasons of such complaints and priorities for elimination thereof;
● Assess if the circumstances giving rise to a certain type of complaints may also result in complaints relating to other services or products;
● Assess if reasons for the complaints can be eliminated and determine course of action for such elimination;
● Where applicable, eliminate the main reasons of the complaints being submitted, or initiate relevant processes for such elimination;
● Ensure that information on repetitive or systemic reasons of complaints are regularly provided to the management of the Company and Payrnet.

The Company shall collect the following information on the complaints received during a reporting period:

● Number of complaints received;
● Underlying causes of complaints;
● Products that complaints relate to;
● Information about similar complaints related to the particular services or products including systemic problems (information about the recurring or systemic reasons for the complaints);
● Other processes or products affected;
● Priority for corrective actions;
● Proposals for actions to be taken by the Company to eliminate underlying causes of complaints.

Having received and analysed the summary of information referred to above, the Managing Directors shall:

● Assess whether underlying causes of certain complaints may cause complaints related to other services or products;
● Assess whether the underlying causes of the complaints can be eliminated, and make decisions on the proposed methods to eliminate them;
● If necessary, initiate actions to eliminate established underlying causes of the complaints.

The Company shall inform Payrnet as soon as reasonably possible but in any event by close of business on the next business day, if it becomes aware of a complaint being made against the Company or Payrnet relating to the Company’s business.

A record of each complaint received must be kept and the measures taken for its resolution and retain that record for at least five (5) years from the date the complaint was submitted.