Our complaints policy
1. Purpose and objectives
1.1. Objectives and goals
The Complaints Policy is designed to promote transparent and efficient procedures for the handling and processing of any complaints received by Íslandsbanki hf. (hereafter referred to as the Bank) from its Customers (defined as both individuals and legal entities). The Policy covers any business conducted with previous, current, or future Customers.
The Bank’s goal is to ensure effective communication with its Customers and that complaints, recommendations and other similar issues are dealt with in a prompt, efficient, objective, and fair manner.
1.2. Legal background
This Policy is set based on Article 6. of Act No. 1001/2018 on the Regulation on normal and healthy business practices of financial entities, paying bodies, and electronic money entities, Article 19 of Act No. 161/2002 on Financial Undertakings, Article 9 of Regulation No. 995/2007 on Investor Protection and the Business Conduct of Financial Undertakings and Article 26 of Act No. 108/2007 on Securities Transactions and Articles.
2. Registration and communication methods
A complaint under this Policy refers to any complaints made to the Bank pertaining to e.g. dissatisfaction with services, handling of cases or business relationships.
Complaints should generally be submitted in writing and can be conveyed via email, mail or submitted electronically via the Bank’s website.
The Customer can submit a complaint free of charge.
Each complaint shall be centrally stored by the employee who received the complaint, in accordance with the applicable procedure, see article 7. The Bank holds a register of complaints and their handling, for a minimum period of 5 years.
All processing of personal data shall be done on a fair, reasonable and lawful ground and in accordance with the Bank‘s data processing policy.
3. Complaints Process
All complaints are processed by the Bank. If the Bank believes that a complaint does not warrant a response, then a substantiated answer shall be given as to why. Receipt of the complaint shall be confirmed by the Bank and either answered in the way it was received or by letter, within a period of four weeks
If the Bank is unable to respond to the complaint within the set period, then an explanation shall be given to the Customer and a response date given.
All relevant data and necessary information shall be obtained by the Bank for the purposes of assessing the complaint in an objective manner, based on the law and available information.
If a complaint is considered vague and it is not clear how the Bank should respond, the employee receiving the complaint shall request further detail from the customer in order to process the complaint.
Complaints shall be processed by the division responsible for the matter. The responsible division shall follow through with the complaint until the matter is considered resolved.
All responses and any communication with Customers shall be clear and non-discriminatory. If a complaint is deemed to be unwarranted, then the Bank shall give written justification. The Customer shall also be informed of any rights and/or remedies.
The Bank reserves the right to ignore any unnecessary complaints or communication that involve threats against employees or their families. Serious or repeated threats may result in the Bank bringing charges against the Customer.
4. Rulings and legal remedies
If a Customer believes that their complaint has not been resolved in accordance with the law and the Bank's regulations, then he/she can contact the Ombudsman.
Individuals can contact the Bank‘s Data Privacy Officer regarding any issues relating to processing of their personal data and information on rights and/or remedies according to data privacy law.
Customers can refer their dispute to the Complaints Committee on Transactions with Financial Firms under the Financial Supervisory Authority. Information on other remedies within the Bank, as well as administrative and legal remedies, is provided on the Bank's website.
5. Processing and follow-up
Warranted complaints shall be assessed as to whether they are an isolated incident or if remedial action is needed to prevent any recurrence and where appropriate, changes shall be made to procedures within the Bank. The results of this assessment shall be saved alongside the complaint data according to Article 2. If improvements are required, then appropriate measures shall be taken.
6. Monitoring
6.1. Monitoring implementation and disclosure
Risk Management monitors the implementation of this policy. It informs the Operations and Security Committee (RÖN), the Risk Policy Committee and the Board about the status and handling of complaints.
6.2. Complaints about investment and additional services
Compliance is responsible for analyzing complaints concerning investment and additional services provided by the Bank and supervises their follow-up and treatment within the Bank.
Compliance shall regularly assess and analyse the handling of complaints regarding investment and additional services and inform RÖN. It shall also, in consultation with risk management, evaluate possible operational risks connected with the issue.
7. Review and procedures
This policy is approved by the Bank's Board of Directors and shall be reviewed every two years.
Íslandsbanki sets further rules of procedure for handling complaints and grievances.
This document is a translation of the Icelandic version of the policy. In case of discrepancy between the documents, the Icelandic version prevails.