1. Definitions

In this complaints procedure, the following terms will have the following meanings:

• Complaint: any written expression of dissatisfaction by or on behalf of a client towards an attorney or persons working under an attorney’s responsibility about the conclusion or performance of a contract for services, the quality of the services or the amount of the invoice, other than a complaint referred to in Section 4 of the Dutch Counsel Act (Advocatenwet);
• Complainant: the client or its representative which expresses a complaint;
• Complaints officer: the attorney responsible for dealing with the complaint.

2. Scope

1. This complaints procedure will apply to every contract for services between Project Moore and the client.
2. Every attorney in Project Moore will respond to complaints in accordance with this complaints procedure.

3. Objectives

The objectives of this complaints procedure are to:

1. establish a procedure for constructively dealing with clients’ complaints within a reasonable period of time;
2. establish a procedure for determining the causes of clients’ complaints;
3. maintain and improve existing relationships by correctly dealing with complaints;
4. train employees to respond to complaints with the client’s needs in mind;
5. improve the quality of the services.

4. Information at the start of the services

1. This complaints procedure has been published at www.projectmoore.com. Before entering into a contract for services, the attorney will inform the client that the firm has a complaints procedure which applies to the services.
2. Complaints which have been taken up, but not resolved, will be submitted to the District Court of Amsterdam, the Netherlands.

5. Internal procedure

1. If a client approaches the firm with a complaint, the complaint will be forwarded to C. G.A.J van Seeters, who will act as the complaints officer.
2. The complaints officer will provide notice of the complaint to the attorney to whom the complaint relates and will give the client and the attorney an opportunity to provide an explanation.
3. The attorney will try to find a solution together with the client, before or after the complaints officer has been consulted.
4. The complaints officer will assess the complaint within one month after receiving it, or will, stating reasons, inform the client that this time period will be deviated from, specifying the period within which a decision on the complaint will be rendered.
5. The complaints officer will provide written notice to the client and attorney concerned of the decision regarding the merits of the complaint, possibly accompanied by recommendations.
6. If the complaint has been resolved satisfactorily, the client, the complaints officer and the attorney concerned will sign the written decision.

6. Confidentiality and no handling fee

1. The complaints officer and the attorney to whom the complaint relates will handle the complaint confidentially.
2. The client will not owe any fee for the costs of handling the complaint.

7. Responsibilities

1. The complaints officer will be responsible for handling the complaint in a timely manner.
2. The attorney to whom the complaint relates will keep the complaints officer informed of his/her contacts with the client and of any possible resolution.
3. The complaints officer will keep the client informed of the handling of the complaint.
4. The complaints officer will maintain the complaint file.

8. Complaint registration

1. The complaints officer will record the complaint, specifying the subject matter.
2. A complaint can be divided into several topics.
3. The complaints officer will periodically report on how the complaints have been handled and will make recommendations for preventing new complaints and improving procedures.
4. At least once a year, the reports and recommendations will be discussed within Project Moore and submitted for decision-making.