Complaints Procedure

HarveyBloom Advocaten Office Complaints Procedure

(pursuant to Article 6.28 of the Dutch Regulation on the Legal Profession)

Article 1

Definitions

For the purposes of this office complaints procedure:

• Complaint: any written expression of dissatisfaction by or on behalf of the client concerning the lawyer or persons working under the lawyer's responsibility, relating to the formation or performance of an engagement agreement, the quality of the services or the amount invoiced, other than a complaint as referred to in Part 4 of the Dutch Advocates Act;

• Complainant: the client or the client's representative who submits a complaint;

• Complaints officer: the lawyer responsible for handling the complaint.

Article 2

Scope

1. This office complaints procedure applies to every engagement agreement between HarveyBloom Advocaten and the client.

2. HarveyBloom Advocaten ensures that complaints are handled in accordance with the office complaints procedure.

Article 3

Objectives

The objectives of this office complaints procedure are:

1. To establish a procedure for handling clients' complaints constructively within a reasonable time;

2. To establish a procedure for determining the causes of clients' complaints;

3. To maintain and improve existing relationships through proper complaints handling;

4. To train employees to respond to complaints in a client-focused manner;

5. To improve the quality of services through complaints handling and analysis.

Article 4

Information at the start of the services

1. This office complaints procedure has been made publicly available. Before entering into the engagement agreement, the lawyer informs the client that the firm has an office complaints procedure and that it applies to the services provided.

2. HarveyBloom Advocaten has specified in its general terms and conditions the independent party or body to which a complaint that remains unresolved after being handled may be submitted for a binding decision, and has communicated this in the engagement confirmation.

3. Complaints as referred to in Article 1 of this office complaints procedure that remain unresolved after being handled by HarveyBloom Advocaten or subsequently by the independent party or body referred to in paragraph 2 of this article shall be submitted to the competent court in The Hague. The client and HarveyBloom Advocaten may agree that such complaints shall be resolved by binding advice or arbitration.

Article 5

Internal complaints procedure

1. If a client approaches the firm with a complaint, the complaint is referred to Ms M.K. de Menthon Bake, who thereby acts as the complaints officer. If the complaint concerns Ms M.K. de Menthon Bake, in whole or in part, the firm appoints another lawyer at HarveyBloom Advocaten as the complaints officer for that matter.

2. A complaint must be submitted within one calendar month after the client becomes aware of the fact giving rise to the complaint.

3. The complaints officer informs the person complained about that a complaint has been submitted and gives both the complainant and the person complained about an opportunity to explain their position regarding the complaint.

4. The person complained about seeks a solution together with the client, with or without the involvement of the complaints officer.

5. The complaints officer handles the complaint within four weeks of receipt or informs the complainant, with reasons, of any departure from that time limit and states the period within which a decision on the complaint will be given.

6. The complaints officer informs the complainant and the person complained about in writing of the decision on whether the complaint is well founded, with recommendations where applicable.

7. If the complaint has been resolved satisfactorily, the complainant, the complaints officer and the person complained about sign the decision on whether the complaint is well founded.

Article 6

Confidentiality and complaints handling free of charge

1. The complaints officer and the person complained about maintain confidentiality when handling the complaint.

2. The complainant is not required to pay any fee for the costs of handling the complaint.

Article 7

Responsibilities

1. The complaints officer is responsible for handling the complaint in a timely manner.

2. The person complained about keeps the complaints officer informed of any contact and any possible solution.

3. The complaints officer keeps the complainant informed about the handling of the complaint.

4. The complaints officer maintains the complaints file.

Article 8

Registration of complaints

1. The complaints officer records the complaint and the subject matter of the complaint.

2. A complaint may be classified under more than one subject.

3. The complaints officer periodically reports on the handling of complaints and makes recommendations to prevent new complaints and improve procedures.

4. The reports and recommendations are discussed within the firm and submitted for decision at least once a year.