Rules for filing a complaint

These rules regulate the acceptance, registration, organization, processing, and review by "EOS Matrix" EAD (hereinafter referred to as "the Company") of received complaints from borrowers and also determine the terms and procedure for maintaining a register of received complaints.

Art. 1. The provisions of these rules establish the following objectives:

1. Ensuring legality and improving the quality of services;
2. Guaranteeing the right of borrowers to free submission and review of their complaints related to the activities of the Company;
3. Creating and maintaining an organization for processing and administering complaints, which ensures fair, timely, and proper review of complaints submitted by borrowers regarding violations;
4. Increasing public trust;
5. Increasing efficiency in preventing and eliminating violations in the Company's activities;
6. Creating guarantees for transparency and accountability in the Company's activities, as well as the possibility for control over it by borrowers, the Company, the Bulgarian National Bank, and other control bodies.

Art. 2. (1) These rules apply to all complaints from borrowers. To bring them to the attention of employees, borrowers, and third parties, the rules are provided in the Company's premises in a visible place and are also published on the Company's website.

(2) For the purposes of these rules, a "borrower" is any natural or legal person against whom the Company has a monetary claim arising from a credit acquired based on a contract for the transfer of claims, respectively a loan granted by a credit or financial institution established and operating in the Republic of Bulgaria, as well as any person representing a borrower within the meaning of the Credit Servicers and Credit Purchasers Act (CSCPA).

Art. 3. These rules comply with the requirements of the CSCPA, the legislation on consumer protection, the legislation on personal data protection, as well as other relevant legal acts and sub-legal acts normative acts applicable to the Company's activities.

Art. 4. The main principles that are observed in the implementation of these rules are:

1. Guaranteeing the rights of borrowers and creating effective mechanisms for their protection and management;
2. Rule of law to ensure the effective protection of human rights and the equality of all citizens before the law;
3. Fair and ethical treatment of borrowers, including regarding their financial situation, and when necessary – directing them to consultations regarding the protection of their rights or to social services.
4. Good management and taking effective actions upon detection of violations;
5. Comprehensive review and fair and effective resolution of disputes between borrowers and the Company;
6. Ensuring a procedure for submitting and reviewing complaints that is free of charge for the borrower, regardless of the decision on them.

Art. 5. When reviewing and administering complaints, the Company's employees, designated to organize the activity on received complaints, are guided by the principles of independence, objectivity, competence, responsibility, integrity, and confidentiality.

Art. 6. Every borrower has the right to submit a complaint free of charge, personally or through an agent authorized on the basis of a written power of attorney, to the Company's registered address located at Sofia, P.O. Box 1766, Mladost district, Mladost IV residential complex, 1 Business Park Sofia Blvd., Block 15, Entrance A, Floor 4, or to the following email address: [email protected]. Information about the addresses specified in the previous sentence is placed in an accessible place on the Company's website, as well as in a visible place in the Company's premises.

Art. 7. In the cases provided for by law, a complaint and any other documents (applications, claim forms, objections, etc.) can be directly addressed to the competent supervisory authorities in the Republic of Bulgaria, including the Bulgarian National Bank, the Consumer Protection Commission, and the Commission for Personal Data Protection, the courts, etc. Regardless, any borrower may file a complaint with the Company against any action or inaction, performed, respectively not performed, within the framework of the relationship between that borrower and the Company.

Art. 8. The Company and its employees do not have the right to refuse the acceptance of complaints that meet the requirements specified below.

Art. 9. The complaint is submitted in writing, in free text, in Bulgarian, and should contain at least the following information:

1. Identification data of the borrower (full names, Personal Identification Number/Personal Number of a Foreigner, identity document number, Unified Identification Code, similar data for foreign persons);
2. Address for correspondence (postal or electronic), and at the borrower's discretion - also a contact telephone number;
3. Statement of the case, description of the circumstances, actions, and omissions against which the complaint is filed, as well as a formulated specific request/proposal to the Company;
4. List of documents attached to the complaint, if any;
5. Signature of the person submitting the complaint, their legal representative, or proxy.

Art. 10. Failure to comply with the above-mentioned requisites does not lead to the inadmissibility of the complaint. When sufficient data for contact with the borrower is not provided, but the identity of the borrower and the alleged violation are established from the complaint, the response to the complaint is recorded in the register of received complaints and is left at the disposal of the borrower, who can receive the prepared response upon request in the Company's premises. Complaints that are not written or are submitted by an anonymous sender are not considered.

Art. 11. After receiving a complaint, an employee from the "Back Office and Archive" department, responsible for receiving correspondence and recording documents addressed to the Company, records the complaint in the Company's electronic document management system, and:

1. Describes the circumstances of the complaint, scans it together with the attachments to it, if any, and makes an entry in an electronic register containing information for all complaints addressed to the Company;
2. Determines the category of the complaint or, in case of difficulty, sends it to the employees from the "Legal" department and the "Risk Management and Compliance" department, who determine the category and the competent functional unit for review;
3. Sends the complaint for review through the Company's electronic document management system.

Art. 12. Received complaints are registered in the Company's document management system on the day of their receipt, with a registration number and date being placed on the document. Anonymous complaints are not registered and are not reviewed by the Company.

Art. 13. Received complaints are distributed for review by the relevant functional unit of the Company, depending on the subject matter of the complaint. The distribution is carried out in the shortest reasonable time.

Art. 14. When the submitted complaint contains allegations that the Company has violated the legislation regarding personal data protection, it is directed to the "Risk Management and Compliance" department and the Data protection officer.

Art. 15. In all other cases, complaints are directed to the employees from the "Legal" department.

Art. 16. At their discretion, the Executive Director and/or the Chairman of the Board of Directors of the Company may assign inspections and investigations on submitted complaints to be carried out by specifically appointed employees.

Art. 17. An employee from the respective responsible unit or department in the Company conducts the necessary investigations and checks on the complaint, after which prepares a reasoned proposal for a response in clear and understandable language, together with all attachments to the prepared response. The reasoned proposal is provided for coordination with the head of the "Legal" department, the head of the "Risk Management and Regulatory Compliance" department, or the data protection officer, respectively their designated deputies.

Art. 18. If it is necessary to present additional information, documents, or other evidence, the relevant employee from the responsible unit or department, to whom the review of the complaint has been assigned, may request them from the borrower, as well as from other units of the Company, indicating a deadline for their submission.

Art. 19. After coordination with the "Legal" department, respectively the "Risk Management and Regulatory Compliance" department and/or the Data protection officer, the response with the result of the conducted inspection and the measures taken is reflected in the document management system, issued, and sent to the borrower at the postal and email address indicated in the complaint.

Art. 20. When several complaints have been filed for the same alleged violation, the Company may review these complaints jointly and provide them with a common response. In case of re-submission of a complaint for the same violation, the Company provides the borrower with information about the response to the previous complaint.

Art. 21. The "Back Office and Archive" department maintains an electronic register of all responses to complaints from borrowers.

Art. 22. The "Back Office and Archive" department maintains a report for each received complaint, creating an electronic file that contains scanned copies of the complaint and all attachments to it, of all collected and/or created documents on the case, including the prepared and sent response. The documents from the electronic file are stored in the Company's information system.

Art. 23. A response to a received complaint is prepared and sent no later than:

1. Seven business days from its receipt by the Company – for complaints received through the Bulgarian National Bank or the Consumer Protection Commission, unless a shorter deadline is specified by the supervisory authority in the cover letter;
2. One month from its receipt by the Company – for complaints addressed directly to the Company, unless a shorter deadline is specified in a normative act.

(2) Except in cases where a legal act provides for the provision of a response within a deadline that cannot be extended, the deadline begins to run after the receipt of the last document on the case, if additional documents have been requested according to Art. 18 of the present Rules, respectively after the expiration of the deadline for submitting such documents, if they have not been provided by the borrower. In any case, the deadline for providing a response cannot be extended by more than one month.

Art. 24. All complaints are recorded in a special electronic register, maintained in an electronic system that ensures full traceability from the receipt of the complaint to the sending of the response to it. The register also contains data on additional information regarding the complaint, received after the sending of the response.

Art. 25. The register for received complaints contains the following information:

1. Unique number and date of receipt of the complaint;
2. Data for the borrower, according to what is indicated by the borrower in fulfillment of Art. 9, item 1 and item 2 of these rules;
3. Subject of the complaint and summarized content of the allegations and requests;
4. Date and outgoing number of the response;
5. Brief description of the measures taken, in case the need to take such measures has been established;
6. Information about the archiving of the file on the complaint.

Art. 26. The register for received complaints is maintained and stored by the employees designated for this in the "Back Office and Archive" department.

Art. 27. At the end of each calendar year, the employees from the "Legal" department and the "Risk Management and Regulatory Compliance" department carry out an analysis of the received complaints, and the head of the "Legal" department and the head of the "Risk Management and Regulatory Compliance" prepare an annual report on the received complaints and the responses to them and, if necessary, propose to the Board of Directors measures to improve the Company's activities and to eliminate the identified omissions and/or violations, when there are such.

Art. 28. The analysis procedure aims to summarize complaints that are submitted by borrowers for a certain period of time, and also to create conditions for an objective, competent, and independent re-examination of the actions performed by employees of the Company regarding the manner of reviewing the complaints.

Art. 29. The scope of the analysis includes verification and assessment of:

1. Compliance with legal requirements when carrying out the Company's activities;
2. Compliance with the internal rules applicable in the Company, including those for protection, fair and ethical treatment of borrowers, for personal data protection, and for consumer protection;
3. Maintaining an up-to-date state of information systems in order to ensure continuity of activity and timeliness of decisions.

§ 1. Regarding complaints related to personal data protection, these rules apply subsidiarily and only to the extent that they do not contradict the rules and procedures for processing requests, notifications, applications, and complaints received from data subjects, created in the Company in implementation of Regulation (EU) 2016/679 of the European Parliament and of the Council and of the Law on Personal Data Protection.

§ 2. Amendment and supplementation of these rules shall be carried out in the order of their adoption.

§ 3. These rules are reviewed at least once a year and are amended in a timely manner when necessary, by a decision of the Board of Directors upon the proposal of the heads of the "Legal" department or the "Risk Management and Regulatory Compliance" department.

§ 4. These rules were adopted on 15/12/2025 by the Board of Directors of the Company.