Complaint Handling Policy

OUR COMMITMENT TO YOU: Bulgaria For Business is committed to delivering professional services of the highest quality to all clients. When things go wrong — or when a client feels they have not received the standard of service they are entitled to expect — we want to hear about it. We treat every complaint seriously, investigate it fairly and thoroughly, and use the findings to improve our services. This policy explains exactly how we handle complaints, what you can expect from us, and what to do if you remain unsatisfied after our response.

1. Purpose of this policy

This Complaint Handling Policy sets out the procedure by which Bulgaria For Business receives, acknowledges, investigates, and resolves complaints from clients and other affected parties in relation to our professional services and conduct.

Our objectives in handling complaints are to:

• resolve complaints quickly, fairly, and consistently;
• treat every complainant with courtesy and respect;
• provide clear, written explanations of our findings and any steps we are taking to address a complaint;
• identify and address any systemic failures that give rise to complaints;
• continuously improve our services based on complaint insights;
• ensure that making a complaint does not adversely affect the complainant’s relationship with Bulgaria For Business or the standard of service they receive.

2. What is a complaint?

A complaint is any expression of dissatisfaction — whether written or verbal — about the services provided by Bulgaria For Business, the conduct of any member of our team, our billing practices, our communication standards, or any other aspect of our relationship with a client or affected party.

A complaint is distinguished from:

• a service enquiry — a request for information, clarification, or status update, which is handled through our normal client communication channels;
• a fee dispute raised as part of normal billing correspondence — which may be handled separately under our billing terms but can be escalated as a complaint if not resolved;
• a request for a change in the scope of services — which is addressed through a variation of the service engagement.

If you are not sure whether your concern constitutes a complaint under this policy, please submit it in writing — we will assess it and respond under this procedure in any event.

3. How to submit a complaint

3.1 Preferred channel

Complaints should be submitted in writing to ensure they are correctly recorded, acknowledged, and tracked. The preferred method is by email to:

3.2 What to include

To allow us to investigate your complaint as quickly and effectively as possible, please include the following information in your complaint:

• Your full name and contact details (email address and telephone number).
• Your client reference number or the name and date of the matter to which the complaint relates (if known).
• A clear description of the nature of your complaint — what happened, when it happened, and which member of our team or which service area it relates to.
• What outcome you are seeking — for example, an explanation, an apology, a correction of work, a fee adjustment, or another specific remedy.
• Copies of any relevant documents, correspondence, or evidence that supports your complaint.

3.3 Verbal complaints

Where a complaint is made verbally — by telephone or in person — the member of staff receiving the complaint will:

• listen carefully and courteously to the full concern;
• make a written record of the complaint immediately;
• if the complaint can be resolved immediately and to the complainant’s satisfaction, seek to do so — and confirm the resolution in writing;
• if the complaint cannot be resolved immediately, advise the complainant that it will be handled under this formal policy and ask them to confirm the complaint in writing.

We encourage complainants to follow up a verbal complaint in writing to ensure accuracy of the record.

4. Complaint handling process — overview

Our complaint handling process follows five stages — from submission through to resolution or escalation.

5. Detailed complaint handling procedure

5.1 Stage 1 — Acknowledgement

On receipt of a written complaint, Bulgaria For Business will:

• send a written acknowledgement within 2 business days confirming that the complaint has been received;
• assign a unique complaint reference number;
• confirm the name and contact details of the person who will be handling the complaint;
• provide an indication of the expected timeline for our response, in accordance with this policy.

5.2 Stage 2 — Initial assessment

Within 5 business days of receipt, the complaint handler will:

• review the complaint and all supporting information;
• assess whether the complaint can be resolved quickly — for example, where the matter involves a straightforward factual error or a miscommunication;
• identify the relevant service area, matter, and personnel involved;
• determine whether any immediate steps are required to prevent further detriment to the complainant (for example, pausing a service activity pending investigation);
• notify the relevant colleagues of the complaint in terms that allow them to respond without compromising the independence of the investigation.

5.3 Stage 3 — Investigation

Where the complaint cannot be resolved at the initial assessment stage, a full investigation is conducted. The investigation:

• is carried out by a senior member of staff who was not directly involved in the subject matter of the complaint — to ensure independence and objectivity;
• involves a review of all relevant files, correspondence, records, and documents;
• may include a request to the complainant for additional information or clarification;
• may involve discussion with the staff members involved in the matter — while maintaining fairness to all parties;
• is documented in an investigation file which records all steps taken, information reviewed, and findings reached.

All parties — the complainant and the staff members involved — are entitled to be treated fairly and to have their perspective considered during the investigation.

5.4 Stage 4 — Final response

On completion of the investigation, a written final response is prepared and sent to the complainant. The final response:

• confirms whether the complaint has been upheld (in full or in part) or not upheld;
• provides a clear explanation of the findings and the reasoning — without use of technical jargon wherever possible;
• where the complaint is upheld, explains what action we are taking or will take to address the matter — which may include an apology, a correction of work, a fee adjustment, or another appropriate remedy;
• where the complaint is not upheld, explains why — with reference to the facts and the applicable professional standards;
• informs the complainant of their right to escalate the matter if they are not satisfied with the response.

5.5 Stage 5 — Escalation and review

If the complainant is not satisfied with the final response, they may request a senior management review. This request should be made within 20 business days of receiving the final response and should explain why the complainant is not satisfied and what outcome they are seeking.

On receiving an escalation request, senior management will:

• review the original complaint, the investigation findings, and the final response independently;
• consider whether the investigation was conducted fairly and in accordance with this policy;
• respond in writing within 10 business days of receiving the escalation request — either confirming the original finding or revising it.

6. Response timelines

The table below summarises the response timeframes applicable at each stage of the complaint handling process. All timeframes are expressed in business days (Monday to Friday, excluding Bulgarian public holidays).

7. Remedies available

Where a complaint is upheld — in full or in part — Bulgaria For Business will consider what remedy is appropriate in the circumstances. Available remedies include:

• Apology — a formal written apology acknowledging that the standard of service fell below what was reasonably expected.
• Explanation — a clear and detailed written explanation of what went wrong and why, where the complainant’s primary concern is to understand what happened.
• Correction of work — where a service deliverable contained an error or omission, re-performing or correcting that work at no additional charge.
• Fee adjustment or refund — where a fee was charged for work that was deficient or for which an error on our part is acknowledged, a partial or full fee adjustment or refund.
• Service improvement commitment — a specific commitment to change an internal process, communication practice, or service standard to prevent recurrence.
• Combination of the above — where the circumstances warrant multiple remedies.

The remedy offered will be proportionate to the nature and severity of the complaint. Bulgaria For Business does not offer ex gratia payments or compensation for consequential losses as a standard remedy under this policy — but we will consider each complaint on its merits and apply professional judgement in determining what is fair.

8. Confidentiality and data protection

All complaints and complaint-related correspondence are treated as confidential. Information about a complaint is shared within Bulgaria For Business only on a need-to-know basis — limited to those involved in investigating and resolving the complaint, and to senior management where required.

Personal data collected in connection with a complaint is processed in accordance with our Privacy Policy and the GDPR. Complaint records are retained for 5 years from the date of final resolution. Complainants have the right to access their complaint file and to exercise other data subject rights as set out in our Privacy Policy.

9. Fairness and non-retaliation

Bulgaria For Business is committed to handling every complaint fairly — to both the complainant and the staff members involved. The person investigating the complaint will approach the matter with an open mind and will consider all relevant evidence before reaching a conclusion.

Making a complaint will not:

• affect the standard of service you receive from Bulgaria For Business;
• result in any adverse treatment of you as a client;
• affect any ongoing service engagement except where a pause in service is necessary to protect one or both parties during the investigation.

Staff members who are the subject of a complaint are entitled to:

• be informed of the complaint in appropriate terms;
• have their perspective considered during the investigation;
• receive a fair and proportionate assessment of their conduct;
• be supported by Bulgaria For Business management throughout the process.

10. Learning and continuous improvement

Bulgaria For Business regards complaints as a valuable source of feedback about the quality of our services and the experience of our clients. All complaints — whether upheld or not — are recorded and analysed to identify:

• recurring themes or patterns that may indicate a systemic problem;
• service areas, processes, or communication practices that require improvement;
• training needs for individual staff members or the team as a whole;
• changes to our engagement terms, service standards, or client communication procedures.

The MLRO / Compliance Officer reviews complaint data at least annually and presents a summary to senior management, including: the number of complaints received; the categories and subject matters; the proportion upheld; the remedies provided; and the improvements made in response. This review informs our quality assurance and professional development programmes.

11. External escalation options

11.1 Supervisory authority — data protection complaints

Where a complaint relates to the processing of your personal data, you may — if you are not satisfied with our response — lodge a complaint with the Bulgarian Commission for Personal Data Protection (Комисия за защита на личните данни — КЗЛД):

11.2 Professional regulatory complaints

Where a complaint relates to the professional conduct of Bulgaria For Business in connection with legal, accounting, or other regulated professional services, you may refer the matter to the relevant Bulgarian professional regulatory body — for example:

• Legal services — the Supreme Bar Council of Bulgaria (Висш адвокатски съвет) where the services were provided by a registered Bulgarian advocate.
• Accounting and audit services — the Institute of Certified Public Accountants of Bulgaria (Институт на дипломираните експерт-счетоводители — ИДЕС) where the services were provided by a registered certified public accountant.

11.3 General consumer / commercial disputes

For complaints about commercial services that cannot be resolved through this procedure, the Bulgarian courts and the general civil dispute resolution framework are available. Bulgaria For Business does not participate in any external alternative dispute resolution (ADR) scheme other than those specified above — but we remain open to mediation on a case-by-case basis where both parties agree that it would be helpful.

12. Unreasonable and vexatious complaints

Bulgaria For Business is committed to handling all complaints seriously and professionally. However, we reserve the right to determine that a complaint — or the manner in which it is being pursued — is unreasonable or vexatious. This determination will be made by senior management and is based on objective criteria, not on the subject matter of the complaint or the complainant’s identity.

A complaint or complaint behaviour may be considered unreasonable or vexatious where:

• it is an exact repeat of a complaint that has already been fully investigated and responded to — without any new information being provided;
• the complainant is persistently making contact in a way that is disproportionate to the matter concerned — for example, multiple contacts per day for minor matters;
• the complaint or the complainant’s behaviour is abusive, threatening, or intimidating to Bulgaria For Business staff;
• the complainant refuses to engage with the investigation process or to provide information requested by the complaint handler;
• the complaint appears designed to disrupt our business rather than to seek a genuine remedy.

Where a complaint is determined to be unreasonable or vexatious, Bulgaria For Business will write to the complainant explaining why this determination has been made and confirming that it will not investigate the matter further unless significant new information is provided.

13. Policy review

This Complaint Handling Policy is reviewed annually by senior management and updated as required to reflect changes in applicable law, regulatory guidance, professional standards, or our internal processes. The current version of this policy is always available at www.bulgaria-for-business.com/complaint-handling-policy.

This Complaint Handling Policy was last reviewed and updated in January 2025. It applies to all professional services provided by Bulgaria For Business. This document does not constitute legal advice. If you have a complaint, please contact us at complaints@bulgaria-for-business.com.