COMPLAINTS PROCEDURE

1 COMPLAINT

In this complaints procedure:

1. "Complaint" means any written expression of dissatisfaction by or on behalf of: (a) a client towards an attorney (advocaat) or a person working under an attorney's responsibility and concerning how a request for services has been dealt with, the quality of services or the amount invoiced, or (b) a counterparty of a client (a "Counterparty") concerning the performance or offering of extrajudicial collection work in accordance with the Debt Collection Services Quality Act (Wet kwaliteit incassodienstverlening), other than a complaint as referred to in Article 4 Attorneys Act (Advocatenwet). The Complaint can be submitted by email for the attention of the Complaints Officer to complaintsofficer@debrauw.com;
2. "Complainant" means the client or the Counterparty, including the representative filing a Complaint on behalf of the client or the Counterparty;
3. "Complaints Officer" means the attorney responsible for handling the Complaint.

2 SCOPE

2.1 This complaints procedure applies to all services provided to clients by one or more attorneys at De Brauw Blackstone Westbroek N.V. ("De Brauw").

2.2 Complaints with respect to De Brauw's performing or providing extrajudicial collection work in accordance with the Debt Collection Services Quality Act also fall under the scope of this complaints procedure.

2.3 Every attorney at De Brauw will respond to Complaints in accordance with this complaints procedure.

3 PURPOSE

The purpose of this complaints procedure is to:

(a) establish a procedure for constructively dealing with a Complaint within a reasonable period of time;

(b) establish a procedure for determining the cause of a Complaint;

(c) maintain and improve existing relationships by correctly dealing with Complaints;

(d) train employees to respond to Complaints with the Complainant's needs in mind; and

(e) improve the quality of services.

4 INFORMATION AT THE START OF SERVICES

4.1 This complaints procedure can be viewed on De Brauw's website at www.debrauw.com/legal-information. Before providing services to a client or while performing or offering extrajudicial collection work for a Counterparty, the attorney will inform the client or Counterparty that De Brauw has a complaints procedure which applies to the services.

4.2 Complaints that have been dealt with but not resolved will be submitted to the Amsterdam District Court, the Netherlands.

5 INTERNAL PROCEDURE

5.1 Every Complaint will be passed on to an attorney (who is not the attorney the Complaint relates to) selected by De Brauw as Complaints Officer.

5.2 The Complaints Officer will inform the attorney who the Complaint relates to of the Complaint and gives the Complainant and the attorney the opportunity to provide an explanation.

5.3 The receipt of a Complaint from a Counterparty with respect to De Brauw's performing or providing extrajudicial collection work will be confirmed in writing by the Complaints Officer (or a person appointed by the Complaints Officer) to the Complainant within two business days.

5.4 The attorney will try to find a solution together with the Complainant, before or after the Complaints Officer's intervention.

5.5 The Complaints Officer will assess the Complaint within four weeks after receiving the Complaint. If this deadline is not met, the Complaints Officer will inform the Complainant of this and explain the reasons. The Complaints Officer will also specify a new deadline for assessing the complaint.

5.6 The Complaints Officer will send a letter to the Complainant and the attorney setting out the Complaint's Officer's view as to whether the Complaint was justified, and the Complaints Officer may make recommendations.

5.7 If the Complaint has been resolved to everyone's satisfaction, the Complainant, the Complaints Officer and the attorney concerned sign the letter.

6 CONFIDENTIALITY AND NO HANDLING FEE

6.1 The Complaints Officer and the attorney who the Complaint relates to must observe confidentiality while dealing with the Complaint.

6.2 The Complainant does not owe any fee for the handling of the Complaint.

7 DUTIES

7.1 The Complaints Officer is responsible for the timely resolution of the Complaint.

7.2 The attorney who the complaint relates to will keep the Complaints Officer informed of the attorney's contacts with the Complainant and of any possible solution.

7.3 The Complaints Officer will keep the Complainant informed of the handling of the Complaint.

7.4 The Complaints Officer will keep the complaint file up to date.

8 COMPLAINTS RECORD

8.1 The Complaints Officer will file the Complaint, specifying the subject matter.

8.2 A Complaint can be divided into several subject matters.

8.3 The Complaints Officer will periodically report on how Complaints are handled and make recommendations for preventing new Complaints and improving procedures.

8.4 At least once a year, the Complaints Officer's reports and recommendations will be discussed and submitted for decision-making within De Brauw.