1. PURPOSE AND SCOPE OF APPLICATION

This procedure deals with the processing and resolution of complaints and claims from users of SILVIO ANGELINI DI SANTE’s services, under its registered trademark silvioangelini.com. It was prepared by SILVIO ANGELINI DI SANTE to respond to the provisions of Article 35 of Law 5/2019 of March 15, regulating real estate credit contracts.

2. CONSIDERATION OF A COMPLAINT OR CLAIM

A complaint is understood to be a protest regarding the operation of the services provided to users by Silvioangelini.com and filed based on delays, neglect, or any other type of action observed in the company’s operation without requesting the restitution of their interests or rights. A claim is understood to be a protest filed by users of services provided by Silvioangelini.com who, with the aim of obtaining restitution of their interests or rights, reveal specific facts related to actions or omissions by the company that constitute harm to the person making the complaint’s interests or rights.

3. PERSONS ENTITLED TO FILE A CLAIM

All users of the services provided by silvioangelini.com or their representatives may file complaints or claims, in accordance with the provisions of this procedure, provided they present the corresponding accreditation. Complaints and claims may be submitted in the format proposed by silvioangelini.com, on its website, or in any other format that the claimant wishes to use.

4. FILING THE CLAIM OR COMPLAINT

The procedure will be initiated by the user, or a legal representative, submitting a document stating: The full name, address, and address of the interested party and, where applicable, of the duly accredited person representing them; National identity document number for individuals and public registry data for legal entities. Reason for the complaint or claim, clearly specifying the issues on which a ruling is requested. Workplace, department, or service where the events that are the subject of the complaint or claim occurred. The complainant is unaware that the matter at issue in the complaint or claim is being substantiated through an administrative, arbitration, or judicial procedure. Means by which the complainant wishes to receive the resolution to the complaint: mail to the address of the interested party or their representative; or by email. Sufficient information must be provided to enable communication. Place, date, and signature. The complainant must provide, along with the above document, any documentary evidence in their possession that supports their complaint or claim. Claims or complaints will be received: By email to the account set up for this purpose, using the standardized form established for this purpose (or any other form used by the claimant), which can be found on the website (reclamaciones@silvioangelini.com). By postal mail, at any of silvioangelini.com’s work centers. Regardless of the process followed by silvioangelini.com, the claimant has one year from the date of filing their complaint or claim to contact the Bank of Spain.

5. CUSTOMER SERVICE DEPARTMENT (CSD)

The Customer Service Department (CSS) is part of the Organization Department. It is responsible for handling complaints received from customers, responding to them, and ensuring that Silvioangelini.com complies with the resolutions issued. Currently, the service is staffed by a single professional: the Customer Service Manager. SILVIO ANGELINI DI SANTE appoints and annually reappoints the Customer Service Manager. The Customer Service Manager, who is directly responsible for customer service, has received specific training from ADR Formación. Annually, and within the framework of the Annual Training Plan, they will receive the necessary training to remain operational.

6. RECEIPT OF CLAIM OR COMPLAINT

Complaints or claims are received at silvioangelini.com by the Customer Service Department (CSS). The use of a specific form is not required; It can be submitted in any format. The person responsible for service verifies that the documentation received meets all the required requirements (that the complainant or their representative (the latter must provide a power of attorney) is identified, and that the complainant has signed the request). Once these checks have been completed, they will notify the complainant as follows: If the documentation submitted allows the complaint or claim to be identified and the person submitting it is identified, an acknowledgment of receipt will be sent to the complainant (to the contact email address provided by the client or prospect) within a maximum of five business days from the day following the date the complaint or claim was received by the company. If the complaint or claim does not sufficiently prove the identity of the complainant, or if an original handwritten signature has not been received, or if the facts surrounding the complaint or claim cannot be clearly established, the signatory will be requested in writing to complete the information or documentation within ten calendar days, during which the one-month period that silvioangelini.com has to resolve the complaint or claim will be interrupted. The user will be informed that if the deficiencies detected are not resolved within the indicated period, the complaint or claim will be archived without further action. In the case of a complaint or claim archived due to lack of documentation, it will be reactivated as soon as the claimant provides said documentation. Complaints and claims may only be rejected for processing in the following cases: When essential information for processing is omitted and cannot be rectified, including cases where the reason for the complaint or claim is not specified. When appeals or other actions, the jurisdiction of which falls within the jurisdiction of administrative, arbitration, or judicial bodies, are intended to be processed as a complaint or claim, or the complaint is pending resolution or litigation, or the matter has already been resolved in those instances. When the facts, reasons, and request specifying the issues at issue in the complaint or claim do not refer to specific transactions. When complaints or claims are made that reiterate previously resolved complaints filed by the same client in relation to the same events. When the deadline for filing complaints and claims established by current laws and regulations has passed. When it becomes aware that a complaint or claim is being processed simultaneously with an administrative, arbitration, or judicial proceeding on the same matter, silvioangelini.com will refrain from processing the former. If the complaint or claim is deemed inadmissible for any of the reasons indicated, the interested party will be notified by means of a reasoned decision, giving them a period of ten calendar days to present their arguments. Once the interested party has responded and the reasons for inadmissibility remain, they will be notified of the final decision.

7. INTERNAL PROCESSING OF THE CLAIM OR COMPLAINT

During the processing of files, the SAC may collect any data, clarifications, reports, or evidence it deems relevant to its decision, both from the complainant and from the various departments and services of silvioangelini.com. The SAC will maintain a digital file with all the documentation generated for each claim or complaint received, which must include documentation on the claim or complaint received and the resolution adopted, as well as all communications made with the customer. If, in light of the complaint or claim, silvioangelini.com rectifies its situation with the complainant to the complainant’s satisfaction, it must notify the competent authority and provide supporting documentation, unless the interested party expressly withdraws the complaint. In such cases, the complaint or claim will be archived without further processing. A quarterly report will be prepared and submitted to the General Management of silvioangelini.com, with the statistics for the period (cases filed, cases resolved, favorable decisions), the actions taken as a result of complaints, and proposals for improving internal procedures to avoid future complaints. This report, along with all documentation and statistics generated, will be made available to the Bank of Spain.

8. WITNESSING A CLAIM OR COMPLAINT.

Interested parties may withdraw their complaints or claims at any time by submitting a written request to the email address provided for this purpose on the website. Withdrawal will result in the immediate termination of the complaint procedure with the interested party. The Customer Service Center will file the complaint or claim without further action. The customer’s communication requesting withdrawal and confirmation from silvioangelini.com of the closure of the claim to the email address expressly provided by the customer must be documented in the file.

9. TERMINATION AND NOTIFICATION.

The file must be finalized within a maximum period of one month from the date the complaint or claim was filed with the Customer Service Center. The decision will always be reasoned and contain clear conclusions regarding the request raised in each complaint or claim, based on the contractual clauses, applicable transparency and customer protection regulations, as well as good financial practices and customs. If the decision deviates from the criteria stated in previous similar cases, the reasons justifying this must be provided. The decision is binding on silvioangelini.com and must be complied with as quickly as possible. Silvioangelini.com will communicate the decision to the complainant at the location indicated in the complaint document. The interested parties will be notified of the decision within ten calendar days from its date, in writing or by electronic, telematic, or computer means, provided that these allow the reading, printing, and storage of the documents, as expressly designated by the complainant. In the absence of such an indication, the complaint or claim may be filed through the same means used to file the complaint or claim. The complaint or claim shall expressly state the right of the claimant to appeal to the appropriate court in the event of disagreement with the outcome of the ruling. In the event of disagreement with the ruling of the SAC, the claimant may file their complaint or claim with the Bank of Spain. Bank of Spain Complaints Service C/ Alcalá, 48, 28014 Madrid Telephone: 913386530 Website: www.bde.es