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offi General Banking Division Head office, Dhaka Policy No: 03/2015 Heads of all Branches Heads of all Divisions at Head Office NRBC gank Limited Dhaka, Bangladesh March 4, 2015 Subiect : Pollcv lor Customer Services and Complaint Manasement of NRBC Eank Limited. Dear Sir, ln accordance with the "Guidelines tor Customer Services and Complaint Manatement" framed by the Flnancial lntegrity & Curtomer Seryices Department (Customer Services Oivision) of Bangladesh Bank, a separate "Policy for Customer Services and Complaint Manatement" has been prepared and approved by the Board of Directors of the Bank in its 25th and 26th meeting held on 22.01.2015 and 07.02.2015 respectively. Therefore, all Executives/Officers of the Branch as well as Head Office are requested to keep themselves thorouShly conversant with the contents ofthis Policy for meticulous compliance. Please note that to implement this Policy a Cell named "Central Customer Service & complaints Management cell (CCS & cMC)" has already been formed at Head office level which has been communicated through email dated February 25. 2015. Now, with a view to stren8then the corporate governance structure of the 8ank, all Head of Branches are requested to form a granch tevel Customer Service & Complaints Management Desk (8LCS&CMD) ro act in accordance with the Policy. It is to be mentioned here that the number of personnel will be determined by the Head of Branch taking into consideration of the number of customers as well as the number of employees of the branch. ln case of very limited or short man-power of the branch, at least one official must be deployed in the BLCS&CMD. For any clarification, please contact Mr. Hasan Mahmud, Principal Officer, General Banking Division. Head Office, Cell no:01955 502 028, e-mail: [email protected]. Thanking you, a-\ <--'- ,.- -) Md. Masum Haider First Vice President Deputy ManaginB Director Enclosurc: Customer SeNices ond Comploint Monogement Policy ol the Bonk.

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Page 1: Customer Service 2015

offi General Banking DivisionHead office, Dhaka

Policy No: 03/2015

Heads of all BranchesHeads of all Divisions at Head OfficeNRBC gank LimitedDhaka, Bangladesh

March 4, 2015

Subiect : Pollcv lor Customer Services and Complaint Manasement of NRBC Eank Limited.

Dear Sir,

ln accordance with the "Guidelines tor Customer Services and Complaint Manatement"framed by the Flnancial lntegrity & Curtomer Seryices Department (Customer ServicesOivision) of Bangladesh Bank, a separate "Policy for Customer Services and ComplaintManatement" has been prepared and approved by the Board of Directors of the Bank in its25th and 26th meeting held on 22.01.2015 and 07.02.2015 respectively.

Therefore, all Executives/Officers of the Branch as well as Head Office are requested to keep

themselves thorouShly conversant with the contents ofthis Policy for meticulous compliance.

Please note that to implement this Policy a Cell named "Central Customer Service &complaints Management cell (CCS & cMC)" has already been formed at Head office levelwhich has been communicated through email dated February 25. 2015. Now, with a view tostren8then the corporate governance structure of the 8ank, all Head of Branches are requestedto form a granch tevel Customer Service & Complaints Management Desk (8LCS&CMD) ro actin accordance with the Policy.

It is to be mentioned here that the number of personnel will be determined by the Head ofBranch taking into consideration of the number of customers as well as the number ofemployees of the branch. ln case of very limited or short man-power of the branch, at leastone official must be deployed in the BLCS&CMD.

For any clarification, please contact Mr. Hasan Mahmud, Principal Officer, General Banking

Division. Head Office, Cell no:01955 502 028, e-mail: [email protected].

Thanking you,

a-\<--'-,.-

-)Md. Masum HaiderFirst Vice President Deputy ManaginB Director

Enclosurc: Customer SeNices ond Comploint Monogement Policy ol the Bonk.

Page 2: Customer Service 2015

POLICY FOR CUSTOMER SERVICES

ANDCOMPLAINT MANAGEMENT

November t2, ZOf4

Page 3: Customer Service 2015

TABLE OF CONTENT

CUSTOMER SERVICESln5titutiona I F ra mework

COMPLAINT MANAGEMENT

INTRODUCTION

ctives of the Guidelines

runctions of cenrrat cuiiiiE celtii|iiillsMana8ement Cell (CCS& CMCIr u nctions of B ra nch Levif diiiim-eiliiiiTtoiEljniManagement Desk (BICS &CMDIlnstttutaonal Approachi-iG6mir sei[ilollcy

f9. ce"e."t MCode ofConductService StandardsCustomer Chartei

?:!r:yi"s jh" p"t.customer Awareness F-ffi

int Lod8ment procedrr;Complaint RecordiPriorjtization of CompE;;clqpqll1Eqlqqtion pro."r,

-Ittitrrdeandlttributeso-o-mplaintiandtingOlf

icial-s(cHo)

It.e Lirntt lot qqltr;t" int R;;;io"Controland ComReward an4 punishment

Root cause Ana tys isliiiiiiForm uta t-ta tioiANNEXURE

Page 4: Customer Service 2015

INTRODUCTION

1.01. Overviewi

Bank is seavice oriented Financial lnstjtution. We collect deposit from the savers and lend thesame under domestic legal framework to the persons facin8 deficit of fund. lt was a day,borrower used to come to us to meet their demand of deficii of fund. aut bf now, not ontybanks but also many Fls and NBFts hawhich are arso service o.i""t"d Fi,;n.i:io";;flilT ;hlT::ilr.I*ll

"ll,XJjjl;the borrower, Banks approach has b€search borrowers uno *,"n0

-ii".i',1:fii"i"...",,,Tj,, ililli;J"r,] Xi,Xl".lldeposrtors/savers fund. tn extendine financiat services o" r* -"oi -o",r"

orJr,o "r r"O"O[acilities, but it also provides non-frirachieving significant profit of the ,"n,to"o

t"t"'t'"t which is now a dominant factor for

more sensitive than th", r r,o"o o.,in,li*r]i;,:X,:frill1lil;Jl:liffi:ffi J:

:.1::-."0":*,: knowledge of tegat framework " ""-0".r0".,* .i,ao."*,.

"narnternational environment to understand customers need

""0 O."ri" ,"rrn", ,, ,,."Althou8h, a the Banks wilh therr emD

'0,,,n",, ",,.,,'"-0,n",:;:: il;J:J"f:::fiJT*T:ff :::ffi,jJ:If :*situation no services sha not be allowed to ert"na ortria" tru fr,i "rr'"i,"r"ii"."***.Customer complajnts are part of theBnnkinr company. As a -;;; ;.;"H::';.ti""J,l;l.l"jll,lll#:,],:;ffi:l

::the prirhe concern of the bank. The banprame motto; providing prompt ana eric'

believes that excellence in customer service is its

business policies. :ient service should get paramount importance in its

Fina ncia I consu mer protection has caled for re8urators to be abre to set minimum standardsfor financial products to ensure fairHowever, in ;",r.",;,; ;.;,;;J" Tf::,'""Il"il"Jii';#r.ffi;'."J::*,J;demands, customer services and consuldiverse. This diversific"a" n", o"* a"r'"r

protection issue become more complex and

or comptexitv ";";;;;;;;fi;Lutrtinuins

remarkabrv rn order to minimize such tvpe

initi"ti,e ror ruir,".ln;";.:ilffi : :Jili11,T,,#.|[T* N RBc Bank is takins such

The Gujdellnes are structured and focused on the aspects of institutional and indjvidual

i,#"llilllil#"omer service quaritv, customer awareness prosram and compraint

Page 1

Page 5: Customer Service 2015

1.02. OBJECTIVES OF THE GUIDEI.INES:

At NRBC Bank, we betieve threrationship, *n"n ,, .o."r'1lo-lt

emplovees and clients stand to Sain from a close, open

Guiderines are formulated to resolvin8 problems and sharing positive feedback. These

customers, satisfaction O ,n*,rn some specifac objectives like attainang and retaining

trnancrar staoilty. rher;r;";;"i::::::t:;tankt €oodwirr' reputation and above al

" .tff;IT#;t"i:*1il1;ilT''" service'practices bv setrins up ftinimumb, To increase tran5parency rn tinanc ia I servicesc. To provide a formalfrad ro provide

"r;;;;;'r;t"1** * complaint cell in the bank'

and manage ,n" .rr.11-t"n"t"tial guidance for the bank officials to handle

efficiently. itomers'complaintssatisfactorily,quickly,effectivelyand

e. To develop consumereducation program,

activi'm through a structured consumer awareness and

1.03. LEGAL BASIS:

ilii:#r;"^,.f Ir,^.,;rx1i,,.,fi ",i,:::Ti,;.J.,-[*,il,[,ii:;are. suppternenrary ,. ;;";;'rr*::i"a'B 'n" 'tur.,,on,

,escribed in the guidetinesreplace orsupersede thor".

- -_ " "' oy the le8islative requirements and thesl wilt not

"u,n",r,." torar%

Page 6: Customer Service 2015

CUSTOMER SERVICES

2.01. INSTITUTIONAI" FRAME WORK:

With a view to strengthening the corporate Bovernance structure of the bank and alsoto brinS about improvement in the quarity of customer services, NRBc bank has constituteCustomer Service & Compl.ints Management Cells as stated below_

At the head office level this cell will be named as Central Customer Service & ComplaintsManaSement ce (ccs&cMc). It wifl be constituted ,"0". * - r,."., ir'"*oa"

",the Managing Director or the Chief Executive Officer (CEO) , ,* 0""*. li rn", o"mentioned here that this cell will be exctusively for dealing with the .orOf",nlr' a'.r*or"l.service retated matters. The number of personnet of tiis cell witt il O"i".rni* o, *"Managing.Authority of the bank. The personnet of this cell will be the di8nitaries and theywill be delegated with adequate power to settle the aisputes wittr Oue aiige;ce.Under the Central Customer Service & C(be the B.anch Lever c,.,.,";;;;;;;'J:;iH.Iil1*""r1il:,:",1J,ffiT[:ffi ",:;]lthe zonal offi.e has €stablished*. The numbe, of p"rson*l *r, O" Ou,"rri"1 O, ,n"branch manager taking into consideration the number of customers as well as thenumber of employees of the branch. tn tlbranch, at reast one offi.i"r .,,t o" a"prol7""li'n";:;ilr[["j.

.,, 'hort

man-power or the

'Establijhlh€nt ofronatoffi.e is subjeq to fo.mation of tood number of br.nches in differenr zone.

Uu,r""n".,o.ar.,o.ffiPage 3

Page 7: Customer Service 2015

The lnstitutional Frame Work of NRBCB is shown in diagram below:

Central Customer Servlce & Complaints Management

Cell(ccs&CMC)

2.02. THE FUNCTIONS OF THE CENTRAL CUSTOMER SERVICE & COMPLAINTSMANAGEMENT CELL (Ccs & cMc):

2.02.A. POLICY RELATED FUNCTIONS:

The Cell shall, illustratively, play the following policy related roles in developing thestandard of customer services of the bank:

1. Establishment of some basic institutional approach or ethical principles regardingbustomer servaces in the bank.

2. lssuance of necessary customer- service- related policy for general management ofthe customer services in the branches,

3. Formulation of Code of Conduct for bank officials {As per para-2.0G).4. Formulation of Service Standard and Customer Charter in the bank. (As per para

2.07 & 2.08)

5. Promulgation of customer awareness program (As per para-2.10).5. Arran8ement of quarterly meeting to review customer services, systematic

deficiencies and take corrective measures thereon.7. The Cell shall submit a brief half yearly report to the board stating the status of

complaints received, resolved and outstanding with su8gestions for improvement ofquality service or products.

Eranah LevelCustomer Service & ComplaintsManatement Desk (BLCS&CMD)

Cuidelines for CustomerSeruiccs and Complaint I\,tanagernent- NRBC Bank Page 4

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2.02.8. OPERATIONAL FUNCTIONS :

1. To deal with the complaints received directly from customers Branch tevel CustomerService & Complaints Mana8ement Desk (BICS & CMD).

2. To monitorthe overallactivities and performances ofthe (BLCS& CMD).

3. To maintain liaison and respond duly and timely to the letters of Bangladesh Bank. Ifthe complaints are related to other divisions, CCS & CMC will take the responsibilityto communicate with the relevant divisions, collect information and give reply toBangladesh Bank.

4. To put forward the proposals to the Managing Authority for modification orformulation of new policy related to the customer service.

5. To comply with and implement the directjons/instructions of Bangladesh Bank.6. To maintain a register of complaints, received either from the customers directly or

from the branch offices. (As per para- 3.02)7. To submit the monthly/quarterly statement containing the number of complaints

received, resolved and outstanding to Bangladesh Bank through Web portal.

2.03. FUNCTIONS OF BMNCH I.EVET CUSTOMER SERVICE & COMPLAINTS

MANAGEMENT DESt( (8t"CS& CMD):

1. granch Level Customer Service & Complaints Management Desk (BLCS&CMD) shalldeal with all the complaints directly received from the customers either in wr,ttenforrn or over telephone. tt will also give patient hearing to those customers whophysically appear before the desk with complaints.

2. The BI"CS&CMD shall also give reply to the customer-service,related queries of thecustome15,

3. The BLCS&CMD shall maintain two separate registers to record the written andtelephonic complaints. Then it willtake action on the complaints received on prioritybasis.

4. The BLCS&CMD shall prepare a monthly/quarterly statement or report in prescribedformat (Annex-C) showing the number of complaints received, resolved andoutstanding and send it to the CCS &CMC within fifth of the next month/the quarterended (Annexure,D).

5. The BLCS&CMD may refer any complex complaint to the CCS & CMC for furthersuggestion or resolution. The BL6&CMO will keep correspondences with CCS&CMCforthis purpose.

Guidelines for Customer Serviccs and Complairtt Management- NRBC Bank Page 5

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2.04. INSTITUTIONAL APPROACH TO CUSTOMER SERVICES:

NRBC Bank has established some corporate principles, ethics, culture, moral standards and

collective attitudes for customer services. The strict exercise of these will result in theinstitutional administrative success as well as the credibility of the banks to theircustomers,

The fundamental ethics and principles that the Bank's employee should follow in

dealin8 with customers'affairs are furnished below:

The f undamental ethics and principles

SL No Core principles/ethlcs Details oI approach

1 Accountability Accountability and Responsibility of each employee

entated in customer service should be desitned

clearly and specifically. Bank official should provide

seNice to their customers with a sense of urgency and

commitment.2 Transparency There should be transparency in all terms & conditions

and information relating to all banking products and

seNices provided bythe bankto the customers.

3 Equity and integrity Eank's officials must exhibit their honesty, integrity,

loyalty, impartiality to their customers. The officials

dedicated to customer services should avoid conflict ofinterest.

4 Compliance Bank's officials must comply wath their relevant rules &

regulations, policies and BB's instructions while rendering

ServiceS to the customers.

5 Safety and security Bank should ensure safety and security in operatin8

system and dealings of their banking products and

Services.

6 Privacy and

confidentiality

Bank's officials should maintain privacy and

confidentiality of the banking transactions of their

customers with some exception such as disclosure under

compulsion of law, public interest, bank's interest

customer's consentetc.

Cuidelines forCustomer Services and Complaint Management_ NRBC Bank Page 6

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2.05, POTICY FOR GENERAL MANAGEMENTOF THE BRANCHES:

NRBC Banking system should be oriented towards providing better customer serviceand therefore, Eank shall periodically study their system and its impact on customerservice. Bank should also have a Managing Authority approved policy for generalmanagement of the branches which include the followinB aspects:

Providing customers with booklets containint all details of services and facilatiesavailable at bank branches in Ben8aliand EnElish.

oisplaying indicator boards at all service counters in both English and Bengali.Surprise inspection and survey of customer services.Reviewing and improvint existing security system in branches and ATM booths.Providing enquiry counters at big branches.

Training ofstaff in line with customer service orientation.Developing banking products or services keeping view to suitability anda ppro priateness for genera I custo me rs.

h) Annualsurvey of customer satisfaction and grievances resolution.

2.06. CODE OF CONDUCT:

Generally Code of conduct is a set of rules for employees, personal behavioral pattern,official decorum, dress code, environmental and disciplinary arrangement for staff,stakeholders ahd stock holders in the bankinB premises set forth by the Bank. The purposeof the code of conduct is to create a sense of oneness among a group ofemployees, customer5 and guests an spite of individual differences. The aim of the code ofconduct is also to develop a common perspective towards a mission & vision of thecompany. A Code of Conduct acts as an internal watchdog and memorandum of the basicrequirements of appropriate professionalism within the organizational culture. Exercrsing

code of conduct helps to make customers happy and improve long term banker-customer.elationship. So bank shall formulate the basic code of conduct for the employees and it willbe applied in five essential areas (5Ps) as listed below:

a. People - The team who serve the customers.

b. Premises - The location from which bankers serve and communicate withcustomers and colleagues.

c. Papers - The documents whach are used to provide and receive information.d. Processes -The operation processes that enable bankers to delight customers.e. Practices - The way in which bankers interact with customers.

a)

b)

c)

d)

e)

f)

8)

Guidelines forCustomer Services and Complaint Managemenr. NRBC Bank Page 7

Page 11: Customer Service 2015

2.06.A. The formulated code of conduct must cover the following topics:

1. Behavioral pattem- Bank shall set forth some basic behavioral standard orindicators for all employees, especially for the officials concerned with Customer

SeNices and Complaints mana8ement. Behavioral pattern includes the standard in

speaking, listening, Breetings that will exhibit loyalty, modesty, impartiality andproactive attitude in providin8 service and that will not show obscene or abusive

languaSe, materials or messages in any way.

2. Oisciplinary arrangement- Bank shall make some rules and arrangements which willhelp to keep customer service point neat, clean, comfortable and disciplined. There

should be sitting arrangement, waiting lounge, drinking water, smoking or nonsmoking 2one, line or arlay at customer service point and counter for customers etc.

2,06,B. Some standard Behavioral pattern and indicators at customer servicepoint are set by the bank

gank authority should strive to motivate their employees to expose standard behavior while

delivering their seNice to customers over the telephone, cell phone or face,to-face. Some

examples set by NRBC Bank are given below:

1. Use basic courtesies such as always try to say "Please" and 'Thank you" while conversint

with the customers.

2. Address customers properly 5uch as Mr. or Ms. and sumame of customer may acceptable.

Never use casual term5 of endearment such as "honey". "yeah", "huh", o( "deat."

3. Treat others as you would like to be treated in the same situation.

4, Nevershowemotional impressionorexpression

5. Be positive, pleasant, courteous and cheerfulwith a good impression.

6. Never interrupt interactions with a customer to take a break, lunch or any lame excuse

etc.

7. Avoid any rubbish or junk word to the customers.

8. Never disparage or criticize anotheremployee or customers.

9. Do not react negatively when someone approaches any help.

10. Do not take anything personally.

11. Avoid technical terminology with all customers

12. Assume everything (remark, comment or any approach) positively and take the best

Guidelines for Customcr Serv ices aDd Complaint Managcmana NRBC Bank Page 8

Page 12: Customer Service 2015

theme or idea, even if the customer actually meant the comment in a

he or she will see that you sincerely want to help them and then

change.

13. Present a professional approach and appearance by practicin8 good

and dressing appropriately in the work place

negative manner,

their attitude will

personal hygiene

14. Be a bank employee, not iust a department employee as the customers see us as "the

bankers" - they do not see individual departments or divisions.

2.07. SERVICE STANDAROS:

a) NRB Commercial Bank Limited formulated a service standard showing the timeline or

time frame, initiating level and disposal level of bankin8 service at the customer service

point or counter in the bank premise. lt will control the dedicated official to render

services in time and efficiently through proper channel. Each employee and each

depanment will choose the level of service they wish to deliver. customer should be

informed of Service Standard of the bank so that they can assume or plan in advance the

requked timeline to obtain services se.vlce Standard of NRBCB has been prepared

considering relevant factors such as number of employees, customers, environment

customers'requirement. availability of lo8istic support etc. keeping in mind that,

standard of each service has set in such a manner as it would be achievable, reasonable

and measurable. Here, the Service Standard set by the bank is shown in annexure_a:

b) Ensure the compliance of the seNice Standard time to time.

2.08. CUSTOMER CHARTER;

Customer Charter i5, in fact, a general statement of commitments for providing bankin8

services and necessary information to customers ThiS may be in the form of written

document, banner, poster, leaflets etc that exhibit the names of bankin8 products and

services available in the bank- lt also contains road maps or indicators for the customers to

get services in the bank premases The indications of lnformation desk, Customer

Relationship Desk, Remittance .Desk, credit Desk etc shall be displayed in the charter for

the customers for tracing the service points easily The Charter will also include a list of

customers' rights & obliSationsio Bank. The main objective of the "Customer charte/' is to

make the customers conscious about their general riShts, obligations, grievance

approach process and thereby help customers taking their own decision Copies of the

Customer Charter should be available on request to all customers at all branches, Customer_

Cui(iclines tbr Custolncr Serviccs and Conrplairll M.rnageD( rrr NRBC Eank Page 9

Page 13: Customer Service 2015

Service-Points and at bank's web site. NRBC Eank shall-

Prepare and preserve their "customei charte." in its respective branches and

exhibit in their premises.

lnform, publish or display customers' rights & obligation5 as well as Bankers' riShts

& obligation5 through its web site, leaflets, notice boards, posters or in any other

communi.ation channels.

2.08.01 CUSTOMERy RTGHTS/BANKERS' OBr-TGATTONS:

NRgC Bank shall allow their customers to obtain the followint rights, i e, Bank shallcarryout the following obligations to their customers:

A ) Disalorure of Current lnte,est Ratei-

Prior to signint the contract with the consumers for both interest-bearing deposils andloans, Bank shall-

1) lnform the customers ofthe term ofthe fixed deposit or loan;2) lnform the customers of the char8es, if any, and consequences of premature

termination of a fixed depositor loan;3) lnform the custo m ers whether the interest rate is fixed or variable;4) lnform the basis and frequency on which interest payments or deductions are to be

made;5) Explain the method used to calculate interest of each producU

6) Disclose prominently the total amount of income that the customers shall receive on

the fixed deposits; and7) Disclose the totalcost of creditwith break up, if any.

B) Disclosure of latest Schedule oI Cha]8es, Fee, Commlssion etc.

NRBC Bank shall, for all char8es and fees to be levied at the time ofservice rendered or on

request?

1) Provide the customers with a schedule of char8es, fees, commissions' payable for theproducts or services that the customers have chosen;

2) Display prominently their standard fees and charSes at all branches,

3) lnlorm the customers of any additiohal charges or expenses that the customers have

to pay, such a5 searching fees to retrieve available past records etc.

a)

b)

Guidelines for Customer Services and Complaint Management_ NRBC Bank Page 10

Page 14: Customer Service 2015

C) Notice of ChanSes to Terms and Condltlons:

The terms and conditions provided by the bankshallhighlight to a consumer the fees,charges, penalties, relevant interest rates and any other consumer liabilities or obligations inthe use of the financial products or services. NRBC Eank shall ensure that a consumer isnotified-

1) At least thirty days in advance before implementing any changes to the terms andconditions, fees or charges, discontinuation of services or relocataon of premises ofthe fina ncia I serv ices provider.

2) lmmediately ofany changes in interest rates regarding the product or service

D) ValueAdded Services:

The Bank should take written consent from their customers for any value addedservices, such as, internet banking, SMS banking, ATM services etc. and inform thecustomers of the terms and conditions along with the charges, levied for that.

E) Guarantor:

Prior to a person acting as a guarantor, bank 5hall in writing:

1) Advise the person of the quantum and nature of his or her potential liabilities; and2) Advise the person to seek independent le8al advice before acting as a personal

gualantor.

F) Disclosure of oth€r facts, such as-

1. BuyinS and selling rates of foreiBn currencies2. Financial statement. financial performance indicators etc3. BankinB hours and holiday notices4. Operating cycle or road map of seNices (indicators showing desk Number, floor

number, room number etc.).

2.08.02 CUSTOMERS' OBUGATTONS/BANKERS' RTGHTS:

a) Customers shallfollow the.banking norms, practices. fu nctiona I rulesetcb) Customers shall abide bythetermsand conditions prescribed for each bankint

productand services.

c) Customers shallmaintain disciplinary arrangement at the customerservice points.

d) Customers shallconvey theirErievance to the bank in proper way or in prescribed

e) Customers shall convey the bank any changes in their address, contact numbers, KyC

&TP

Cuidelines forCustomer Serviccs and Complaint Management- NRBC Bank Page 11

Page 15: Customer Service 2015

c)

Customer shall not try to show unreasonable persistence, demand, argument &behavior.

Customers generally shallask any query at prescribed desk such as Customers,Service Desk, Help Desk, lnformation Desk or Enquiry Desk at first instance.Customer should avoid misunderstanding as far as possible.h)

2.09. DISPLAYING THE CONTACT DETAILS OF THE OFFICIAI.S OF CUSTOMERSERVICES AND COMPLAINT MANAGEMENT CEtL5:

With a view to making the complaint lodgment easier NRBC bank shall-

a) Display the contact details including names, complete address, telephone number,fax number, emait address, etc. of the officials of CCS&CMC and BLCS&CMD an theprominent place of the branches.

b) Oisplay on their web-sites the contact details including names, complete address,telephone number, fax number, email address, etc. of the officials of CCS&CMC andBLCS&CMC.

2.10. CUSTOM€R AWARENESS PROGRAM:

Now a days it has been observed that financial scams, financialfrauds & forgeries, financialcrisis, financial corruptions and customer harassment have been incurring frequently infinancial sector with the development of E-banking (E- bankinS Benerally refers to theprovision of banking products and services through electronic channels such as the personalcomputer, through land phone and mobile phone connections, or through automated tellermachines - ATMS, Point of Sales etc.). The primary reasons behind these are identified as theinformation gap as well as the communication gap between customers & bankers and thelack of awareness & financial education of customers. tn such a situation customerawareness is a key defence against fraud, forgery and identity theft and security breach.That's why bank should take attempt to make customers aware of and to make educated forfinancial literacy with a view to stren8thening customers, knowledge and experience andthereby to reduce fraud, forgery and harassment. Customer Awareness and EducationProgram for customers can be arranged for providing customers with the knowledge andunderstanding of the wide range of banking products and services. Thus, the customers willbe aware and conscious oI their own rjghts and responsibilities,safety measure thereofindependently. Besides, bank shall continue monitoring off- line risks as well as onlinethreats such as hacking, phishing, identity theft etc and reviewing security procedures dayto day.

Cuidelines for Customer Services and Complaint Managcmena NRBC Bank PaEe 72

Page 16: Customer Service 2015

tu a part of Customer Awareness Program NRBC bank shall perform the activities as statedbelow:

a. Eankshall publish or declare customers alert and precautionary message, guidelinesetc. on their products and services time to time through brochures,leaflets andadvertisement in communication channels on the following topics.. Customer alert and precautionary message on general banking.. Customer alert and precautionary message on tnternet banking. Customer alen and precautionary message on loan and advances.. Customer alert and precautionary message on localand foreign remittances etc.

b. Bank shall arrange meeting, seminar, workshop or any other non formal pro8ramsperiodically to convey their awareness message and alert tips to the customersrelating to their own banking products and services.

c. Bank shall also train up their customer-service_related officials to enhance theirefficiency, skill, knowledge, tact, technique for excellent customer services.

2.10.01 lnstructions for customers, alert:NRBC Bank shall provide Seneral instruction for customers, alert such as:

A. GENERAL BANKING ISSUES

1) Read the terms and condltlons of each product and te.vices carefully:

Customers have to read and understand the terms and conditions of an agreement/contractfor any loan or investment related product prior to signin8 any related documents.

2) Responribilities of a guarantor:

Customers have to understand the responsibilities and obligations of a guarantor.Guarantors are legally bound to make repayment ifthe borrower fails to settle the loan.

3) Oisclosure of ,inanciel informatlon:

Customer should not disclose Jheir financial information such as account number. creditcard number, password and other personal particulars to third parties either via telephone,e-mails or any links in websites.

4) Transadions at ATM booth:

Customer should not allow thard parties to make transactions at ATM machines on behalf ofcustomer, even to those whom customers know such as spouse, son or daughter. personalas5istantetc.

Cuidclines for Customer Services and Conrplaint tltanagemcnt- NRBC Bank Page 13

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5) Credit card transactionsi

Customers Should use Credit Cards as a payment instrument and utilization should be withincustomers'means. Customers should also verify the amount deducted after each credit card

transaction and make sure the card returned belongs to customer.

6) Submission of documents:

Customels should be cautious themselves before submittin8 photocopies of theiridentification card or passport to third parties, other than to financial institutions or lawyers

acting on their behalf.

7) lnternet bankiry facilities:

Customer should be alert not to be deceived in opening an internet bankin8 account in

order to win prizes or inheritance from an unknown party. This could be a scam af one has

already done so. ln such cases the customers should contact and report to bank and to thepolice immediately for their further action, also keep Bank informed.

8) Memorycache function:

Customer should make sure that customers have log8ed-out properly after usiog the

internet banking and clear the memory cache after completing the transactions.

B. INTERNET BANKING SECURITY ISSUES:

Customers should

1) not to share orgive outown access lD, user name, pa sswords, o r secu rity cha llenBe

questions & answers

2) not to use same personal information as own access lD, user name & password in all

cases

3) create difficultor uncommon passwords that inclu de letters & numbers and upper&

lowercase letters combined.

4) change own password frequenily

5) avoid using public computeri to access your internet banking.

6) not provide any personal information to web sites that do not use encryption or other

secure methods of protection.

7) ensure that computer is equipped with up to date anti virus software protection .

Guidelines for Customer Sewices and Complaint N4anagement- NRBC Bank PaEe 14

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COMPLAINT MANAGEMENT

Safeguarding the interest of depositors and other customers is a fundamental requirementin the financial system. The bank-customer relationship is disrupted and complaints areraised when interests of the customers are neglect€d. Unresolved complaints lnay causelosses for the customers, or Bank. The publication of complaints through the media mayalso damage the reputation of gank in the public eye and can erode pu-blic confidence inthe financial system if complaints are not handled promptly with proper procedures.Therefore, with a view to safeguardint the interests of bank customers as wefl as fosteringpublic confidence to the banking sector the Bank must have an effective complaintmanaS€ment System for addressing complaints of their customers with specific emphasis onresolving such complaints fairly and expeditiously. NRBC bank treated comptaintmanagement as a series of activities such as facilitating complaint lodgment, developintcomplaint recordinS system, comprarnt resorution process,,oo, a"r." anarysis of thecomplaints laised and necessa ry po ljcy form ulatio n. These are illustrated below:

3.01. COMPLAINT I.ODGMENT PROCEDURE:

a) Sank shall facilitate the customers to lodte complaints by any available means (forexample, Ietter, telephone, facsimile, email, or in person) and the bank shallnotinsist that complaints be necessarily made only in writing.

b) Electronic compraints rodgment system can be produced in the web portar of thebank.

c) Eank shall facilitate the customeB to lod8e their complaints at any branch ofthebank regardless the branch at which the customer opened an account or branch atwhich the customer conducted a tinanc ia I activity or transaction.

d) Bank shall accept complaints lodged by customers, or authorizedrepresentative of the customers.

e) A description of the complaints handling system, or bank.s prescribed form(Annexure-c) for submittinS compraints shourd be accessibre/avairabre tocustomers, via the bank,s website, or through pamphlets and posters.

cuidotines for custome, s"mPage 15

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3.02. COMPLAINT RECORDING

a) Bank shall maintain Complaints Registers (Annexure_B) and records of complaintsreceived. The registers should include, but not be limited to the followings:. Dateofcomplaintsreceived;. Name and contact details of the complainants or authorized customer

representatives;. Briet descriptaon ofthe complaints;. Name and desi8nation of the official, handled the complaintsj. Resolution status;. Settlement date;

b) Bank shall retain the detailed records ofhandling and resolution ofcomplaints.

3.03. PRIORITIZATION OF COMPLAINTS:

NRBC Bank shall prioritize the complaints on the basis of the gravity and sensitivity of thematter involved. For this purpose, complaints received at any level of the bank, shall beclassified lnto the following categories and shall be marked as H,S. for Hithly Sensitave, S forSensitiveorG for Generalcategory on the complaints:

Nature ofcomplaint CategoryAllegations of fraud forgeryAllegations that require prompt action in the failure ofwhich it may cause great loss to the complainant.References from Ministries of Govt./ BanBladesh Bank/BAB/VlPs

l.ff"gtior" of l.rU" U"f'urior, U.iO"l.V -Alletation related to foreign remittance, non-payment ofoverdue foreign bills.

Alle8ations related to the different prioratized products ofthe bank

Allegations related to the Govt. prioritized products

{AEricultural Credit, subsidias to the farmers etc.), loansunder Government's Poverty Alleviation programs, SocialSecurity Products (old age allowances, widow allowancesetc.)

Hithly Sensitive(Hs)

Sensitive(s)

Other kinds of complaints General(Gl

Sank shall take necessary action on the basis of priority of the compiaints"

Cuidelines forCustomcr Serviccs and Complairrt Maragentcnt- NRBC Bank Page 16

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3.04. COMPIAINT RESOLUTION PROCESS:

Complaint handlinS is one of the important functions in an oGanization for theirinstitutional reputation and existence. Bank,s Complaint Management Team should followa systematic procedure to settle the complaints atainst Bank. The Complaint Resolutionprocess requires at least the following five statesi

a) Acknowledgmentb) Screening of complaintsc) Departm enta I actions for resolution.d) Appealand reviewe) Response and closure

The stages of resorution process are depicted berow in a diagram and stated in detairs foreasy references and understanding:

Guidelines forCustomer Services and Coffiaint Uanugem"rt- f,lnAC eantr' Page 77

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Complaintsa\-

Aaknowledtment

DIAGRAM: COMPLAINT RESOLUTTON PROCESS of NRaC aank

a. To acknowledge comptaints through e-mait,phofle, mobile, Fax, etc.

b. To provide Refer€nce Number and datec. To provide expected time for finat response

b. Distribution of complaints to relevant Dept_ orcomplaint handling off icials

a) Resolution by taking opinion/ctarjfication fromthe concerned depanment/branch

b) Resolution by negotiation o. mediataon.

c) Resolntion through anvestigation

a. Screenin8 the comptaintsprioritization and importance

a. Providing scope for appeal if resolution is notsatisfactory to the complainants.

b. Review the resolution process and d€cision bythe higher authority.

a. Convey the resolution status ro the

b. Convey the reason if the de€ision Soes a8ainst

the complainant and close the file.

3.04.01 ACKNOWLEDGEMENT

a) A complaint must be acknowledged promptly to assure the client that the complainthas been taken into consideration. The acknowledgement should outline thecomplaint process and provide contact detaals, preferably the name of a contactperson. lt should also mention the probable time for resolving the complaint.

Screening ofcomplaints

Oepartmentalactions for Resolution

Appealand review

Response and

Guidelines forCustomer Services and Complainr Management- NRBC Bank Page 18

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It is not always necessary that the acknow,edgement will be in written form. tf thecomplaint is received through telephone, the acknowledgement can be conveyed to thecomplainants over Phone.

The complainants should be kept informed of the progress and the outcome of thecomplaint if it is a long outstandinS case.

d) Electronic complaint lodgment systems can also be programmed to send anautomatic acknowledgement to the customers.

3.04.02 SCREENING OF COMPI.AINTS

a. The nature of complaint may vary ca5e to case. Some complaints may be highlysensitive whereas some may be of general sensitivity. Some complaints may deservequick disposal whereas other complaints may be of normal importance. So, the Head ofComplaint Cell {HCC) shall to through, screen and scrutinize each complaint anddetermine the priority ofthe cases on the basis of merit and urSency.

b. Then HCC shall forward the complaints to the concerned officers or to the concerneddepartment with appropriate direction/advice and shall confirm dispatch or recordkeeping of each complaint.

3.04.03 DEPARTMENTAL ACTIONS FOR RESOLUTION:

a) Resolution by takih8 opinlon/clarification from the concerned department/

branch:

lf prima-facie scrutiny of a complaint reveals that it requires some clarifications, opinions,any additional information or documents for better undeGtanding of the complaintfrom the concerned or accused branch/department, the Complaint Cell shall ask forthose in written (through letter or e-mail) and then settle the complaint amicably. ln sucha situation the accused branches/departments will be bound to follow the advice andinstructions thereof.

b) Resolution by mediation or negotiation:

ln some cases, dispute may adse between the bank and the complainant and for thesolution of the problem mutual discussion may be needed. ln such cases, Complaint Cellshallarrange a meeting, mediation or netotiation with the complainant and thus help toresolve the case peacefully. The mediator will facilitate the process, but not insist theparties to abide by the declsion.

b)

Guidelines forCustomer Serviccs and Complaint Management- NRBC Bank Page 19

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Resolution through investigation;

ln the cases of complex nature such as fraud, fortery, financjal corruption, financialembezzlement which need physical inspection or investigation, an inspectron orinvestigation shall be conducted by the bank either by their tnternal Audit and tnspectionDepartment or by forming a special inspection team with qualified officials ofthebank to find out factual event. The iospection report should contain their findrngs indetails, the specific indication of the persons/officials responsible for the event and therecommendation thereon. tf any complajnt involves in criminal activity, legalactions/steps should also be taken bythe bankas per rule.

Action on Anonymous and pseudonymous Complaints:

Any complaint that does not bear the name, addresses, contact number ot thecomplainant, will be treated a5 anonymous complaint. The complaint whiah does not bearthe full particulars of the complaanant or is unsigned or is renounced subsequently by acomplainant is a pseudonymous complaint. As a general rule, no action is required to betaken on anonymous and pseudonymous complaints. But the bank shall take it intoconsideration for taking action on it when the complaint contains the allegations likefraud, forgery, corruption that may harm the jnterest of the bank or of the customers.Any complaint which is not related to the Bank will not be considered as complaint andtherefore no action is required on it.

3.04.04 APPEAL AND REVIEW PROCESS:

Bank shall have a provision for reviewing the appeals of the customers. lf any complainant is notsalisfied with the decision of the bank regarding the resolution of his complaint. he/she mayappeal to the upper tier of the bank. ln such cases the bank shall review the whole process ofthe complaint resolution conducted by the bank in the first instance and may collect furthernecessary documents for better judgment. Then the bank shall determine whether they willuphold the original decision or review it. The revlew process should be conducted by a differentset of people or team and they should demonstrate impartiality and credibility to thecomplainants.

lf any complainant still remains dissatisfied with the decision of the bank, he/she may lodge a

formal complaint to the Bangladesh Bank along with the supporting documents and the copy ofbank final decision about the complaint.

c)

d.

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3.04.05 RESPONSES AND CI.OSURE:

Banks shall-

1) Convey the resolution status to the complainant2) Convey the reason if the decision goes against the complainant and then close the file.

3.05 ATTITUDE AND ATTRIBUTES OF COMPLAINT HANDLING OFFICIALS (CHO):

The bank shall ensure that the complaint handling officials sholld have at least the followingattitude and attributes. :

a) Commitment: Attitude and commitment of the Management are reflected generally in theconduct of the employees and the performances of the company. Theircommitment to effective complaint management establishes the motive and incentives forall personnel to strive for customer satisfaction. 5o Management will ensure committedattitude for complaint handling staffto handle each complaint responsively.

b) lmpartiality and fairness: The impartiality and fairness are the crucial attributes for theofficials involved in complaint management to handle the complaints properly and

accurately. lf the designated officials have vested interest in the outcome of the

dealin8s/lnvestigation, it may undermine the complaint handling process and can cause

further distress to those concerned, Therefore, the mana8ement shall ensure impartiality

and fairness of the officia15 in all aspects of complaint handling procedure.

c) Competency: The official5 assigned for investiBations should have sufficient knowledBe and

skills to take appropriate action and/or decision to settle the complaints. So Management

shall ensure competency and efficiency of Complaint Management Team.

d) Avoiding conllict of interest A conflict of interests exists when an employee has a personal

interest that may lead to interfere potentially with his/her objectivity in performing his/her

duties or exercising his/her judgment on behalf of bank. so Management shall monitor and

motivate to avoid conflict of interest for Complaint Handling Staff.

3.06. TIME I.IMIT FOR COMPLAINT RESOLUTION:

NRBC Eank shall set a time limit in the initiatin8 and disposal leve' of the complaints as

mentioned below:

Guidelines forCustomer Serviccs and Complaint Management- NRBC Bank Page 21

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SL No Nature of Complaints/actions lnitiatinB tevel Di5posalLevel Time Limit1 FAQ CallCentre callCentre lnstantly2 Highly Sensitive but No

investigation Required

Complaint

Handling Officer(cHo)

Head ofComplaint Cell

(Hcc)

3 days

3 HighlySensitive and

investigation requiredcHo cEo

4 Sensltlve and a lot of moneyinvolved.

cHo cEo 5 days

5 Sensitive but a little amount ofmoney involved

cHo HCC 3 days

6 General complaints cHo HCC 3 days1 Response to complaints cHo HCC Within 3

days afterresolution

lf any complaint cannot be resolved within stipulated time due to any unavoidablecircumstances, the CHO shall explain the facts to the HCC and will issue reminder Eivin8another 3/5 five days time limit for response or settlement. Similarly, if any investigationrequires a long process and requires additional times, HCC will convey the fact to CEO andmonitor the investigation process time to time and fix up time limit a8ain.

3.07. CONTROI. AND COMPLIANCE

3.07.01 COMPLIANCE TO BANGLADESH BANK

a) NRBC Bank shall comply with Bangladesh Eank's advice/order in the matter ofhandling complaints again5t them. ln retard to all first resort complaint5 forwarded

by 88, the bank shall resolve the complaints in the shortest possible time and informBB accordingly.

b) When BB calls for opinions/comments/explanations on the complaints received orany additional information/documents from the bank, the same should be furnished

withinthe stipulatedtime mentaoned in the letterofBB.

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c) When BB asks the bank to investigate about a particular complaint, the bankconcerned should submit the findings from its investigation along with the copies ofsupporting documents to BB within the stipulated time.

When awards/decision on a particular complaint is passed by BB and BB orders thebank to implement such awards/decision or take administrative/punitive actionagainst the staff/official(s) concerned in the case of proven allegations, the bankshould comply with such advice/order within the stipulated time and inform BBaccordintly,

3.07.02 COMPLIANCE OF THE GUIDELINES:

a) BB shall determine appropriate sanctions under the gank Company Act, 1991(Amended up to 2013) against the bank, if fails to comply with the requirements ofthe 6uidelines.

3.08. REWARD AND PUNISHMENT:

Bank should have reward and punishment provision for their officials for the compliance ofthe Guidelines. Bank officials, who shall perform with the best practices of the guidelines.may be rewarded or recognized under the bank's existing policy. Simultaneously, bankshould have the punishment provision for the officials who are reluctant or noncompliancewith the requirement of the guidelines.

Where allegations of fraud,forgery, embezzlement of money or any irregularity raised bycustomers or any media including print and electronic media against one or more officials ofbank and the saad alle8ations appeared true in the inquiry/investi8ation conducted by thebank, then bank shall take disciplinary action or appropriate punishment measures againstthose officials under the existing rules and procedure of the bank.

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3.09. ROOT CAUSE ANALYSIS AND POLICY FORMULATION:

Complaint information provides a plcture of weaknesses in existing products, policies, andservices and system of the bank. Complaints are also rich source of information about theperformance of the bank and the necessary improvements it might make. This is possiblewhen good records of complaints are kept and the information is regularly analyzed. Theanalysis should cover the followings:

. ldentify customer service areas in which the complaints are frequently receivedj

. ldentify frequent sources of complaint-whether they are businesses, communitygroup5 or individuels.

. ldentify systemic deficiencies;

' The Eeographical spread of complaints etc.

Numerous on8oing complaints about the same thin8 are usually a sign of a systemic orrecurrent problem that requires further investigation and possible action by the bank. tt is

Sood practice for bank to produce rcgular reports on complaints for presentation to seniormana8ement. lnformation of this nature can help organizatjons improve services, safeguardtheir reputation and better prepare for the future.

Eank shall analyze the complaint data in various ways, but care must be taken in theinterpretation- lt is important not to look for only one cause of a problem: often therewill be several, such as process, behavioral, system and organizational causes.Effective root-cause analysis of complaints inrormation (how did this particular problemhappen?) should be carried out by a team of people in the bank who have a range of skillsand organizational knowledge. The likelihood recurrence of the problems and complaintscan be reduced only if the root causes of problems are identified and dealt with in a

coordinated way.

Bank should regularly review and analyze their complaint handlinB systems to measure thesystems' efficiency and effectiveness. Both quantitative measurement (for example, thenumber of complaints resolved in a given period) and qualitative measurement (forexample, the degree of customer satisfaction with the process) should be undertaken. Amajor element of tood complaint handlint, and one that i5 relatively easy to measure, is

timeliness-at each sta8e of the process and overall. How customers feel at the end of thecomplaint process is equally important. Customer satisfaction can be accessed throughroutine feedback from complainants and by periodic surveys. ln order to practice an effectiveRoot cause analysis NRgC bank shallconsider four elements (1) Sources ofthe complaints (2)

Reason for the complaints (3) tnvolvements (4) Quick Measure to resolve the complaintswhich ultimately provide satisfaction to the concern customers

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Complaint information can also be useful for staff management. lt can identify lndividualstaff members or teams that are performin8 well, as well as those that are not. lnformationabout problem areas and common concerns can also help the bank to determine stafftraining and development needs.

Having considered all these thinSs the bank should have a system of effective root causeanalysis for better performance in up cominB days.

Process flow ofeffective ComDlaint manaqement

"-n\>

Cuidelines for Customer Serices and Complaint Management- NRBC Bank Page 25

^,,,.",.,,." ^"",.

^-t>idd.. Yh / -/'

"-,.::il.:*.(-..-J

Page 29: Customer Service 2015

ANNEXURE-A

SERVICE STANDARD OF NRBC BANK TIMITED

lnitl.tinglevel(Customer service Point)

Dlsposal L€velTotalTime Limit

{ouratro.')

1. Cufi€ntA/C, SND A/c2. savinE A/c, shohoi sanchay3. FDR/TBDS/ M8S/ D8D54. MMs/Corporat€ Money Maker

/Student Savings Scheme/Lakhopotisavings scheme/ Millionaire SavinssScheme/ Priority Deposit Scheme/Deposit Pension Scheme

5 8 Minutes 2 5 Mlnutes 7 13 Minutes

Cash Cheque payment

1. High value 13 Minutes

12 Min'rtes

13 Minutes

l Minute

2-5 Minutes

2-3 Minutes

1.3 Minutes l Minute 2 4 Min!tes

Domesric ChequeClearine 12 Minutes 1 Day 1 Oay

For€i8n cheque Cle.rin8 1 2 Minutes 2'5 Oays 2 S Days

Shorr Term Loan sanction 1-3 Days 7-10 Days 7 10 Days

LonE Term Loan sanction 1-5 Days 15 30 Orys 15 30 Days

lssueof POlDD

1. localPO/DD

2. Foreign OO

2-3 Minutes

10'20 Minutes

1'2 Minutes

5-10 Minutes

3 5 Minutes

15-30 Minutes

utiliry Bill.eceipt I 2 Mlrutes 1 2 Minutes

BillPayment Depends on nature of bill

1 Master LC

2 BTB LC

Sime Day

Sam€ Oay

same oay

Same Day Same Day

Bank Guarantee issuance 10 20 Minutes 10 Minut€s 10-30.MinLrtes

BillAcceptance 5 10 Minutes 15 Minutes 6 15 Minut€s

lssuingCheqire Book 12 Minutes 2'4 Days 2-4 Days

Balanc€ conf irmation Certif icaie

2. lnstitut ional A/C

1 2 Minules 2 3 Minutes 3'5 Minutes

Starement of Account issue l Minule 2 Mioutes 3 Minutes

lssuing Debit/Credit Grd 12 Minutes 2 3 Dayt 2 3 Days

Page 30: Customer Service 2015

ANNEXURE.E

SAMPLE OT' COMPLAINT REGISTER

5lNo.

oateof

receipt

Name &

theComDlainant

Subject Conc€rnedBranch/Oflicial

ResolutionStatus

SettlementDate

ComplaintHandlingOfficer

Remark

1 2 3 4 5 6 7 8 9

Cuidelines for Customer Services and Complaint Management- NRBC Bank PaEe 27

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ANNEXURE.C

COMPLAINT LODGMEN'T FORM TEMPLATE

lqfumt't qtfrnat ryr zri)

To ({c]Tr)

subiect (Av4:

Concerned Branch/Officials:(cv?t {nF r,v^tu)

Details of the Complaint (Please add pages if required):tqfur@rv f4.ii (stqlwn q&FE dI ?r{{r

".fi )l

wha t yo u like u s to d o (qtrlzrr 6'!'t /+-f{ s&rlf rrd):

Signature(al,") Date (sfi")

Full name(?-.|al{):

Add ress(1tr,"4:

Phone numb€(r4oF4r<): t ma il(l-.Tiz)

Cuidelines forCustomer Services and Complaint Managemcnt- NRBC Bank

Aw9

Page 28

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ANNEXURE.D

MONTHLY/QUARTERLY STATEMENT OF COMPUIINTS

For the month/quarter

*lratua€ o, complalnts

. GeneralBanking

. loans & Advances

. Debit Ca.d/Credir CardlAIM card

. Mobile BankinS

. lnternet BankinS

. Remittance

. lmport Bill (Local)

. lmport gil! (ForeiSn)

. Export Related

. Eank Guarantee

. Miscellaneous

Dat€ IDDate

1 2 3 4 5 6 8 9 10 11

Guidelines for Cu stomer Services and Complaint Management 29