Complaints Procedure

In this regulation, the following terms are defined as: a. Agency: SAJ Recherche B.V., established in Amsterdam, registered with the Chamber of Commerce under number 96790954. b. Client: the natural person or legal entity with whom the Agency has concluded a written contract of engagement for the performance of investigation services, and then only as from the moment at which such contract has come into effect. c. Data subject: the natural person who is the subject of an investigation or whose personal data are processed in the context of an investigation. d. Complaint: a written expression of dissatisfaction about the Agency's services, the conduct or omission of employees, or the processing of personal data. e. Complainant: solely the Client or the Data subject who submits a complaint in accordance with this procedure. Expressly not regarded as a Complainant are (prospective) clients, applicants or other parties with whom no agreement has been concluded and who have approached the Agency only at the preliminary, exploratory stage; no right to invoke this procedure accrues to them. f. Complaints officer: the person designated by the Agency to handle complaints.

2.1 This complaints procedure applies solely to complaints submitted by (i) Clients with whom an agreement for services has been concluded and (ii) Data subjects in an investigation carried out or completed by the Agency. It covers investigation services, TSCM inspections, background checks and other services performed pursuant to such an agreement.

2.2 The procedure expressly does not apply to, and cannot be invoked by, persons or parties with whom no agreement has been concluded and who have approached the Agency only at the preliminary, exploratory stage. Any contact, correspondence, intake meeting, quotation, exploratory discussion or other exchange prior to the conclusion of an agreement creates no legal relationship to which this procedure applies and gives no right to the handling of a complaint.

2.3 The Agency is free at all times, for as long as no assignment has been entered into, to refuse a (prospective) assignment, to terminate the services or to withdraw, without stating any reason and without being liable to any compensation or accountability in that respect. Such a decision can never be the subject of a complaint under this procedure.

3.1 A complaint must be submitted in writing to the Agency's complaints officer, by email to [email protected] or by post to SAJ Recherche B.V., attn. Complaints Officer, Amsterdam.

3.2 The Complainant is required to identify themselves properly when submitting the complaint. To that end, the complaint must state at least the following details of the Complainant: (i) full name, (ii) address, (iii) place of residence, (iv) email address and (v) telephone number.

3.3 In addition to the identification details referred to in article 3.2, the complaint must contain at least a description of the complaint, the date or period to which the complaint relates, and any relevant documents or evidence.

3.4 Anonymous complaints, as well as complaints in which the identification details referred to in article 3.2 are missing or incomplete, will not be taken into consideration. The Agency is entitled to request the Complainant to further substantiate their identity before the complaint is taken into consideration.

The complaints officer acknowledges receipt of the complaint within five (5) working days. The acknowledgement states: the name of the complaints officer, a summary of the complaint, the expected timeframe for resolution, and the procedure that will be followed.

The complaints officer investigates the complaint carefully and impartially. Where relevant, both sides are heard. The complaints officer may request additional information from the complainant, the employee(s) involved and any third parties. The complainant is given the opportunity to explain the complaint orally if desired.

The complaint is resolved within four (4) weeks of receipt. If the complaint cannot be resolved within this period, the complainant is informed in writing, stating the reason for the delay and the new expected resolution date. The maximum resolution period is eight (8) weeks after receipt of the complaint.

The complainant receives a written and reasoned decision regarding the complaint. The decision states: whether the complaint has been declared well-founded, partially well-founded or unfounded, the reasoning behind the decision, any measures taken by the Agency, and the options available to the complainant if they disagree with the decision.

If the complaint is declared wholly or partially well-founded, the Agency takes appropriate measures to prevent recurrence. These measures may include: an apology to the complainant, adjustment of working methods or procedures, additional training for employees involved, and/or offering appropriate compensation.

If the complainant disagrees with the decision, they may file a written appeal with the Agency's management within four (4) weeks of the decision. The management will decide on the appeal within four (4) weeks. The management's decision is binding.

Without prejudice to the right of appeal, the complainant may at any time contact: a. The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) for complaints about the processing of personal data. b. The Ministry of Justice and Security (Screening Authority) for complaints about the Agency's professional conduct. c. The competent court for disputes of a legal nature.

All information provided in the context of the complaints procedure is treated confidentially. The complaint and its outcome are shared only with those directly involved in the handling of the complaint. Personal data are processed in accordance with the General Data Protection Regulation (GDPR).

The Agency registers all complaints received and the manner of their resolution. The complaints register is evaluated annually with the aim of improving the quality of services. The register is retained for a period of five (5) years.

There are no costs to the complainant for filing and handling a complaint.

This complaints procedure takes effect on 1 January 2025 and replaces all previous versions. The Agency reserves the right to amend this procedure. Amendments are published on the Agency's website. This procedure is governed by Dutch law.