Complaint Handling Policy
1. Purpose and Scope
Company in Lithuania UAB (hereinafter: the “Company”, “we”, or “us”), incorporated in the Republic of Lithuania under registration number 304377400, with its registered address at Lvovo g. 25–104, Vilnius, 09320, Lithuania, is committed to providing high-quality professional services to all of its clients. We recognise, however, that from time to time clients may be dissatisfied with the services they receive or with any aspect of our conduct, communication, or billing.
This Complaint Handling Policy (hereinafter: the “Policy”) establishes the procedures by which the Company receives, acknowledges, investigates, and resolves complaints from clients and other affected parties. It reflects the Company’s commitment to treating complaints as an opportunity to improve its services and to maintaining the highest standards of client care.
1.1 Scope of Application
This Policy applies to:
- All clients of the Company, whether current, former, or prospective;
- Any other person who has been directly affected by the Company’s provision of services and who wishes to raise a concern or complaint;
- All directors, employees, consultants, and agents of the Company who receive or handle complaints.
1.2 What Constitutes a Complaint
For the purposes of this Policy, a complaint is any expression of dissatisfaction — whether oral or written — made by or on behalf of a client or affected person, relating to:
- The quality, accuracy, or completeness of a service provided by the Company;
- A failure by the Company to meet an agreed deadline or deliverable;
- The conduct, communication, or professional behaviour of any employee, director, consultant, or agent of the Company;
- A billing dispute or disagreement regarding fees charged;
- A failure by the Company to respond adequately to a previous request, query, or communication;
- Any other aspect of the Company’s services or operations that has caused or is likely to cause detriment to the complainant.
Requests for services, general enquiries, and feedback that do not express dissatisfaction are not complaints within the meaning of this Policy, though we value all such communication and will respond to it promptly.
2. Guiding Principles
The Company handles all complaints in accordance with the following principles:
2.1 Accessibility
Complaints may be submitted through multiple channels and in multiple languages. We do not impose unreasonable formal requirements on the submission of a complaint. Any person who is dissatisfied with our services should feel confident that they can raise a concern without procedural obstacles.
2.2 Fairness and Impartiality
Every complaint is investigated impartially and with an open mind. The person who handled the matter complained of is not responsible for assessing the complaint — complaints are reviewed by a person who was not directly involved in the matter giving rise to the complaint, wherever possible.
2.3 Timeliness
We acknowledge complaints promptly and aim to resolve them within the timescales set out in Section 4 of this Policy. Where a complaint requires a more extended investigation, we keep the complainant informed of progress at regular intervals.
2.4 Transparency
We explain our investigation process clearly, communicate our findings fully, and explain the reasons for any decision we reach. Where we uphold a complaint, we explain what steps we will take to remedy the situation. Where we do not uphold a complaint, we explain why, clearly and honestly.
2.5 Confidentiality
Complaints and the information provided in connection with them are treated as confidential. Complaint information is not disclosed to third parties without the complainant’s consent, except where disclosure is required by law, by a regulatory authority, or by a court of competent jurisdiction.
2.6 No Retaliation
No person who submits a complaint in good faith shall be subject to any adverse treatment by the Company as a result of having submitted that complaint. Our commitment to a client relationship is not affected by the fact that the client has raised a complaint.
2.7 Continuous Improvement
We treat complaints as a source of information about areas where our services can be improved. The outcomes of complaints are reviewed periodically to identify systemic issues and to implement improvements that prevent recurrence.
3. How to Submit a Complaint
3.1 Submission Channels
A complaint may be submitted through any of the following channels:
| Channel | Contact Details |
|---|---|
| Email (preferred) | [email protected] |
| Post | Complaints Officer, Company in Lithuania UAB, Lvovo g. 25–104, Vilnius, 09320, Lithuania |
| In person | By appointment at our registered office: Lvovo g. 25–104, Vilnius, 09320, Lithuania |
| Online form | Via the contact form on our website at www.companyinlithuania.com — please mark the subject as “Complaint” |
3.2 Languages
Complaints may be submitted in English, Lithuanian, or Russian. Where a complaint is submitted in another language, we will make reasonable efforts to arrange for translation and to respond in the language of the complaint where practicable.
3.3 Information to Include
To enable the Company to investigate a complaint effectively and without delay, complainants are encouraged to provide the following information:
- Full name and contact details (email address, postal address, telephone number);
- A description of the service or engagement to which the complaint relates, including the approximate date(s) on which the events giving rise to the complaint occurred;
- A clear description of the nature of the complaint — what happened, how it affected you, and what outcome you are seeking;
- Copies of any relevant correspondence, documents, or evidence that support the complaint;
- Details of any previous attempt to resolve the matter informally with the Company.
The Company will not reject a complaint solely because not all of the above information has been provided — we will contact the complainant to request any additional information needed to progress the investigation.
3.4 Oral Complaints
Where a complaint is submitted orally — in person or by telephone — the Company will make a written record of the complaint, confirm the details with the complainant, and provide the complainant with a copy of the written record or a written acknowledgement of the oral complaint. The complaint will then be treated in accordance with the written complaint procedure set out in this Policy.
4. Complaint Handling Procedure
All complaints are handled in accordance with the following five-stage procedure:
| 1 | Acknowledgement — within 2 business days Upon receipt of a complaint, the Company sends a written acknowledgement to the complainant confirming: (a) that the complaint has been received; (b) the reference number assigned to the complaint; (c) the name and contact details of the person responsible for handling the complaint; and (d) the expected timeline for investigation and response. |
| 2 | Initial Assessment — within 3 business days of acknowledgement The Complaints Officer or the designated responsible person carries out an initial assessment of the complaint to determine: (a) whether the complaint falls within the scope of this Policy; (b) whether any immediate interim action is required to prevent ongoing harm; (c) the appropriate level of investigation required; and (d) whether the complaint involves a matter that should be referred to a senior decision-maker. |
| 3 | Investigation A thorough and impartial investigation is conducted. This includes: reviewing all relevant files, correspondence, and records relating to the matter complained of; speaking with the employee(s) involved where appropriate; obtaining any relevant information from third parties where necessary; and assessing whether the Company’s services, conduct, or billing met the standard reasonably expected of a professional services firm. |
| 4 | Decision and Response — within 20 business days of acknowledgement The Company issues a written final response to the complainant setting out: (a) the findings of the investigation; (b) the decision on the complaint — upheld, partially upheld, or not upheld; (c) the reasons for the decision; (d) any remedial action the Company will take; and (e) information on the complainant’s right to escalate the matter further if they remain dissatisfied. |
| 5 | Closure and Follow-Up The complaint is recorded in the complaints register and closed. Where the Company has committed to remedial action, implementation is monitored. Where the complainant accepts the resolution offered, the matter is closed. Where the complainant remains dissatisfied, the escalation routes set out in Section 6 are communicated. |
4.1 Timescales
The Company aims to resolve all complaints within twenty (20) business days of the date of acknowledgement. Where a complaint is complex and cannot be fully investigated within twenty business days, the Company will:
- Inform the complainant in writing before the expiry of the twenty-business-day period;
- Explain the reasons for the delay and provide an estimated revised completion date;
- Provide progress updates at no less than two-week intervals until the investigation is complete.
In exceptional cases, the maximum period for resolving a complaint is eight (8) weeks from the date the complaint is received. If a complaint has not been resolved within eight weeks, the Company will issue a written explanation of why the complaint has not been resolved and confirm the complainant’s right to pursue external escalation as set out in Section 6.
4.2 Responsible Person
Each complaint is assigned to a designated Complaints Officer or another appropriate member of the Company’s management who was not directly involved in the matter giving rise to the complaint. The assigned person is responsible for managing the complaint through all stages of the procedure and for maintaining communication with the complainant throughout. The name and direct contact details of the assigned person are provided in the acknowledgement letter.
4.3 Interim Measures
Where a complaint raises concerns that may cause ongoing harm to the complainant — for example, a dispute about a service that is ongoing, or a billing matter affecting an active engagement — the Company may take interim action to pause or modify the relevant activity while the investigation is conducted. Any interim action taken will be communicated to the complainant promptly.
5. Remedies and Redress
Where the Company upholds or partially upholds a complaint, it will offer an appropriate remedy proportionate to the nature and impact of the complaint. Available remedies include:
5.1 Apology and Acknowledgement
Where the complaint identifies a failure in the Company’s service, conduct, or communication, the Company will provide a written apology acknowledging the failure and explaining what steps have been or will be taken to prevent a recurrence.
5.2 Service Correction
Where a complaint identifies an error in a document, filing, advice, or other deliverable prepared by the Company, the Company will correct the error promptly at no additional charge to the client and will confirm the correction in writing.
5.3 Fee Adjustment or Refund
Where a complaint relates to billing — including the charging of fees not agreed in advance, the application of incorrect rates, or the billing for work that was not performed to the agreed standard — the Company will review the relevant invoices and, where the complaint is upheld, will issue a credit note, adjust the outstanding invoice, or arrange a refund as appropriate.
5.4 Service Remediation
Where a complaint identifies that a service was not delivered to the agreed standard or within the agreed timeframe, and the deficiency has resulted in a quantifiable loss to the client, the Company will assess the appropriate remediation and discuss the proposed remedy with the complainant in good faith.
5.5 Process Improvement
Where a complaint identifies a systemic issue — a process failure, a communication gap, or a recurring error pattern — the Company will implement the improvements identified and confirm to the complainant what changes have been made. This may not constitute a direct financial remedy but reflects the Company’s commitment to preventing the recurrence of similar issues.
The remedy offered will be communicated in the final written response and, where the complainant accepts the proposed remedy, the complaint will be closed on those terms. Where the complainant does not accept the proposed remedy and wishes to pursue further escalation, the procedures in Section 6 apply.
6. Escalation and External Redress
6.1 Internal Escalation
Where a complainant is not satisfied with the initial handling of their complaint or with the decision communicated in the final response, they may request that the complaint be reviewed by the Director of the Company. A request for internal escalation must be made in writing within twenty (20) business days of the date of the final response and must explain why the complainant considers the initial decision to be incorrect or insufficient.
The Director will conduct an independent review of the complaint and the initial decision and will issue a written escalation response within ten (10) business days of receiving the escalation request.
6.2 External Escalation — Supervisory Authorities
Where a complainant remains dissatisfied following the Company’s internal escalation process, they have the right to raise the matter with the appropriate external authority. Depending on the nature of the complaint, the relevant external authorities include:
6.2.1 State Consumer Rights Protection Authority (VVTAT)
Clients who are consumers — natural persons acting outside the scope of their business or professional activities — may submit a complaint to the State Consumer Rights Protection Authority (Valstybinė vartotojų teisių apsaugos tarnyba — VVTAT) where the complaint relates to a consumer service provided by the Company. Contact details: www.vvtat.lt.
6.2.2 Lithuanian Bar Association
Where the complaint relates to the conduct of a lawyer or legal professional acting on behalf of the Company, the matter may be referred to the Lithuanian Bar Association (Lietuvos advokatūra) for assessment under its professional conduct framework. Contact details: www.advokatura.lt.
6.2.3 Lithuanian Chamber of Auditors
Where the complaint relates to audit or assurance services provided by a licensed auditor engaged by or through the Company, the matter may be referred to the Lithuanian Chamber of Auditors (Auditorių rūmai). Contact details: www.auditoriai.lt.
6.2.4 Financial Crime Investigation Service (FNTT)
Where the complaint relates to the Company’s handling of AML/CTF obligations, a concern may be submitted to the Financial Crime Investigation Service (Finansinių nusikaltimų tyrimo tarnyba — FNTT). Contact details: www.fntt.lt.
6.2.5 Lithuanian Courts
The complainant retains the right at all times to seek resolution through the Lithuanian courts. Disputes between the Company and its clients are subject to the jurisdiction of the courts of the Republic of Lithuania, and Lithuanian law applies to all service agreements unless otherwise expressly agreed in writing.
6.2.6 Alternative Dispute Resolution
The Company is prepared to participate in appropriate alternative dispute resolution processes — including mediation conducted under the auspices of the Lithuanian Mediation Centre or another mutually agreed ADR provider — where the complainant requests such a process and where it is appropriate to the nature of the dispute.
7. Complaint Records and Reporting
7.1 Complaints Register
The Company maintains a complaints register recording the following information for each complaint received:
- The date on which the complaint was received;
- The name and contact details of the complainant;
- A summary of the nature of the complaint;
- The reference number assigned to the complaint;
- The name of the person assigned to handle the complaint;
- The key dates in the complaint handling process (acknowledgement, investigation completion, final response);
- The outcome of the complaint (upheld, partially upheld, not upheld);
- The remedy offered and whether it was accepted by the complainant;
- Whether the complaint was escalated and the outcome of any escalation.
7.2 Retention
Complaint records are retained for a minimum period of five (5) years from the date on which the complaint is closed, in accordance with applicable data protection law and the Company’s general records retention policy.
7.3 Periodic Review
The Complaints Officer or the Director reviews the complaints register at least quarterly to identify any patterns, recurring issues, or systemic concerns. The outcomes of the periodic review are used to inform improvements to the Company’s services, processes, and communication practices. A summary of complaints received and their outcomes is included in the Company’s annual internal review.
8. Data Protection
Personal data collected in connection with a complaint is processed by the Company in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 — GDPR) and the Law of the Republic of Lithuania on Legal Protection of Personal Data. Personal data collected for complaint handling purposes is used solely for the purpose of investigating and resolving the complaint and is not shared with third parties except where required by law or by a competent authority.
Complainants have the right to: access the personal data held about them in connection with their complaint; request correction of inaccurate data; request deletion of their data subject to applicable retention obligations; and lodge a complaint with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija — VDAI) at www.vdai.lrv.lt if they consider that their data protection rights have been infringed.
The Company’s full Privacy Policy, which describes all personal data processing activities, is available on the Company’s website at www.companyinlithuania.com.
9. Policy Review and Updates
This Policy is reviewed and updated at least annually by the Director of the Company. The Policy may also be reviewed and updated at any time in response to:
- Changes in applicable Lithuanian or EU legislation or regulatory guidance relevant to complaint handling;
- Significant changes in the Company’s services or client base;
- Recurring complaint patterns that indicate a need for procedural revision;
- Feedback from clients or from external authorities regarding the adequacy of the complaint handling process.
The current version of this Policy is published on the Company’s website and is available to all clients on request. Previous versions are retained in the Company’s records.