Skundų nagrinėjimo politika

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)	info@tet.lt
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.tet.lt — 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 the applicable statutory or internal deadline. For complaints submitted by consumers within the meaning of Lithuanian consumer protection legislation, the Company must provide a detailed, reasoned written response within 14 calendar days of receiving the consumer’s written complaint, unless a different statutory deadline applies. The response must address the consumer’s demands and, where those demands are rejected in whole or in part, explain the grounds for the decision and provide relevant supporting documents. For complaints not subject to this statutory deadline, the Company aims to provide a final written 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 complaints within twenty (20) business days of acknowledgement, except where a shorter statutory deadline applies. Consumer complaints falling within the scope of Article 21 of the Lithuanian Law on Consumer Rights Protection must receive a reasoned written response within 14 calendar days of receipt. This statutory deadline cannot be extended merely because the complaint is complex or requires additional internal investigation. Where a non-consumer complaint cannot be resolved 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.

For complaints not subject to a shorter mandatory statutory deadline, the Company aims to complete its internal investigation within a maximum of eight (8) weeks from receipt. If the investigation remains incomplete, the Company will explain the reasons for the delay and the available escalation options. This internal timeframe does not override mandatory consumer protection deadlines or restrict the complainant’s right to seek assistance from a competent authority or court. In particular, consumers may refer eligible disputes to the State Consumer Rights Protection Authority (VVTAT) if their demands are rejected in whole or in part, or if the Company fails to provide a response within 14 calendar days.

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 dissatisfied with the handling or outcome of their complaint, they may request a further internal review by the Director of the Company, preferably within twenty (20) business days of receiving the final response. This internal review is voluntary and does not restrict, postpone or replace any statutory right to seek external dispute resolution, report concerns to a competent supervisory authority or initiate court proceedings. Consumers are not required to exhaust the Company’s internal escalation procedure before referring an eligible unresolved consumer dispute to VVTAT, provided that the applicable statutory requirements have been met.

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

Complainants may contact a competent supervisory authority, consumer dispute resolution body or court whenever permitted under applicable Lithuanian or EU legislation. They are not required to complete the Company’s voluntary internal escalation procedure before exercising these rights. The appropriate external body depends on the nature of the complaint, the legal status of the complainant and the activity or professional conduct concerned. Relevant external bodies may include:

6.2.1 State Consumer Rights Protection Authority (VVTAT)

Clients qualifying as consumers under Lithuanian law may refer eligible unresolved consumer disputes to the State Consumer Rights Protection Authority (VVTAT). Consumers must generally first submit a written complaint to the service provider, specifying their demands. If the Company rejects those demands in whole or in part, or fails to provide a reasoned written response within 14 calendar days, the consumer may apply to VVTAT for out-of-court dispute resolution. The consumer must also comply with the applicable statutory submission deadlines. This procedure does not generally apply to disputes arising from services acquired for business or professional purposes.

6.2.2 Lithuanian Bar Association

Complaints concerning the professional conduct of an advocate (advokatas) or an advocate’s assistant (advokato padėjėjas) may be referred to the Lithuanian Bar Association (Lietuvos advokatūra), provided that the professional falls within its disciplinary jurisdiction. The Lithuanian Bar Association does not supervise all legal consultants, company formation advisers or other persons providing legal-related services. Complaints concerning such service providers must be directed to the appropriate competent authority or resolved through applicable contractual and judicial procedures.

6.2.3 Lithuanian Chamber of Auditors

Complaints concerning statutory audit quality or possible violations of Lithuanian audit legislation may be submitted to the Authority of Audit, Accounting, Property Valuation and Insolvency Management (AVNT), which exercises public oversight of statutory auditors and audit firms in Lithuania. The Lithuanian Chamber of Auditors also performs professional functions within its statutory competence. The appropriate authority depends on the nature of the alleged misconduct. Ordinary bookkeeping or accounting service disputes should not automatically be referred to the Lithuanian Chamber of Auditors.

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

Complainants retain the right to seek judicial protection before a court having jurisdiction under applicable Lithuanian law, EU legislation and relevant international agreements. The applicable law and competent court depend on the contractual arrangements, the parties’ circumstances and mandatory legal provisions. A contractual choice of Lithuanian law or jurisdiction cannot override mandatory consumer protection rules or jurisdictional provisions established by Regulation (EU) No 1215/2012 and other applicable legislation. The Company’s Complaint Handling Policy does not restrict a client’s statutory right to bring proceedings before a competent court.

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 only for as long as necessary to fulfil the purposes for which they were collected, comply with applicable legal obligations and establish, exercise or defend legal claims. The Company may apply a standard retention period of up to five (5) years following closure of a complaint where justified by the applicable legal basis and documented retention policy. Records may be retained for longer where required by law or necessary in connection with ongoing proceedings. Personal data must be securely deleted or anonymised when the applicable retention period expires, in accordance with the GDPR storage limitation principle.

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 in connection with complaints is processed for the purposes of receiving, investigating, resolving and documenting complaints, complying with applicable legal obligations, improving service quality where appropriate, and establishing, exercising or defending legal claims. Processing must be based on an appropriate legal ground under Article 6 of the GDPR. Personal data may be shared with authorised service providers, professional advisers, insurers, competent authorities or courts where a valid legal basis exists and appropriate data protection safeguards are applied. The Company applies data minimisation, access restrictions and appropriate retention periods in accordance with the GDPR.

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.tet.lt.

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.