Clause 1 Definitions 

In this office complaints procedure, the following definitions shall apply: 

- complaint: any written expression of dissatisfaction by or on behalf of the client towards the lawyer (advocaat) or the persons working under its responsibility regarding the conclusion and/or the execution of an agreement for services, the quality of the services or the fee amount, not being a complaint as referred to in section 4 of the Dutch ‘lawyers act’ (Advocatenwet). 

- complainant: the client or its representative who makes a complaint; 

- complaints officer: the lawyer in charge of handling the complaint.

Clause 2 Scope of procedure 

1. This complaints procedure applies to every engagement between HSA Lawyers (also: ‘the firm’) and the client. 
2. Any fee-earner of HSA Lawyers shall ensure that complaints are handled in accordance with this complaints procedure.

Clause 3 Purpose 

The purpose of this complaints procedure is to:
a. establish a procedure to deal constructively with client-complaints within a reasonable period of time;
b. establish a procedure to determine the causes of client complaints; 
c. maintain and improve existing relationships through proper complaint handling;
d. train our employees in dealing with client-complaints in a client-centred way; and
e. improving the quality of our services through complaint handling and complaint analysis.

Clause 4 Information at start of rendering services

1. This complaints procedure has been made public via HSA Lawyers' website. Before entering into the engagement agreement, the responsible fee-earner informs the client that the firm has a complaints procedure and that it applies to the provision of services.
2. HSA Lawyers will make it unambiguously clear in writing to the complainant to which independent party or body a complaint that has not been resolved through the complaints procedure can be submitted for a binding decision.
3. A complaint not resolved by means of the complaints procedure shall be submitted to the Court of first instance (Rechtbank) of The Hague.

Clause 5 Internal complaints procedure

1. If a client files a complaint with the firm, the complaint will be forwarded to Mr H.H. van Efferink, who acts as complaints officer. If the complaint concerns Mr H.H. van Efferink or a file handled by or under the responsibility of Mr H.H. van Efferink, the complaint will be passed on to Mr G.-J. van Dalen, who acts as complaints officer in such cases. If Mr H.H. van Efferink is unavailable, Mr G.-J. van Dalen will act as complaints officer, except if the complaint concerns Mr G.-J. van Dalen or a file handled by or under the responsibility of Mr G.-J. van Dalen, in which case Mr R. Geurts will act as complaints officer. 
2. The complaints officer will notify the concerned person about the fact that a complaint has been filed and will give the complainant and the person the complaint sees to, the opportunity 2 to provide an explanation.
3. The person the complaint sees to shall try to reach a solution together with the client, with or without the intervention of the (acting) complaints officer.
4. The complaints officer shall resolve the complaint within four weeks of receiving it, or shall notify the complainant of any deviation from this deadline, stating the reasons, and indicate the deadline by which a decision regarding the complaint will be made.
5. The complaints officer shall notify the complainant and the person the complaint sees to in writing of its decision regarding the (in)validity of the complaint and, where appropriate, such decision may include recommendations.
6. If the complaint is resolved satisfactorily, the complainant, the complaints officer and the person the complaint saw to shall sign a settlement instrument regarding the (in)validity of the complaint.

Clause 6 Confidentiality and costs

1. The complaints officer and the person the complaint sees to shall observe confidentiality in dealing with any complaints.
2. The complainant shall not be charged for the costs of handling the complaint through this complaints procedure.

Clause 7 Responsibilities

1. The complaints officer shall be responsible for the timely handling of any complaints.
2. The person the complaint sees to shall keep the complaints officer informed about any contact and possible resolution of the complaint.
3. The complaints officer shall keep the complainant informed about the handling of the complaint.
4. The complaints officer shall maintain a file concerning the complaint.

Clause 8 Registration of complaints 

1. The complaints officer shall register the complaint, including the subject of the complaint.
2. A complaint may pertain to more than one topic.
3. The complaints officer shall report periodically on the handling of complaints and issue recommendations to prevent new complaints and to improve procedures.