Master Mind NPL 114 S.r.l. (the “Company”) has a dedicated Complaints Office responsible for handling complaints submitted by its clients.

Definition of Complaint

A Complaint is any written objection or dissatisfaction, such as a letter or an e‑mail, concerning an action or omission, addressed to the Company by the account holder or an authorised representative, relating to the conduct of Master Mind NPL 114 in the course of its institutional activities, in respect of which the Complainant expects a response and/or remedial action.

Submission of Complaints to the Company

The Complainant may first contact his/her usual contact person in order to seek a simplified resolution of the issue. If a simplified solution cannot be reached, a written Complaint may be submitted.

Written Complaints must be sent to Master Mind NPL 114 S.r.l. using one of the following methods:

1. Ordinary mail or Registered letter to: Via Fra’ Paolo Sarpi, 46/A – 35138 Padua, Italy
2. Certified e‑mail (PEC) to: reclamimm114@pec.it;
3. E‑mail to: reclami@mastermindnpl.com;

The Complaint must, under penalty of inadmissibility, contain the following:

• all information necessary and useful to identify the Complainant. Any anonymous Complaint, or any Complaint where the Complainant cannot be clearly identified, cannot be processed;
• where the Complainant is represented by a lawyer, in addition to the identification documents referred to above, the lawyer must provide a copy of the power of attorney, indicating the Complainant’s details and clearly evidencing the professional mandate granted;
• a clear description of the subject‑matter of the Complaint together with the reasons for it.

Handling of Complaints

Upon receipt of a written Complaint, the Complaints Office informs the Complainant that the Complaint has been taken in charge and provides information on the handling process and the expected timeframes (so‑called acknowledgment letter). This communication is sent by registered mail with return receipt or by certified e‑mail.

The Complaints Office, having carried out its assessment on the basis of the documentation available and all evidence gathered during the review phase, in compliance with the amendments to the “Provisions on the transparency of banking and financial transactions and services – fairness of relations between intermediaries and customers” introduced by the Bank of Italy decision of 19 March 2019, undertakes to provide a written reply within 60 days from receipt of the Complaint.

The reply will expressly indicate:

• if the Complaint is upheld, the measures that the Company intends to take and the timeframe for their implementation;
• if the Complaint is considered unfounded or inadmissible, a clear and comprehensive explanation of the reasons for such decision.

Out‑of‑court dispute resolution systems

If the response provided by Master Mind NPL 114 S.r.l. is not satisfactory to the Complainant, it is possible to apply, as an alternative to ordinary courts, to the Banking and Financial Ombudsman (Arbitro Bancario Finanziario – ABF), provided that:

• the subject of the application corresponds to that of the original Complaint;
• a monetary payment is requested for an amount not exceeding EUR 100,000;
• or a request is made for the ascertainment of rights, obligations or powers (in this case with no amount limit).

The decision‑making body does not have jurisdiction over claims for damages that are not the immediate and direct consequence of the intermediary’s breach or misconduct; it likewise has no jurisdiction over matters relating to tangible assets or services other than the banking and financial services which are the subject of the contract between the customer and the intermediary or of contracts connected thereto.

Furthermore, applications cannot be submitted in relation to disputes that are already before the courts, referred to arbitration, or for which a conciliation attempt is pending pursuant to applicable law.

For further information on the Banking and Financial Ombudsman and how to file an application, please refer to the “ABF Guide to submitting a complaint” and “The ABF in plain language” available below and on the website www.arbitrobancariofinanziario.it.