Legal Notice

Concentra Global Corretores de Seguro, SA, legal entity no. 501278699 with a share capital of €1,300,000.00, has its registered office at Rua Embaixador Martins Janeira, nº 14, 1º e 2º, 1750-097 Lisbon and has been registered since 27/01/2007 with the ASF – Insurance and Pension Funds Supervisory Authority as an insurance broker in the LIFE and NON-LIFE branches under no. 607177996/3 and also since 07/01/2014 as a reinsurance intermediary, under no. 814399567, and is thus authorized to carry out insurance and reinsurance brokerage and consulting activities, as can be verified and confirmed on the official ASF website.

Special Information Duties

Concentra Global Corretores de Seguro, SA, with registered office at Rua Embaixador Martins Janeira, nº14, 1º e 2º, 1750-097 in Lisbon, with a share capital of €1,300,000.00, and tax identification number 501278699, has been registered since 27/01/2007 with the ASF – Insurance and Pension Funds Supervisory Authority as an insurance broker in the LIFE and NON-LIFE branches under number 607177996/3 and since 07/01/2014 as a reinsurance intermediary, under number 814399567, and is thus authorized to carry out insurance and reinsurance brokerage and consulting activities, as can be verified and confirmed on the official website of the said ASF at www.asf.com.pt.

By means of this document, Concentra Global Corretores de Seguro, SA fulfills the special information duties to which it is bound, under the terms and for the purposes set out in Article 31 of the Legal Regime for the Distribution of Insurance and Reinsurance, approved as an annex to Law No. 7/2019, of January 16.

INDEPENDENCE

Concentra Global Corretores de Seguro, SA does not hold any direct or indirect stake in any Insurance Company, and no Insurance Company holds any direct or indirect stake in the share capital of Concentra Global Corretores de Seguro, SA. As "Insurance Brokers," we conduct our mediation activity independently of all Insurance Companies, based on an impartial analysis of a sufficiently large and diverse number of insurance companies and the types of insurance contracts available on the market. This allows us to make a recommendation, according to professional criteria, regarding the insurance contract best suited to the client's needs, based on their characteristics, the information they provide, and the complexity of the recommended insurance contract.

INTERVENTION

Our involvement extends beyond the signing of the contract; it also encompasses providing assistance throughout the duration of the insurance contract. The remuneration for our services is the responsibility of the Insurance Company and is included in the insurance premium and, unless otherwise agreed, takes the form of a commission. It may also be charged directly to the client as previously agreed professional fees, or other types of remuneration connected with the insurance contract, or a combination of any of the aforementioned types of remuneration. The client has the right to request information regarding the remuneration that Concentra Global Corretores de Seguro, SA receives for its mediation work, which will be provided upon request.

Authorized to enter into insurance contracts on behalf of and for the account of insurance companies, Concentra Global Corretores de Seguro, SA does not itself assume risk coverage, which is a role reserved for insurance companies, nor does it exercise powers to settle claims that have not been granted to it. In our capacity as brokers, we are authorized to collect premiums and pay refunds and indemnities, under the terms agreed with the insurance companies and the insured, using any means of payment.

Where applicable, Concentra Global Corretores de Seguro, SA will inform the client of the names of the insurance companies or insurance brokers involved in the insurance contract(s).

If, in addition to Concentra Global Corretores de Seguro, SA, other insurance intermediaries are involved in the same insurance contract, they are all jointly and severally liable under paragraph 4 of Article 47 of the RJDSR (Legal Regime of Insurance Distribution and Reliability) to the insured parties, policyholders and insurance companies for acts of insurance distribution.

Whenever Concentra Global Corretores de Seguro, SA requests payments from its clients under the insurance contract(s) after their conclusion, other than regular premiums and scheduled payments, it will inform the client of the nature and amount of each payment that must be made.

COMPLAINT MANAGEMENT

Concentra Global Corretores de Seguro, SA has in place a Policy for the Treatment of Policyholders, Insured Parties, Beneficiaries and Injured Third Parties, which guarantees the equitable treatment of those concerned, as well as the processing of their personal data and their complaints, which can be consulted on its website www.concentragrupo.com/pt.

PROCESSING AND PROTECTION OF PERSONAL DATA

Personal data transmitted within the scope of the presentation, proposal, conclusion, and execution of the insurance contract, through Concentra Global Corretores de Seguro, SA, including pre-contractual due diligence and support for its management, especially in the event of a claim, will be processed and stored electronically by Concentra Global Corretores de Seguro, SA as "data controller," "subcontractor," or "joint data controller," and are intended for the execution and management of the contractual relationship, including communications related thereto, with the data subject, and between the data subject and the insurer. This processing is necessary for the execution of the insurance contract, with the intervention of Concentra Global Corretores de Seguro, SA, in accordance with the privacy and personal data protection policy adopted and respected by Concentra Global Corretores de Seguro, SA. By concluding the insurance contract through Concentra Global Corretores de Seguro, SA, the data subject declares, for all legal purposes, to know and accept this as a condition for its conclusion, execution, and management.

Concentra Global Corretores de Seguro, SA, in its legitimate interest or that of third parties, may process personal data for the purpose of conducting audits, quality and service improvement, and analyzing customer satisfaction.

Omissions, inaccuracies, falsehoods, and outdated information, whether regarding mandatory or optional data, are the responsibility of the data subject, whether acting as a policyholder, insured party, beneficiary, or their representative, or as a claimant, third party, or their representatives.

Concentra Global Corretores de Seguro, SA, in its legitimate interest or that of third parties, will also process personal data collected within the scope of the legal and contractual relationship, and during its validity, for communications regarding campaigns and marketing actions for products and services related or not to those transacted with the data subject, but not necessary for their execution and management. If the data subject does not wish to receive such communications, they may refuse them immediately or on the occasion of each communication, through the personal data protection contact identified below.

Thus, the personal data collected may also be processed for some or all of the following purposes, not necessary for the execution and management of the specific insurance contract entered into, through Concentra Global Corretores de Seguro, SA, provided that the data subject gives their consent freely, expressly, specifically, informedly and explicitly for each of these purposes in the manner requested in this document relating to compliance with the special duty of information incumbent upon Concentra Global Corretores de Seguro, SA by virtue of the provisions of Article 31 of the legal regime for the distribution of insurance and reinsurance (RJDSR), approved as an annex to Law No. 7/2019, of January 16.

The processing of personal data will be based on the consent of the data subject, who has the right to object to the processing or withdraw their consent at any time for one or more of the aforementioned purposes. To do so, they should contact the data protection department below.

The selected personal data is communicated, under a confidentiality agreement, to other companies that are in a relationship of control or ownership (Group), already established or to be established, which the intermediary is part of or will become part of, whose identification and contact details can be requested at any time from the Personal Data Protection Contact, identified below. The data may also be processed by other entities in relation to which Concentra Global Corretores de Seguro, SA acts as an intermediary, if applicable, as a "subcontractor" or "joint controller," as well as by those to whom Concentra Global Corretores de Seguro, SA has subcontracted its processing, and also by its insurance co-intermediaries or Persons Directly Involved in Insurance Mediation Activity (PDEAMS). Personal data may also be processed by other insurers or co-intermediaries in the context of claims settlement.

For the purposes described and in compliance with legal obligations, personal data may be transmitted to judicial, administrative, supervisory or regulatory authorities, as well as to entities that lawfully carry out or conduct data compilation, fraud prevention and combating actions, market research, or statistical or actuarial studies.

The data subject has the right to request, through the data protection contact provided below and under the terms set out in applicable legislation, which includes Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), access to personal data concerning him or her, the rectification of inaccurate or incomplete personal data, the erasure of personal data, the restriction of processing of personal data in whole or in part, the right to object to processing and the right to data portability in a structured, commonly used and machine-readable format.

For matters relating to the protection of personal data, please contact us in writing at the following addresses:

Concentra Global Insurance Brokers, SA Insurance Consultants and Brokers, SA.

Address: Rua Embaixador Martins Janeira, nº 14, 1º e 2º 1750-097 Lisboa
Email: dpo@concentragrupo.pt

Finally, it is reported that the legal regime for the distribution of insurance and reinsurance (RJDSR), approved as an annex to Law No. 7/2019, of January 16, defines that Concentra Global Corretores de Seguro, SA, in its capacity as a legal entity Insurance Broker, under the terms of subparagraph b) of paragraph 1 of article 9, carries out insurance mediation activities independently from insurance companies.

(Information provided in accordance with and by virtue of the provisions of Article 31 of the Legal Regime for Insurance Distribution (RJDS) approved as an annex to Law No. 7/2019, of January 16, and Regulation (EU) 2016/679 (General Data Protection Regulation).

Policy for the Treatment of Policyholders, Insured Parties, Beneficiaries, and Injured Third Parties

CHAPTER I – OBJECT, SCOPE AND FUNDAMENTAL PRINCIPLES

Article 1.

OBJECT

This Data Processing Policy aims to establish, in accordance with and pursuant to Articles 32, 33, 38 and 39 of Regulatory Standard No. 13/2020-R of December 30, in conjunction with the provisions of subparagraph t) e) of paragraph 1 of Article 24 and paragraph 3 of Article 28 of the RJDSR, the principles, rules and procedures that must be observed within the framework of the relationship between Concentra Global Corretores de Seguro, SA and its clients/policyholders, insured parties, beneficiaries or injured third parties, ensuring them equitable treatment, as well as the proper processing of their personal data and their complaints.

Article 2.

SCOPE

The Treatment Policy is mandatory for all employees of Concentra Global Corretores de Seguro, SA, as well as for the commercial network of Concentra Global Corretores de Seguro, SA and its respective operators (persons directly involved in the insurance distribution activity – PDEADS), whether employed or independent, and for all those who, on behalf of Concentra Global Corretores de Seguro, SA, provide services to their respective clients/policyholders, insured parties, beneficiaries or injured third parties (hereinafter the “employees”).
For the purposes of the preceding paragraph, Concentra Global Corretores de Seguro, SA will, whenever necessary, inform and adequately bind all those acting on its behalf and for its account to comply with this Data Processing Policy.

Article 3.

EQUITY, DILIGENCE AND TRANSPARENCY

The employees of Concentra Global Corretores de Seguro, SA must contribute to ensuring that all clients/policyholders, insured parties, beneficiaries, or injured third parties receive equitable, diligent, and transparent treatment.

Article 4.

INFORMATION, CLARIFICATION AND ADEQUACY

Concentra Global Corretores de Seguro, SA and its employees must, in the exercise of their activity, ensure that clients/policyholders, insured parties, beneficiaries or injured third parties, taking into account their respective profile, the information provided by them and the nature and complexity of the situation, receive the legally required and necessary information and the clarifications appropriate for making an informed decision, duly ensuring that insurance contracts or capitalization operations with characteristics that are mismatched to the profile and needs conveyed by policyholders and insured parties are not marketed.
All legal documentation and commercial information regarding the products distributed and mediated by Concentra Global Corretores de Seguro, SA will be made available by the company in conjunction with the insurance companies involved, which are or will be party to the insurance contracts and/or capitalization operations in question, in order to allow for the correct and complete clarification and explanation of the policyholders and insured parties.

Article 5.

Prevention and Management of Conflicts of Interest

Employees of Concentra Global Corretores de Seguro, SA must proactively disclose and identify to the management of Concentra Global Corretores de Seguro, SA all situations that could generate conflicts of interest, particularly in the context of managing complaints from clients/policyholders, insured parties, beneficiaries, or injured third parties, and must refrain from intervening in such situations.
A conflict of interest is considered to exist whenever any employee of Concentra Global Corretores de Seguro, SA is, directly or indirectly, interested in the situation or claim in question, or if their spouse or partner, relative or in-law in the first degree, or a company or other collective entity in which any of them directly or indirectly holds a shareholding exceeding 10% and/or is a member of the management or administration body.

Article 6.

SPEED AND EFFICIENCY IN MANAGEMENT

Employees of Concentra Global Corretores de Seguro, SA must perform their assigned duties or tasks with rigor and quality, aiming for swift and efficient management of processes related to clients/policyholders, insured parties, beneficiaries, or injured third parties, particularly regarding claims and complaints.

Article 7.

ADEQUATE QUALIFICATION

Concentra Global Corretores de Seguro, SA ensures the appropriate initial and ongoing qualification of its employees, namely the members of the management body designated as responsible for insurance distribution activities, and the PDEADS (Product Development and Assistance Services) with direct communication and interaction with clients/policyholders, insured parties, beneficiaries or injured third parties, in order to guarantee, at all times, the quality, correctness and professional competence of the service, whether in person or remotely.
All employees of Concentra Global Corretores de Seguro, SA who have direct contact with clients/policyholders, insured parties, beneficiaries, or injured third parties must possess the appropriate qualifications stipulated in the RJDSR (Legal Regime for Insurance and Other Compensation) and its regulations, specifically through successful completion of an insurance course relevant to their activity and recognized by the ASF (Portuguese Insurance and Pension Funds Supervisory Authority).

Article 8.

Anti-fraud policy

Concentra Global Corretores de Seguro, SA complies with the policies for preventing, detecting, and reporting insurance fraud practices implemented by the insurance companies it collaborates with, and will provide clients/policyholders, insured parties, beneficiaries, or injured third parties with any relevant information upon request.

CHAPTER II – PROCESSING OF PERSONAL DATA

Article 9.

PROCESSING OF PERSONAL DATA

The processing, whether or not using computer means, of personal data collected from clients/policyholders, insured parties, beneficiaries, or injured third parties, is carried out by Concentra Global Corretores de Seguro, SA in an equitable and transparent manner, in strict compliance not only with the Privacy and Personal Data Protection Policy adopted by Concentra Global Corretores de Seguro, SA, available on its website – www.concentragrupo.pt – but also with applicable legal regulations, in particular those established in Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data [General Data Protection Regulation (GDPR)] and Law No. 58/2019, of 8 August, which ensures the implementation, in the national legal order, of the GDPR, and the security rules, of a technical and organizational nature, appropriate to the risk that the The processing of the data presents and represents it.

CHAPTER III – HANDLING COMPLAINTS

Article 10.

Complaints Management Policy and Point of Contact

Concentra Global Corretores de Seguro, SA has internal regulations regarding the policy for managing complaints from clients/policyholders, insured parties, beneficiaries, or injured third parties, which must be followed by all employees.
The contact point for Concentra Global Corretores de Seguro, SA for the purpose of submitting complaints by clients/policyholders, insured parties, beneficiaries or injured third parties, and for responding to complaints submitted, is reclamacoes@melior-seguros.pt.

Article 11.

METHOD OF SUBMITTING COMPLAINTS

When submitting complaints to Concentra Global Corretores de Seguro, SA by clients/policyholders, insured parties, beneficiaries or injured third parties, electronic communication should be prioritized using the contact point referred to in paragraph 2 of the previous article.
The preference outlined in the previous paragraph does not preclude clients/policyholders, insured parties, beneficiaries, or injured third parties from submitting their claims through the following alternative channels:
1. by mail to the headquarters of Concentra Global Corretores de Seguro, SA: Rua Embaixador Martins Janeira, nº 14, 1º e 2º Pisos 1750-097 Lisboa;
2. through the use of the electronic Complaints Book www.livrodereclamacoes.pt.

Article 12.

MINIMUM COMPLAINT REQUIREMENTS

The claimant must attach to the claim all documents and information that are relevant for its analysis, namely:
1. Full name of the claimant and, if applicable, of the person representing them;
2. Reference to the claimant's status, specifically as a policyholder, insured party, beneficiary, or injured third party, or a person representing them;
3. Contact details of the claimant and, if applicable, of the person representing them;
4. Claimant's identification document number and tax identification number;
5. If the complaint is submitted through a representative, a power of attorney with sufficient powers is required;
6. Description of the facts that motivate the complaint, identifying the parties involved and the date on which the facts occurred, unless this is manifestly impossible;
7. Additional information that the complainant considers necessary for the management of their complaint;
8. Date and location of the complaint.
Whenever a complaint submitted does not include the necessary elements for its management by Concentra Global Corretores de Seguro, SA, particularly when the reason for the complaint is not specified or is unclear, Concentra Global Corretores de Seguro, SA will invite the complainant to remedy the omission. Failure to respond to a request from Concentra Global Corretores de Seguro, SA for a period exceeding 10 working days will result in the complaint being archived.
If the complaint submitted does not relate to the activity of Concentra Global Corretores de Seguro, SA, the company will inform the complainant of this fact and forward the complaint to the financial sector entity to which the complaint relates, if it maintains commercial relations with that entity.
Concentra Global Corretores de Seguro, SA reserves the right to file and not accept complaints when:
1. Essential data that would make its management impossible and that have not been corrected in accordance with paragraph 2 should be omitted;
2. If you intend to file a complaint regarding a matter that falls under the exclusive jurisdiction of arbitration or judicial bodies, or when the subject matter of the complaint is pending or has already been decided by those bodies;
3. Please reiterate any previous complaint(s) submitted by the same complainant regarding the same matter that has/have already been addressed by Concentra Global Corretores de Seguro, SA;
4. The complaint may not have been submitted in good faith or its content is considered offensive by Concentra Global Corretores de Seguro, SA.

Article 13.

TIMEFRAMES IN COMPLAINT MANAGEMENT

Within two working days, the complainant is informed of the receipt of the complaint, as well as the reference number that allows them to obtain information about the status of the procedure.
Except in the cases of archiving referred to in the previous article, Concentra Global Corretores de Seguro, SA will notify the claimant, within 5 working days of receiving the complaint, of its acceptance and inform them that it will proceed with its analysis.
Without prejudice to the provisions of paragraph 2 of the preceding article, Concentra Global Corretores de Seguro, SA shall notify the claimant of the conclusion of the analysis of the complaint within a period of up to 20 days from the date of receipt of the complaint containing the information provided for in paragraph 1 of the same article, except in exceptional cases of particular complexity, in which the period may be extended up to a limit of 90 days.
The deadline stipulated in the previous paragraph is suspended when a deadline is running for the provision of information or for the submission of useful or necessary elements requested by Concentra Global Corretores de Seguro, SA for the completion of the analysis.
In exceptional situations of high complexity of the complaint, where Concentra Global Corretores de Seguro, SA is unable to meet the maximum period of 20 days foreseen in point 3, it must inform the complainant indicating the estimated date for the conclusion of the analysis of the respective process, as well as keep them informed about the steps being taken and those to be adopted for the purpose of responding to the complaint submitted.
In handling complaints, Concentra Global Corretores de Seguro, SA will prioritize electronic communication with the complainant, using the contact point referred to in paragraph 2 of Article 11, without prejudice to the use of other forms of communication in paper or other durable media.
Any communications regarding the summary non-admission or response to complaints made by Concentra Global Corretores de Seguro, SA will be duly justified and transmitted using clear and understandable language.

Article 14.

OUT-OF-COURT DISPUTE RESOLUTION MECHANISMS

Concentra Global Corretores de Seguro, SA is a member of the Lisbon Consumer Conflict Arbitration Centre: www.centroarbitragemlisboa.pt, an out-of-court dispute resolution body that clients/policyholders, insured parties, beneficiaries or injured third parties may always resort to in order to resolve any dispute with Concentra Global Corretores de Seguro, SA.
The contact point for the Lisbon Consumer Conflict Arbitration Centre is through the website indicated in point 1, where the form available through the following link must be completed and submitted: http://www.centroarbitragemlisboa.pt/form_reclamacao.php
Without prejudice to the possibility of submitting complaints under this Treatment Policy, resorting to the out-of-court dispute resolution body provided for in the preceding paragraphs or even resorting to the courts, complaints from clients/policyholders and other interested parties may be submitted to the Insurance and Pension Funds Supervisory Authority (ASF), directly or through the Complaints Book, in electronic format (www.livroreclamacoes.pt) or physical format, the latter available at the establishments of Concentra Global Corretores de Seguro, SA for this purpose.

CHAPTER IV – DISSEMINATION AND ENTRY INTO FORCE

Article 15.

DISCLOSURE OF TREATMENT POLICY

The Board of Directors of Concentra Global Corretores de Seguro, SA assumes responsibility for the approval, implementation, and monitoring of this Policy in an appropriate manner, reflecting it in the relevant documents inherent to the exercise of the insurance distribution activity. It also ensures the necessary dissemination and explanation of the rules contained in this Treatment Policy, in order to guarantee its knowledge and compliance by all employees of Concentra Global Corretores de Seguro, SA. This policy is permanently available and accessible, both internally and publicly, specifically through its availability at www.concentragrupo.pt, as well as, whenever requested, through delivery or sending in paper or other durable medium to clients/policyholders, insured parties, beneficiaries, or injured third parties.

Article 16.

ENTRY INTO FORCE AND DISSEMINATION

This Treatment Policy comes into effect on the date of its publication and is available on the Concentra Global Corretores de Seguro, SA website at www.concentragrupo.pt

COMPLAINT MANAGEMENT POLICY

REGULATIONS

Chapter I – General Provisions

Article 1. Subject Matter

This regulation defines the policy and operating rules of the complaints management system for policyholders, insured parties, beneficiaries or injured third parties, its implementation and monitoring of its compliance.

Article 2. Scope

This regulation applies to Concentra Global Corretores de Seguro, SA and insurance brokerage companies controlled by it, without prejudice to the need for formal ratification by their respective management bodies.
Complaint management is the responsibility of the person designated to manage complaint-related processes.
The responsibility of the person in charge of managing complaints processes excludes complaints related to personal data protection issues that do not originate from the Complaints Book (physical or electronic) and the Insurance and Pension Funds Supervisory Authority (ASF).
The management of complaints related to personal data protection issues that do not originate from the Complaints Book (physical or electronic) and the ASF (Portuguese Insurance and Pension Funds Supervisory Authority) is the responsibility of the Data Protection Officer (DPO).

Article 3. Person responsible for managing complaint processes.

The person responsible for managing complaints processes is appointed by the management body from among the company's staff, or by resorting to an independent professional with the qualifications, competence, experience and integrity required to perform the role, and will act as a central point for receiving and responding to all complaints addressed to the company and its subsidiaries.
The person responsible for managing complaint processes will perform their duties independently, reporting directly to the management body.
The designation of the person responsible for managing complaint processes will be communicated internally to all employees of the company and its subsidiaries for the purpose of centralizing the receipt and response to complaints.
The identification of the person responsible for managing complaint processes must be included on the company's institutional website and, whenever justified, in other company presentation documents, along with their contact details, in order to ensure full accessibility for complainants.

Article 4. Duties of the person responsible for managing complaint processes.

The person responsible for managing complaint processes will act diligently and with the utmost care, in an autonomous, independent and completely impartial manner.
The person responsible for managing complaints processes must immediately inform the management body of any facts or circumstances that may constitute a conflict of interest, including, in particular, situations in which they have committed the act being complained about, have a personal interest in the matter under their consideration, or in which there is an interest on the part of:
1. from an entity to which you have been linked for at least 2 years, as a partner/shareholder, member of a statutory body, through an employment contract or service agreement;
2. of the spouse or person living with him/her in a de facto union, descendants or ascendants and other relatives who have cohabited with him/her for more than one year;
3. of an entity in which any of the persons mentioned in the preceding paragraph is linked as a partner/shareholder, member of a statutory body, by means of an employment contract or service agreement.
3. In a situation of potential conflict of interest on the part of the person responsible for managing complaint processes, Concentra Global Corretores de Seguro, SA will designate, from among its qualified, experienced and suitable staff, an "ad hoc" representative to monitor the complaint in which such a situation arises, promptly informing the designated person and their contact details, and notifying the company's services and third parties to whom the complaint relates.
4. The person responsible for managing complaint processes will inform the administrative body monthly of the complaints received and their conclusions, in a manner that allows the body to detect and correct any recurring or systemic problems and to mitigate any legal or operational risks.

Article 5. Duties towards the person responsible for managing complaint processes.

Employees of the company and its subsidiaries will immediately communicate, via email, to the person responsible for managing complaint processes, any complaints they have directly received, for the purpose of centralizing the receipt and response to complaints, accompanied by any information they have regarding the complaints, and will provide any clarifications requested.

Article 6. Definition of Complaint

For the purposes of this regulation, "Complaint" means any expression of disagreement with the position taken by Concentra Global Corretores de Seguro, SA, or dissatisfaction with the distribution services provided by the company, as well as any allegation of possible non-compliance, submitted by policyholders, insured parties, beneficiaries, or injured third parties.
The concept of a complaint does not include statements that are part of the contractual negotiation process, demands for compliance with legal or contractual obligations, communications inherent to the claims settlement process, and any requests for information or clarification.

Article 7. Form of communications

Communication between the company, its subsidiaries, claimants, and third parties related to a claim must always be in writing, with electronic communication being preferred, particularly for the submission of written claims.
Without prejudice to the provisions of special legislation, applications may be submitted directly to Concentra Global Corretores de Seguro, SA through the following channels:
1. Communication between the company, its subsidiaries, claimants, and third parties related to a claim must always be in writing, with electronic communication being preferred, particularly for the submission of written claims.
2. Without prejudice to the provisions of special legislation, applications may be submitted directly to Concentra Global Corretores de Seguro, SA through the following channels:
  1. Send to the email address of Concentra Global Corretores de Seguro, SA (reclamações@melior-seguros.pt),
  2. Send by mail to the address of Concentra Global Corretores de Seguro, SA: Rua Embaixador Martins Janeira, nº 14, 1º e 2º Pisos 1750-097 Lisboa;
  3. Electronic Complaints Book www.livrodereclamacoes.pt

CHAPTER II – Complaints Management

Article 8. General principles for managing complaints.

In handling complaints, Concentra Global Corretores de Seguro, SA will adhere to best administrative practices of efficiency, speed, and cost-effectiveness, treating all those with whom it interacts fairly and impartially.
The following general principles are adopted in managing complaint processes:
1. Impartial management of complaints submitted within the framework of the respective organizational model, promoting actions that prevent conflicts between personal, financial or corporate interests and the interests of the company, and reporting any situation that may constitute a conflict of interest.
2. Availability and commitment of employees to undertake the necessary steps and efforts to identify and resolve any dissatisfaction brought to their attention, prioritizing personalized contact for the sake of a good business relationship.
3. Maintaining a record of all complaints received, with the respective processing and response to the complainant, ASF or any other entity, by Concentra Global Corretores de Seguro, SA.
4. Immediate provision of the physical Complaints Book, free of charge, whenever requested at the premises of Concentra Global Corretores de Seguro, SA, with a guarantee of confidentiality associated with any records contained in the provided Book.
5. Submitting a complaint is free of charge, as is access to the response(s) to the complaint(s) submitted.
6. Complaints are received by the person responsible for managing the complaints process through the channels mentioned in Article 7.
7. Concentra Global Corretores de Seguro, SA will analyze received complaints in order to identify common causes for certain types of complaints, verify if such causes may also affect similar situations even if they are not directly the subject of the complaint, and prevent the recurrence of the causes of the complaint.
The company has joined the Lisbon Consumer Conflict Arbitration Center for the alternative resolution of any potential disputes.
Without prejudice to the applicable general principles and rules, in carrying out its complaints management activity, Concentra Global Corretores de Seguro, SA prioritizes the use of electronic means to obtain and provide the necessary information, promoting transparency, speed and proximity to stakeholders.

Article 9. Form of complaint

The claimant must attach to the submitted request all documents and information that are relevant for its analysis, namely:

Full name of the claimant and, if applicable, of the person representing them;
Reference to the claimant's status, specifically as a policyholder, insured party, beneficiary, or injured third party or person representing them;
Contact details of the claimant and, if applicable, of the person representing them;
Claimant's identification document number and tax identification number;
If the complaint is submitted through a representative, a power of attorney with sufficient powers is required;
Description of the facts that motivate the complaint, identifying the parties involved and the date on which the facts occurred, unless this is manifestly impossible;
Additional information that the complainant considers necessary for the proper handling of their complaint;
Date and location of complaint.

Article 10. Opening of the procedure

Following the receipt of a complaint, a complaint procedure is initiated by assigning an identification reference and entering it into an electronic platform.

Article 11. Filing

The complaint is summarily dismissed, particularly when:
1. If it is not possible to identify the person or persons from whom it originates or against whom it is directed, if it is written in an unintelligible manner, or if it is clear that its subject matter lacks any basis.
2. If you intend to file a complaint regarding a matter that falls under the jurisdiction of arbitration or judicial bodies, or when the matter of the complaint has already been resolved or is awaiting resolution by those bodies.
3. A previous complaint submitted by the same complainant regarding the same matter, and which has already been answered, is admissible unless it contains new facts.
4. The complaint was either not made in good faith or its content is considered vexatious.
In cases where the statement of facts on which the request is based is not sufficiently clear, or where it is imperceptible or lacks essential elements for its analysis, namely those referred to in Article 9, Concentra Global Corretores de Seguro, SA requests that the claimant send the necessary data within a maximum period of 10 working days, under penalty of dismissal.
If the complaint submitted does not report to the insurance brokerage activity of Concentra Global Corretores de Seguro, SA, the company will inform the complainant of this fact and forward the complaint to the relevant financial sector entity.

Article 12. Procedure

The complainant is informed, within two working days, of the receipt of the complaint, as well as the reference number that allows them to obtain information about the status of the procedure.
Except in the cases of archiving referred to in the previous article, Concentra Global Corretores de Seguro, SA will notify the claimant, within 5 working days of receiving the complaint, of its acceptance and inform them that it will proceed with its analysis.
If the complaint is not admitted under Article 11, Concentra Global Corretores de Seguro, SA will inform the complainant of this fact, explaining the reasons for that decision.
Whenever deemed necessary, Concentra Global Corretores de Seguro, SA may request the provision of additional elements and/or information necessary for the clarification of the situation and its respective assessment.
The lack of response to the requests referred to in the previous paragraph implies the suspension of the assessment of the complaint until the date the requested information is made available.

Article 13. Analysis period

Concentra Global Corretores de Seguro, SA will notify the claimant of the conclusion of the analysis of the claim within a period of up to 20 days from the date of receipt of the claim containing the information provided for in Article 9, except in cases of particular complexity, in which the period may be extended up to a maximum of 90 days.
The deadline stipulated in the previous paragraph is suspended when a deadline is running for the provision of information or for the submission of useful or necessary elements requested by Concentra Global Corretores de Seguro, SA for the completion of the analysis.
In exceptional cases of highly complex complaints where Concentra Global Corretores de Seguro, SA is unable to meet the 20-day deadline indicated in point 1 above, it must inform the complainant of the estimated date for the completion of the analysis of the respective processes, as well as keep them informed about the steps being taken and those to be adopted in order to respond to the complaint submitted.
In handling complaints, Concentra Global Corretores de Seguro, SA will prioritize electronic communication with the complainant, using the contact point referred to in point a) of paragraph 2 of article 7, without prejudice to the use of other forms of communication in paper or other durable media.
Any communications from Concentra Global Corretores de Seguro, SA will be duly substantiated and transmitted using clear and understandable language.

Article 14. Extinction

The complaint procedure is terminated by:
1. Communication by the complainant indicating withdrawal of the claim;
2. Entering into an agreement or transaction relating to the subject matter of the complaint;
3. Celebration of an agreement to initiate mediation, arbitration, or another alternative dispute resolution procedure;
4. Notification to the claimant of the conclusion of the analysis by Concentra Global Corretores de Seguro, SA.
5. Failure to respond to requests for additional information submitted by Concentra Global Corretores de Seguro, SA pursuant to paragraph 21 of Article 11.
Concentra Global Corretores de Seguro, SA ensures that the claimant is notified of the termination of the claim management procedure concerning them.

Chapter III – Report on Complaints Management

Article 15 Report relating to complaints management

Concentra Global Corretores de Seguro, SA prepares annually, by the end of February, a report on claims management for the previous financial year, consisting of two parts:

The first part relating to statistical data segmented according to the model set out in Annex VI of Regulatory Standard No. 13/2020-R of 30 December.
The second part reports to the conclusions drawn from the complaints management process and the measures implemented or to be implemented.

Chapter IV – Validity

Article 16 Frequency of review and authority for approval

Annually, or whenever deemed necessary, the person responsible for managing the complaints process shall assess the suitability of these regulations for their intended purpose and, when justified, propose their revision to the Board of Directors.

Article 17 Entry into force and dissemination

This regulation comes into effect upon its publication and availability to all employees, and will be available on the intranet of Concentra Global Corretores de Seguro, SA.