NEO
Client service policy
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Executive Summary
How to submit a complaint ?
NEO PAYMENT FACTORY S.L. and NEO CAPITAL MARKETS S.A., S.V. have established an internal complaints procedure to ensure that all complaints are managed promptly and by the appropriate personnel within our Customer Service Assistance department (“SAC”)
To facilitate a swift resolution of your issue, please provide the following details:
- Your name and address
- Your client contract number
- A clear and precise description of the concern or complaint
- Information on how you would like us to resolve the matter
- Any relevant supporting documents
- Contact details (phone number and/or email)
Complaints, claims, and any related documents can be submitted to SAC through any NEO department, area, or service, at any NEO office open to the public, or via the following addresses:
Mailing Address
NEO PAYMENT FACTORY, S.L. or NEO CAPITAL MARKETS SV, SA
Attention Customer Service
Travessera de Gràcia 18, 3-3
08021 Barcelona, Spain
Email Address
How We Handle Your Complaint ?
We strive to resolve your complaint as quickly as possible.
If an immediate resolution is not feasible, you will receive written acknowledgment of your complaint within 5 business days. For complex issues, we will keep you informed about the progress as we work toward a resolution. Our goal is to provide a final response within 2 months from the date the complaint is submitted. If you do not receive a response within this timeframe, you may refer the matter to the Market Conduct and Complaints Department of the Bank of Spain, as detailed below.
Our final response will include:
- A description of the complaint
- A summary of the investigation results
- Acknowledgment of any error, if applicable, and confirmation of the complaint’s validity
- Details of any offer or proposed resolution, along with the period during which the offer is valid
Below, you will find the full text of the Client Service Policy.
Chapter I. Purpose and Scope
Article 1. Objective
1.1. The purpose of these regulations is to govern the operations of the Customer Service Assistance (hereinafter, SAC in Spanish) to ensure compliance with Order ECO/734/2004, of 11 March, regarding customer service departments and the customer ombudsman of financial institutions. This regulation establishes procedures for managing customer complaints and claims.
1.2. The companies subject to these regulations are NEO PAYMENT FACTORY, S.L., with CIF No. B67475111, registered with the Bank of Spain (code 6891), and having its registered office at Travessera de Gràcia 18, 3rd floor, 08021 (Barcelona), and NEO CAPITAL MARKETS S.V., S.A., with CIF No. A66888595, registered with the CNMV (number 283), and with its registered office at Travessera de Gràcia 18, 3rd floor, 08021 (Barcelona) (hereinafter, collectively referred to as “NEO”).
1.3. NEO is dedicated to providing high-quality services, placing customer satisfaction at the core of its operations.
1.4. To this end, NEO has established these Regulations, which define the activities, internal rules, and operations of the Customer Service, as well as the procedures for processing and resolving customer complaints and claims.
Article 2. Scope and General Provisions
2.1. NEO is committed to addressing and resolving, under the terms described in these Regulations, the complaints and claims presented, either directly or through representation, by NEO’s customers. Such complaints and claims must relate to their legally recognized interests and rights, whether arising from contracts, transparency and customer protection regulations, or good financial practices and usages, with particular attention to the principle of equity. For the purposes of these Regulations, NEO clients are considered to be natural or legal persons, Spanish or foreign, who are users of NEO’s financial services.
2.2. Complaints refer to those filed by customers due to delays, negligence, or other deficient performance observed in NEO’s operations.
2.3. Claims refer to those filed by customers seeking the restitution of their interests or rights in response to specific actions or omissions by NEO that negatively impact their legally recognized interests or rights.
2.4. The performance of the Customer Service (hereinafter, “SAC”) is governed by Order ECO/734/2004, of 11 March 2004, concerning customer service departments and services and the customer ombudsman of financial institutions, as well as by applicable regulations related to transparency and customer protection at any given time.
2.5. Proceedings before the SAC are free of charge.
Chapter II. Customer Service
Article 3. Customer Service Manager
3.1. The head of the SAC must be a person of commercial and professional integrity, possessing adequate knowledge and experience to perform their duties. For the purposes of these Regulations, it is understood that:
a) Commercial and professional integrity is reflected in individuals who demonstrate a history of compliance with commercial laws, regulations governing economic activity and business practices, as well as adherence to good commercial and financial practices.
b) Adequate knowledge and experience are demonstrated by those who have performed functions related to NEO’s core financial activities.
Article 4. Designation of the Customer Service Head
4.1. The head of the SAC will be appointed by the NEO Board of Directors.
4.2. The appointment of the SAC head will be communicated to the Conduct Department of the Bank of Spain.
Article 5. Term of Appointment and Termination
5.1. The term of office for the SAC head shall be indefinite.
5.2. The Board of Directors may dismiss the SAC head at any time, providing reasons for its decision and notifying the SAC head and the Bank of Spain in writing.
5.3. The SAC head will cease their functions if any of the following occurs:
a) Termination of their employment or commercial relationship with NEO;
b) Voluntary resignation;
c) Death or disability preventing them from fulfilling their duties;
d) Conviction by a final judgment in criminal proceedings;
e) Loss of the commercial and professional integrity required as per Article 3 of these Regulations;
f) Holding a position within NEO incompatible with the role of SAC head.
5.4. In the event of the SAC head’s termination, NEO will appoint a replacement within thirty (30) calendar days, in accordance with the procedure outlined in Article 4. During the interim period, the Board of Directors will appoint a provisional SAC head.
Article 6. Causes of Incompatibility and Ineligibility
6.1. The following individuals are ineligible to serve as SAC head:
a) Those declared insolvent or in a similar status in other jurisdictions, without rehabilitation;
b) Those with a criminal record for crimes such as forgery, offenses against the Public Treasury, document misappropriation, breach of confidentiality, money laundering, embezzlement, or property-related offenses;
c) Individuals disqualified or suspended from public office or holding management roles in financial institutions;
d) Individuals performing operational or commercial roles at NEO.
Article 7. Customer Service Organization
7.1. The SAC operates independently from other departments, ensuring independence in decision-making and avoiding conflicts of interest.
7.2. NEO shall provide the SAC with the necessary human, material, technical, and organizational resources to fulfill its duties and strengthen them as necessary. NEO will also ensure SAC staff have adequate knowledge of relevant transparency and customer protection regulations.
7.3. All NEO departments must collaborate with the SAC, providing requested information to enhance SAC operations, particularly regarding complaints and claims.
Article 8. Customer Service Competencies
8.1. The SAC is responsible for handling complaints and claims described in Articles 2.2 and 2.3, regardless of their amount, if not resolved in favor of the client by the department or service concerned. SAC decisions on complaints and claims are binding on NEO, subject to judicial recourse, alternative dispute resolution mechanisms, and administrative protection as applicable.
Chapter III. Duty to Provide Information
Article 9. Duty to Provide Information
9.1. NEO shall make the following information available at all public offices and on its website:
a) Existence of the SAC, with postal and email addresses as detailed in Annex I;
b) NEO’s obligation to resolve customer complaints and claims within two (2) months, as described in Article 11;
c) The Conduct Department of the Bank of Spain and Commissioners for Financial Services Customer Protection, with contact information for clients dissatisfied with SAC outcomes;
d) The existence of this Regulation;
e) References to applicable transparency and customer protection regulations.
Chapter IV. The Procedure for Submission, Processing, and Resolution of Complaints and Claims
Article 10. Deadline for Submission
10.1. Complaints and claims must be submitted within two (2) years from the date the client became aware of the facts causing the complaint or claim.
10.2. Complaints or claims submitted after this deadline will not be accepted by the SAC.
Article 11. Form, Content, and Place of Submission of Complaints and Claims
11.1. Complaints and claims may be submitted in person or by proxy, in paper format by mail to the SAC’s address or via the designated email.
11.2. Clients must submit a document containing the following:
a) Name, surname, address, and email for notifications, and representative details if applicable;
b) Reason for the complaint or claim;
c) Office, department, area, or service involved;
d) Statement that the matter is not subject to other proceedings;
e) Place, date, and client signature.
11.3. Clients must attach supporting documents to their complaint or claim.
11.4. Complaints and claims can be submitted to the SAC or any NEO public office or department.
Article 12. Admission to Processing
12.1. If a complaint or claim is unresolved by the relevant department, it will be forwarded to the SAC.
12.2. The SAC will resolve complaints within two (2) months of receipt, acknowledging receipt in writing.
12.3. The SAC will assign a file number to each case.
12.4. If claimant identity or complaint details are unclear,
the SAC will request the claimant to provide additional information and/or documentation within ten (10) calendar days. Failure to comply will result in the complaint or claim being archived without further action. The period for correcting errors will pause the complaint resolution timeline as specified in Article 12.2. If the claimant corrects the deficiencies outside the ten (10) day period, a new file will be opened, and the two (2) month resolution period will restart as described in Article 12.2.
Article 13. Refusal of Admission
13.1. The SAC may refuse to process complaints or claims under the following circumstances:
a) Missing essential data for processing that cannot be remedied, including unspecified complaint reasons;
b) Cases intended for other bodies such as administrative, arbitral, or judicial processes, or those pending resolution in those forums;
c) Complaints or claims that do not pertain to specific operations or do not meet Article 2.1 requirements;
d) Repetitive complaints or claims previously resolved by the same client regarding the same facts;
e) Complaints or claims submitted after the Article 10 deadline.
13.2. The SAC must refrain from processing a complaint or claim if a simultaneous administrative, arbitral, or judicial proceeding on the same matter is ongoing.
13.3. If a complaint or claim is deemed inadmissible, the SAC will inform the claimant with a reasoned decision. The claimant has ten (10) calendar days to present arguments. If the grounds for inadmissibility persist, the final decision will be communicated to the claimant.
Article 14. Processing
14.1. Once a complaint or claim file is opened, the SAC will request a report from the relevant NEO office, department, area, or service justifying their actions.
14.2. During the file’s processing, the SAC may gather relevant data, clarifications, reports, or evidence from the claimant or NEO offices and departments to make an informed decision.
14.3. All NEO offices, departments, and services must actively collaborate with the SAC, responding promptly to information and documentation requests.
Article 15. Rectification and Withdrawal
15.1. If NEO rectifies the issue to the claimant’s satisfaction during the complaint or claim process, it must notify the SAC and provide justification. The SAC will then archive the case, unless there is express withdrawal by the claimant.
15.2. Claimants may withdraw complaints or claims at any time, which will terminate the procedure regarding their case.
Article 16. Termination and Notification
16.1. The SAC shall issue a resolution within the timeframe specified in Article 12.2.
16.2. The SAC’s decision will be reasoned and will contain conclusions on the complaint or claim, based on contractual clauses, transparency rules, applicable customer protection regulations, and good financial practices. Deviations from previous decisions must be justified.
16.3. The decision will be communicated to claimants within ten (10) calendar days of its issuance via post or email, depending on the method indicated in the complaint submission, or by the same means if no preference was specified.
16.4. Final resolutions will inform claimants of their right to appeal to the Conduct Department of the Bank of Spain or relevant commissioners if dissatisfied with the SAC’s decision.
16.5. If the SAC does not resolve a complaint or claim within the stipulated period, claimants may approach the Conduct Department of the Bank of Spain or relevant commissioners for financial services protection.
Article 17. Relationship with the Conduct Department of Entities of the Bank of Spain and Commissioners for the Protection of Financial Services Customers
17.1. The SAC head must comply with requirements from the Conduct Department of the Bank of Spain and the Commissioners for the Protection of Financial Services Customers within established deadlines, in accordance with applicable regulations.
Chapter V. Annual Report
Article 18. Annual Report
18.1. The SAC head must submit an annual report to the NEO Board of Directors within the first quarter of each calendar year, detailing SAC activities during the previous year. The report will include:
a) A statistical summary of complaints and claims, including numbers, admissibility, reasons for inadmissibility, issues raised, and affected amounts;
b) A summary of decisions, indicating whether they were favorable or unfavorable to claimants;
c) General decision-making criteria applied;
d) Recommendations or suggestions for improved SAC operations.
18.2. NEO shall include a summary of the SAC report in its annual report.
Chapter VI. Adoption of the Rules of Procedure
Article 19. Adoption of the Rules of Procedure
19.1. These Regulations must be approved by the NEO Board of Directors.
19.2. Any amendments to these Regulations require Board approval.
Article 20. Verification by the Bank of Spain and CNMV
20.1. This Regulation, including modifications, must be verified by the Bank of Spain, as the supervisory body for NEO PAYMENT FACTORY, S.L., and by the National Securities Market Commission (CNMV), as the supervisory body for NEO CAPITAL MARKETS S.V., S.A., before taking effect.
Annex I – Contact
Postal Address and Email Address of Customer Service
According to these Regulations, complaints and claims, along with any required documents, must be addressed to the SAC through any NEO office, department, or service or submitted to:
Mailing Address
NEO PAYMENT FACTORY, S.L. or NEO CAPITAL MARKETS S.V., S.A.
Attention: Customer Service
Travessera de Gràcia 18, 3-3
08021 Barcelona, Spain
Email Address
Annex II – Full Document
Client Service Policy (English)
Client Service Policy (Spanish)
