Answer

The NQC complaints policy outlines how stakeholders (e.g. clients, suppliers etc) can raise complaints regarding the NQC platform and ESG rating activities. We are committed to maintaining open, transparent, and accountable service delivery. For matters regarding our ESG rating activities, this policy complies with Regulation (EU) 2024/3005 (EU ESG Rating Regulation).

Background

1. Scope and Categories
Complaints are processed under one of two dedicated workflows to ensure they are handled by the appropriate team within required timeframes.

Workflow 1: Operational Platform or Service Complaints
This complaints workflow covers day-to-day service delivery, including platform availability, feature functionality, integrations, or system performance in addition to service delivery, client management or communication concerns.

Workflow 2: ESG Rating & Methodology Complaints
This complaints workflow covers formal complaints concerning our ESG rating outputs and activities. To qualify as a formal regulatory complaint, a submission must be based on one of the following grounds:

- Methodology Execution: Alleged misapplication, calculation errors, or improper deviation from our published ESG scoring methodologies.
- Procedural Integrity: Alleged failure to adhere to our documented assessment workflows or quality control protocols.
- Conflicts of Interest: Concerns regarding the independence or objectivity of the assessment process.

Note: Disagreement with an assigned ESG rating or assessment outcome does not constitute a valid regulatory complaint. Submissions must cite specific factual, procedural, or methodological grounds.

2. Investigation & Resolution Timelines
We handle all complaints according to defined Service Level Agreements (SLAs):
Platform/Service
Acknowledgement - Within 1 business day
Admissibility Confirmation - Immediate upon review
Target Resolution - Within 5 business days

ESG Rating
Acknowledgement - Within 1 business day
Admissibility Confirmation - Within 3 business days
Target Resolution - Within 30 calendar days

Independent Review Principles
In accordance with EU regulatory requirements, all ESG rating complaints undergo an independent investigation. The review is conducted by independent compliance personnel who had no direct involvement in data collection, calculation, or quality assurance for the specific rating being appealed.

Updates on Complex Matters
Operational Platform/Service Issues: If a technical investigation requires additional development analysis, status updates will be provided every 48 hours until resolved.
ESG Rating Issues: If a complaint requires an extended methodological audit, you will receive written notification prior to the 30-day mark outlining the updated timeline and rationale (up to a maximum 15-day extension).

3. Decision Communication & Remedies
Upon completion of the investigation, you will receive a formal written outcome detailing our findings and the rationale behind the decision.

Depending on the nature of the complaint, remedies may include:
- Technical fixes or service adjustments.
- Data corrections, rating recalculations, published assessment updates, or internal process adjustments.

4. Confidentiality & Record Keeping
All submissions are treated confidentially and processed in accordance with applicable data protection laws (GDPR). In line with regulatory standards, formal records of all ESG rating complaints -including submissions, independent review notes, and final determinations-are securely maintained for a minimum of 5 years and are subject to regulatory oversight by competent authorities (such as ESMA).

Steps

How to Submit a Complaint
To initiate a formal review, complaints must be submitted in writing to our designated email address: complaints@nqc.com
If you raise a formal complaint directly via our Support Centre or through one of our Client Success Managers, they will forward your submission to our central team to ensure it is logged immediately.

Required Submission Details
To help us investigate your concern efficiently, please include the following in your complaint submission:
- Account Details: Full entity name and details of the individual raising the complaint (name, email address and job title).
- Category: Explicit indication of whether the matter relates to a general operational platform or service related issue or an ESG Rating related issue.
- Detailed Summary: A clear explanation of the issue, including relevant dates, impacted features, or specific rating reports.
- Supporting Documentation:,/strong> Evidence supporting your submission.
- Requested Outcome: The specific resolution or remedy requested.

Incomplete submissions may result in a paused review until all necessary documentation is provided.