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In accordance with Section 29 (1) of Act CLIV of 1997 on Health Care (hereinafter referred to as the "Health Act"), patients have the right to lodge complaints about healthcare services with the healthcare provider. Pursuant to Section 29 (3) of the Health Act, the detailed rules for investigating complaints must be defined in the internal regulations of the healthcare provider. In compliance with this legislation, the Duna Medical Center Ltd. (hereinafter referred to as the "Institution") has established the following procedures for handling complaints:

1. Purpose of the Policy

The purpose of this policy is to regulate the investigation, response, and record-keeping of complaints submitted by patients, their relatives, and/or other individuals.

2. Scope of the Policy

This policy applies to all units of the Institution, its contractors, individual collaborators, and all personnel engaged under contractual or other employment arrangements.

Institution's Address: 1095 Budapest, Lechner Ödön fasor 5.

References

• Act CLIV of 1997 on Health Care
• Act CXVI of 2000 on Medical Mediation
• Act CXII of 2011 on Informational Self-Determination and Freedom of Information
• Act XLVII of 1997 on the Processing and Protection of Health and Related Personal Data
• Regulation (EU) 2016/679 of the European Parliament and Council (General Data Protection Regulation - GDPR)
• Act XXC of 2023 on Complaints, Public Interest Disclosures, and Rules Related to Reporting Misconduct

3. Classification of Received Complaints

3.1. Verbal complaints made at specific organizational units (inpatient wards, maternity departments, outpatient clinics, diagnostic departments, customer service locations), as well as at the Executive Secretariat of the Institution.

3.2. Complaints submitted in writing.

3.3. Complaints mediated by patient rights representatives.

3.4. Inquiries and official procedures initiated by authorities (e.g., National Public Health Center, National Consumer Protection Authority, police, etc.) in connection with complaints.

3.5. Requests from forensic expert chambers for mediation proceedings.

3.6. Complaints submitted to the Institution's Ethics Committee.

4. Complaint Handling Procedures

4.1. Verbal Complaints

4.1.1. Verbal complaints can be submitted via telephone or in person. In such cases, the unit manager or their deputy informs the complainant that, according to this policy, only written complaints submitted via panasz@dunamedical.com or visszajelzes@dunamedical.com, or via the customer feedback book, will be investigated.

4.1.2. If deemed necessary by the unit manager or their deputy, a written record of the verbal complaint is prepared and forwarded to the Executive Secretariat for further consideration.

4.2. Complaints can be submitted in writing via email to panasz@dunamedical.com or visszajelzes@dunamedical.com, or by post.

4.2.1. Written complaints received directly by a unit must be forwarded by the unit manager to the Executive Secretariat within 2 business days.

4.2.2. The Executive Secretariat logs the complaint and assigns a tracking number, if necessary.

4.2.3. The Executive assigns the complaint to the relevant department head (e.g., head of outpatient care, inpatient care, maternity services, finance/customer service) within 2 business days.

4.2.4. The department head forwards the complaint to the relevant unit manager (investigating officer) within 1 business day. The investigating officer gathers information, interviews involved parties, and reviews relevant documents (e.g., medical records). A written report must be prepared within 5 business days.

4.2.5. If the complaint is directed against the manager responsible for investigation, the respective director or an alternate unit manager appointed by the director will conduct the investigation. In cases involving complaints against the Executive, all related documentation must be forwarded to their employer immediately.

4.2.6. Individuals who may have a conflict of interest in the complaint cannot participate in its resolution. Such individuals must notify their direct supervisor without delay. Failure to disclose a conflict of interest or delay in doing so may result in disciplinary and financial consequences.

4.2.7. The investigative report must be submitted to the Executive Secretariat within 2 business days.

4.2.8. If necessary, and if the complexity of the complaint requires it, the complete documentation of the investigated complaint, along with the preliminary decision of the Executive, must be forwarded by the Executive to the Institution's designated legal representative within 2 business days. The legal representative will review the documents for potential legal and formal errors and prepare the response to be sent to the complainant. The draft response must be submitted to the Executive within 3 business days.

4.2.9. The response prepared by the legal representative must be sent by the Executive to the complainant and any involved parties within 15 business days from the receipt of the complaint. If resolving the issue requires more time and the response cannot be sent within 15 business days, the complainant must be notified in advance, requesting their patience.

The exercise of the right to lodge a complaint does not affect the patient's right to seek assistance from other authorities for the investigation of the complaint. This should be explicitly stated in the response letter to the complainant.

4.2.10. If the complaint is found to be valid, the Executive, in collaboration with the respective director, ensures:

- Resolution of the identified issues.
- Remediation of any harm caused.
- Initiation of ethical or disciplinary procedures, if necessary.
- Notification of authorities if a criminal offense or regulatory violation is suspected.

4.2.11. Complaints may be dismissed in the following cases:

I). Repeated complaints identical to previously submitted ones.
II.) Complaints submitted more than six months after the complainant became aware of the issue.

Complaints submitted more than one year after the occurrence of the alleged activity or omission will not be investigated by the authorized Executive.

Refund to Patients

Refunds to patients must be approved in writing by the Executive Director and the Head of Finance. Prior to this, the responsible case manager is required to provide the Finance Department with the necessary information to identify the patient, including the patient’s personal data and bank account details.

4.3. Anonymous Complaints

4.3.1. Complaints submitted without a name and/or signature are handled at the discretion of the Executive after assessing their content. Complaints sent via email from an unknown email address are also considered anonymous.

4.3.2. The Executive will order the investigation of the complaint if it suggests a criminal offense, regulatory violation, or significant irregularity.

4.3.3. The procedures outlined in Section 4.2 are otherwise applicable to anonymous complaints as appropriate.

4.4. Role of the Patient Rights Representative

4.4.1. The Patient Rights Representative is responsible for safeguarding patients' legally defined rights and assisting them in understanding and exercising these rights.

4.4.2. Information about the Patient Rights Representative, including their name, contact details, and office hours, is displayed in all patient care units.

- Complaints received through the Patient Rights Representative are handled in accordance with Section 4.1, with the modification that deadlines specified in Section 4.1 are calculated in calendar days instead of business days. The Patient Rights Representative must also be informed of the outcome of the investigation.

The Executive must respond to inquiries from the Patient Rights Representative as follows:

• For requests to investigate a complaint: within 30 days, or within 60 days if the investigation or resolution requires the involvement of another authority or organization.
• For observations related to the Institution’s operations: within 15 days.
• For requests to review or provide copies of documentation related to the service recipient:
  • Immediately, if the documentation is readily available on-site.
  • Within 5 business days, if the documentation is not immediately available.

4.5. Inquiries from Supervisory Authorities and Regulatory Bodies

4.5.1. Inquiries related to complaints made by supervisory authorities or regulatory bodies are handled in accordance with the procedures outlined in Section 4.2.

4.5.2. The Executive is required to provide a written report to the requesting authority regarding the outcome of the complaint investigation.

4.6. Medical Mediation

4.6.1. The purpose of mediation is to facilitate the resolution of disputes between the healthcare provider and the patient related to the provision of services through out-of-court settlements, ensuring the quick and effective enforcement of the parties' rights.

4.6.2. A party requesting mediation may submit the application to the nearest regional forensic expert chamber (hereinafter referred to as the "Chamber"). The Chamber forwards the application to the Institution within 15 days of receipt.

4.6.3. The Institution must respond within 15 days of receiving the application to indicate whether it consents to the mediation process. The decision is made by the Executive after consulting with the individuals involved in the complaint, the relevant director, and the Institution’s liability insurer (hereinafter referred to as the "Insurer"). The institutional lawyer assists in drafting the written decision.

4.6.4. Otherwise, the provisions of Act CXVI of 2000 on Medical Mediation apply to the process.

4.7. Procedure of the Institutional Ethics Committee

4.7.1. Complaints submitted to the Institutional Ethics Committee are handled in accordance with the committee's internal rules of procedure.

4.7.2. Upon conclusion of the committee’s proceedings, the committee secretary sends a memorandum to the Executive, which includes the committee’s decision.

4.8. Complaints Involving Claims for Compensation

4.8.1. Any complaint that explicitly states or implies a claim for compensation must be forwarded by the Data Protection Officer to the Insurer without delay, provided the complainant has granted the necessary consent outlined in Section 4.8.2. The results of the internal investigation under Section 4.2 are also forwarded to the Insurer. If consent is not granted, the Data Protection Officer informs the Insurer of the claim by providing the complainant’s initials and the amount of the claim.

4.8.2. Personal data provided by the complainant is presumed to be consented for use. Other personal data may only be processed with explicit consent from the complainant. Special data concerning health status can only be processed with written consent.

4.8.3. If the claim for compensation is rejected, the complaint response follows the procedure outlined in Section 4.2.

4.8.4. If the internal investigation concludes that the claim for compensation is valid, the Executive, after consulting with the Insurer, informs the complainant that the Insurer will negotiate the terms of the out-of-court settlement. The agreement is reviewed by the designated legal representative. The Executive is authorized to conclude the out-of-court settlement with the legal representative’s endorsement.

5. Complaint Record-Keeping

5.1. Complaints are recorded in chronological order in a register maintained by the Executive Secretariat. The register (Appendix 1) includes the following details:

- Date of receipt of the complaint,
- Name of the complainant,
- Subject of the complaint (the organizational unit it is directed against),
- Name and position of the responsible manager handling the case,
- Name and position of the investigating officer,
- Actions taken to resolve the complaint (if any),
- Date of closure,
- Registration number.

5.2. The Executive Secretariat compiles statistical data for the annual evaluation of complaints within the Institution and submits this data to the Executive by January 31 each year.

5.3. Complaints and related investigation documents must be retained in accordance with the Institution's Document Management Policy for a minimum of 5 years at the Executive Secretariat/Finance Department.

This policy supersedes all previously issued quality management documents on the same subject upon its entry into force and remains effective until revoked.