Complaints and Dispute Settlement

You will find a summary of this procedure in the brochure for the complaints and disputes. You can consult the brochure here. In the brochure you will find, among other things, the addresses of the authorities to which you can turn when submitting a complaint.

Where indications are used in this procedure that are identical to those appearing in the applicable statutes and pension regulations of the Heineken Pension Fund, they have the same meaning.

Further is understood by:

The fund: Heineken Pension Fund;
The Board: the Board of the Fund;
Managing Board the Managing Board of the Fund;
Complainant: the (former) member, person entitled to a pension or other stakeholder who submits a complaint with the fund;
Complaint: all written or electronic statements submitted to the fund in which a stakeholder expresses his/her dissatisfaction about a service provided by the fund;
Dispute: a difference of opinion between one or more stakeholders on the one hand and the fund on the other hand regarding the execution or interpretation of the fund’s pension scheme whereby the rights of that (those) stakeholder(s) is/are at issue, and which do not relate to a general decision.

The dispute procedure is the same as the complaints procedure. Where below a complaint is stated in these regulations, the dispute is always
meant, unless explicitly stated otherwise.

The following shall not be deemed a complaint or dispute within the meaning of this complaints and dispute settlement procedure:
• a judicial or arbitral procedure;
• a complaint submitted with the National Ombudsman; or
• a complaint submitted with the Pensions Ombudsman.

Article 1. Submit a complaint
A (former) member, person entitled to a pension or other stakeholder has the right to lodge a complaint with the Managing Board. The complaint must be submitted by letter or email. A complaint submitted in writing must be signed by the complainant.

All complaints, either in writing or in digital format, should at least contain:
• the name and address of the complainant;
• the policy number:
• the date;
• a clear description of the situation to which the complaint relates;
• the grounds for the complaint, possibly supported by documents.

The complaint will be processed by the Managing Board. Complaints against the Managing Board must be submitted to the board.

Article 2. Handling of the complaint
The complaint is handled as follows:

  1. The Managing Board will send a written confirmation of receipt to the complainant, unless the complaint can be dealt with within two working days. The acknowledgment of receipt contains information about the expected settlement time and indicates to whom the complainant can turn if he has any questions.
  2. The complaint will in principle be dealt with within 30 days of the day of receipt. If the 30-day period is exceeded, the Managing Board also notifies the board and sets a reasonable period for handling the complaint, preferably no more than 30 days.
  3. The complainant may be represented by an authorized representative to represent his interest.
  4. The complainant is given the opportunity to clarify his position or have it clarified if, in the opinion of the board, this is necessary for the proper handling of his complaint.
  5. The complainant has the right to inspect the complaint file in accordance with the privacy regulations of the fund, which is otherwise fully applicable with regard to the complaints procedure.
  6. The assessment of the complaint must be based on a sufficient investigation and on facts and documents that are known to the complainant.
  7. The decision must be based on a sound statement of reasons and must address all aspects of the complaint. The decision contains an opinion, unless it concerns a dispute, as to whether the method of carrying out the work that is being complained about has been sufficiently careful towards the complainant.
  8. If, after a thorough investigation, it is determined that it is not possible to ascertain the true facts with sufficient degree of certainty to base an opinion on this, the issuing of an opinion may be omitted.
  9. The decision on the complaint is communicated to the complainant by letter, unless the complainant has indicated that he does not appreciate it by letter.

Complaints against the Managing Board are handled by the board.

With regard to these complaints, the provisions under 1 up to and including 9 apply mutatis mutandis, on the understanding that the  ‘’Board’’ must be read instead of the ‘’Managing Board’’.

It is not possible to appeal against decisions on complaints in accordance with the provisions of Article 3. The complaint can nevertheless be submitted to the Pensions Ombudsman in accordance with the provisions of Article 4.

The Managing Board brings quarterly written reports to the board on the received complaints. At the request of the board, the Managing Board submits the correspondence and/or other documents of a complaint file to the board. The board is subject to the privacy policy.

Article 3. Appeal to the board
If the complainant does not agree with the decision of the Managing Board, the complainant has the right to appeal to the board. This is communicated to the complainant when deciding on the complaint. The complainant can request to submit the complaint to the board within 30 days of being informed of the decision on the complaint, by letter or by e-mail ( This request contains as clear a description as possible of the reasons why, in the complainant’s opinion, the decision on the complaint cannot be upheld.

With regard to the appeal to the board, the provisions of article 2 sub 2 to 9, apply mutatis mutandis on the understanding that the board should be read instead of the Managing Board.

Article 4. Ombudsman Pensions
When the board confirms the decision of the Managing Board, the complainant has the right to submit his dispute to the Pensions Ombudsman. This is communicated to the complainant in the decision of the board.

The Pensions Ombudsman only deals with disputes about the implementation or interpretation of the fund’s pension scheme involving the rights of those interested(s), not relating to a decision of general application. The Pensions Ombudsman therefore does not deal with complaints regarding dissatisfaction with a service or a service provided by the fund. The Pensions Ombudsman deals with disputes by giving written advice that he notifies exclusively to the complainant and the Board. The board informs the complainant by letter stating whether the advice of the Pensions Ombudsman is being followed.

Article 5. Final provisions
This complaints and disputes procedure was last amended on 6 July 2021.