Complaints Handling Policy

Introduction

This Policy regulates the effective, clear, and fast handling of complaints submitted to the Company in relation to its services. The Company maintains records of its complaints and measures taken for their expedient resolution, in line with applicable Laws, Rules, and/or Regulations. The Company manages all complaints equally and fairly, without any discrimination, in harmony with the procedure of this Policy. The Policy also promotes accessibility to the complaints handling process for all consumers while ensuring compliance with anti-discrimination requirements.

2. Definitions

Complaint: An official complaint submitted to the Compliance Department, as per the guidelines of this Policy and following the completion and submission of the relevant Complaint Form included in Appendix 1. A Complaint is defined as an expression of dissatisfaction by the financial consumer in respect of the products or services provided by the Company, or the conduct of the Company in the provisioning of products or services, and where a response or resolution is expected by the financial consumer.

3. Submitting a Complaint

A complaint can be raised to the Company via telephone or written electronic communication (email) to the Customer Support Department. The complainant should report the event, the date of the incident, the subject of the complaint, and provide all supplementary evidence as soon as possible. This ensures the Company can investigate the complaint efficiently and in a timely manner. Complaints may also be lodged on behalf of a complainant, provided that written consent has been submitted. Complaints must be related to services rendered under the Terms & Conditions of the Company, which are available on the Company’s website.

4. Investigation of a Complaint

If possible, complaints shall be investigated on the same day of submission. The Company will conduct necessary checks, liaise internally, and gather all related information to provide an impartial response to the Client’s complaint.

5. Response to Complaints and Resolution Timeframes

Upon submitting a complaint, the Company will provide a reply within twenty-one (21) business days, unless otherwise informed. Some complaints may be resolved more quickly, depending on complexity. However, if additional clarifications or supporting evidence are required, the resolution period may be extended up to ninety (90) business days, with the complainant notified accordingly.

The Compliance Department is responsible for managing and resolving complaints. If the Customer Support Department cannot resolve the issue efficiently, they will escalate it to the Compliance Department. If the complainant is unsatisfied with the resolution offered by Customer Support, they may directly approach the Compliance Department.

The Company will acknowledge the receipt of a complaint within 2 business days, including:

• A unique reference number for the complaint
• The name and contact details of the designated officer or department handling the complaint.
• A clear timeframe for the response.

The Company aims to resolve matters promptly, ensuring a response is provided within the maximum timeframe of twenty-one (21) business days. All complaints must be submitted via email and will be recorded accordingly.

6. Record-Keeping of Complaints

The Company maintains a Complaint Registry in accordance with applicable laws and ensures it is regularly updated. All written or electronic documents related to complaints will be preserved for a period of 7 years. The Company may also prepare statistical reports to improve complaint-handling efficiency.

7. Settlement of Disputes

If a complaint remains unresolved or the Client is dissatisfied, they may escalate their complaint to the relevant financial authority. Contact details and procedures for dispute resolution are available on the Company’s website.