Real Exchange (REX) Limited

Complaints Management Policy – Master Sheet – Version Control

1. Introduction

This Complaints Management Policy (this “Policy”) sets out the process adopted by Real Exchange (REX) Limited (the “Company”) for the reasonable and prompt handling of complaints, disputes or grievances received from its clients (the “Client(s)”).

The Company’s aim is to provide high quality services to its Clients and to ensure that all complaints are handled as efficiently and effectively as possible.

This Policy has been reviewed and approved by the Board of Directors of the Company. The compliance officer of the Company (the “Compliance Officer”) is responsible for the implementation of this Policy and monitoring its compliance in accordance with the Virtual Financial Act (Chapter 590, Laws of Malta), any subsidiary legislation issued thereunder and/or applicable rules, rulebooks or guidelines issued by the Malta Financial Services Authority (“MFSA”) from time to time (“Applicable Law”). The identity and contact details of the Compliance Officer, as the person responsible for the complaint management function, have been provided to the MFSA.

2. What is a Complaint?

A complaint is an expression of dissatisfaction or displeasure made by a Client, whether verbally or written, regarding a product or service.

Each complaint will be investigated impartially and on its own merits, and shall also be logged in the Complaints Register of the Company. Feedback is taken seriously and seen as an opportunity for improvement. Client confidentiality will be maintained at all times when dealing with complaints.

3. Who may Complain?

Any Client or their representative(s), who is dissatisfied with the Company’s services, for any reason, may submit a complaint.

It is a fundamental principle of the complaints management process that Clients have the right to voice a complaint and to have such complaint investigated without any adverse effect upon their continued or future treatment. All relevant staff are encouraged to deal with complaints, as they arise, in an open and non-defensive way, and in accordance with this Policy and Applicable Law.

4. How may a Client lodge a Complaint with the Company?

A. Customer Support Department

If a Client has a query or is dissatisfied with any product or service provided by the Company, the Client should contact the Customer Support Department via email at support@kyrrex.mt

The Customer Support Department will acknowledge receipt of any complaint in writing. In the event that a complaint is received orally, the Company will summarise the complaint in writing and ask the Client to confirm this summary in writing.

The Customer Support Department will determine if the query may be resolved immediately or, alternatively, if it will require further investigation. If a query cannot be resolved immediately, the Company will aim to resolve the query in a prompt and efficient manner (typically within forty eight (48) business hours). If a Client is not satisfied with the response, the Client will be directed to file an official complaint with the Compliance Department following the process indicated below.

B. Compliance Department

An official complaint means a statement of dissatisfaction relating to the provision of a product or services, addressed by the Client to the Compliance Department via email at support@kyrrex.mt

An official complaint in writing must include (the “Complaint Notice”):

• the Client’s name, surname, identity card/passport number (or company registration number) and any other relevant information;
• the Client’s account login details;
• the affected transaction number(s), if applicable;
• the date and time that the issue arose; and
• an accurate description of the complaint.

Any Complaint Notices addressed to the Compliance Department should be sent from the registered e-mail address of the Client, or the appointed representative(s), as soon as practical after the subject matter of the complaint arose.

The Company will confirm receipt of the Complaint Notice within five (5) business days. This receipt, in writing, will include:

• a confirmation that the Compliance Department has received the Complaint Notice;
• an indication that the Company will investigate the complaint;
• any further details, evidence or information necessary for the Company to investigate and resolve the complaint.

We will update the Client on the progress/ handling of the Complaint Notice, as appropriate

The Company will investigate the Complaint Notice and provide the Client with the outcome, in writing, without unnecessary delay and by not later than fifteen (15) business days from when the Complaint Notice was registered, in accordance with Applicable Law. In the unlikely event that the Company is unable to settle the Complaint within fifteen (15) days, the Company will inform the Client of the reasons for the delay and indicate the period of time within which the investigation is likely to be completed

In communicating its final decision in relation to a Complaint Notice to the Client, the Compliance Department shall:

• include a description of the Complaint Notice, and the outcome of the investigation;
• set out the Company’s final view on the issues raised in the Complaint Notice; and
• include details of any redress at the disposal of the Client.

5. The Arbiter of Financial Services

If a Client is not satisfied with the Company’s final decision, the Client may refer the complaint to the Office of the Arbiter of Financial Services in terms of the Arbiter for Financial Services Act (Chapter 555, Laws of Malta). The Arbiter of Financial Services may be contacted at ‘The Office of the Arbiter of Financial Services, First Floor, St. Calcedonious Square, Floriana, FRN 1530, Malta.’

Further information may also be found at www.financialarbiter.org.mt

6. Record Retention

The Company will maintain electronic records of all complaints made by its Clients and any action taken in relation thereto. The Company shall analyse its complaints handling data on an ongoing basis to ensure that it identifies and addresses any recurring or systemic problems, and potential legal and operational risks.

All complaint records and relevant documents will be retained for a period of six (6) years from the date of receipt of a complaint.

7. Training

This Policy has been provided to all relevant staff of the Company. An overview of this Policy has also been incorporated into the Company’s corporate induction training.

All relevant staff will have an understanding of the complaints handling process. Advice and support is available from the Compliance Officer to help all relevant staff deal with complaints in relation to any service with which they are associated.

8. Review of this Policy

The Compliance Officer shall be responsible for this Policy and shall ensure that it is kept up-to-date.

The adequacy and effectiveness of this Policy shall also be reviewed by the Board of Directors of the Company at least on an annual basis. Any material updates to this Policy shall be discussed with the Compliance Officer and approved by the Board of Directors of the Company.

9. Contact Us

If you have any questions or comments about this Policy, please contact the Company via email at support@kyrrex.mt.