Real Exchange (REX) Limited

Complaints Management Policy – Master Sheet – Version Control

1. Introduction

Real Exchange (REX) Limited (the “Company”) is a company registered in Malta with Company Registration Number C 88077. It is licensed by the Malta Financial Services Authority (MFSA) under Article 14 of the Virtual Financial Assets Act (VFA Act) as a Class 4 VFAA License Holder (“License”) to provide the following services:

1. Providing custody and administration of crypto-assets on behalf of clients
2. Reception and transmission of orders for crypto-assets on behalf of clients
3. Providing transfer services for crypto-assets on behalf of clients

This Complaints Management Policy (the "Policy") outlines the procedures the Company follows for the prompt and reasonable handling of complaints, disputes, or grievances received from its clients (the "Clients").

The Company is committed to delivering high-quality services and ensuring that all complaints are managed as efficiently and effectively as possible.

This Policy has been reviewed and approved by the Company’s Board of Directors. The identity and contact details of the Chief Compliance Officer (CCO) have been duly submitted to the Malta Financial Services Authority (MFSA) as the individual responsible for overseeing the complaints management framework, whereas the Chief Operating Officer (COO) is designated as the officer responsible for the operational execution of the complaints management process.

2. What is a Complaint?

A complaint is defined as an expression of dissatisfaction or grievance, whether made verbally or in writing, by a Client regarding a product or service. It also includes any dissatisfaction from holders of asset-referenced tokens regarding the issuance, offering, or seeking of admission to trade under Regulation (EU) 2023/1114.

Clients can submit complaints free of charge via the methods outlined in Section 4.2 of this Policy. Information on how to file a complaint is available on the Company’s website.

All complaints are handled impartially, assessed on their merits, and logged in the Company’s Complaints Register. Client confidentiality is maintained throughout the complaint-handling process.

3. Who may Complain?

In line with the EBA’s Regulatory Technical Standards (issued on March 14, 2024), a complaint may be lodged by any natural or legal person, or by consumer associations representing holders of asset-referenced tokens, who are presumed eligible for the Company to consider their complaint.

Clients have the right to file complaints without it affecting their future interactions with the Company. Staff members are are are encouraged to handle complaints openly and in compliance with this Policy and Applicable Law.

4. Complaints Management Function

The Company maintains a robust complaints management function that ensures complaints are handled fairly and potential conflicts of interest are mitigated.

All complaints are recorded in a dedicated register (Annex 1), and the human resources allocated to complaints handling include:

• Customer Support Team
• Chief Operating Officer (COO)
• Chief Compliance Officer (CCO) – For Compliance Related Issues
• Chief Legal Officer (CLO) – For Legal Related Issues

The HR department and the Company’s management retain records of the individuals in charge of handling complaints, including their qualifications and professional experience relevant to their role.

Technical resources used in handling complaints include:

• A dedicated complaints section on the Kyrrex Platform
• Secure email communications via Zendesk
• Voice communications where applicable

5. How to lodge a complaint

Clients may lodge a complaint through the following channel:

Customer Support Department

Clients can submit complaints via email to support@kyrrex.mt, where a dedicated customer support member will review it. If necessary, the complaint will be escalated to the COO and the CCO.

The Customer Support Department will acknowledge receipt of any complaint in writing. If received orally, the complaint summarized in writing and sent to the Client for confirmation.

If the issue cannot be resolved immediately, the Company will aim to address it promptly. If the Client is unsatisfied with the initial response, they will be directed to submit a formal complaint to the Compliance Department.

6. Complaint Template

The Company provides a template for filing complaints (Annex 1). All further communication with the Client, including remedies, will be conducted via the contact methods provided.

7. Procedures for Responding to Complaints

The Company will acknowledge receipt of the complaint within five (5) business days, providing:

• Confirmation that the complaint has been received
• Any additional information needed to investigate the complaint
• An assurance that the complaint will be investigated

8. Investigating Complaints

REX assesses all complaints fairly and in a timely manner, following these steps:

• Determining if the complaint is clear and complete
• Requesting additional information if necessary
• Explaining reasons for rejecting incomplete or inadmissible complaints
• Gathering all relevant information for investigation
• Notifying the complainant if REX is not the competent authority to handle the complaint

Clients will be kept informed throughout the process. The Company will provide a final decision on the complaint within fifteen (15) business days. If more time is needed, the Client will be notified of the delay.

9. Communication

Clients will be informed of the outcome of the investigation in plain language and without undue delay. If the decision does not satisfy the complainant, they will be informed of their further options.

Details on the complaint-handling process are available on the Company’s website.

10. The Arbiter of Financial Services

If a client is dissatisfied with the Company’s final decision, they may refer the complaint to the Office of the Arbiter of Financial Services in Malta. Further information is available at www.financialarbiter.org.mt.

11. Reporting to Authorities

When required, the Company will report complaint data to the MFSA, including the number of complaints received and their causes. Clients also retain the right to file complaints with the MFSA under Regulation (EU) 2023/1114.

12. Record Retention

The Company will maintain electronic records of all complaints and actions taken for a period of ten (10) years from the date of receipt.

13. Training

This Policy is distributed to all relevant staff members and incorporated into the Company’s corporate induction training.