From time to time, the platform expects to run into complaints by its customers (Investors and Issuers). The platform expects the complaints to be of the following nature:

• erroneous token transfer
• delay in submission of the performance progress report(s) by the Issuer(s)
• delay in updating the status of the offering displayed on the home page of the platform
• delay in processing any transfer(s) made by the Investor(s) to the escrow account 
• delay in ascription of the investor’s wallet with tokens

Complaints Handling Procedure (for Retail Clients)

1) An email shall be provided to the Clients, where the complainant can describe the subject

2) On the receipt of a complaint, the platform will acknowledge the complaint in writing. Along with an acknowledgement, the platform will:

• share the contact details of any relevant employee (during ITL, the complaint shall be dealt with by the Fiannce Officer, or the SEO) responsible for handling complaint
• state that a copy of the Complaint Handling Procedures is available free of charge upon request.

3) After acknowledgement of the complaint, the platform will consider the subject matter of the complaint and will forward it to a relevant employee (if needed). The relevant employee will:

• handle the complaint in a fair and impartial manner
• have sufficient authority to resolve the complaint
• have access to individuals with the necessary authority

If the platform considers another Regulated Financial Institution to be entirely or partly responsible for the complaint, it will forward the complaint to the Regulated Financial Institution only after it receives approval from the complainant to do so.

4) If the relevant employee expects the resolution of the Complaint to take longer than 30 days, he/she will update the complainant weekly on the progress of the complaint.

5) Upon conclusion of the investigation of the complaint, the platform will:

• advise the complainant in writing on the resolution
• offer the complainant with terms of compensation (if any)
• fulfil the terms of compensation, if accepted by the complainant

The platform will update its systems and controls in order to remedy any problems identified from the Complaint.

6) If the complainant is not satisfied with the terms of the compensation, the complainant shall be given the opportunity to escalate the matter to the regulatory authorities.

7) The platform will maintain records of all complaints made against it for a period of six years. The records will contain the name of the complainant, the substance of the complaint and the platform’s response.

Complaints Handling Procedure (for Professional Clients)

The same policies and procedures will be put in place by the platform to address any complaint made against it by Professional Clients.