Complaints Handling Policy – First Crypto

1. Policy Statement

First Crypto ("the Company/Firm", "We" and "Our") is committed to upholding the highest standards of professionalism, integrity, and client service. As part of this commitment, the firm has implemented a comprehensive Complaints Resolution Framework to ensure that all client concerns are handled with transparency, efficiency, and fairness.

This policy governs the end-to-end handling of client complaints, from initial receipt through to final resolution and post-resolution monitoring. It is designed to foster trust, enhance client satisfaction, and support continuous service improvement. The framework aligns with applicable regulatory expectations and reflects First Crypto's core values of responsiveness and accountability.

Applicability

This policy applies to all complaints submitted by clients, prospective clients, or their authorized representatives in relation to any of First Crypto's products, services, communications, or conduct. It covers:

• Channels and procedures for submitting complaints
• Internal processes for investigating and addressing issues raised
• Timelines for response and resolution
• Escalation mechanisms and client recourse
• Record-keeping and reporting obligations
• All employees, contractors, and third-party service providers acting on behalf of First Crypto are expected to be familiar with and adhere to the principles outlined in this policy.

2. Complaint Recognition and Root Cause Analysis

First Crypto defines a complaint as a clear expression of dissatisfaction regarding any of its services, virtual asset activities, products, or internal processes. For a complaint to be formally recognized, it must be submitted through one of First Crypto's designated communication channels and must include sufficient information to identify the complainant and the nature of the grievance. These channels include our website's complaint form, email, postal correspondence, and in-person submissions at our registered office. To ensure the integrity and effectiveness of our complaints handling framework, First Crypto has established a robust mechanism for not only recognizing individual complaints but also identifying potential patterns of systemic issues. The procedures are designed to monitor and analyze all incoming complaints and take proactive measures to mitigate reoccurrence.

In accordance with this commitment, First Crypto will:

• Recognize and Log Complaints Promptly: All complaints received through recognized channels will be formally acknowledged and logged in the internal complaints management system upon receipt
• Continuously Monitor Submission Channels: The Compliance team will oversee all communication platforms designated for complaints to ensure timely recognition and capture of all client concerns.
• Conduct Root Cause Analysis: Each complaint will be assessed to determine any underlying issues. Complaints will be periodically reviewed in aggregate to identify common causes or trends.

Evaluate Broader Impact: Where systemic issues are identified, First Crypto will assess whether similar failures or vulnerabilities may exist in other services, products, or virtual asset activities—even those not specifically named in the complaint.

Implement Corrective Measures: Identified root causes will be addressed through appropriate corrective action, which may include procedural revisions, enhanced staff training, policy updates, or technical system improvements.

By embedding these steps into our complaints handling procedures, First Crypto ensures that client concerns are not only resolved on a case-by-case basis, but also serve as critical feedback to strengthen our operations, improve service delivery, and reinforce client trust.

2.1 Procedures for Managing Client Complaints

The Company has established structured and transparent procedures for the timely, fair, and consistent handling of client complaints. These procedures are readily accessible on our official website and are presented in clear, client-friendly language to ensure ease of understanding and engagement.

Submission of Complaints

Clients may lodge complaints through any of the following channels:

• Email: complaints@fce.global
• Online Form: Available on the "Contact Us" or "Complaints" section of our website
• In Writing: Via postal correspondence to our registered office
• In Person: At our main office during regular business hours

Clients are encouraged to provide the following information to facilitate prompt resolution:

• Full name and contact information
• Account or reference number (if applicable)
• A detailed description of the complaint
• Any supporting documentation or evidence

3. Complaints Resolution and Timelines

The Company ensures it will handle all client complaints in a prompt, transparent, and fair manner. Our complaints resolution process is structured to ensure that every grievance is acknowledged swiftly, investigated thoroughly, and resolved within a clearly defined timeframe. To uphold this commitment and align with regulatory expectations, First Crypto adheres to the following time-bound procedures:

• Timely Acknowledgment: All complaints received through our official channels will be acknowledged in writing within one week of receipt. This acknowledgment will confirm that the complaint has been logged and is under review, while also outlining the next steps in the resolution process.
• Resolution Within Four Weeks: In the ordinary course of business, First Crypto aims to investigate and fully resolve complaints within four weeks of the date the complaint was submitted. The resolution response will include a clear explanation of the findings and any remedial actions
• taken, where applicable.

Exceptional Circumstances: If, due to exceptional or unforeseen complexities, a complaint cannot be resolved within the standard four-week period, First Crypto will notify the complainant by the fourth week. This communication will:

• Provide an update on the current status of the investigation,
• Explain the specific circumstances causing the delay, and
• Outline the anticipated timeframe for final resolution.
• Maximum Resolution Period: In cases involving extraordinary delays, the final resolution of the complaint will not exceed eight weeks from the original date of submission.

This structured approach ensures that all clients receive timely responses and clarity throughout the complaint lifecycle. First Crypto's objective is to not only address individual concerns, but also to enhance client satisfaction and reinforce long-term confidence in the integrity of its services.

4. Client Accessibility and Third-Party Complaints Coordination

The Company is dedicated to making the complaints submission process as accessible and user-friendly as possible to ensure that all clients, regardless of their preferences or circumstances, are able to communicate their concerns without undue burden. To support this objective:

• Multi-Channel Complaint Submission: Clients may submit complaints through multiple accessible channels, including but not limited to the dedicated online complaints form available on First Crypto's official website, email, telephone, physical correspondence, or in-person at designated offices. While a standardised complaint form is provided to guide clients in submitting relevant details, the use of this form is not mandatory. First Crypto will not restrict the recognition of a complaint to any single format or medium.
• User-Friendly Tools and Guidance: The complaints webpage includes step-by-step instructions on how to lodge a complaint, including where and how to submit it, the expected timelines, and what information to include to ensure swift processing.

Third-Party Involvement: Where First Crypto's services include or rely on third-party entities—such as outsourced service providers, technology platforms, or other strategic partners—clear procedures have been established to coordinate the resolution of complaints involving such entities. These procedures ensure efficient communication and collaboration between First Crypto and the third parties concerned.

Responsibility and Oversight: Notwithstanding the involvement of third-party entities, First Crypto retains full responsibility for the proper handling and ultimate resolution of all client complaints related to its services. The firm ensures that all third-party contributors cooperate fully and adhere to the standards of fairness, transparency, and responsiveness set out in this policy.

5. Fee-Free Submission and Complaints Recordkeeping

First Crypto upholds its commitment to fairness and accessibility by ensuring that no fees or charges are imposed on clients for lodging a complaint or for any action taken in response to a complaint. The complaints process is entirely free of cost, reinforcing First Crypto's dedication to transparency and client-centric service. In addition, robust documentation and recordkeeping procedures are maintained to ensure full traceability and regulatory compliance. First Crypto keeps comprehensive and accurate records of the following:

• All Client Complaints: Every complaint received—regardless of the channel or format—is documented in a centralized complaints register.
• Actions Taken: Each step taken in response to a complaint, including investigations, communications, and interim measures, is recorded in detail.
• Final Resolutions: The outcome of every complaint, whether resolved or escalated, is logged with supporting evidence and dates of closure.

These records are retained securely and remain accessible for inspection or audit, serving as a basis for internal reviews and improvements to client service. This recordkeeping process is also integral to identifying systemic issues and maintaining compliance with the relevant provisions of the VARA Market Conduct Rulebook.

6. Policy Review and Continuous Improvement

To uphold the highest standards of client service and regulatory compliance, First Crypto commits to conducting a comprehensive review of this Complaints Handling Policy at least annually—or sooner if prompted by regulatory updates, operational changes, or insights derived from complaint trends and client feedback.

Each review is conducted under the oversight of senior management to assess the policy's effectiveness, relevance, and alignment with applicable laws, including the VARA Market Conduct Rulebook and any other regulatory expectations. Proposed updates are formally approved by management and promptly communicated to all relevant departments to ensure seamless implementation.

In the interest of transparency, the most current version of this policy is made publicly accessible via First Crypto's official website. This review mechanism ensures that our complaints management framework remains dynamic, client-focused, and reflective of evolving best practices across the virtual asset sector.