The Company is committed to providing high-quality service to all clients. We value feedback and take complaints seriously. This policy outlines our procedure for handling and resolving complaints in a fair, timely, and transparent manner.

This policy applies to all complaints received from clients or the public regarding our Company, including transactions, customer service, compliance, or the conduct of our employees or agents. A complaint is any expression of dissatisfaction from a customer regarding our services, staff conduct, fees, transaction processing, or any other aspect of our business operations.

1. Purpose and Scope

Clients may submit complaints through:

• Email: compliance@onfin.io

Clients should provide their name, contact information, relevant account/transaction details, and a clear description of the complaint.

2. Complaint Channels

We will retain a record of all complaints and their resolution for a minimum of 5 years, in accordance with our regulatory obligations, including:

• Complaint details and customer information
• Investigation notes and findings
• Resolution provided and customer response
• Time taken to resolve

4. Record Keeping

The Compliance Officer quarterly reviews all complaints and reports to senior management on complaint trends. This Policy should be reviewed annually and updated as necessary to ensure its effectiveness. It may be changed to identify systemic issues and implement corrective actions. Also this Policy will be reviewed when regulatory requirements change.

5. Reporting and Reviewing

3.1 Receipt and Acknowledgement

All complaints must be logged immediately in the Complaints Register. The Company will acknowledge receipt of the complaint within 5 business days and provide the customer with a complaint reference number.

3.2 Investigation

The Company will assign complaint to appropriate staff member.

• Simple complaints (transaction inquiries, fee questions, service delays) will be assigned to Client Service Representative
• Complex complaints (disputes over transactions, regulatory concerns, fraud allegations) should be assigned to Compliance Officer 
• Serious complaints (potential violations, systemic issues, significant financial losses) are escalated immediately to Compliance Officer and senior management

The assigned staff member must:

1. Gather Information

- Contact the customer for additional details if needed
- Interview staff members involved in the transaction or service
- Collect all relevant documentation

2. Review Evidence
- Transaction records, receipts, and system logs
- Applicable policies, procedures, and service agreements
- Communication records (emails, recorded calls, messages)
- Relevant regulatory requirements and internal controls
- Previous similar complaints and their resolutions

3. Analyze and Determine Facts
- Identify what occurred and assess whether company policies were followed
- Determine if customer expectations were reasonable and clearly communicated
- Assess if there was any error, misconduct, or service failure
- Consider applicable consumer protection and AML/ATF regulations

4. Consult as Needed
- Seek input from department managers for operational matters
- Consult Compliance Officer for regulatory interpretation
- Involve legal counsel for significant legal exposure or complex disputes

5. Document Findings
- Prepare written investigation summary with timeline of events
- Note all evidence reviewed and persons consulted
- Record conclusions and basis for proposed resolution

Target resolution is of 30 calendar days from receipt. If more time is required due to complexity, the Company must notify the customer in writing before the 30-day deadline, explain the reason for delay, and provide a new expected resolution date.

3.3 Resolution and Response

The Client Service Manager or the Compliance Officer must provide written response to the client explaining:

• Findings of the investigation
• Resolution or proposed remedy
• Reasons for the decision
• Further escalation options if unsatisfied