Utrg UAB Complaints Handling Policy

Last updated: 17th of March 2025.

Introduction

1.1. This Complaints Handling Policy and Procedures (hereinafter referred to as "Policy") outlines Utrg UAB's (hereinafter referred to as "Company") commitment to addressing and resolving any concerns or dissatisfaction that our customers, clients, or partners may have. We understand that complaints are valuable feedback that helps us improve our products, services, and processes.

In accordance with Lithuanian regulations and best practices, this policy establishes a structured and transparent approach to handling complaints. The Company aims to ensure that every complaint is addressed promptly, fairly, and with the utmost professionalism. By maintaining an efficient complaints handling process, we intend to uphold our reputation for customer satisfaction and continuous improvement.

This policy reflects our dedication to maintaining open lines of communication, resolving issues, and turning negative experiences into positive ones. We value customers' trust and are committed to using their feedback to enhance our offerings and the overall customer experience.

Scope

2.1. The Policy shall disclose appropriate management controls and ensure that the Company shall take reasonable steps to:

ensure the organisation of the process of managing applicants' complaints quickly, fairly, efficiently and properly;
adhere to the deadlines for dealing with complaints;
process the personal data and other information provided by the applicant in accordance with the requirements established by legal acts;
avoid any conflicts of interest, and take all necessary measures to identify and eliminate conflicts of interest;
entrust the handling of complaints to employees who have the sufficient skills, knowledge and experience to perform this function, give them access to all the information needed to deal with complaints;
keep proper and organized records of the complaints received and information on the measures taken to resolve the complaint;
monitor the effectiveness of the complaints management processes and update them when necessary;
establish, maintain and operate an internal information system to ensure an effective complaints management process.

2.2. This Policy is based on several European regulations and directives in force or being in force in the following year, such as the Article 71 of EU Markets in Crypto Assets Regulation (MiCAR), ESMA and EBA relevant guidelines, as well as Lithuanian law.

Definitions

3.1. The following terms are used in this Policy:

3.1.1. Complaint - a written or oral application submitted to the Company by the eligible complainant stating that the rights or legitimate interests of a person arising from or related to the services provided by the Company or concluded agreements have been violated.

3.1.2 Complaints register - an electronic register of complaints, in which the Company registers complaints received by entering the information specified in clause 5.4 of the Policy.

3.1.3 Crypto service complaints - complaints received by the Company from eligible complainants in regard to its activity as a crypto-asset service provider or issuer of asset-referenced tokens.

3.1.4 Eligible complainant - natural or legal person, who is a confirmed customer of the Company and uses the Company’s services or partners of the Company, natural or legal persons, providing services to the Company on the basis of the agreements which support dedicated services proposed to the Company’s end customer

3.1.5 - Payment service complaints - complaints received by the Company from eligible complainants in regard to its activity as a payment service provider, either by providing such services on its own or with partners. Such complaints may refer to fiat account services such as IBAN accounts, physical and virtual cards, fiat exchange services, fiat transmitting services, etc.

3.1.6 Person handling the complaint - a person designated by the Board who is responsible for handling complaints: collecting information required for complaints, handling complaints, making decisions and submitting responses to the eligible complainant.

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Lodging and Receiving Complaints

4.1. Complaints shall be submitted either orally by phone or in writing by filing a complaint electronically through the web interface (https://utpay.io/complaint), by email or in-app, or upon delivery to the Company's registered office Kareivių g. 19-149, Vilnius, Lithuania, LT-09133..

4.2. The complaint must contain the following information, corresponding to the standard template provided in the Annex to COMMISSION DELEGATED REGULATION (EU) 2025/294 :

1. Information about the complainant

1.a. Complainant's Details: * Last name (for natural persons) or Legal entity name. * First name (for natural persons). * EUID or, if not available, national Registration or ID number (for individuals); Legal Entity Identifier (LEI) or registration number (for legal entities). * Client reference (if available). * Address (street, number, floor; for legal entities, registered office), Postcode, City, Country. * Telephone number. * Email address.

1.b. Contact Details (if different from 1.a): * (Provide corresponding details: Last name/Legal entity name, First name, Address, Postcode, City, Country, Telephone, Email address if different from above.)

2. Information about the legal representative (if applicable)

2.a. Representative's Details: * Last name (for natural persons) or Legal entity name of the representative. * First name (for natural persons) of the representative. * Registration number and LEI (if available). (Note: Added based on template) * Address (street, number, floor; for legal entities, registered office), Postcode, City, Country of the representative. * Telephone number of the representative. (Note: Added based on template) * Email address of the representative. * Basis of representation (e.g., power of attorney or other official document, to be provided as an attachment).

2.b. Representative's Contact Details (if different from 2.a): * (Provide corresponding details: Last name/Legal entity name, First name, Address, Postcode, City, Country, Telephone, Email address if different from above)

3. Information about the complaint

Full reference of the crypto-asset service to which the complaint relates (e.g., name of the service, transaction references).
Description of the complaint's subject matter: actions (inactions) of the Company which the complaint is lodged against or related to the Company’s activities/provision of services, including arguments and reasons.
Date(s) of the facts that have led to the complaint.
Requirements of the complainant and description of damage, loss, or detriment caused (where relevant).
Other comments or relevant information (where relevant).
List of confirmation documents enclosed with the complaint - Power of attorney (if applicable), documents or information confirming the fact of contractual relationships/ If needed, then other supporting documentation should be provided to confirm the basis for the complaint.
Place and Date of complaint submission.
Signature of the Applicant or his/her representative (required for complaints delivered to the Company’s registered office).

4.3. The complainant must enclose with the complaint all documents confirming his/her arguments and claims. If the Complaint is lodged by the representative of the complainant, the complaint must be accompanied by a valid authorisation or other document certifying the right of the representative’s powers to lodge a complaint and receive a response from the Company.

4.4. The complaint could be lodged in the official language of the EU Member State where the service is provided.

4.5. The employee receiving the complaint should check if the complainant is eligible to lodge a complaint in accordance with clause 3.1.4. of this Policy.

4.6. The submitted complaint shall be assessed if it is compliant with the requirements set out in paragraphs 4.2, 4.3 and 4.4 of the Policy. If the complaint meets the requirements and it is lodged by an eligible complainant, it shall be accepted, and a notice that the complaint has been accepted, specifying the deadline for handling the complaint and informing that the complaint handling process is free of charge, should be sent to the complainant on the next business day at the latest.

4.7. If the complaint does not comply with the requirements indicated in Paragraphs 4.2, 4.3 and 4.4 of the Policy, the complainant shall be notified not later than within three (3) business days by sending a notice indicating the deficiencies of the complaint and proposing to eliminate them.

4.8. Anonymous complaints are not accepted.

Registering Complaints

5.1 The employee of the Company who has accepted the complaint shall register the complaint in the Complaint Register, deployed in the Company's intranet portal with a respective reference number.

5.2. When registering a Complaint, the details listed in paragraph 5.4 of the Policy shall be entered, and an electronic version of the complaint shall be enclosed (if the complaint is lodged by mail or delivered to the Company's registered office, the complaint, including all annexes to it, shall be scanned).

5.3. After the Complaint has been registered, the employee shall not later than on the next business day refer the complaint, including all annexes thereto, to the Person handling the complaint by setting a relevant issue in Jira.

5.4. The following data shall be entered into the Complaint register:

5.4.1. Registration date;

5.4.2. Complainant's full name (for natural persons) or name (for legal entities);

5.4.3. Complainant's unique identifier inside the Company's system in case the complainant is the customer of the Company (UserID);

5.4.4. The complainant's address specified in the complaint and other contact details;

5.4.5. Date of the complaint receipt and its receipt method;

5.4.6. The type of complaint, depending on the services it's aimed at, either crypto service or payment service;

5.4.7. The specific part of the service indicated in the complaint (such as technical issues, transfer issues, KYC issues, communication issues, account/wallet issues, etc.);

5.4.8. The essence of the complaint (brief contents);

5.4.9. Dates of sending a reply to the complainant;

5.4.10. Due date for the final complaint handling outcome (decision);

5.4.11. Final complaint handling outcome (decision);

5.4.12. Name and position of the employee of the Company who examined the Complaint and provided a response to the complainant;

5.4.13. Comments and additional important information with supporting documentation.

5.5. The Company collects information on the number of received Complaints, broken down by the reasons for submission and the results of the examination (received complaints, examined complaints, satisfied complaints, partially satisfied complaints).

5.6. The complainant must be, in all cases, answered in writing by sending a response by e-mail or other durable medium if agreed between the complainant and the Company.

5.7. Examined complaints, including all documentation, shall be stored in the Company's electronic data storage system in accordance with the procedure established by law, but not less than three (3) years from the date of submission of final reply to the complainant.

Complaint Handling and Decision Making

6.1. The Company shall seek to handle Complaints as promptly and comprehensively as possible. The Company shall handle Complaints following the principles of respect for human rights, justice, good faith, reasonableness, objectivity, impartiality, operation, and other principles established in the legal acts of the Republic of Lithuania applicable to the Company.

6.2. The Person handling the complaint shall handle the Complaint himself/herself and draw up a reply to the Complainant within the shortest possible time but not later than within the time limits specified in paragraph 6.6. of the Policy.

6.3. If the complaint is lodged regarding the actions (inactions) of the Person handling the complaint or the actions (inactions) of his/her close relatives (if such are employed in the Company), the Person handling the complaint shall notify the Regulatory Compliance Officer (RCO) of the Company of the same and disengage himself/herself from handling such complaint. In such a case, the RCO of the Company shall appoint another competent person, who shall handle the complaint, make a decision, and submit a reply to the complainant. A person, whose actions (inactions) are reported against, a close relative of such person, or a person directly subordinate to such person may not be appointed to handle the complaint. In the event of any other circumstances that cause a conflict of interest, the Person handling the complaint must immediately inform the RCO of the Company and disengage himself/herself from handling a particular complaint.

6.4. The Person handling the complaint shall collect and evaluate all documents and data related to the complaint in question, which have been submitted by the complainant and which the Company may legitimately collect on its own initiative.

6.5. If necessary, the Person handling the complaint shall have the right to request the complainant to provide additional information and/or documents, which may affect the proper handling of the complaint, within a specified time limit, which may not be less than 5 calendar days.

6.6. The complaint shall be examined, and a response shall be submitted to the complainant no later than 15 business days from the day of receipt of the complaint. If the complaint cannot be examined within the period specified in this paragraph, the Person handling the complaint must inform the complainant, indicate the circumstances of the delay in replying and the deadline (which may be extended to 35 business days) by which the complaint will be examined and an answer shall be submitted to the complainant.

6.7. The Person handling the complaint shall prepare a response in light of the circumstances identified during the complaint handling process and, if applicable, take one of the following decisions:

6.7.1. To dismiss the complaint;

6.7.2. To partially satisfy the requirements declared in the complaint;

6.7.3. To fully satisfy the requirements declared in the complaint.

6.8. If, during the complaint handling process, the complainant who has complained waives his/her claim in writing, the Person handling the complaint shall terminate the complaint examination. In such a case, a respective entry of the waiver of complaint and termination of complaint examination process shall be made in the Complaint register in the Decision field.

6.9. When the complainant is provided with the decision specified in clauses 6.7.1 and 6.7.2 of the Procedure, the complainant shall be informed of the reasons for refusing to satisfy the complaint and other means of protection of the complainant's interests shall be indicated, such as if complainant considered to be a customer he/she will have the right to use Online Dispute Resolution platform (ec.europa.eu/consumers/odr) that the European Commission provides.

6.10. The complainant must be, in all cases, answered in writing by sending a response by post, e-mail or other durable medium if agreed between the complainant and the Company.

6.11. Examined complaints, including all documentation, shall be stored in the Company's electronic data storage system in accordance with the procedure established by law, but not less than 3 years from the date of submission of final reply to the complainant.

6.12. If the service the complaint is lodged for is provided jointly with other third parties, then the notification or report should be sent to such third party according to the conditions of the agreement signed in order to provide such a service.

Internal Controls and Improvements

7.1. The RCO shall control the complaint management process, monitor and ensure that the Company's complaint management process is efficient and prompt, and provide his/her remarks on the root causes and complaint handling process improvement.

7.2. The RCO shall give suggestions for amendments and/or supplements to the complaint-handling procedure and improvements of the services or processes that caused a complaint, if needed.

7.3. To ensure a smooth complaint-handling process, the RCO shall:

7.3.1. collect and analyze the information on similar complaints to determine the root causes of such complaints and determine the priorities of the elimination of the causes;

7.3.2. assess whether the root causes of complaints may be eliminated and make suggestions to the Board with respect to addressing the causes of complaints;

7.3.3. assesses whether the underlying cause of certain complaints may lead to complaints about other services of the Company;

7.3.4. provide for an action plan to address the root causes of complaints;

7.3.5. analyze the disturbances in the complaint handling process and make suggestions for the improvement of this process;

7.3.6. ensures that information on recurring or systemic reasons for complaints is provided to the Board on a regular basis;

7.3.7. advise the persons handling the complaints on uncertainties and issues arising during the complaint handling process.

7.4. Having assessed the suggestions made by the RCO or the improvement of the complaint-handling process, remedial actions, and elimination of complaints sources, the Board shall make decisions on the amendments of the complaint-handling process and approve the course of actions for the elimination of complaints sources.

Awareness and Training

8.1. Ensuring that all relevant personnel understand and adhere to this Complaints Handling Policy is crucial for its effectiveness and for maintaining customer trust. All employees, particularly those in customer-facing roles, support functions, or positions directly involved in the complaints process (including receiving, registering, handling, and decision-making ), must be fully aware of the procedures outlined herein. This awareness ensures that complaints are managed consistently, fairly, promptly, and in compliance with regulatory requirements and company standards..

8.2. To equip employees with the necessary competencies, the Company will provide appropriate training. Initial training on this policy and associated procedures will be mandatory for new hires in relevant positions. Regular refresher training will be conducted to reinforce understanding and communicate any updates to the policy or related procedures. Training sessions will cover key areas such as identifying eligible complainants, procedures for lodging and receiving complaints, registration requirements, handling timelines, communication protocols, decision-making processes, confidentiality, data protection, and the importance of impartiality and managing potential conflicts of interest. The Regulatory Compliance Officer may also provide ongoing guidance as needed. Records of training completion will be maintained for all relevant staff..

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FILING OF A COMPLAINT

(to be sent by the client to the crypto-asset service provider)

1.a. Information about the complainant

Last name/Legal entity name:

…

First name:

…

EUID or if not available national Registration or ID number:

…

Legal Entity Identifier (if available):

…

Client reference (if available):

…

Address (street, number, floor) (for legal entities, registered office):

…

Postcode:

…

City:

…

Country:

…

Telephone:

…

Email address:

…

1.b. Contact details (if different from 1.a)

Last name/Legal entity name:

…

First name:

…

Address (street, number, floor) (for legal entities, registered office):

…

Postcode:

…

City:

…

Country:

…

Telephone:

…

Email address:

…

2.a. Information about the legal representative (if applicable) (a power of attorney or other official document as proof of the appointment of the representative to be provided as an attachment to this form)

Last name/Legal entity name:

…

First name:

…

Registration number and LEI (if available):

…

Address (street, number, floor) (For legal entities, registered office)

…

Postcode:

…

City:

…

Country:

…

Telephone:

…

Email address:

…

2.b. Contact details (if different from 2.a)

Last name/Legal entity name:

…

First name:

…

Address: street, number, floor (For firms registered office)

…

Postcode:

…

City:

…

Country:

…

Telephone:

…

Email:

…

3. Information about the complaint

3.a. Full reference of the crypto-asset service to which the complaint relates (i.e. name of the crypto-asset service provider, crypto-asset service reference number, or other references of the relevant transactions …)

…

3.b. Description of the complaint’s subject-matter

…

Please provide any documentation supporting the facts mentioned.

3.c. Date(s) of the facts that have led to the complaint

…

3.d. Description of damage, loss or detriment caused (where relevant)

…

3.e. Other comments or relevant information (where relevant)

…

In ___________________________________(place) on ____________________(date)

SIGNATURE

COMPLAINANT/LEGAL REPRESENTATIVE OF THE COMPLAINANT

Documentation provided (please check the appropriate box):

Power of attorney or other official document as proof of the appointment of the representative

Copy of the contractual documents of the investments to which the complaint relates

Other documents supporting the complaint: