1. INTRODUCTION AND REGULATORY CONTEXT

Cregis Custody FZE ("Cregis" or the "Company")

This Policy is adopted in accordance with the regulatory requirements and guidance issued by the Dubai Virtual Assets Regulatory Authority (VARA), the applicable UAE federal laws and regulations, and any other relevant regulatory obligations applicable to the Company's custody operations.

2. SCOPE AND ELIGIBLE COMPLAINANTS

Complaints may be submitted by:

• clients of Cregis;
• prospective clients;
• authorised representatives of clients; and
• where applicable, end‑users of institutional clients in matters directly relating to Cregis's custody services.

This Policy applies to all complaints relating to Cregis's services, staff, operations, or the handling of a previous complaint.

3. DEFINITION OF A COMPLAINT

A complaint is defined as:

"Any expression of dissatisfaction made to or about Cregis Custody FZE related to our products, services, staff, or the handling of a previous complaint, where a response or resolution is explicitly or implicitly expected or legally required."

All complaints, including verbal complaints, are treated as formal complaints and recorded accordingly.

4. HOW TO SUBMIT A COMPLAINT

Complaints may be submitted through any of the following channels:

Email us at: [email protected]

Subject line: "Official Complaint – Cregis Custody FZE"

Complaint Form

Clients may complete the Complaint Form available on the Company's website and submit it by email with any supporting documentation.

Information to Include (where available):

• Subject: Official Complaint – Cregis Custody FZE
• full name of the complainant;
• registered contact details;
• description of the issue;
• relevant dates, transactions, or references; and
• supporting documents.

Where a complaint involves a third‑party service provider engaged by Cregis, the Company will coordinate with such party; however,

5. ACKNOWLEDGEMENT AND INVESTIGATION

Acknowledgement

• Verbal complaints are acknowledged promptly and confirmed in writing.
• Written complaints are acknowledged in writing.

Investigation

Once a complaint is received, we will:

• Review the details carefully and assess the nature of the concern.
• Conduct a fair and impartial investigation.
• Gather relevant information, including records and communications where necessary.
• Reach out to you if additional information or clarification is required.

We aim to complete investigations as quickly as possible and will keep you informed of progress where appropriate. Once the review is complete, we will provide you with a clear response outlining our findings and any actions taken.

If an issue is identified, we will take appropriate steps to address it and improve our processes to help prevent similar occurrences in the future.

6. RESOLUTION & OFFICIAL COMPLAINT RESPONSE (OCR)

A formal Official Complaint Response (OCR) will be issued when:

• The complaint is not resolved within one week, or
• The client requests a written response.

Standard Resolution Timeline

• Complaints will be resolved within 4 weeks.

Extraordinary Circumstances

If additional time is required:

• An update will be provided within 4 weeks explaining the reason for delay.
• Final resolution will be provided no later than 8 weeks.

The OCR Will Include:

• Summary of issues raised
• Findings and factual assessment
• Explanation of the decision
• Information on escalation options

An OCR is not required where the complaint is resolved within four (4) weeks.

7. CONFIDENTIALITY AND DATA PROTECTION

All complaints are handled confidentially. Information is disclosed only on a need‑to‑know basis and processed in accordance with applicable UAE data protection laws.

8. ESCALATION

if you are not satisfied with our final response, you have the right to escalate your complaint to Sanadak through www.sanadak.gov.ae, 800 SANADAK(7262325), and Sanadak Mobile App within 6 months of the date of our final response or https://www.vara.ae/en/register-a-complaint/

9. RECORD KEEPING

Cregis Custody FZE maintains records of:

• All complaints received
• Steps taken during investigation
• Final resolutions

All records are retained for a minimum of 8 years, in accordance with regulatory requirements.

10. RESPONSIBLE PERSON AND OVERSIGHT

The responsibility for complaint handling shall rest with the Money Laundering Reporting Officer (MLRO) / Compliance Officer, who will oversee the day-to-day management and resolution of complaints. Oversight responsibility shall be maintained by the Board of Directors and Senior Management, ensuring appropriate governance, review, and accountability.

11. IDENTIFYING AND ADDRESSING SYSTEMIC ISSUES

Cregis Custody FZE takes proactive steps to identify and address recurring or systemic issues by:

• Analyzing complaint patterns and root causes
• Assessing whether issues impact other clients or services
• Implementing corrective measures to strengthen internal processes and controls

12. ADDITIONAL INFORMATION

Cregis Custody FZE is committed to fair, transparent, and timely complaint resolution in line with Rule III.A of the VARA Market Conduct Rulebook. We will:

• Acknowledge complaints within one week
• Resolve complaints within four weeks, or within eight weeks under extraordinary circumstances

13. GOVERNING LAW AND REVIEW

This Policy is governed by the laws of the Emirate of Dubai and applicable federal laws of the UAE. The Policy shall be reviewed at least annually or sooner where required by regulatory or operational developments.

Cregis_Custody FZE - Complaints_Form.pdf