Complaints Policy

Our Commitment

Valtorum is committed to operating a transparent, fair and professional permissioned digital settlement infrastructure. We value feedback from our users, counterparties and business partners and aim to address complaints promptly, objectively and consistently.

This Complaints Policy explains how complaints may be submitted, how they are reviewed, and what users can expect during the complaint handling process.

Nothing in this Policy limits Valtorum's legal rights or regulatory obligations.

Scope

This Policy applies to complaints relating to:

• Website services
• USDV authorization applications
• Identity verification
• Compliance onboarding
• Wallet authorization
• USDV issuance
• USDV redemption
• Customer support
• Technical issues
• Operational delays
• Billing or fees
• Data protection
• Privacy matters
• Security incidents
• Service availability
• API services
• Business relationships
• Other Valtorum products or services

What Is a Complaint?

A complaint is an expression of dissatisfaction regarding the Services provided by Valtorum where the individual or organization believes that a review or response is appropriate.

A complaint does not need to use specific legal terminology.

Matters Covered by this Policy

Examples include:

• Delays in application processing
• Customer service concerns
• Technical problems
• Website errors
• Identity verification issues
• Redemption delays
• Issuance enquiries
• Operational communication
• Data protection concerns
• Privacy enquiries
• Service interruptions
• Billing concerns
• Accessibility issues
• General dissatisfaction with our Services

Matters Not Covered

The following are generally outside the scope of this Policy:

• Market price movements
• Blockchain network congestion
• Third-party wallet failures
• Third-party exchange services
• Banking delays outside Valtorum's control
• Court orders
• Regulatory actions taken by government authorities
• Criminal investigations
• Law enforcement actions
• Requests for legal advice
• Investment performance
• Decisions made by third-party service providers

Decisions That Are Generally Not Appealable

Certain decisions are made in accordance with legal, regulatory or risk management obligations and may not be subject to appeal.

These include, but are not limited to:

• Authorization approvals or refusals
• Suspension or revocation of authorization
• Compliance risk assessments
• Internal risk ratings
• Enhanced due diligence decisions
• Sanctions screening outcomes
• Fraud prevention measures
• AML or CTF decisions
• Internal security controls
• Business acceptance decisions

Valtorum may, at its discretion, reconsider a decision where new or materially different information is provided.

How to Submit a Complaint

Complaints should include, where applicable:

• Full name
• Company name (if applicable)
• Email address
• Reference number
• Wallet address (where relevant)
• Description of the issue
• Relevant dates
• Supporting documentation
• Screenshots
• Transaction hashes
• Any steps already taken to resolve the matter

Providing complete information assists us in reviewing your complaint efficiently.

Complaint Review Process

Step 1

Receipt

Once received, your complaint will be recorded within our internal case management system.

Step 2

Acknowledgement

Valtorum will acknowledge receipt of the complaint within a reasonable period.

Where additional information is required, we may contact you before commencing our review.

Step 3

Assessment

The complaint will be assessed by the appropriate operational, technical, compliance or management team depending on its nature.

Where appropriate, additional documentation may be requested.

Step 4

Investigation

Where necessary, Valtorum may investigate the circumstances surrounding the complaint.

Investigations may involve:

• Technical analysis
• Internal records
• Communication history
• Blockchain analysis
• Operational review
• Compliance review
• Third-party information where appropriate

Step 5

Decision

Following review, Valtorum will provide a response explaining the outcome where legally and operationally appropriate.

Responses may include:

• Complaint upheld
• Complaint partially upheld
• Complaint not upheld
• Additional information required
• Matter outside our responsibility
• Matter referred to another provider
• Matter closed

Expected Timeframes

Valtorum aims to:

• Acknowledge complaints promptly.
• Review complaints as quickly as reasonably practicable.
• Keep complainants informed where additional time is required.

Complex matters involving third parties, regulatory obligations or technical investigations may require additional time.

Response times are estimates only and do not create contractual obligations.

Confidentiality

Complaint information will be handled confidentially and shared only with personnel or third parties who reasonably require access in order to investigate or resolve the matter.

Information may also be disclosed where required or permitted by applicable law.

Compliance and Regulatory Matters

Certain complaints may involve legal or regulatory obligations.

Examples include:

• Anti-money laundering
• Counter-terrorist financing
• Sanctions compliance
• Fraud prevention
• Cybersecurity
• Financial crime
• Identity verification

Where such matters arise, Valtorum may be legally prohibited from disclosing:

• Internal compliance assessments
• Risk scoring
• Investigation methods
• Suspicious activity reporting
• Information shared with authorities
• Reasons supporting compliance decisions

Accordingly, the level of detail that can be provided in our response may be limited.

Fraud Reports

Reports of suspected fraud should include all available supporting information.

Examples include:

• Identity theft
• Fake Valtorum websites
• Counterfeit communications
• Phishing attempts
• Wallet compromise
• Unauthorized use of Valtorum branding
• Fraudulent USDV activity
• Social engineering

Fraud reports may be prioritised for immediate review.

Abuse of the Complaints Process

Valtorum reserves the right to limit, suspend or decline further engagement where complaints are:

• Repetitive
• Vexatious
• Abusive
• Threatening
• Harassing
• Frivolous
• Submitted in bad faith
• Intended to disrupt operations

This does not affect any legal rights available under applicable law.

Regulatory Escalation

Where permitted by applicable law, complainants may have the right to refer certain complaints to an appropriate regulator, ombudsman or dispute resolution body.

Valtorum's internal complaints process should normally be completed before external escalation, unless applicable law provides otherwise.

No Effect on Compliance Actions

Submitting a complaint does not suspend or prevent:

• Compliance reviews
• Fraud investigations
• Identity verification
• Regulatory reporting
• Enforcement actions
• Authorization decisions
• Suspension of Services
• Revocation of authorization

These processes may continue independently where required by law or internal policy.

Reservation of Rights

Valtorum reserves the right to:

• Request additional information
• Close incomplete complaints
• Decline matters outside its responsibility
• Consolidate duplicate complaints
• Correct factual errors
• Amend this Policy from time to time

Nothing in this Policy limits Valtorum's rights under its Terms of Use, Privacy Policy, Compliance & Enforcement Policy or applicable law.

Contact

Complaints may be submitted through Valtorum's official support or compliance contact channels.

Users should avoid sending sensitive personal information through unsecured communication methods unless specifically requested by Valtorum.

Final Notice