WUBU FZCO | COMPLAINTS HANDLING POLICY | JULY 2024

WUBU FZCO (“Wubu”) provides ‘Broker Dealer Services’ (“Services”) for virtual assets and is licensed by the Virtual Assets Regulatory Authority (“VARA”) in Dubai. This Complaints Handling Policy (“Complaints Handling Policy” or “Policy”) has been developed by Wubu. This Complaints Handling Policy is reviewed annually, unless there is a change in regulation or Wubu’s business that requires to implement an earlier update.

1. PURPOSE 1.1.

Wubu is committed to promptly, fairly, consistently, and efficiently resolving all complaints received by its clients. Wubu views complaints as an opportunity to complete the loop, and continually improve the quality of its services.

1.2. To that end, Wubu has formulated and implemented this Policy and established procedures to facilitate the handling of complaints and redressal of grievances by complainants (“Complainants”). Any complaint, or any other expression of dissatisfaction, whether oral or writtenabout a service or activity relating to the services provided by Wubu (“Complaints”) will be dealt with in accordance with this Policy.

1.3. Wubu remains committed to resolving Complaints in accordance with the

following principles: a. reasonableness,

b. fairness, c. justice, d. cost effectiveness, e. cooperation with the Complainant, and f. reaching a solution as amicably as possible.

2. COMPLIANCE OFFICER 2.1. Wubu has appointed a compliance officer (“Compliance Officer”) shall be responsible for the day-to-day

implementation and supervision of compliance with this Policy and any related procedures.

2.2. The Compliance Officer shall ensure that each Complaint is duly addressed by the concerned persons, and the Complaint is ultimately processed and resolved in accordance with this Complaints Handling Policy.

2.3. The Compliance Officer shall collect and evaluate all documents and data related to the Complaint to analyze and evaluate the historical data related to the servicing of the Complainant, assess other information available and relevant to the complaint investigation, and take any other necessary actions to investigate the complaint properly.

3. COMPLAINT LIFECYCLE AND TIMELINES 3.1. Filing a Complaint

3.1.1 A Complainant may file a Complaint by:

a. filling out this form www.wubu/help.com form for Complaints (“Complaint Form”) and emailing the duly filled Complaint Form to help@wubu.com ; or

b. by way of email to help@wubu.com; c. or by way of letter to Wubu FZCO, Floor no. 25, Premises - EO54-SRT, Sheikh Rashid Tower.

3.1.2 The Complainant must include the following details in each Complaint made:

a. Name of the Complainant; b. Account details; c. Nature of Complaint; d. Date on which issue first arose; e. Details of Service; f. Details of Complaint; g. Action sought by Complainant; h. Supporting documents like proof of payment.

3.1.3 Recognition of Complaints:

a. Service: All Complaints must be made in writing and (save as otherwise stated) by letter or email to Wubu at help@wubu.com and shall be deemed to be duly made to Wubu:

i. when delivered to Wubu at Wubu FZCO, Floor no. 25, Premises - EO54-SRT, Sheikh Rashid Tower. , in the case of personal delivery; ii. on receipt of a confirmation of

successful delivery, in the case of an email; or iii. on receipt of a confirmation of successful delivery, after being dispatched by an internationally

recognized courier, in the case of a letter,

b. Form of Complaint: All Complaints must either be in the Complaint Form set out at Clause 3.1.1 or include all the details specified in Clause 3.1.2, as the case may be, to be considered duly made.

c. Mediums: Wubu shall only recognise and monitor those Complaints that have been made in accordance with the terms of this Complaints Handling Policy.

3.1.4 Wubu does not impose any fees or charges for the submission or handling of any Complaints, including for liaising with any third parties in case of a Compliant involving a third-party.

3.2 Investigation and resolution timeline

3.2.1 Wubu shall investigate all Complaints promptly and resolve the Complaints as soon as practicable within a reasonable period of time, such time not exceeding:

a. 1 (one) week from a Compliant being made for acknowledgment of the Compliant; and b. 4 (four) weeks from a Compliant being made for resolution of the Complaint.

3.2.2 Notwithstanding Clause 3.2.1 above, in case of extraordinary circumstances where the Complaint cannot be resolved within 4 (four) weeks, Wubu shall ensure that the Complainant is provided with an update on the status of the Complaint along with an explanation of the extraordinary circumstances delaying the resolution of the Complaint. In any case, Wubu shall resolve the Complaint no later than 8 (eight) weeks from when the Complaint was made.

3.2.3 Upon conclusion of an investigation of a Complaint, Wubu shall:

a. Inform the Complainant in writing, through a complete, reasoned and documented response, of the Wubu’s resolution for the Complaint;

b. provide the Complainant with clear terms of redress, if applicable; and c. comply with the terms of redress if accepted by the Complainant.

3.2.4 Wubu shall provide responses to all Complaints in a clear and easily understandable manner.

3.2.5 If the Complainant is not satisfied with the terms of redress offered by Wubu, the Complainant may seek recourse to the dispute resolution terms contained in the Agreement.

3.3 Third Parties

If a third-party engaged by Wubu or partnered with Wubu is entirely or partly responsible for the subject matter of a Complaint, Wubu shall refer the Complaint, or the relevant part of it, to the relevant third-party. In the event Wubu refers a Complaint to a third-party, Wubu shall:

a. Inform the Complainant promptly and in writing that it is referring the Complaint, to said third-party; b. Provide the Complainant with adequate contact details of such third-party; c. Facilitate and manage the Complaints by liaising with the Complainant and the third-party as necessary; d. Remain responsible for a resolution being provided for the Complaint by the third-party.

4 RECORD KEEPING AND DISCLSOURE

Wubu shall maintain a record of all complaints made and resolutions offered for a minimum period of eight (8) years from the date of receipt of a complaint. The record must contain:

a. Name, date and contact details of the Complainant; b. The subject matter, cause and substance of the Complaint; c. Wubu’s responses and resolutions; d. The outcome of the complaint and any other relevant correspondence, documentation or action taken by

the Wubu to resolve the complaint. 3.2. Wubu shall publish and update (as required) on this website in a clear and easy-to-understand manner its

complaints handling procedures.

5 ANALYSIS AND IMPROVEMENT Wubu shall take all reasonable steps to ensure that in handling Complaints it identifies and remedies any recurring or systemic problems, including conducting an annual thorough analysis of all Complaints received in order to identify the common root causes, implement measures to address and correct such root causes to avoid reoccurrences, and also consider whether these root causes affect other processes, services or products of Wubu, including but not limited to the Services.