Claims Handling & Dispute Resolution Policy

1. INTRODUCTION AND PURPOSE

At World Golden Gate Virtual Assets Broker & Dealer Services L.L.C (WGG), we are committed to providing a transparent, fair, and accessible process for handling all client complaints, claims, and disputes related to our Spot and OTC virtual asset trading services. Our approach is governed by both the Dubai Virtual Assets Regulatory Authority (VARA) and the UAE Personal Data Protection Law (PDPL), reflecting international best practices.

This summary outlines how we manage, investigate, and resolve complaints efficiently and impartially, fostering a culture of trust, accountability, and continuous improvement. We recognize that effective complaint handling is a cornerstone of client protection and market integrity.

2. WHO IS COVERED BY THIS POLICY

This policy applies to:

• All clients, counterparties, and service users interacting with WGG platforms and services

• All WGG staff involved in client interaction or complaint handling

• Any external stakeholder affected by or engaged in a service or transaction with WGG

This includes both retail and institutional clients, partners, outsourced service providers, and applicants for onboarding.

3. WHAT CONSTITUTES A COMPLAINT OR CLAIM

• A Complaint is any dissatisfaction (verbal or written) expressed about our services, operations, or performance.

• A Claim is a formal demand for redress, compensation, or corrective action resulting from a specific issue or loss.

Examples include:

• Trade execution errors

• Delays in withdrawals or confirmations

• Asset discrepancies

• Breaches of contractual or disclosure obligations

• Allegations of market manipulation, insider trading, or other serious misconduct

4. HOW TO SUBMIT A COMPLAINT

Clients may submit complaints via:

• Email: complaints@worldgoldengate.com

• Online Portal: Complaint form available on our website

• Mail: Addressed to the Chief Compliance Officer at our registered Dubai office

• Telephone: Verbal complaints are accepted but must be followed up in writing

All complaints must include:

• Full name and contact information

• Client Identification Number (if available)

• Description of the issue, date, and evidence (if any)

• Preferred resolution (if applicable)

Once submitted, the complaint will be logged, assigned a unique reference number, and routed to the appropriate handler.

5. WHAT HAPPENS AFTER YOU FILE A COMPLAINT

Within five (5) business days, you will receive an acknowledgment letter including:

• Case reference number

• Name of the handling officer

• Outline of the complaint process and next steps

• Expected timeframe for response and resolution

We may request additional documentation if needed. Incomplete complaints will not be closed; instead, we will proactively assist in clarifying or gathering missing details.

6. RESPONSE TIMELINES AND ESCALATION TIERS

If deadlines cannot be met, you will be informed of the delay and provided an estimated resolution date. Progress updates will be provided weekly for unresolved cases.

7. INVESTIGATION, RESOLUTION, AND FINAL RESPONSE

• All investigations are conducted independently and objectively.

• The investigator will review internal records, technical logs, and engage relevant departments.

• Interviews or follow-ups with the complainant may be required for clarity or evidence.

• A Final Response will be provided within four (4) weeks (extendable to eight (8) weeks in complex cases).

The Final Response includes:

• Summary of findings and legal basis

• Any compensation or remedial actions offered

• Instructions for escalation or appeal

• Timeline for acceptance of any proposed resolution (typically 7 calendar days)

8. APPEALS AND ADDITIONAL REMEDIES

If you are not satisfied with the Final Response, you may:

• File a complaint with VARA

• Pursue action before the Dubai Courts or relevant judicial bodies

• Agree to arbitration (if mutually acceptable)

Appeals must be lodged within 30 calendar days of the Final Response.

WGG will cooperate fully with regulators and legal authorities and make records available as required.

9. THIRD-PARTY COMPLAINTS AND DATA PRIVACY

If your issue involves a third-party service provider:

• WGG will inform you in writing before referring the matter

• Your data will only be shared with your written consent and under strict PDPL compliance

• WGG retains final responsibility for complaint resolution and ensures closure to your satisfaction

10. RECORD-KEEPING AND OVERSIGHT

WGG retains a full record of all complaints and correspondence for at least eight (8) years. Our central Complaint Register includes:

• Date, nature, and severity of the complaint

• Responsible staff and case resolution timeline

• Supporting documents, investigation trail, and outcome

• Audit trail of decisions, escalations, and internal reviews

These records are securely stored, encrypted, and subject to regulatory inspection.

11. ROOT CAUSE ANALYSIS AND SERVICE IMPROVEMENT

After every resolved complaint, we conduct Root Cause Analysis (RCA) to:

• Identify procedural, technical, or human control gaps

• Implement corrective actions and process improvements

• Feed insights into compliance monitoring and staff training

• Ensure systemic learnings are recorded and tracked through our Compliance Dashboard

12. GOVERNANCE, REVIEW, AND TRAINING

• This policy is reviewed annually, or sooner if required by regulation

• Updates require Board-level approval and are communicated via internal training

• All client-facing teams, especially Customer Support and Compliance, undergo regular training on complaint handling procedures, VARA standards, and service ethics

13. CONFIDENTIALITY AND RETALIATION PROTECTION

• All complaint submissions are treated confidentially

• Personal and sensitive information is protected under WGG’s Data Privacy and Information Security Policies

• Complainants and whistleblowers are shielded from retaliation or adverse consequences for raising concerns in good faith

14. VARA SUPERVISORY COLLABORATION AND COOPERATION

• WGG maintains active cooperation with VARA and other UAE authorities

• We submit quarterly complaints reports (where required) and maintain transparency in supervisory engagements

• We promptly notify VARA of any trends indicating systemic risk, misconduct, or potential market abuse identified through complaints

15. CONTACT INFORMATION

For all complaint or dispute matters:

Chief Compliance Officer

World Golden Gate Virtual Assets Broker & Dealer Services L.L.C

Office 214, Al Wasl, Dubai, UAE

Email: complaints@worldgoldengate.com

WGG values your feedback and remains committed to resolving all matters with transparency, diligence, and regulatory integrity.