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1. INTRODUCTION

QFEX Bermuda Ltd. (“QFEX,” “we,” “us,” or “our”) is committed to providing high-quality services to all participants in our waitlist and referral program (the “Program”). This Complaints Policy (“Policy”) outlines our procedures for receiving, investigating, and resolving complaints about our services. QFEX is subject to Bermuda law and regulation, including the Investment Business Act 2003, and we are committed to maintaining the highest standards of customer service and regulatory compliance. We take all complaints seriously and are committed to resolving them fairly, efficiently, and in accordance with applicable regulatory requirements.

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2. WHAT IS A COMPLAINT?

A complaint is any expression of dissatisfaction about our services, staff, or the way we have handled your account or personal information. This includes complaints about: (a) Service Quality: The quality or availability of our services; (b) Staff Conduct: The behavior or actions of our personnel; (c) Account Management: How we have managed your account or participation in the Program; (d) Privacy and Data Protection: How we have handled your personal information; (e) Communication: Our communication practices or failure to communicate; (f) Technical Issues: Problems with our website, systems, or technology; (g) Fees and Charges: Any fees or charges related to the Program; (h) Compliance: Our compliance with applicable laws and regulations; (i) Investment Services: Any future investment services we may provide; (j) Regulatory Matters: Issues related to regulatory compliance or reporting.

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3. HOW TO SUBMIT A COMPLAINT

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3.1 Complaint Submission Methods

You may submit a complaint by email to complaints@qfex.com.

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3.2 Information to Include

To help us investigate your complaint effectively, please provide the following information: (a) Personal Details: Your full name, email address, and account information; (b) Complaint Details: A clear description of your complaint, including dates, times, and relevant circumstances; (c) Supporting Documentation: Any relevant documents, screenshots, or other evidence; (d) Desired Outcome: What you would like us to do to resolve your complaint; (e) Previous Contact: Details of any previous contact with us about the same issue; (f) Contact Preferences: How you would prefer us to contact you about your complaint; (g) Financial Impact: Any financial impact or loss you have suffered (if applicable).

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3.3 Anonymous Complaints

While we prefer to receive complaints with full contact information so we can respond to you directly, we also accept anonymous complaints. However, our ability to investigate and resolve anonymous complaints may be limited.

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4. COMPLAINT HANDLING PROCESS

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4.1 Acknowledgment

We will acknowledge receipt of your complaint within two (2) business days of receiving it. Our acknowledgment will include: (a) A unique complaint reference number; (b) The name and contact information of the person handling your complaint; (c) An explanation of our complaint handling process; (d) The expected timeframe for resolution; (e) Information about your rights and options.

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4.2 Initial Assessment

Within five (5) business days of receiving your complaint, we will conduct an initial assessment to: (a) Determine the nature and scope of your complaint; (b) Identify any immediate actions needed; (c) Assign the complaint to the appropriate department or personnel; (d) Determine the appropriate investigation process; (e) Assess any regulatory reporting requirements.

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4.3 Investigation

We will conduct a thorough and impartial investigation of your complaint, which may include: (a) Document Review: Reviewing relevant documents, records, and communications; (b) Staff Interviews: Interviewing relevant staff members; (c) System Analysis: Analyzing system logs and technical data; (d) External Consultation: Consulting with external experts or advisors if necessary; (e) Additional Information: Requesting additional information from you if needed; (f) Regulatory Consultation: Consulting with regulatory authorities if appropriate.

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4.4 Resolution Timeframes

We aim to resolve complaints within the following timeframes: (a) Simple Complaints: Within 15 business days of receipt; (b) Complex Complaints: Within 35 business days of receipt; (c) Regulatory Complaints: Within timeframes specified by applicable regulations; (d) Exceptional Circumstances: If we need more time due to exceptional circumstances, we will notify you and provide regular updates.

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4.5 Response

We will provide you with a written response that includes: (a) Investigation Summary: A summary of our investigation and findings; (b) Decision: Our decision on whether your complaint is upheld, partially upheld, or not upheld; (c) Reasoning: The reasoning behind our decision; (d) Remedial Action: Any remedial action we will take to resolve your complaint; (e) Prevention Measures: Steps we will take to prevent similar issues in the future; (f) Further Options: Information about further options if you are not satisfied with our response; (g) Regulatory Rights: Information about your rights to escalate to regulatory authorities.

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5. TYPES OF REMEDIAL ACTION

If we uphold your complaint, we may take the following types of remedial action:

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5.1 Corrective Action

(a) Service Correction: Correcting any service deficiencies or errors; (b) Account Adjustments: Making appropriate adjustments to your account; (c) Process Improvements: Implementing process improvements to prevent recurrence; (d) Staff Training: Providing additional training to relevant staff members; (e) System Improvements: Making improvements to our systems and technology.

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5.2 Compensation

Where appropriate, we may provide compensation, which may include: (a) Fee Refunds: Refunding any fees inappropriately charged; (b) Service Credits: Providing credits for future services; (c) Monetary Compensation: Providing monetary compensation for losses or inconvenience; (d) Non-Monetary Remedies: Providing non-monetary remedies such as apologies or service improvements; (e) Interest Payments: Paying interest on delayed payments or refunds (where applicable).

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5.3 Systemic Changes

For complaints that reveal systemic issues, we may implement: (a) Policy Changes: Updating our policies and procedures; (b) System Improvements: Making improvements to our systems and technology; (c) Training Programs: Implementing new training programs for staff; (d) Monitoring Enhancements: Enhancing our monitoring and quality assurance processes; (e) Regulatory Compliance: Improving our regulatory compliance procedures.

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6. ESCALATION PROCEDURES

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6.1 Internal Escalation

If you are not satisfied with the initial response to your complaint, you may request escalation to: (a) Senior Management: The complaint will be reviewed by senior management; (b) Independent Review: An independent internal review may be conducted; (c) Executive Review: The complaint may be escalated to executive level for final internal review; (d) Board Review: Serious complaints may be escalated to board level.

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6.2 External Escalation

If you remain unsatisfied after our internal complaint process, you may escalate your complaint to:

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6.2.1 Alternative Dispute Resolution

We may participate in alternative dispute resolution processes, including: (a) Mediation: Voluntary mediation through recognized mediation services; (b) Arbitration: Binding arbitration as provided in our Terms and Conditions; (c) Ombudsman Services: Relevant ombudsman services where available; (d) Industry Schemes: Industry-specific dispute resolution schemes.

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7. COMPLAINT RECORDS AND REPORTING

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7.1 Record Keeping

We maintain comprehensive records of all complaints, including: (a) Complaint Details: Full details of each complaint received; (b) Investigation Records: Records of our investigation process and findings; (c) Resolution Actions: Details of any remedial actions taken; (d) Communication Records: Records of all communications with complainants; (e) Outcome Tracking: Tracking of complaint outcomes and follow-up actions; (f) Regulatory Reporting: Records of any regulatory reporting or notifications.

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7.2 Regulatory Reporting

We provide regular reports to the BMA and other relevant regulatory authorities on: (a) Complaint Statistics: Number and types of complaints received; (b) Resolution Timeframes: Time taken to resolve complaints; (c) Systemic Issues: Any systemic issues identified through complaints; (d) Remedial Actions: Actions taken to address complaints and prevent recurrence; (e) Trends Analysis: Analysis of complaint trends and patterns.

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7.3 Management Reporting

We provide regular reports to senior management on complaint trends, systemic issues, and improvement opportunities.

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8. COMPLAINT ANALYSIS AND IMPROVEMENT

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8.1 Trend Analysis

We regularly analyze complaint data to identify: (a) Common Issues: Frequently occurring complaint types; (b) Root Causes: Underlying causes of complaints; (c) Systemic Problems: Systemic issues requiring attention; (d) Improvement Opportunities: Opportunities to enhance our services; (e) Regulatory Risks: Potential regulatory compliance issues.

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8.2 Continuous Improvement

Based on our complaint analysis, we implement continuous improvements including: (a) Process Enhancements: Improving our processes and procedures; (b) System Upgrades: Upgrading our systems and technology; (c) Staff Training: Enhancing staff training and development; (d) Policy Updates: Updating our policies and procedures; (e) Regulatory Compliance: Strengthening our regulatory compliance framework.

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9. CONFIDENTIALITY AND PRIVACY

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9.1 Confidentiality

We treat all complaints confidentially and will only share information: (a) As Necessary: With personnel who need to know to investigate and resolve your complaint; (b) With Consent: With third parties where you have provided consent; (c) Legal Requirements: Where required by law or regulation; (d) Regulatory Reporting: For regulatory reporting purposes (in anonymized form where possible); (e) Professional Advisors: With our professional advisors (subject to confidentiality obligations).

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9.2 Privacy Protection

We handle all personal information in complaints in accordance with our Privacy Policy and applicable data protection laws.

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10. NO RETALIATION

We prohibit retaliation against anyone who submits a complaint in good faith. We will not: (a) Discriminate: Discriminate against you for submitting a complaint; (b) Penalize: Penalize you for using our complaint process; (c) Restrict Services: Restrict your access to our services because of a complaint; (d) Negative Treatment: Treat you negatively because you have complained; (e) Future Services: Deny you future services because of a complaint.

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11. FRIVOLOUS OR VEXATIOUS COMPLAINTS

While we take all complaints seriously, we reserve the right to: (a) Decline Investigation: Decline to investigate complaints that are clearly frivolous or vexatious; (b) Limit Resources: Limit resources devoted to repetitive or unreasonable complaints; (c) Set Boundaries: Set reasonable boundaries on communication with persistent complainants; (d) Legal Action: Take legal action against persons who abuse our complaint process.

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12. UPDATES TO THIS POLICY

We may update this Policy from time to time. We will notify you of material changes by posting the updated Policy on our website. The effective date of any changes will be clearly indicated.

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13. CONTACT INFORMATION

For questions about this Policy or to submit a complaint, please contact us at: Complaints Department
Email: complaints@qfex.com Business Hours: Monday to Friday, 9:00 AM to 5:00 PM (Atlantic Standard Time)
This Policy should be read in conjunction with our Terms and Conditions, Privacy Policy, and other applicable policies.