1. Introduction This Complaints Handling Policy outlines the procedures and responsibilities for handling complaints from clients and stakeholders of Shipfinex FZCO (‘Shipfinex’). The policy ensures transparency, fairness, and prompt resolution of all complaints, maintaining the integrity and reputation of Shipfinex.

2. Scope This policy applies to all complaints received from clients, including holders of Maritime Asset Tokens (MATs), regarding any aspect of the services provided by Shipfinex. It covers the submission, investigation, resolution, and monitoring of complaints, ensuring that all issues are handled fairly and consistently. 

3. Objectives - Ensure all complaints are handled in a transparent, fair, and timely manner.

   - Maintain comprehensive records of all complaints and resolutions.

   - Ensure continuous improvement in service quality and compliance.

   - Define the role of the Marine Asset Technical Committee (MATC) in addressing complaints.

4. Roles and Responsibilities 1. Complaint Handling Officer (CHO): The Chief Operating Officer is currently the designated CHO responsible for receiving, recording, and managing the complaints. 

   2. Marine Asset Technical Committee (MATC): An independent body that oversees and adjudicates complaints related to maritime asset tokenization.

   3. Senior Management: Ensures adequate resources are available for effective complaint handling and reviews complaint data to identify systemic issues and implement improvements.

5. Complaint Handling Procedure Shipfinex is dedicated to providing exceptional service and ensuring that any issues or concerns raised by clients are addressed promptly and effectively. The following procedure outlines the steps for receiving, recording, assessing, investigating, resolving, and escalating complaints, ensuring transparency and accountability throughout the process. This procedure applies to all complaints received from clients regarding any aspect of the services provided by Shipfinex, with specific protocols for handling complaints related to Maritime Asset Tokenization (MAT).

Receiving Complaints

• Complaints can be submitted via email [support@shipfinex.com], or through the Shipfinex website [www.shipfinex.com] – chat support or embedded form.

• Upon receipt, the CHO will acknowledge the complaint within 2 business days of a complaint being made.

• Ensure all submission channels are easily accessible to clients, and provide clear instructions on how to submit a complaint.

• Offer assistance through customer support representatives to help clients articulate their complaints clearly and comprehensively.

• No fees or charges are imposed for the submission or handling of complaints.

Recording Complaints

• All complaints are logged into the Complaints Register, detailing the complainant’s information, nature of the complaint, and date received.

• Complaints are stored securely to ensure confidentiality and data protection.

• Assign a unique tracking number to each complaint to facilitate easy reference and follow-up.

• Maintain an audit trail of all actions taken regarding the complaint for transparency and accountability.

Initial Assessment

• The CHO conducts an initial assessment to determine the nature and complexity of the complaint.

• Complaints related to MATs or maritime asset tokenization are referred to the MATC for independent review.

• Categorise complaints based on their severity and complexity to prioritise investigation and resolution efforts.

• For urgent or severe complaints, take immediate steps to mitigate any potential harm to the client or the company.

Investigation

• The CHO or MATC, as applicable, investigates the complaint. This includes gathering relevant information, consulting with involved parties, and reviewing documentation.

• For MAT-related complaints, the MATC will assess vessel integrity, operational data, and financial data against industry benchmarks.

• Conduct interviews with relevant parties, including the complainant, to gather comprehensive insights into the issue.

• Review all relevant documents, communications, and records to ensure a thorough investigation.

Resolution

• A resolution is proposed based on the findings of the investigation. The CHO will communicate the resolution to the complainant within  four [4] weeks of receiving the complaint.

• In cases where the complaint cannot be resolved within this timeframe due to extraordinary circumstances, the client is provided with an update on the status of the complaint and an explanation for the delay. The resolution is ensured no later than eight [8] weeks from the date the complaint was made.

• Seek the complainant’s agreement on the proposed resolution and address any further concerns they may have.

• Document the resolution process and the final outcome in detail.

Escalation

• If the complainant is unsatisfied with the resolution, they can escalate the complaint to senior management or an external dispute resolution body.

• The MATC’s decisions on MAT-related complaints are final and enforceable, ensuring independence and impartiality. However, this does not obligate clients to refrain from raising complaints to VARA if they are not satisfied with the resolution.

• Provide clear guidance to clients on the escalation process, including contact information for senior management and external bodies.

• Ensure follow-up with the complainant after the escalation process to confirm their satisfaction with the final resolution.

Record Keeping

• Detailed records of all complaints, investigations, and resolutions are maintained for a minimum of eight [8] years.

• These records are available for audit and regulatory review.

• Shipfinex maintains a log of all complaints received, including details of the complainant, the nature of the complaint, and the actions taken, and will regularly report complaint statistics and trends to senior management for review and action.

• Ensure all records are stored securely and comply with data protection regulations.

• Maintain transparency in record-keeping to build trust with clients and regulatory bodies.

Monitoring and Reporting

• The CHO provides regular reports to senior management on the status and trends of complaints.

• The MATC submits monthly reports on complaints related to maritime asset tokenization to ensure transparency and accountability.

• Analyse complaint data to identify recurring issues and areas for improvement in service delivery.

• Use insights from complaints to continuously improve processes, policies, and client services.

This comprehensive approach ensures that all complaints are handled fairly and consistently, reinforcing Shipfinex’s commitment to maintaining the highest standards of client service and regulatory compliance.

6. Complaints Involving Third Parties Shipfinex is committed to facilitating the resolution of complaints related to Virtual Asset (VA) Activities involving third-party entities in a fair and efficient manner. Clients can submit their complaints via the already mentioned channels clearly identifying any third-party entity involved. Upon receipt, Shipfinex will acknowledge the complaint and conduct a preliminary review to determine the involvement of third-party entities and gather necessary information.

   Once a complaint is identified as involving a third-party entity, Shipfinex will contact the relevant third-party within a specified timeframe to inform them of the complaint and request their cooperation in resolving the issue. A joint investigation will be conducted to ascertain the facts and determine an appropriate resolution, with the proposed resolution communicated to the client promptly. Shipfinex will make a final decision on the resolution of the complaint, ensuring that all actions taken are documented and retained for a minimum of 8 years, and will be available to VARA for inspection upon request. This process ensures that Shipfinex remains responsible for the resolution of such complaints, maintaining high standards of client service and regulatory compliance.

7. Role of the Marine Asset Technical Committee (MATC) The Market Arbitration and Trading Committee (MATC) at Shipfinex ensures fair and transparent handling of complaints related to maritime asset tokenization. Key aspects of the MATC include:

   
   

   • Independent Oversight: The MATC functions independently to ensure fair play and transparency in addressing complaints related to maritime asset tokenization.

   • Expert Panel: The MATC comprises experts from ship registry, insurance, chartering, technical management, crewing, ownership, selling, commercial management, maritime regulatory bodies, blockchain, and banking technology.

   • Adjudication: The MATC reviews and adjudicates complaints, ensuring decisions are based on industry benchmarks and best practices.

   • Enforceability: The MATC’s decisions are binding and enforceable, providing assurance to MAT holders that their complaints are addressed impartially and effectively.

8. Training and Awareness Shipfinex is committed to maintaining high standards of service and ensuring that complaints are handled fairly and efficiently. To support this commitment, we have implemented comprehensive measures to educate our staff and inform our clients about the complaint handling process.

   • Regular training programs are conducted for staff to ensure they understand the complaints handling procedures and the importance of fair treatment. These programs are designed to equip our team with the knowledge and skills necessary to manage complaints effectively and to ensure that all clients are treated with respect and fairness.

   • Information about the complaint handling process is made readily available to all clients and stakeholders. This includes clear guidelines on how to submit complaints, the steps involved in the complaint resolution process, and what clients can expect in terms of response times and outcomes. By providing transparent and accessible information, we aim to make the complaint handling process straightforward and reassuring for all parties involved.

   
   

9. Review and Continuous Improvement

   • This policy is reviewed annually to ensure it remains effective and up-to-date with regulatory requirements and industry best practices.

   • Feedback from clients and stakeholders is used to continuously improve the complaint handling process.

By implementing this comprehensive Complaints Handling Policy, Shipfinex ensures that all complaints are managed effectively, maintaining trust and satisfaction among its clients and stakeholders.

Appendix: Shipfinex Complaint Form Template

Complaint Reference Number: [Auto-generated]

Complainant Information

- Name: 

- Contact Details (Email/Phone): 

- Relationship to Shipfinex (Client/Investor/Other): 

Complaint Details

- Date of Complaint: 

- Description of Complaint: 

- Relevant Documents Attached (Yes/No): 

Acknowledgment

- Date Acknowledged: 

- CHO Initials: 

Investigation Notes

- Investigator Name: 

- Findings: 

- Resolution Proposed: 

- Date: 

Resolution Communication

- Date Communicated: 

- Complainant's Response: 

Closure

- Date Closed: 

- CHO Initials:

Complaint Register Template*

* Note that this is just a reference template. The actual register will be kept separately, monitored, and updated in real time.