STOKR COMPLAINTS HANDLING POLICY

This Complaints Handling Policy (the "Policy") applies to the online services provided on http://www.stokr.io and forms an integral part of STOKR's General Terms.

What does this Complaints Handling Policy aim to provide?

This Policy provides for the steps and measures that we will take in accordance with Article 71 of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets to ensure effective internal rules and controls for prompt, fair and consistent complaints handling.

The following terms in this Policy are defined as:

"Business day" means any day other than a Saturday or a Sunday or a public holiday in the Grand Duchy of Luxembourg.
"Client" means an Investor or Issuer on STOKR.
"Complaint" means a statement of dissatisfaction addressed to us by a Client relating to the provision of one or more crypto-asset services.
"Complaint form" means the form that a Client shall complete and submit to us to file a complaint. The form is available here.
"Investor" means a natural or legal person who has registered as an investor on STOKR.
"Issuer" means a legal person who seeks to tokenize financial instruments and obtain investments through cryptocurrencies and FIAT from professional and qualified Investors.
"Services" means the provision of transfer and custody of crypto-assets on behalf of clients.
"STOKR", "we", "us" or "our" means STOKR S.A. and its registered branches. STOKR S.A. is a public company limited by shares (société anonyme) incorporated under the laws of the Grand Duchy of Luxembourg having its registered office at 9, rue du Laboratoire, L-1911 Luxembourg and registered with the Luxembourg trade register (registre du commerce et des sociétés) under number B 226662.
"Support Team" means our dedicated support team on STOKR responsible for receiving and handling Complaints.

Complaints form and admissibility criteria

Complaints can be filed and will be handled free of charge, however, you shall bear your own expenses (including obtaining external advice) in relation to submitting a Complaint.

You may fill out the Complaint form in Bulgarian, Croatian, Czech, Danish, Dutch, English, Estonian, Finnish, French, German, Greek, Hungarian, Irish, Italian, Latvian, Lithuanian, Maltese, Polish, Portuguese, Romanian, Slovak, Slovenian, Spanish and Swedish.

Only complaints submitted in writing and containing all the information indicated below will be reviewed by us according to this Policy.

For us to understand the nature of your complaint, please make sure that you give us the relevant evidence and information in a clear and precise manner.

The Complaint Form available here should contain all the required information below:

• your personal data whether you are a natural or legal person
• your contact details
• personal data of your legal representative (if applicable) together with a document establishing the proof for power of attorney
• contact details of the legal representative
• information about the Complaint:
  • a full reference of the investment and/or agreement to which the Complaint relates
  • a description of the Complaint's subject matter together with the documents supporting the facts mentioned
  • dates of the facts that have generated the Complaint
  • description of damage, loss or detriment caused (if applicable)
  • other comments or relevant information.

Please note that you need to provide the signed Complaint form together with all the Complaint supporting evidence and relevant documents.

Please make sure that all information provided in the form is complete and correct. We need to have all relevant evidence and information to investigate the Complaint and we accept no liability in case some of the information provided is incomplete or inaccurate. Where appropriate, we may request additional information on your Complaint.

STOKR will accept and treat Complaints only from Clients. No third-party Complaint will be accepted.

In case we receive a Complaint from a third party who is not a Client on STOKR, we can provide normal support and redirect the party to the entity against whom they have made a Complaint.

STOKR is only responsible for Services it provides, and we will not accept a Complaint about a service or activity for which we are not responsible for.

Complaint handling procedure

Please note that we will always communicate in writing by electronic means. If you wish to be contacted in paper form, please make sure to indicate and explicitly request this way of communication.

STOKR will acknowledge receipt and confirm whether the Complaint is admissible within 10 business days of its receipt.

We will send you an email confirming that your Complaints form has been received and will provide the following information:

• whether your Complaint is admissible and if not the reasons for it's rejection
• if admissible, the timeframe for dealing with the Complaint
• a reference/ticket number for the Complaint
• details of STOKR contact person including their email address and telephone number to whom you can address any query related to your Complaint
• an overview of how we intend to address the Complaint.

Upon receipt of an admissible Complaint, we will take all necessary measure to resolve it without undue delay and we will send you a response no longer than fifteen (15) business days after your complaint has been received. We will assess whether all the information and documents provided are clear and complete and where we deem necessary, we will promptly ask for additional information so that we can assign appropriate resources and staff to review your complaint and to communicate with you.

We will assign our resources and involve senior management as necessary to best handle your complaint.

We will gather and retrieve all relevant evidence and information regarding the Complaint and will keep you duly informed about the process without undue delay.

Please note that we will keep on record the Complaints received to ensure that we establish an effective and consistent decision-making process for Complaints in similar circumstances.

Please note that only written replies to written complaints submitted to us according to this Policy and received by us are admissible and will be considered for the decision on the Complaint.

We will address all the issues stated in the Complaint in a clear manner and we will do our best to resolve it within the timeframe mentioned in our acknowledgement email. In case we are unable to give you a decision within the specified timeframe, we will contact you by e-mail and provide a clear explanation and reason for the delay and we will inform you of the deadline for delivering the decision and for completing our review.

Decisions and remedies

After examining the evidence and information of your Complaint, we will provide a written response addressing all points raised by you.

We will:

• explain our findings
• how we reached the decision
• our course of action to resolve the Complaint and
• the reasons for the resulting decision
• in case of an admissible Complaint what is the remedial action that we will offer.

In the case that our decision rejects your Complaint, does not satisfy your Complaint, or partially satisfies it, we will provide a thorough explanation of the outcome and will inform you of the remedies available.

If you are not satisfied with our decision, you may also:

• submit your Complaint to the Luxembourg regulator CSSF through the link here within one year after you filed a complaint with us.
• take civil actions and refer the matter to the competent court of the Grand Duchy of Luxembourg pursuant to the effective laws and regulations of the Grand Duchy of Luxembourg, to the extent permitted by law, except where any mandatorily applicable law requires a specific dispute to be exclusively resolved by the courts of another jurisdiction.

Please note: Our aim is to keep the consistency in previous decisions in similar circumstances. Therefore, Complaints presenting similar circumstances will give rise to decisions that are consistent with each other, and if we are not able to adhere to this Policy, we will provide justification for any deviation from previously taken decisions by STOKR.

For any additional questions on your Complaint you can send an email to our Support Team at [email protected] including the following information:

• your Complaint/ ticket number (if such has been given to you by us)
• if you are a natural person – your name and last name
• if you are a legal person – your company's name, and your authorised representative's first name and last name
• your full phone number, including country code
• a brief message describing your question.

In addition, please note that this Policy does not apply to our service providers and in the event where you are not satisfied with the services they provide independently from us, you should submit a Complaint directly to the responsible party.

Changes to this Policy

We may modify or amend this Policy at our own discretion and whenever any changes therein may become necessary. Therefore, we encourage you to periodically review it to be informed about how we are handling Complaints and the procedure to submit a Complaint on STOKR.