Canada Complaints Policy

1. Purpose

This policy details how Overchain (Canada) Ltd (the Firm) will deal with complaints relating to the provision of its cryptoassets services.
The Firm is Regulated and registered with Fintrac and Bank of Canada. Our definition of a complaint is as an expression of dissatisfaction (oral or written) about the provision of, or failure to provide, a financial service. It alleges how you have suffered (or may suffer):

• financial loss;
• material distress; or
• material inconvenience

2. Review of Policy

This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the Firm’s Management Body in the event of changing circumstances or regulations.

3. Responsibilities

3.1 Management Body Responsibilities

The Management Body of the Firm are responsible for the implementation of the Complaints Policy and for monitoring compliance with it.

The Management Body have appointed the Nominated Officer of Complaints as the Chief Operating Officer (COO) supported by the Chief Compliance Officer as Deputy

3.2 Complaints Manager Responsibilities

The Complaints Manager is responsible for the investigation of complaints.

3.3 Compliance Responsibilities

The Compliance Function, in conjunction with the COO, is responsible for analysing complaints and the
complaints handling data to identify and address any risks or issues and for the completion of the annual Report.

3.4 Employee Responsibilities

All employees are expected to refer any verbal or written complaints to the Complaints Manager at the earliest opportunity and to cooperate fully with the Complaints Manager in its investigations.

4. Policy

It is the Firm’s policy to treat all complainants the same.

Clients and potential clients are able to submit complaints free of charge.

Complaints will be handled promptly, effectively and in an independent manner, obtaining additional
information as necessary.

The Firm will always communicate with clients and potential clients clearly in plain language that is easy tounderstand and will reply to the complaint without undue delay.

The Firm will assess fairly, consistently and promptly:

• The subject matter of the complaint
• Whether the complaint should be upheld
• What remedial action or redress may be appropriate
• Whether another party may be solely or jointly responsible for the matter alleged in the complaint

The Firm will promptly comply with any offer or remedial activity, or redress accepted by the complainant. The Firm will consider a complaint closed when it has issued a final response.

4.1 Consumer Awareness

The Firm has published Complaints Procedures (as part of this Policy) that include contacts details of the
Complaints Officer and Compliance Officer. The procedures are made available to clients and potential clients on request and when the Firm is acknowledging a complaint.

4.2 Timings

We will acknowledge receipt of the complaint within 48-72 hours.  

An initial written acknowledgment will be sent within 14 days, and we aim to resolve the issue promptly within this timeframe. If there are exceptional circumstances, the Firm will take no more than 56 business days to issue a final response to the complainant, and this timeframe must be followed as the maximum period. 

Investigating Complaints 

Assessment: Our Support team will evaluate the complaint to understand its scope and impact. 

Investigation: We will work with the collected relevant information and consult with involved parties as necessary to establish eligible grounds for a solution. 

Resolution: We will determine the most effective solution that satisfies the customer’s needs and take appropriate action to resolve or compensate the customer.  

The opened ticket would be resolved within 14 business days of our acknowledgement of the complaint. Final written responses to the customer shall be issued within the same 56 days per required reporting guidelines in the province. The resolution will include: 

• A summary of the complaint 

• The results of our investigation 

• Our decision to make an offer to resolve the complaint or deny it and an explanation of our decision.

4.2.1 Complaints resolved by close of the third business day

If the Firm satisfactorily resolves the complaint by close of business on the third business day following the receipt of the complaint, then the Firm will issue a written “Summary Resolution Communication” to the complainant, advising that it considers the complaint as resolved and inform the complainant.
In addition to sending a complainant a “Summary Resolution Communication”, the Firm may also use other methods to communicate the information where:

• It considers that doing so may better meet the complainant’s needs; or
• The complainant and the Firm have already been using another method to communicate about the
  complaint.

4.2.2 Complaints not settled within 3 business days

On receipt of a complaint the Firm will send the complainant a written acknowledgement providing
confirmation that is has received the complaint and is dealing with it.
The Firm will ensure that the complainant is kept informed of the progress of the measures being taken forresolution of the complaint.
The Firm will issue a final response to the complainant within 15 business days.

Letter

Timing

Initial response letter Holding letter Final response

Promptly: by the next working day unless there are exceptional circumstances. Optional until the fifteenth business day. The holding letter can be issued more frequently if necessary or desirable. By end of the fifteenth day after the receipt of the complaint in all cases, but sooner whenever possible. If, exceptionally, a full response is not possible by this time the Firm must send out a holding letter explaining why it has not been able to issue a decision within the above time frame and that it expects to be able to provide a decision before the end of the 35th business day.

The final response will clearly set out:

• Whether the Firm accepts or rejects the complaint
• The reasons for rejection, where applicable
• The intention to offer redress or remedial action, where applicable
• Details of the redress to be offered and any compensation offered with a clear method of calculation

The Firm will consider a complaint closed when it has issued its final response.

4.3 Complaints forwarding

The Firm may promptly forward the complaint in writing to another party if they have reasonable grounds to believe that the other party may be solely or jointly responsible for the matter alleged in the complaint. If a complaint is forwarded, the Firm will inform the complainant promptly in a final response of why the complaint has been forwarded to another party and provide the complainant with the other party’s contact details.

If the Firm receives a forwarded complaint, the complaint will be treated as if the Firm has received the
complaint directly and the same time limits will apply from the date on which the Firm has received the
forwarded complaint.

5. The Procedure

Refer any complaint verbal or written to the Complaints Officer at the earliest opportunity.

The Complaints Officer will then,

1. Make an initial assessment of the complaint, contacting the complainant for further information if
   required. This can be done via telephone, email or any other appropriate means of communication.
2. If there is sufficient information and the complaint can be resolved within 3 business days, then proceed to step 9.
3. If the complaint cannot be resolved within 3 business days, send out an initial response letter to the
   complainant using the Initial Response Letter Template, adding the details known about the complaint by the next working day, stating that the complaint has been received and is being dealt with.
4. Investigate the complaint impartially obtaining additional information from the Firm and/or the
   complainant as necessary.
5. Enter the complaint onto the Complaints Log and create a Complaint Record.
6. Assess fairly, consistently and promptly:
   a) The subject matter of the complaint
   b) Whether the complaint should be upheld
   c) What remedial action or redress (or both) may be appropriate
   d) If appropriate, whether it has reasonable grounds to be satisfied that another party/respondent may be solely or jointly responsible for the matter alleged in the complaint.
7. If appropriate, forward the complaint to the relevant party/respondent and advise the complainant in writing as to why the complaint has been forwarded to the other party and provide the other party’s contact details.
8. If the complaint is unresolved after 15 business days, send out a holding letter using the Holding letter template, advising an expected resolution date that is within 35 business days.
9. If the complaint is resolved, communicate the Firm’s position on the complaint to the complainant or
   that the complainant may be able to take civil action, using the Final Response Letter template. If the
   complaint was resolved within 3 days, use the Summary Resolution Communication instead.
10. In the final response letter, clearly set out whether the Firm accepts or rejects the complaint, the
    reasons for rejecting any complaint or where the Firm accepts the complaint, and intends to offer
    redress or remedial action, details of the redress to be offered, any compensation offered and a clear
    method of calculation.
11. Comply promptly with any offer of remedial action or redress accepted by the complainant.
12. Conduct a root cause analysis in the case of any complaint and record with the appropriate action
    having been taken. Record any actions within the individual complaint record.
13. Liaise with senior management if any changes need to be made to the Firm’s procedures based on the analysis.
14. Update the Complaints Log and Complaints Record with the final decision including details of the
    amount of any redress offered.
    

6. Record Keeping

The Firm will keep a record of each complaint received and the measures taken for its resolution, including any redress offered, and retain that record for three years from the date the complaint was received.

7. Breaches of the Complaints Policy and Procedure

Any breaches of the Complaints Policy and Procedures will be recorded on the Firm’s breach log in conjunction with its Regulatory Breach policy.

8. Complaints Escalation

If you have any issues with the resolution of the complaint, you may try further escalation in the following ways:
a. ADR Chambers Banking Ombuds Office (ADRBO)
This is the most common independent dispute resolution service provider for MSBs not federally regulated as banks.

Website: https:// www.adrbo.com
Phone:1-800-941-3655
Email: info@adrbo.com
b. Ombudsman for Banking Services and Investments (OBSI)
Some MSBs may also use OBSI, though it’s more common for investment firms and banks.
Website: https://www.obsi.ca
c. FINTRAC
If the complaint involves suspected non-compliance with anti-money laundering (AML) or terrorist financing
laws, the customer can report the matter directly to:
FINTRAC (Financial Transactions and Reports Analysis Centre of Canada)
Website: https://www.fintrac-canafe.gc.ca
d. FSRA
If the MSB is allegedly operating in violation of Ontario regulations (e.g., unregistered, misleading activities), complaints can also be filed with:
FSRA (Financial Services Regulatory Authority of Ontario)
Website: https://www.fsrao.ca
e. Small Claims Court
In cases involving monetary damages or contractual breaches, customers may also seek remedies through Small Claims Court in Ontario, especially if other resolution efforts fail.

9. How to Make a Complaint

If you would like to make a complaint or follow up on an existing one, please contact us:

• Phone: +1 647 556 2231
• Email: complaints@overchain.io

The Company will acknowledge receipt of a compliant within 48-72hours (no more than 3 business days). An initial written acknowledgment will be sent within 14 calendar days, and we aim to resolve the issue promptly within this timeframe. If there are exceptional circumstances, the company will take no more than 56 calendar days to issue a final response to the complainant, and this timeframe must be followed as the maximum period.