Complaints Handling Procedure - Bleap SIA

1. General Provisions

This Procedure sets out the rules for receiving, registering, analysing, assessing the merits of, and responding to complaints (complaint handling).

Capitalised terms used in this Procedure have the following meanings:

• Compliance Officer – means the person designated by the Management Board to perform the function of Compliance Officer within the Company, responsible inter alia for ensuring the Company’s compliance with applicable law and internal regulations (the Compliance Officer function may in particular be performed by the Chief Compliance Officer);
• Client – means any natural person to whom the Company provides crypto-asset services;
• Employee – means an employee of the Company or any person performing tasks entrusted by the Company in connection with the provision of services, under an employment contract, mandate agreement, contract for specific work, graduate internship, traineeship, civil law agreement, or equivalent legal relationship;
• Procedure – means this Procedure;
• Complaint – means any expression of dissatisfaction addressed to the Company by a Client in connection with the Company’s provision of crypto-asset services, including: (i) exchange of crypto-assets for funds; (ii) exchange of crypto-assets for other crypto-assets; 
• Regulation 2025/294 – means Commission Delegated Regulation (EU) 2025/294 of 1 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the requirements, templates and procedures for complaint handling by crypto-asset service providers;
• Management Board – means the Management Board of the Company.

2 . Publication of Information on the Procedure

The Company publishes, in English and Latvian, on its website at https://www.bleap.finance/how-to-submit-a-complaint, the current description of the Procedure together with the standard Complaint form referred to in 3(6), ensuring easy access for clients, including via the mobile version of the website and the Bleap application.

In addition to the documents referred to in paragraph 1, the Company also publishes contact details enabling the submission of a Complaint.

The Company provides clients with the current description of the Procedure upon request and together with the acknowledgement of receipt of a Complaint.

3. Rules for Submitting Complaints

Complaints are submitted and handled free of charge.

A Complaint may be submitted by a Client:

1. 1. in paper form – in person at the Company’s registered office or by post or by a delivery service operating within the European Union;
   2. in electronic form – by email to: complaints@bleap.finance.

A Complaint should be submitted in English, Latvian, or any other language used by the Company for marketing its services or communicating with clients.

A Complaint must contain at least the information necessary to unambiguously establish the identity of the Client or potential Client, i.e. full name (or company name and registration number, in the case of a legal person), correspondence address, and the Client’s objections to the Company’s crypto-asset services.

The rules described in paragraphs 3–4 above constitute the admissibility conditions for a Complaint.

A Complaint may be submitted using the standard form attached as Annex 1 to the Procedure, corresponding to the form established in the annex to Regulation 2025/294; however, failure by the Client to use this form shall not constitute grounds for rejecting the Complaint.

The rules described in paragraphs 3–4 apply accordingly to complaints submitted by natural person clients.

A Complaint may be submitted by a proxy holding a power of attorney granted in ordinary written form, unless specific circumstances indicate the need for another special form and the Client was informed of this at the time of entering into the agreement.

Upon receipt of a Complaint, it is marked with the date of receipt and forwarded to the Compliance Officer for entry in the appropriate register referred to in 9 and for preparation of a draft response.

4. Communication with Clients

In the complaint handling process, the Company communicates with clients clearly, using plain language that is easy to understand.

All communications conducted by the Company under 5–8 of the Procedure and addressed to a Client are conducted in the language in which the Client submitted the Complaint, provided that the language used by the Client is one of the languages referred to in 3(3).

Complaint communications are conducted electronically where the Company holds the Client’s email address, or – at the Client’s request – in paper form to the Client’s correspondence address.

Responses to complaints submitted by natural person clients are provided in writing and delivered to the client’s correspondence address, or – at the client’s request – by email to the address provided by the client.

5.Acknowledgement of Receipt and Admissibility Assessment

The Company acknowledges receipt of a Complaint to the Client without undue delay and no later than 7 days from the date of receipt.

The acknowledgement of receipt must contain at least the following information:

1. 1. the name, identification and contact details, including email address and telephone number, of the person to whom the Client may direct any queries relating to the Complaint;
   2. the date of receipt of the Complaint;
   3. a reference to the deadline referred to in  7(3);
   4. where the Complaint was submitted electronically – a copy of the Complaint;
   5. the current description of the Procedure.

The template acknowledgement of receipt of a Complaint is attached as Annex 2 to the Procedure.

Subject to 6(2), if a Complaint does not meet the admissibility conditions set out in 3, the Company provides the Client with a clear explanation of the reasons for rejecting the Complaint as inadmissible.

6.Examination of the Complaint

Upon receipt of a Complaint, the Company assesses it on both substantive and formal grounds without undue delay, including verifying whether it is clear and complete and contains all required information.

Where a Complaint is found to be unclear or incomplete, the Company requests the Client to provide the information necessary for proper handling.

The Company makes every effort to obtain and analyse all relevant information relating to the Complaint. The Company does not require the Client to provide information that is already in the Company’s possession or that the Company is legally required to hold.

Complaints that do not contain sufficient data to identify the Client are left without consideration if the steps taken by the Company to identify the Client on the basis of the information contained in the Complaint and in the Company’s possession have not led to identification. In such cases, the Compliance Officer documents the decision to leave the Complaint without consideration in the form of an internal memorandum.

The Company informs the Client of any additional steps taken to handle the Complaint and responds without undue delay to any reasonable requests for information submitted by the Client.

7.Rules and Timelines for Handling Complaints

The Company handles Complaints thoroughly, diligently, and in a timely manner, with objectivity and in compliance with applicable law and good practice.

Complaints are handled in full by the Compliance Officer, provided that the Compliance Officer may assign preliminary handling to an employee of the relevant organisational unit of the Company.

Complaints are handled without undue delay and no later than 30 days from the date of receipt of a complete Complaint. In particularly complex cases or exceptional circumstances preventing resolution within the above timeframe, the Company may extend the deadline to a maximum of 60 days, simultaneously informing the Client of:

1. 1. the reasons for the delay;
   2. the circumstances requiring further investigation;
   3. the expected date of resolution of the Complaint.

Where the deadlines set out in paragraph 3 are not met in respect of a Complaint submitted by a natural person client, the Complaint shall be deemed to have been resolved in accordance with the wishes of that client.

In the course of handling a Complaint, the Compliance Officer in particular:

1. 1. individually reviews each Complaint;
   2. requests a written explanation from the person responsible for the matter that is the subject of the Complaint, and where necessary also from that person’s superior;
   3. upon receiving the written explanation referred to in point (b), makes a final decision on the direction of handling and informs the Client of the outcome;
   4. maintains the Complaint register.

Each Employee is obliged to provide the Compliance Officer with detailed explanations necessary for the handling of a Complaint.

Where handling a Complaint requires obtaining legal advice, an interpretation, or documents from third parties, the Compliance Officer immediately informs the Management Board, which takes the necessary action.

The Compliance Officer informs the Management Board of the intended manner of handling each Complaint. The President of the Management Board may direct an alternative approach or specific actions.

If significant irregularities in the Company’s operations are identified in the course of handling a Complaint, the Compliance Officer immediately notifies the President of the Management Board and takes other actions provided for in the Company’s internal regulations or applicable law.

8.Response to a Complaint

In its decision on a Complaint, the Company addresses all issues raised and provides reasoning for the outcome. The decision must be consistent with any previous decisions taken by the Company in relation to similar Complaints, unless the Company is able to justify why a different conclusion was reached.

The response to a Complaint shall contain:

1. 1. a comprehensive statement of facts and legal reasoning, including in respect of the reported issue, unless the Complaint was resolved in accordance with the Client’s wishes;
   2. a comprehensive statement of the Company’s position on the objections raised, including reference to the relevant provisions of the contract or applicable law, unless the nature of the objections does not require this;
   3. the full name of the person providing the response and their position, together with the signature(s) of the person(s) referred to in paragraph 8.5;
   4. the deadline by which the claim raised in the Complaint, resolved in accordance with the Client’s wishes, will be fulfilled, which shall not exceed 30 days from the date the response is prepared.

Where the Company’s decision does not meet the Client’s request, or meets it only in part, the Company clearly sets out the reasoning for its decision and informs the Client of the right to:

1. 1. appeal to the Management Board against the position set out in the response, within 14 days of receiving the response, in the manner described in  7.3.b;
   2. in the case of natural person clients – use mediation or arbitration proceedings before the court of arbitration;
   3. in the case of natural person clients – seek assistance from consumer protection authorities;
   4. bring a claim against the Company before a court of general jurisdiction.

The response to a Complaint is signed by the Compliance Officer or another person authorised by the Management Board.

The Management Board handles the appeal referred to in paragraph 8.3.a within the timelines applicable to the handling of Complaints. The response to the appeal is signed by the Management Board in accordance with the rules of representation.

9.Complaint Register and Archiving

The Compliance Officer maintains – through a secure electronic system – a register of Complaints submitted in a given calendar year.

The register shall contain at least the following data:

the full name or business name of the complainant;

1. 1. the date the Complaint was submitted;
   2. the subject matter of the Complaint and the manner in which it was handled;
   3. the measures taken to handle the Complaint.

The register is maintained on a continuous basis, with Complaints numbered sequentially.

The content of Complaints, the documents used in their handling, and the Company’s decisions and responses are archived by the Company for a period of 5 years.

10.Ensuring Consistent Complaint Handling

In order to ensure consistent complaint handling, the Compliance Officer continuously analyses data relating to the handling of Complaints and submits a quarterly report to the Management Board. This data covers all of the following:

• the average time for handling Complaints during a given period at each stage of the complaint handling procedure, including the time for acknowledging receipt, examining, and responding to Complaints;
• the number of Complaints received during a given period and, for each stage of the procedure, the number of Complaints for which the Company failed to meet the maximum deadlines set out in the Procedure;
• the categories of subjects covered by Complaints;
• the outcomes of Complaint examinations.

11.Final Provisions

The Procedure has been established and adopted by the Management Board, which is also responsible for monitoring its proper implementation.

The Management Board makes the Procedure available to all Employees via the internal drive and official email addresses. All Employees are required to read and apply the Procedure.

The Compliance Officer is responsible for providing Employees with training on the proper application of the Procedure, including for new Employees and in every case of an amendment to the Procedure and/or changes in applicable law. Where necessary, the Compliance Officer may also organise ad hoc training.

The Company allocates appropriate resources to complaint management, ensuring that Complaints are handled free from conflicts of interest. The Compliance Officer is responsible for the resources referred to above and reports to the Management Board on the implementation and effectiveness of the Procedure, including the data referred to in 10, for each completed calendar year.

All processing of personal data provided in connection with a Complaint must be carried out in accordance with applicable EU data protection law.

The annexes to the Procedure form an integral part thereof.

Any amendments to the Procedure require a resolution of the Management Board.

The Procedure enters into force on the date on which the Company obtains authorisation to operate as a crypto-asset service provider.

Annex 1:  Standard Complain Form