I. INTRODUCTION

This policy regulates effective, clear and efficient handling of complaints submitted to Securcap
Securities Limited operating under the brand name XLNTrade (the “Company”) in relation to the
performance and procedures of the Company.
The Company shall maintain Records of Complaints and measures taken for expedient complaint
resolution, in line with applicable Laws, Rules and/or Regulations.

II. DEFINITIONS

Complaint:

  • Complaints are defined as specific requests or claims related to the performance, services
    or products of the Company, which objects the performance or expresses negligence of
    the Company and lodges a relevant, specific and clear demand.
  • Asking an opinion or position about any specific case or requesting general information
    about the operation and services of the Company shall not constitute a complaint.

Complainant:

  • The Complainant could be a natural or legal person, a company without legal entity or
    other organization that requires services of the Company or the addressee of information
    or offer related to the service.
  • When the complaint is submitted by a representative or other duly authorized person,
    the Company will investigate the legal basis of the submission, which must be presented
    by the Complainant in a format required by law. If no authorization is available, the
    Company will approach the Complainant directly in order to accelerate the procedure.

III. SUBMITTING THE COMPLAINT

The Complainant, if possible, should report the event or the date of the event, clearly outlining
the subject of the complaint to the Company as soon as possible. This is necessary to enable the
Company to investigate the complaint as efficiently as possible.

The following opportunities are available for submitting a complaint to our Company:

  • by mail,
  • by telephone,
  • by e-mail,
  • in writing, or
  • verbally, both delivered personally.

Employees of the Customer Service Department shall be the first to receive and manage
complaints within the Company. Employees of the Customer Service Department shall help the
Complainant in compiling and submitting the complaint. The Complainant must submit
complaints related to services rendered on the basis of the online trading agreement to the
Customer Service of the Company. The contact details of the Customer Service department are
available at the ‘Contact Us’ page of the Company’s website.

The telephone line of the Customer Service is available for submitting complaints by telephone.
If the Complainant calls another telephone number of the Company to submit his/her complaint,
he/she will be redirected to the Customer Service.

Clients wishing to submit complaints personally, may visit the head office of the Company in
office hours (9:00 -16:00 hours on working days).

Alternatively those wishing to submit complaints in writing will be required to attach – if possible
– copies of documents supporting the complaint. The Company will be prepared to receive
complaints submitted by e-mail on an ongoing basis.

IV. REGISTRATION OF COMPLAINTS

The Company, until dealt with, shall register all complaints in a complaints register. This register
shall record at least the following information:

  • date of submitting the complaint,
  • description of the complaint
  • brand name
  • customer ID
  • name and surname of customer
  • measures implemented to settle or solve the complaint,
  • status of complaint

Where the complaint is made on an anonymous basis, the Company pays special attention to
avoid collection of data about the complainant with the exception of recording data aimed to
settle the complaint. All personal particulars obtained in relation of managing the complaint shall
be deleted from records or made unsuitable for identification.
The Company manages complaints within a transparent system; they could be traced and
administered in each and every stage of the procedure.
Unless settled on the spot, the Company records a written memorandum on all verbally
submitted complaints. For this purpose the Company is entitled to use a complaint format or to
register the complaint electronically. The Company will acknowledge the receipt of the
complaint within 2 working days.

V. MANAGING COMPLAINTS

The Company manages all complaints and Complainants equally, without any discrimination, in
harmony with the procedure regulated by this Policy.

The Complaints are handled by:

▪ Customer Service
All complaints are to be settled without undue delay. If immediate settlement of a verbal
complaint is not possible or the Complainant rejects the solution offered on the spot, an
employee of the Company shall record the complaint and the Company’s position in a
memorandum and forwards them to Customer Service, unless the complaint was
submitted directly to Customer Service. Similarly, Company employees are to forward all
complaints submitted in writing to Customer Service.
Customer Service shall be responsible for settling complaints. The officers of the
Customer Support Department will inform you of the appropriate process to follow.
If a person is to contact the company us on behalf of another person, we shall ask for
proof of that person’s consent to the handling of their Complaint by a third party. We aim
to resolve the matter within thirty (30) business days.

▪ Compliance Officer
If employees at Customer Services are unable to settle the complaint efficiently or within
a reasonable period of time, they shall forward the complaint to the Compliance officer
of the Company. The Complainant, if he/she does not accept the solution offered by
Customer Service, is also entitled to approach the Compliance officer directly by writing
an email to compliance@xlntrade.com

▪ Directors of the Company
Within the organization of the Company, Directors of the Company represent the highest
level of authority in deciding the settlement of complaints. Directors of the Company shall
settle those complaints which cannot be managed within the above procedure; they shall
take into account the opinion of the Compliance officer of the Company.
The employee of the Company who participated in the measure related to the complaint
or made a decision subject of the complaint must not participate in making any decision
related to the complaint. Such employee must provide every reasonable help to the
Company in the procedure aimed to settle the complaint as soon as possible and in the
interest of the Complainant.

VI. RESPONSE TO COMPLAINTS

The Company follows the outlined procedures to ensure that your Complaint is resolved within
a period of thirty (30) business days. This response, including the reasoning, is always mailed to
the Complainant. Some Complaints can be resolved more quickly depending on the facts and the
nature of the Complaint. If the Complaint is more complex and takes longer than thirty (30)
business days to resolve, we will communicate the reasons for the delay.
Clients may be requested to supply additional information required for investigating the
complaint. In this case the client is to respond at their earliest convenience.
When the complaint is submitted by another person or with a method unsuitable for establishing
proper authorization of the submission, the Company may ask the person authorized to submit
the complaint to confirm the complaint in question.

The Company adds a correct, clear and unanimous reasoning to every decision brought down in
order to settle complaints, which are mailed to the Complainant in writing. If the decision refers
to a legislation, not only the legislation, but its relevant regulations must also be included in the
above reasoning. In parallel with informing the Complainant about the decision in question, the
Company informs the Complainant about the opportunities of appeal and possible damage
compensation.

VII. MONITORING OF COMPLAINTS

After settling the procedure, the Company shall preserve every written or electronic documents
related to complaints for a period of 3 years. The Company shall be entitled to prepare statistics
and reports about complaints, which will be aimed to improve the efficiency of administering
complaints.

VIII. SETTLEMENT OF DISPUTES

When disputes between the Company and the Complainant cannot be settled by the official
procedure, regulations of chapter “Settlement of Disputes” of the Company Rules and
Regulations shall be applicable. When the complaint is rejected, the Complainant may lodge an
appeal at the Seychelles Financial Services Authority.