General Procedure of BlockDev PLC for Handling and Processing Complaints Relating to the Crypto-Asset Services Offered by the Company
I. General provisions
Article 1. (1) This Procedure lays down the rules and organisation for the submission of complaints by clients and prospective clients of BlockDev PLC (the Company), as well as the requirements that employees and other persons working for the Company under contract should observe in connection with the receipt and handling of such complaints.
(2) The submission of a complaint, its handling, the measures taken to resolve it and the subsequent reply to the client are carried out in accordance with this Procedure. The Company should take all reasonable steps to investigate complaints and should respond in a timely manner to all complaints received.
(3) This Procedure applies solely to the submission of complaints relating to the crypto-asset services offered by the Company and is aligned with the requirements of Commission Delegated Regulation (EU) 2025/294 of 1 October 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the requirements, templates and procedures for the handling of complaints by the crypto-asset service providers.
(4) With regard to the services that the Company offers on behalf of an electronic money institution licensed by the Bulgarian National Bank (BNB), namely services under Article 4, items 3 and 5 of the Payment Services and Payment Systems Act (PSPSA), as an agent of PayNovus AD, the General Procedure of BlockDev PLC for Handling and Processing Complaints Relating to the Payment Services Offered by the Company as an Agent is published on the Company’s website. Where a client of the Company who uses the payment services offered by the Company submits a complaint under this Procedure, the complaint is referred to the competent persons for handling and the client is informed accordingly; where the information provided is incomplete, the client is asked for additional details and documents.
Article 2. (1) Before entering into a contract with a client, the Company is required to provide the following information in an easily accessible manner:
- the arrangements for submitting complaints under this Procedure and the web page on which this Procedure is published;
- the possibility of lodging complaints with the Financial Supervision Commission and other public authorities, as well as the forms of out-of-court dispute resolution available to clients of crypto-asset services in the Republic of Bulgaria.
(2) In handling complaints, the Company applies the following core principles:
- Commitment to clients — the Company should provide high-quality services and resolve the complaints it receives effectively.
- Transparency — the complaints-handling process is clear and accessible to all clients.
- Confidentiality — the Company and its employees maintain confidentiality throughout the handling of all complaints.
- Compliance — the Company complies with all applicable legal and regulatory requirements.
II. Definitions
Article 3. For the purposes of this Procedure, the following definitions apply:
- “complaint” means a statement of dissatisfaction addressed to a crypto-asset service provider by one of its clients relating to the provision of one or more crypto-asset services;
- “complainant” means a natural or legal person who submits a complaint to the Company;
- “website” means the web pages www.yugo.finance and www.blockdev.bg.
III. Roles and responsibilities
Article 4. (1) The Board of Directors of the Company:
- approves this Procedure;
- is responsible for its adoption and implementation.
(2) The Head of the Compliance Department:
- manages the resources relating to the complaints-handling process;
- reports directly to the Board of Directors of the Company on the effectiveness of the complaints-handling procedures and policies;
- is responsible for keeping the register and for providing replies to complainants;
- ensures that complaints are investigated thoroughly, completely and correctly;
- performs all other functions provided for in this Procedure.
IV. Procedure for receiving and handling complaints. Admissibility
Article 4. (1) Every complainant has the right to submit a complaint to the Company entirely free of charge.
(2) The Company undertakes to provide its clients with information about this Procedure free of charge. The information can be obtained from the Company’s website, where this Procedure is published, as well as in person at the Company’s office.
Article 5. (1) Complaints concerning the Company’s activities and the crypto-asset services it provides are submitted in writing, in Bulgarian or in English.
(2) Complaints may be submitted using the template set out in Annex No. 1 to this Procedure, or in free text, in the following ways:
- on paper, at the Company’s office or by letter with return receipt to the following address: 9A Pozitano Str., apt./office 12, 4th floor, 1000 Sofia, Bulgaria;
- by email to: complaints@yugo.finance
(3) The Company is not obliged to accept, and will accordingly treat as inadmissible, complaints received from an anonymous sender. Complaints must contain the contact details of the sender. Complaints by email are accepted only if they are received from the email address that the client concerned has designated for communication.
Article 6. (1) Within 1 working day of receipt, the Head of the Compliance Department enters the complaint, in order of receipt, in the complaints register (Annex No. 2). Where, in the course of communication with the complainant, the Company sends a reply to the complaint but the complainant responds with a further grievance or a comment on the reply, and the communication continues in this cycle once or several times, the Company examines and replies to the repeat grievances in the same manner as it examines and replies to the complaint itself; however, repeat grievances are not entered in the complaints register as separate complaints but, being logically and procedurally connected with the original complaint, are recorded under its unique number.
(2) Within 2 working days of registering the complaint, the Head of the Compliance Department sends the complainant a notification containing the following:
- the name, identity and contact details, including email address and telephone number, of the person to whom, or the department to which, complainants can address any queries relating to their complaint;
- the date of receipt of the complaint;
- information on the timeframes for handling the complaint, including for acknowledging receipt of the complaint, requesting additional information where appropriate, and investigating the complaint, as well as for communicating the decision on the complaint to the complainant;
- where the complaint is filed using an electronic form, a copy of the complaint;
- where a complaint is rejected as inadmissible, the reasons why the complaint is inadmissible.
(3) A file is opened for each complaint received and registered, containing all documents and information collected or created by the Company in relation to the complaint.
Article 7. (1) Complaints received and registered are handled by the Head of the Compliance Department.
(2) A complaint may not be handled by a person connected with the breaches alleged in it. If the complaint is against the Head of the Compliance Department, it is referred to the Executive Director of the Company for handling.
Article 8. (1) The Head of the Compliance Department should:
- assess whether the complaint is clear and complete and contains all the necessary information; where the Company concludes that a complaint is unclear or incomplete, it should request any additional information necessary for the proper handling of the complaint;
- gather and examine all relevant evidence and information regarding the complaint; the Company may not require from the complainant information that is already in its possession or that it is legally required to have in its possession;
- analyse all relevant facts and circumstances relating to the breaches of applicable law and/or of the Company’s internal regulations alleged in the complaint, and may request written explanations from all persons on the Company’s staff who are alleged to have committed a breach or who have information about the facts relating to the alleged breach;
- correspond with the complainant in clear and accessible language that both parties can understand, and reply to reasonable requests for information made by the complainant without undue delay.
(2) Communication with the complainant in connection with the handling of the complaint is conducted in Bulgarian (if the complainant is a Bulgarian citizen) or in English (if the complainant is a foreign national) and must be in writing.
(3) Where the complaint provides an email address, communication with the complainant is conducted primarily by electronic means, unless the complainant has expressly requested that it be conducted on paper at a correspondence address specified in the complaint.
Article 9. After gathering all relevant information on the complaint, the Head of the Compliance Department reviews the circumstances set out in it in order to establish:
- whether the facts alleged in the complaint are consistent with the circumstances identified during the review;
- whether there has been a breach of applicable law and/or of the Company’s internal rules and procedures;
- where breaches have been established, whether they resulted from culpable conduct by employees or other persons working for the Company under contract.
Article 10. (1) The Head of the Compliance Department prepares a written reply to the complainant within the time limit under Article 11 and submits it for signature to a legal representative of the Company.
(2) The reply to the complainant sets out the Company’s clearly reasoned position on all issues raised in the complaint. Where the Company does not satisfy the complainant’s request, or satisfies it only in part, the complainant is entitled to continue to pursue the protection of their interests through:
- the Financial Supervision Commission — address: 16 Budapeshta Str., 1000 Sofia; switchboard: +3592 94 04 999; email: delovodstvo@fsc.bg;
- the Sectoral Conciliation Commission at the Commission for Consumer Protection for the resolution of disputes in the field of financial services, including the distance provision of financial services relating to consumer and mortgage credit — address: 1 Vrabcha Str., floors 3, 4 and 5, Sofia; telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg;
- the General Conciliation Commission at the Commission for Consumer Protection — address: 1 Vrabcha Str., floors 3, 4 and 5, Sofia; telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg.
(3) The decision on a complaint should be consistent with any previous decisions taken by the Company in respect of similar complaints, unless the Company is able to justify why it has reached a different conclusion.
Article 11. (1) The Company is obliged to register, notify the complainant of the registration of, examine and reply to every complaint received without undue delay, within the following time limits:
- registration of the complaint — the same working day, unless the complaint is received after the end of the working day, in which case it is registered on the next working day;
- notification of the complainant of the registration of the complaint — no later than 2 (two) working days after the complaint is registered;
- examination, including requesting additional information (where applicable) and investigation — as soon as possible, but no later than 1 (one) month after the complaint is registered;
- preparation of a reasoned reply — as soon as possible, but no later than 2 (two) months after the complaint is registered.
(2) Where a reply cannot be sent within the time limit under paragraph 1, item 4, the Company should immediately notify the complainant and the Financial Supervision Commission of the reasons for the delay and indicate a time limit for completing the review and preparing a reply.
Article 12. Where the complaint is wholly or partly well-founded, the Head of the Compliance Department makes every possible effort to satisfy the client’s claims and to prevent potential court or arbitration proceedings.
Article 13. By the 10th day of the month in which a new quarter begins, the Head of the Compliance Department submits to the Board of Directors of the Company a report on the complaints received during the preceding quarter, if any, and on the outcome of their handling.
(2) The report contains at least the following information:
- the date of receipt and the unique number of each complaint received;
- the name/company name and other identification details of the person who submitted the complaint;
- the name of the employee responsible for handling the complaint;
- the measures taken in relation to the complaint;
- the date on which the reply to the complaint was sent, and the means by which it was sent;
- the number of contacts made in connection with the complaint;
- a brief summary of the complaint, covering at least the type of service, the complainant’s grievance or request, and the means by which the complaint was received;
- the means of communication through which the complainant can obtain ongoing information on the progress of the handling of the complaint.
Article 14. As part of his or her control activities, the Head of the Compliance Department analyses the complaints received once a year and prepares a report in which he or she proposes that the Board of Directors of the Company take measures or, to the extent possible within the scope of his or her powers, directly takes measures to remedy weaknesses, risks or problems in the Company’s activities identified on the basis of the complaints, and, as a minimum, continuously analyses the following complaints-handling data:
- the average processing time, for the relevant period under consideration, for each step of the complaints-handling procedure, including acknowledgement, investigation and response time;
- the number of complaints received for the relevant period under consideration and, for each step of the complaints-handling procedure, the number of complaints where the Company did not comply with the maximum time limits set out in this Procedure;
- the categories of topics to which the complaints relate;
- the outcomes of the investigations.
Article 15. The report under Article 14 is considered by the Board of Directors of the Company no later than 10 (ten) working days after its submission; the Board decides what measures are to be taken to remedy the risks and problems and ensures that they are taken without undue delay.
V. Record-keeping. Retention of information
Article 16. (1) The Head of the Compliance Department documents every complaint submitted and the measures taken in relation to it; the documentation is kept on electronic and/or paper media.
(2) The file created for each complaint is kept by the Company for 5 (five) years from the date on which the complaint was registered.
(3) For the purposes of keeping the register of complaints received, and of receiving, registering and processing complaints, the Company uses the standard software applications and other technical resources available to it for keeping records of its activities and for processing and archiving file documentation, including the main computer operating system in use, the MS Office suite and other applications that allow the complaint received and the documentation attached to it to be stored. The register of complaints received is kept in accordance with the template in Annex No. 2.
Article 17. The Company ensures a high level of security during the processing of electronic data, as well as with regard to the integrity and confidentiality of the information recorded.
Article 18. (1) The documentation relating to complaints, as well as the register and the files of complaints received under Article 6, are kept in a manner that ensures easy access to the relevant information and protection against manipulation or falsification of the information; for every subsequent change or addition to the information entered in the register or in the relevant file, an audit trail is kept from which the content of the information before the change or addition can easily be established.
(2) Access to the register and to the complaint files is granted to the Head of the Compliance Department and to the Board of Directors of the Company; other members of the Company’s staff are granted access only with the express approval of the Head of the Compliance Department.
Article 19. The Head of the Compliance Department familiarises employees and other persons working for the Company under contract with this Procedure when they join the Company or begin working for it; on that occasion, and upon every amendment of the Procedure, the Head presents it to them for acknowledgement against signature.
Article 20. The Company publishes this Procedure and the complaint submission template on the website, so that the Company’s clients and prospective clients can familiarise themselves with the rules and procedures that the Company follows when receiving and processing complaints.
VI. Review of the complaints-handling procedure
Article 21. (1) This Procedure will be reviewed and updated regularly to ensure its effectiveness, fairness and compliance with legal and regulatory requirements.
(2) This Procedure will be reviewed at least once a year, or more frequently in the event of significant changes in the nature of the services provided, the applicable legislation or the operational structure.
This Procedure was adopted by a decision of the Board of Directors of BlockDev PLC on 16 February 2026 and amended by decisions of the Board of Directors of 29 July 2026 and 27 September 2026.
Annexes:
- Annex No. 1 – Standard complaint submission form
- Annex No. 2 – Template of the complaints register
Annex No. 1 – Standard complaint submission form
FILING OF A COMPLAINT
(to be sent by the client)
1.a. Information about the complainant
Field
Details
Last name/Legal entity name
First name
EUID or, if not available, national registration or ID number
Legal Entity Identifier (if available)
Client reference (if available)
Address (street, number, floor) (for legal entities, registered office)
Postcode
City
Country
Telephone
Email address
1.b. Contact details (if different from 1.a)
Field
Details
Last name/Legal entity name
First name
Address (street, number, floor) (for legal entities, registered office)
Postcode
City
Country
Telephone
Email address
2.a. Information about the legal representative (if applicable)
(A power of attorney or other official document as proof of the appointment of the representative must be provided as an attachment to this form.)
Field
Details
Last name/Legal entity name
First name
Registration number and LEI (if available)
Address (street, number, floor) (for legal entities, registered office)
Postcode
City
Country
Telephone
Email address
2.b. Contact details (if different from 2.a)
Field
Details
Last name/Legal entity name
First name
Address: street, number, floor (for legal entities, registered office)
Postcode
City
Country
Telephone
3. Information about the complaint
3.a. Full reference of the crypto-asset service to which the complaint relates (i.e. name of the crypto-asset service provider, crypto-asset service reference number, or other references of the relevant transactions …)
…
3.b. Description of the complaint’s subject-matter
…
Please provide any documentation supporting the facts mentioned.
3.c. Date(s) of the facts that have led to the complaint
…
3.d. Description of damage, loss or detriment caused (where relevant)
…
3.e. Other comments or relevant information (where relevant)
…
In _______________ (place) on _______________ (date)
SIGNATURE
COMPLAINANT/LEGAL REPRESENTATIVE OF THE COMPLAINANT
Documentation provided (please tick the appropriate box):
☐ Power of attorney or other official document as proof of the appointment of the representative
☐ Copy of the contractual documents of the investments to which the complaint relates
☐ Other documents supporting the complaint: