EN
General Procedure for the Handling and Processing of Complaints of “BlockDev” JSC in connection with the crypto-asset services offered by the Company
I. General provisions
Art. 1 (1)This procedure sets out the order and organisation for the submission of complaints by clients and potential clients of BlockDev JSC (the Company), as well as the requirements that employees and other persons working under contract for the Company must observe in connection with the acceptance and handling of such complaints.(2) The submission of a complaint, its handling, the measures taken to resolve it and the subsequent response to the client are carried out in accordance with the procedure laid down herein. The Company shall take all reasonable steps to investigate complaints and to respond in a timely manner to all complaints received.(3) This procedure applies solely to the submission of complaints in connection with 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 the regulatory technical standards specifying the requirements, templates and procedures for the handling of complaints by crypto-asset service providers.(4) With respect to the services that the Company offers on behalf of an electronic money institution licensed by the BNB — services under Art. 4, items 3 and 5 of the Payment Services and Payment Systems Act (PSPSA) as an agent of PayNovus JSC — a General Procedure for the Handling and Processing of Complaints of “BlockDev” JSC in connection with the payment services offered by the Company as an agent is published on the Company's website. Where a client of the Company using the payment services offered by the Company submits a complaint under this procedure, that complaint is transferred for handling by the competent persons and the client is notified thereof; where the information submitted is incomplete, additional data and documents are requested from the client.
Art. 2 (1) Before concluding a contract with a client, the Company is obliged to provide, in an easily accessible manner, the following information:1. the procedure for submitting complaints under this Procedure and the website on which the latter is published;2. the possibility of submitting complaints to the Financial Supervision Commission and other state 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) When handling complaints, the Company applies the following core principles:1. Client commitment — the Company shall provide quality services and the effective resolution of the complaints received.2. Transparency — the complaints-handling process is clear and accessible to all clients.3. Confidentiality — in the process of handling all complaints, the Company and its employees observe confidentiality.4. Compliance — the Company complies with all applicable statutory and regulatory requirements.
II. Definitions
Art. 3. For the purposes of this procedure, the following definitions apply:1. “complaint” means a statement of dissatisfaction addressed to a crypto-asset service provider by its client and relating to the provision of one or more crypto-asset services;2. “complainant” means a natural or legal person who submits a complaint to the Company;3. “website” means the internet pages: www.yugo.finace and www.blockdev.bg
III. Roles and responsibilities
Art. 4 (1) The Board of Directors of the Company:1. approves this procedure;2. is responsible for its adoption and implementation.(2) The Head of the Compliance Department:1. manages the resources related to the complaints-handling process;2. reports directly to the Board of Directors of the Company on the effectiveness of the complaints-handling procedures and policies;3. is responsible for maintaining the register and for providing responses to complainants;4. ensures that complaints are investigated comprehensively, fully and correctly;5. performs all other functions under this procedure.
IV. Procedure for the acceptance and handling of complaints. Admissibility.
Art. 4 (1) Every complainant has the right to submit a complaint to the Company entirely free of charge.(2) The Company undertakes to provide information about this procedure to its clients free of charge. The information may be obtained from the Company's website, where this procedure is published, as well as on site at the Company's office.
Art. 5 (1) Complaints regarding the Company's activity and the crypto-asset services it provides are submitted in writing, in Bulgarian and in English.(2) Complaints may be submitted using the template contained in Appendix No. 1 to this procedure, or in free text, in the following ways:1. on paper at the Company's office or by registered letter with acknowledgement of receipt to the address: Bulgaria, Sofia 1000, 9A Pozitano St., apt./office 12, 4th floor;2. by email to the following address: complaints@yugo.finance(3) The Company is under no obligation to accept, and will accordingly treat as inadmissible, complaints received from an anonymous sender. Complaints must contain contact details of their sender. Complaints by email are accepted only if they have been received from the email address that the respective client has designated for communication.
Art. 6 (1) Within up to 1 business day of its receipt, the Head of the Compliance Department enters the complaint, in the order of its receipt, in the complaints register (Appendix No. 2). If, in the course of communication with the complainant, the Company sends a response to the complaint but the complainant replies with a subsequent grievance or comment on the response, and the communication continues in this cycle one or more times, the Company handles and responds to the repeated grievances in the same manner as it handles and responds to the complaint itself; however, the repeated grievances are not entered in the complaints register as separate complaints but, since they are logically and procedurally linked to the original complaint, are recorded under its unique number.(2) Within up to 2 business days of registering the complaint, the Head of the Compliance Department sends a notification to its sender, containing the following elements:1. the name, identity and contact details, including email address and telephone number, of the person or department to whom or to which complainants may address enquiries relating to their complaint;2. the date of receipt of the complaint;3. information on the timeframes relating to the handling of the complaint, including for acknowledging receipt of the complaint, for requesting additional information where appropriate, and for investigation, as well as for communicating the decision on the complaint to the complainant;4. where the complaint is submitted via an electronic form — a copy of the complaint;5. where a complaint has been rejected as inadmissible, the reasons why the complaint is inadmissible.(3) For each complaint received and registered, a file is created containing all documents and information collected or created by the Company in respect of the complaint.
Art. 7. (1) Complaints received and registered are handled by the Head of the Compliance Department.(2) A submitted complaint may not be handled by a person who is connected with the violations alleged therein. If the complaint is against the Head of the Compliance Department, it is referred for handling to the Chief Executive Officer of the Company.
Art. 8 (1) The Head of the Compliance Department shall:1. 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, the Company shall request any additional information necessary for the proper handling of the complaint;2. collect and examine all relevant evidence and information in respect of the complaint, whereby the Company has no right to require from the complainant information that it already holds or that it is required by law to hold;3. analyse all relevant facts and circumstances regarding the violations of the applicable legislation and/or of the Company's internal acts alleged in the complaint, having the right to request written explanations from all persons within the Company who are alleged to have committed a violation or to hold information regarding the factual situation concerning the alleged violation;4. conduct correspondence with the complainant in language that is clear, accessible and comprehensible to both parties, and respond 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 foreigner) and is carried out mandatorily in writing.(3) If an email address is provided in the complaint, communication with the complainant is conducted primarily electronically, unless the complainant has expressly requested that it be conducted on paper at a correspondence address specified by them in the complaint.
Art. 9. After collecting all relevant information on the complaint, the Head of the Compliance Department carries out a verification of the circumstances set out therein, in order to establish:1. whether identity has been established between the factual situation alleged in the complaint and the circumstances identified during the verification;2. whether there is a violation of the applicable legislation and/or of the Company's internal rules and procedures;3. in the case of established violations, whether they were committed as a result of culpable conduct by employees or other persons working under contract for the Company.
Art. 10. (1) The Head of the Compliance Department prepares a written response to the complainant, within the period under Art. 11, and provides it for signature to a legal representative of the Company.(2) The response to the complainant contains the clearly reasoned position of the Company on all matters raised in the complaint. Where the Company does not satisfy the complainant's request, or satisfies it only partially, the complainant has the right to continue to protect their interests through:1. the Financial Supervision Commission — address: Sofia 1000, 16 Budapeshta St., switchboard: +359 2 94 04 999, email: delovodstvo@fsc.bg;2. the Sectoral Conciliation Commission at the Commission for Consumer Protection for the resolution of disputes in the field of financial services, including in the provision of financial services at a distance relating to the provision of consumer and mortgage loans — address: Sofia, 1 Vrabcha St., floors 3, 4 and 5, telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg;3. the General Conciliation Commission at the Commission for Consumer Protection — address: Sofia, 1 Vrabcha St., floors 3, 4 and 5, telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg.(3) The decision on a complaint shall be consistent with any previous decisions taken by the Company on similar complaints, unless the Company is able to justify the reasons why it reached a different conclusion.
Art. 11. (1) The Company is obliged to register, notify the complainant of the registration of, handle and respond to every complaint received without undue delay, within the following timeframes:1. for registering a complaint — the same business day, save where it is received after the end of the business day, in which case registration is carried out on the following business day;2. for notifying the complainant of the registration of the complaint — no later than 2 (two) business days from the registration of the complaint;3. for handling, including the requesting of additional information (where applicable) and investigation — as soon as possible, but no later than 1 (one) month from the registration of the complaint;4. for preparing a reasoned response — as soon as possible, but no later than 2 (two) months from the registration of the complaint.(2) Where a response cannot be sent within the period under para. 1, item 4, the Company shall immediately notify the complainant and the Financial Supervision Commission of the reasons for the delay and indicate a period for completing the verification and preparing a response.
Art. 12. Where the complaint is wholly or partially 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 disputes.
Art. 13. By the 10th day of the month in which a new quarter begins, the Head of the Compliance Department provides the Board of Directors of the Company with a report on the complaints received during the elapsed quarter, if any, as well as on the results of their handling.(2) The report contains at least information on:1. the date of receipt and the unique number of each complaint received;2. the name/designation and other identification details of the person who submitted the complaint;3. the name of the employee responsible for handling the complaint;4. the measures taken in connection with the complaint;5. the date on which a response to the complaint was sent, and the method of its sending;6. the number of contacts made in connection with the complaint submitted;7. a brief summary of the complaint, covering at least the type of service, the complainant's grievance or request, and the method of submission;8. the method of communication with the complainant through which they may receive ongoing information on the progress of the handling of the complaint.
Art. 14. The Head of the Compliance Department, as part of their control activity, analyses the complaints received once a year and prepares a report, proposing to the Board of Directors of the Company the adoption of measures or, to the extent possible within their powers, directly taking measures to remedy weaknesses, risks or problems in the conduct of the Company's activity identified on the basis of the complaints, and at a minimum continuously analyses the following data from the complaints-handling process:1. the average processing time for the respective period under review for each stage of the complaints-handling procedure, including acknowledgement, investigation and response time;2. the number of complaints received for the respective period under review and for each stage of the complaints-handling procedure, and the number of complaints in respect of which the Company failed to observe the maximum timeframes set out in this procedure;3. the categories of topics with which the complaints are associated;4. the results of the investigations.
Art. 15. The report under Art. 14 is reviewed by the Board of Directors of the Company no later than 10 (ten) business days from its submission; the Board decides what measures are to be taken to remedy the risks and problems and ensures that they are taken without unjustified delay.
V. Reporting. Data retention
Art. 16. (1)
The Head of the Compliance Department documents every complaint submitted and the measures taken in connection with it, whereby the documentation is stored on magnetic and/or paper media.(2) The file created for each complaint is kept by the Company for 5 (five) years from the date of registration of the complaint.
Art. 17. The Company ensures a high level of security during the processing of electronic data, as well as in respect of the integrity and confidentiality of the recorded information.
Art. 18. (1) The documentation relating to complaints, as well as the register and the files of complaints received under Art. 6, are maintained in a manner that guarantees easy access to the relevant information, ensuring protection against manipulation or falsification of the information; and for every subsequent change or addition to information entered in the register or the respective file, an audit trail is maintained by which the content of the information prior to the change or addition can easily be established.(2) Access to the register and the files of complaints received is provided to the Head of the Compliance Department and the Board of Directors of the Company, whereby access for other persons within the Company is granted only after the express approval of the Head of the Compliance Department.
Art. 19. The Head of the Compliance Department familiarises the employees and other persons who work under contract for the Company with this procedure upon their commencement of work or of activity for the Company, and in that case, as well as upon any amendment thereto, presents it to them for familiarisation against signature.
Art. 20. This procedure and the complaint-submission template are published by the Company on the website, in order to enable clients and potential clients of the Company to acquaint themselves with the rules and procedures that the Company observes in the acceptance and processing of complaints.
VI. Review of the complaints-handling procedure
Art. 21. (1)
This procedure will be regularly reviewed and updated 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 decision of the Board of Directors of BlockDev JSC on 16.02.2026 and amended by decision of the Board of Directors of 29.07.2026.Appendix No. 1 - Standard complaint-submission template
SUBMISSION OF A COMPLAINT(sent by the client)
1.a. Complaint informationSurname / Name of the legal entity
First name
EUID (European Unique Identifier) or, if not available, national registration or identification number
Legal entity identifier (LEI) (if any)
Client details (if any)
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
1.b. Contact details (if different from 1.a)Surname / Name of the legal entity
First name
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
2.a. Information about the legal representative (if applicable) (a power of attorney or other official document evidencing the appointment of a representative must be provided as an annex to this form)Surname / Name of the legal entity
First name
Registration number and LEI (if any)
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
2.b. Contact details (if different from 2.a)Surname / Name of the legal entity
First name
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email
3. Complaint information3.a. Full details of the crypto-asset service to which the complaint relates (i.e. name of the crypto-asset service provider, reference number of the crypto-asset service or other details of the relevant transactions…)
3.b. Description of the subject matter of the complaint
Please provide any documentation supporting the stated facts.3.c. Date(s) of the facts on which the complaint is based
3.d. Description of the damage, loss or harm suffered (where relevant)
3.e. Other remarks or relevant information (where relevant)
In ________________ (place) on ________________ (date)SIGNATURECOMPLAINANT / LEGAL REPRESENTATIVE OF THE COMPLAINANTAttached documents (please tick the relevant box):Power of attorney or other official document evidencing the appointment of the representative☐Copy of the contractual documents for the investments to which the complaint relates☐Other documents in support of the complaint☐Appendix No. 2 — Complaints register template[In the source document, this appendix is referenced by title only; its column layout is not included in the file provided for translation.]
I. General provisions
Art. 1 (1)This procedure sets out the order and organisation for the submission of complaints by clients and potential clients of BlockDev JSC (the Company), as well as the requirements that employees and other persons working under contract for the Company must observe in connection with the acceptance and handling of such complaints.(2) The submission of a complaint, its handling, the measures taken to resolve it and the subsequent response to the client are carried out in accordance with the procedure laid down herein. The Company shall take all reasonable steps to investigate complaints and to respond in a timely manner to all complaints received.(3) This procedure applies solely to the submission of complaints in connection with 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 the regulatory technical standards specifying the requirements, templates and procedures for the handling of complaints by crypto-asset service providers.(4) With respect to the services that the Company offers on behalf of an electronic money institution licensed by the BNB — services under Art. 4, items 3 and 5 of the Payment Services and Payment Systems Act (PSPSA) as an agent of PayNovus JSC — a General Procedure for the Handling and Processing of Complaints of “BlockDev” JSC in connection with the payment services offered by the Company as an agent is published on the Company's website. Where a client of the Company using the payment services offered by the Company submits a complaint under this procedure, that complaint is transferred for handling by the competent persons and the client is notified thereof; where the information submitted is incomplete, additional data and documents are requested from the client.
Art. 2 (1) Before concluding a contract with a client, the Company is obliged to provide, in an easily accessible manner, the following information:1. the procedure for submitting complaints under this Procedure and the website on which the latter is published;2. the possibility of submitting complaints to the Financial Supervision Commission and other state 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) When handling complaints, the Company applies the following core principles:1. Client commitment — the Company shall provide quality services and the effective resolution of the complaints received.2. Transparency — the complaints-handling process is clear and accessible to all clients.3. Confidentiality — in the process of handling all complaints, the Company and its employees observe confidentiality.4. Compliance — the Company complies with all applicable statutory and regulatory requirements.
II. Definitions
Art. 3. For the purposes of this procedure, the following definitions apply:1. “complaint” means a statement of dissatisfaction addressed to a crypto-asset service provider by its client and relating to the provision of one or more crypto-asset services;2. “complainant” means a natural or legal person who submits a complaint to the Company;3. “website” means the internet pages: www.yugo.finace and www.blockdev.bg
III. Roles and responsibilities
Art. 4 (1) The Board of Directors of the Company:1. approves this procedure;2. is responsible for its adoption and implementation.(2) The Head of the Compliance Department:1. manages the resources related to the complaints-handling process;2. reports directly to the Board of Directors of the Company on the effectiveness of the complaints-handling procedures and policies;3. is responsible for maintaining the register and for providing responses to complainants;4. ensures that complaints are investigated comprehensively, fully and correctly;5. performs all other functions under this procedure.
IV. Procedure for the acceptance and handling of complaints. Admissibility.
Art. 4 (1) Every complainant has the right to submit a complaint to the Company entirely free of charge.(2) The Company undertakes to provide information about this procedure to its clients free of charge. The information may be obtained from the Company's website, where this procedure is published, as well as on site at the Company's office.
Art. 5 (1) Complaints regarding the Company's activity and the crypto-asset services it provides are submitted in writing, in Bulgarian and in English.(2) Complaints may be submitted using the template contained in Appendix No. 1 to this procedure, or in free text, in the following ways:1. on paper at the Company's office or by registered letter with acknowledgement of receipt to the address: Bulgaria, Sofia 1000, 9A Pozitano St., apt./office 12, 4th floor;2. by email to the following address: complaints@yugo.finance(3) The Company is under no obligation to accept, and will accordingly treat as inadmissible, complaints received from an anonymous sender. Complaints must contain contact details of their sender. Complaints by email are accepted only if they have been received from the email address that the respective client has designated for communication.
Art. 6 (1) Within up to 1 business day of its receipt, the Head of the Compliance Department enters the complaint, in the order of its receipt, in the complaints register (Appendix No. 2). If, in the course of communication with the complainant, the Company sends a response to the complaint but the complainant replies with a subsequent grievance or comment on the response, and the communication continues in this cycle one or more times, the Company handles and responds to the repeated grievances in the same manner as it handles and responds to the complaint itself; however, the repeated grievances are not entered in the complaints register as separate complaints but, since they are logically and procedurally linked to the original complaint, are recorded under its unique number.(2) Within up to 2 business days of registering the complaint, the Head of the Compliance Department sends a notification to its sender, containing the following elements:1. the name, identity and contact details, including email address and telephone number, of the person or department to whom or to which complainants may address enquiries relating to their complaint;2. the date of receipt of the complaint;3. information on the timeframes relating to the handling of the complaint, including for acknowledging receipt of the complaint, for requesting additional information where appropriate, and for investigation, as well as for communicating the decision on the complaint to the complainant;4. where the complaint is submitted via an electronic form — a copy of the complaint;5. where a complaint has been rejected as inadmissible, the reasons why the complaint is inadmissible.(3) For each complaint received and registered, a file is created containing all documents and information collected or created by the Company in respect of the complaint.
Art. 7. (1) Complaints received and registered are handled by the Head of the Compliance Department.(2) A submitted complaint may not be handled by a person who is connected with the violations alleged therein. If the complaint is against the Head of the Compliance Department, it is referred for handling to the Chief Executive Officer of the Company.
Art. 8 (1) The Head of the Compliance Department shall:1. 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, the Company shall request any additional information necessary for the proper handling of the complaint;2. collect and examine all relevant evidence and information in respect of the complaint, whereby the Company has no right to require from the complainant information that it already holds or that it is required by law to hold;3. analyse all relevant facts and circumstances regarding the violations of the applicable legislation and/or of the Company's internal acts alleged in the complaint, having the right to request written explanations from all persons within the Company who are alleged to have committed a violation or to hold information regarding the factual situation concerning the alleged violation;4. conduct correspondence with the complainant in language that is clear, accessible and comprehensible to both parties, and respond 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 foreigner) and is carried out mandatorily in writing.(3) If an email address is provided in the complaint, communication with the complainant is conducted primarily electronically, unless the complainant has expressly requested that it be conducted on paper at a correspondence address specified by them in the complaint.
Art. 9. After collecting all relevant information on the complaint, the Head of the Compliance Department carries out a verification of the circumstances set out therein, in order to establish:1. whether identity has been established between the factual situation alleged in the complaint and the circumstances identified during the verification;2. whether there is a violation of the applicable legislation and/or of the Company's internal rules and procedures;3. in the case of established violations, whether they were committed as a result of culpable conduct by employees or other persons working under contract for the Company.
Art. 10. (1) The Head of the Compliance Department prepares a written response to the complainant, within the period under Art. 11, and provides it for signature to a legal representative of the Company.(2) The response to the complainant contains the clearly reasoned position of the Company on all matters raised in the complaint. Where the Company does not satisfy the complainant's request, or satisfies it only partially, the complainant has the right to continue to protect their interests through:1. the Financial Supervision Commission — address: Sofia 1000, 16 Budapeshta St., switchboard: +359 2 94 04 999, email: delovodstvo@fsc.bg;2. the Sectoral Conciliation Commission at the Commission for Consumer Protection for the resolution of disputes in the field of financial services, including in the provision of financial services at a distance relating to the provision of consumer and mortgage loans — address: Sofia, 1 Vrabcha St., floors 3, 4 and 5, telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg;3. the General Conciliation Commission at the Commission for Consumer Protection — address: Sofia, 1 Vrabcha St., floors 3, 4 and 5, telephone: +359 2 933 05 65; email: info@kzp.bg; website: www.kzp.bg.(3) The decision on a complaint shall be consistent with any previous decisions taken by the Company on similar complaints, unless the Company is able to justify the reasons why it reached a different conclusion.
Art. 11. (1) The Company is obliged to register, notify the complainant of the registration of, handle and respond to every complaint received without undue delay, within the following timeframes:1. for registering a complaint — the same business day, save where it is received after the end of the business day, in which case registration is carried out on the following business day;2. for notifying the complainant of the registration of the complaint — no later than 2 (two) business days from the registration of the complaint;3. for handling, including the requesting of additional information (where applicable) and investigation — as soon as possible, but no later than 1 (one) month from the registration of the complaint;4. for preparing a reasoned response — as soon as possible, but no later than 2 (two) months from the registration of the complaint.(2) Where a response cannot be sent within the period under para. 1, item 4, the Company shall immediately notify the complainant and the Financial Supervision Commission of the reasons for the delay and indicate a period for completing the verification and preparing a response.
Art. 12. Where the complaint is wholly or partially 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 disputes.
Art. 13. By the 10th day of the month in which a new quarter begins, the Head of the Compliance Department provides the Board of Directors of the Company with a report on the complaints received during the elapsed quarter, if any, as well as on the results of their handling.(2) The report contains at least information on:1. the date of receipt and the unique number of each complaint received;2. the name/designation and other identification details of the person who submitted the complaint;3. the name of the employee responsible for handling the complaint;4. the measures taken in connection with the complaint;5. the date on which a response to the complaint was sent, and the method of its sending;6. the number of contacts made in connection with the complaint submitted;7. a brief summary of the complaint, covering at least the type of service, the complainant's grievance or request, and the method of submission;8. the method of communication with the complainant through which they may receive ongoing information on the progress of the handling of the complaint.
Art. 14. The Head of the Compliance Department, as part of their control activity, analyses the complaints received once a year and prepares a report, proposing to the Board of Directors of the Company the adoption of measures or, to the extent possible within their powers, directly taking measures to remedy weaknesses, risks or problems in the conduct of the Company's activity identified on the basis of the complaints, and at a minimum continuously analyses the following data from the complaints-handling process:1. the average processing time for the respective period under review for each stage of the complaints-handling procedure, including acknowledgement, investigation and response time;2. the number of complaints received for the respective period under review and for each stage of the complaints-handling procedure, and the number of complaints in respect of which the Company failed to observe the maximum timeframes set out in this procedure;3. the categories of topics with which the complaints are associated;4. the results of the investigations.
Art. 15. The report under Art. 14 is reviewed by the Board of Directors of the Company no later than 10 (ten) business days from its submission; the Board decides what measures are to be taken to remedy the risks and problems and ensures that they are taken without unjustified delay.
V. Reporting. Data retention
Art. 16. (1)
The Head of the Compliance Department documents every complaint submitted and the measures taken in connection with it, whereby the documentation is stored on magnetic and/or paper media.(2) The file created for each complaint is kept by the Company for 5 (five) years from the date of registration of the complaint.
Art. 17. The Company ensures a high level of security during the processing of electronic data, as well as in respect of the integrity and confidentiality of the recorded information.
Art. 18. (1) The documentation relating to complaints, as well as the register and the files of complaints received under Art. 6, are maintained in a manner that guarantees easy access to the relevant information, ensuring protection against manipulation or falsification of the information; and for every subsequent change or addition to information entered in the register or the respective file, an audit trail is maintained by which the content of the information prior to the change or addition can easily be established.(2) Access to the register and the files of complaints received is provided to the Head of the Compliance Department and the Board of Directors of the Company, whereby access for other persons within the Company is granted only after the express approval of the Head of the Compliance Department.
Art. 19. The Head of the Compliance Department familiarises the employees and other persons who work under contract for the Company with this procedure upon their commencement of work or of activity for the Company, and in that case, as well as upon any amendment thereto, presents it to them for familiarisation against signature.
Art. 20. This procedure and the complaint-submission template are published by the Company on the website, in order to enable clients and potential clients of the Company to acquaint themselves with the rules and procedures that the Company observes in the acceptance and processing of complaints.
VI. Review of the complaints-handling procedure
Art. 21. (1)
This procedure will be regularly reviewed and updated 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 decision of the Board of Directors of BlockDev JSC on 16.02.2026 and amended by decision of the Board of Directors of 29.07.2026.Appendix No. 1 - Standard complaint-submission template
SUBMISSION OF A COMPLAINT(sent by the client)
1.a. Complaint informationSurname / Name of the legal entity
First name
EUID (European Unique Identifier) or, if not available, national registration or identification number
Legal entity identifier (LEI) (if any)
Client details (if any)
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
1.b. Contact details (if different from 1.a)Surname / Name of the legal entity
First name
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
2.a. Information about the legal representative (if applicable) (a power of attorney or other official document evidencing the appointment of a representative must be provided as an annex to this form)Surname / Name of the legal entity
First name
Registration number and LEI (if any)
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
Email address
2.b. Contact details (if different from 2.a)Surname / Name of the legal entity
First name
Address (street, number, floor) (for legal entities — registered seat)
Postal code
City
Country
Telephone
3. Complaint information3.a. Full details of the crypto-asset service to which the complaint relates (i.e. name of the crypto-asset service provider, reference number of the crypto-asset service or other details of the relevant transactions…)
3.b. Description of the subject matter of the complaint
Please provide any documentation supporting the stated facts.3.c. Date(s) of the facts on which the complaint is based
3.d. Description of the damage, loss or harm suffered (where relevant)
3.e. Other remarks or relevant information (where relevant)
In ________________ (place) on ________________ (date)SIGNATURECOMPLAINANT / LEGAL REPRESENTATIVE OF THE COMPLAINANTAttached documents (please tick the relevant box):Power of attorney or other official document evidencing the appointment of the representative☐Copy of the contractual documents for the investments to which the complaint relates☐Other documents in support of the complaint☐Appendix No. 2 — Complaints register template[In the source document, this appendix is referenced by title only; its column layout is not included in the file provided for translation.]