Complaint Handling Procedure

Procedure for Handling Complaints Pursuant to Regulation (EU) 2023/1114 and Delegated Regulation (EU) 2025/294 of “Bifinance” EOOD

1. Purpose

This procedure governs the process for receiving, registering, reviewing, resolving, and archiving complaints submitted by customers of “Bifinance” EOOD, UIC 206805699, with its registered office and address of management: Bulgaria, Sofia, Postal Code 1000, Sredets District, 11 Petko R. Slaveykov Square, Floor 6, represented by Kosta Kostadinov (hereinafter referred to as the “Company”), in its capacity as a crypto-asset service provider, in accordance with Regulation (EU) 2023/1114 (MiCA) and Delegated Regulation (EU) 2025/294.

2. Scope

This procedure applies to all complaints submitted by customers, potential customers, and other interested parties in connection with the crypto-asset services provided.

3. Definitions

• “Complaint” means an expression of dissatisfaction by a client regarding a crypto-asset service being provided or that has been provided.
• “Complainant” means a person who has filed a complaint against the Company.

4. Filing Complaints

• 4.1. Customers have the right to file complaints with the Company free of charge.
• 4.2. The Company reviews complaints filed by customers free of charge.
• 4.3. Complaints may be submitted in Bulgarian, English, Spanish, and Portuguese in accordance with Article 3, paragraph 2, subparagraph “a” of Delegated Regulation (EU) 2025/294.
• 4.4. Complaints may be submitted:
  • By email: support@blockforia.com
  • On paper, as follows:
    • Sent by courier or mail to the Company’s registered office: Bulgaria, Sofia, 1000, Sredets District, 11 Petko R. Slaveykov Square, 6th Floor.
    • Submitted in person at the Company’s office.

  *If a customer submits a complaint in hard copy by sending it via courier or mail, the customer is required to pay the shipping costs, and this does not constitute the imposition of a fee for filing a complaint with the Company and, accordingly, does not preclude the application of the provision of Article 71, paragraph 2, of Regulation (EU) 2023/1114.

• 4.5. When filing a complaint through a client’s authorized representative, a notarized power of attorney certifying the representative’s authority must be attached to the documents. When the representative is an attorney, if the documents are submitted with an advanced or qualified electronic signature within the meaning of Regulation (EU) No. 910/2014, they must be signed in original form—not scanned—so that the identity of the signatory can be verified.
• 4.6. The power of attorney must be in writing only, in accordance with Article 25 of the Bar Act. When the appeal is filed by a legal representative, an official document proving the existence of the power of representation must be submitted.

5. Content of the Appeal and Conditions for Admissibility of Appeals

• 5.1. The Company does NOT consider anonymous complaints.
• 5.2. Minimum required content of the complaint:
  • Full name of the individual/name of the legal entity;
  • National identification number/legal entity identification number;
  • Permanent/current address for a natural person/registered office and business address for a legal entity;
  • Contact information—address (if different from the one provided); phone number; email;
  • Full details of the crypto-asset service to which the complaint relates;
  • Description of the subject matter of the complaint;
  • Date(s) of the facts on which the complaint is based;
  • Description of the damages, loss, or harm suffered (where applicable);
  • Other comments or relevant information (where applicable);
  • The method by which the customer wishes to receive the decision on the complaint—electronically (via email) or on paper—at the specified mailing address. If the complainant has not specified a method, the Company will communicate and provide the decision in writing via email.
  • Attachments to the complaint—where applicable.
• 5.3. Customers may submit their complaints in free-form text, including the information listed above, or by using the template contained in the appendix to this Procedure.
• 5.4. Complaints should be addressed to the “Business Operations” department of Bifinance EOOD, with the following contact information: support@blockforia.com

6. Registration of Complaints

• 6.1. Each complaint is immediately entered into the Complaints Register and assigned a unique reference number. The complainant is sent a confirmation of receipt within 5 business days, along with the reference number under which the complaint was registered, including notification to the complainant as to whether the complaint is admissible.
• 6.2. If the complaint does not meet the admissibility criteria set forth in Section 5, the Company shall provide the complainant with a clear explanation of the reasons why the complaint was rejected as inadmissible.
• 6.3. The acknowledgment of receipt of a complaint shall contain all of the following elements: the name, identity, and contact information—including email address and phone number—of the Business Operations Department employee handling the complaint, to whom the complainant may direct inquiries regarding their complaint, as well as the date of receipt and registration of the complaint; information regarding the deadlines specified in Section 8, and, when the complaint is submitted via an electronic form, a copy of the complaint.

7. Handling of Complaints

• 7.1. Complaints are handled objectively, fairly, and without undue delay. The department responsible for handling complaints is the “Business Operations” department. The Company ensures that all actions taken during the review process are documented.
• 7.2. In cases where it is objectively necessary, the Company may request additional information from the complainant regarding the case.
• 7.3. When communicating with the complainant, such communication must be in a language that is clear, accessible, and understandable to the complainant.
• 7.4. Any communication sent by the Company to the complainant shall be drafted in the language in which the complainant filed the complaint, provided that the language used by the complainant is one of the languages specified in Section 4.3. Communication shall be conducted in writing via electronic means or, at the complainant’s request, on paper.

8. Deadline for a Response and Decision on the Complaint

• 8.1. A final response shall be provided within 15 business days of the complaint’s receipt.
• 8.2. In cases of factual or legal complexity, as well as in the cases specified in Section 7.2, the complainant shall be notified of the reasons for the delay and the expected completion date, which may not exceed 2 months from the date of receipt of the complaint.
• 8.3. In exceptional cases where a decision on a complaint cannot be issued within the timeframes specified in sections 8.1 and 8.2, the Company shall notify the complainant without undue delay of the reasons for the delay and specify the date on which the decision is expected.

9. Decision on the Complaint

• 9.1. In its decision on a complaint, the Company shall address all issues raised in the complaint and state the reasons for the outcome of the investigation.
• 9.2. When rendering a decision, any previous decisions made by the Company on similar complaints are taken into account, unless “Bifinance” EOOD is unable to justify the reasons why it reached a different conclusion.
• 9.3. When the Company’s decision does not satisfy the complainant’s request or satisfies it only partially, the Company clearly states the reasons for its decision and includes information on the available legal remedies.
• 9.4. If the customer is not satisfied with the response/decision received regarding the complaint, “Bifinance” EOOD takes the following additional measures:
  • a request for a re-examination by the “Business Operations” department, as well as an investigation by the “Compliance” department;
  • providing the option for alternative/out-of-court dispute resolution, where applicable;
  • filing a complaint with the competent national supervisory authority;
  • the possibility of judicial remedy;
  • measures taken by the Company to prevent the violation (if any).

10. Register and Storage.

• 10.1. The Company maintains an up-to-date register of complaints, which is an integral part of this Procedure. The person responsible for maintaining the register is Stephen De Marco (Customer Relations, Reports, and Complaints Manager) – Business Operations Department.
• 10.2. Every complaint submitted, with the exception of anonymous ones, must be entered into the designated register.
• 10.3. The documentation is retained for a period of 5 years. In the event of pre-trial or judicial proceedings, the information is retained for 5 years from the conclusion of the relevant proceedings.

11. Control and Reporting. Consistency in the Handling of Complaints

• 11.1. A file should be maintained for each complaint, which includes:
  • the text of the complaint and the attached evidence;
  • the date of submission and receipt;
  • internal assessments, investigations, and communications;
  • the final decision;
  • all measures taken;
  • measures recommended for implementation within the Company.
• 11.2. Employees of the Business Operations Department conduct periodic analyses (at least twice a year) of complaints to identify systemic issues, improve processes, and mitigate operational and reputational risk.
  • 1) The Business Operations Department shall prepare an analysis (on an ongoing basis) of each stage of the complaint handling procedure for the purpose of timely detection of inefficiencies, non-compliance, or deviations.
  • 2) If any non-compliance, deviations, or total or partial inefficiencies are identified, the Business Operations Department should prepare a report with proposed measures and submit it directly to one of the Company’s Managers in accordance with Article 2, paragraph 3 of Delegated Regulation (EU) 2025/294.
  • 3) The analysis must include:
    • the average processing time for the relevant period under review for each stage of the complaint handling procedure, including acknowledgment, investigation, and response time;
    • the number of complaints received during the relevant period under review and for each stage of the complaint-handling procedure, as well as the number of complaints for which the maximum time limits set forth in this procedure were not met;
    • the categories of issues to which the complaints relate;
    • the results of the investigations.
• 11.3. A file should be maintained for each complaint, which includes:
  • the text of the complaint and the attached evidence;
  • the date of submission and the date of receipt;
  • internal assessments, investigations, and communications;
  • the final decision;
  • all measures taken;
  • measures recommended for implementation within the Company.

12. Stages in the decision-making process for customer complaints:

• a) Initial Assessment
  The responsible employee from the “Business Operations” department reviews the complaint and determines the necessary actions.
• b) Objective Analysis
  The responsible employee from the “Business Operations” department analyzes the facts and information, including those provided by the customer and the internal data of “Bifinance” EOOD.
• c) Escalation as Necessary
  In cases of heightened significance, the “Compliance” department and/or senior management, represented by one of the managers, must be involved.
• d) Documentation and Approval
  A written decision is prepared, including the rationale and recommendations for action.
• e) Notifying the Client
  • the decision on the complaint (fully granted, fully or partially denied)
  • If the complaint is fully or partially denied, the Company must provide reasons for its decision;
  • measures taken or proposed;
  • information on additional remedies;
  • contact information for inquiries.

13. Internal Organization of Complaint Handling

• 13.1. The department responsible for receiving, logging, communicating with customers regarding the case, and reviewing complaints is “Business Operations.”
  • 1) The employee responsible for handling complaints in the “Business Operations” department is Stephen De Marco (Manager of Customer Relations, Reports, and Complaints).
  • 2) In the event of operational necessity, complaints may also be handled by Teodora Dzhamova (Manager of Business Operations and Key Accounts).
  • 3) Depending on the nature and complexity of the issue, the responsible employee from the Business Operations Department should escalate it to the Head of the Compliance Department—Maaria Juntti—and/or Senior Management, represented by one of the managing directors, Shideh Andersen or Kosta Kostadinov.
• 13.2. Upon making initial contact with the complainant, the responsible officer shall provide the complainant with the following information:
  • Is the complaint admissible? (If the conditions for admissibility are not met, a clear explanation must be provided as to why the complaint was rejected as inadmissible.)
  • Date of receipt and reference number of the complaint;
  • Contact information—name, identification, email address, and phone number;
  • Information on the timeframes for processing the complaint;
  • If the complaint is submitted via an electronic form — a copy of the complaint.
• 13.3. The designated officer may not request from the complainant any information that the Company already possesses or is required by law to possess.
• 13.4. The responsible officer shall duly inform the complainant of all additional steps taken to address the complaint via email, or, if expressly requested by the complainant, in writing.
• 13.5. The decision shall address all issues raised in the complaint and state the reasons for the outcome of the investigation.
• 13.6. When handling complaints, the responsible person must communicate with the complainants in a language that is clear, accessible, and understandable to them.
• 13.7. Any processing of personal data from a received complaint is carried out in full compliance with Regulation (EU) 2016/679.
• 13.8. The Company’s managers are responsible for overseeing the proper implementation of this procedure.

14. Fair and Effective Handling of Complaints

In order to comply with Recital 11 of Delegated Regulation (EU) 2025/294, the Company allocates appropriate management resources to ensure that complaints are handled without any conflict of interest, as follows:

• 14.1. A conflict of interest exists when a person involved in the review of a complaint:
  • has a personal, financial, or professional interest in the outcome of the complaint;
  • has been involved in providing the service that is the subject of the complaint;
  • is in a hierarchical relationship with a person affected by the complaint;
  • has a close relationship with the complainant or an affected employee;
  • has any other interest that may affect their objectivity.
• 14.2. Measures to Prevent Conflicts of Interest:
  • designating independent employees to handle complaints;
  • separating operational and oversight functions;
  • prohibiting a person connected to the case from handling the complaint;
  • providing periodic training for staff;
  • documenting all actions and decisions.
• 14.3. Any person who identifies a potential conflict of interest must immediately notify the Head of the Compliance Department or one of the Company’s Managers and recuse themselves from handling the complaint. Any recusal and actions taken must be documented in writing.
• 14.4. In the event of a conflict of interest, the complaint shall be assigned to another independent and competent person from the “Business Operations” Department or shall be handled as a case by the Head of the “Compliance” Department or by a person designated by the latter who is part of the Company’s organizational structure.

15. Final Provisions

• 15.1. The Complaints Register maintained by “Bifinance” EOOD—Appendix No. 1—is an integral part of this Procedure.
• 15.2. This Procedure was drafted, adopted, and entered into force by a Decision of the Manager of “Bifinance” EOOD dated December 10, 2025.
• 15.3. This policy has been amended, supplemented, and enters into force by Order No. 8 of June 1, 2026, issued by the Manager of “Bifinance” EOOD.

APPENDIX:
COMPLAINT FORM