Complaint Handling Procedure

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

1. Objective

This procedure governs the process for receiving, registering, reviewing, resolving, and archiving complaints submitted by clients of BFinance EOOD, Company Registration No. 206805699, with its registered office and seat of management at: Bulgaria, Sofia City, postal code 1000, Sredets District, 11 Petko R. Slaveykov Sq, fl. 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 any Complaints submitted by clients, potential clients, and other interested parties regarding the crypto-asset services provided.

3. Definitions

• “Complaint” refers to a client’s expression of dissatisfaction regarding a crypto-asset service that was provided or is being provided.
• “Complainant” means a person who has filed a Complaint against the Company.

4. Filing Complaints

• 4.1. Clients have the right to file Complaints with the Company free of charge.
• 4.2. The Company reviews filed client Complaints 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 filed:
  • By email: support@blockforia.com
  • In hard copy, as follows:
    • Sent by courier or mail to the Company’s registered office: Bulgaria, Sofia City, postal code 1000, Sredets District, 11 Petko R. Slaveykov Sq, fl. 6.
    • Submitted in a Company office.
      *If a client submits a Complaint in hard copy by courier or mail, the client is required to pay the shipping costs; 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 representative, a notarized power of attorney certifying the representative’s authority must be attached to the documents. When the authorized representative is an attorney-at-law, the power of attorney must be in writing only, in accordance with Article 25 of the Bar Act. When the Complaint is filed by a legal representative, an official document proving the existence of the power of representation must be submitted.
• 4.6. When submitting documents with an advanced or qualified electronic signature as defined in Regulation (EU) No. 910/2014, the documents must be signed in the original and not scanned, so that the identity of the signatory can be verified.

5. Content of the Complaint and Conditions for Admissibility of Complaints

• 5.1. The Company does NOT review anonymous Complaints.
• 5.2. Minimum required content of the Complaint:
  • Full name of individual/legal entity;
  • National identification number / legal entity identification number;
  • Permanent/current address for individuals; registered office and business address for legal entities;
  • Contact information – address (if different from the one provided); phone number; email;
  • Complete information about the crypto-asset service to which the Complaint relates;
  • Subject matter of the Complaint;
  • Date(s) of the Events Giving Rise to the Complaint;
  • Description of the damage, loss, or harm sustained (where applicable);
  • Other comments or relevant information (where applicable);
  • The preferred method for receiving the decision on the Complaint, electronically (by email) or in hard copy at a specified mailing address. If the Complainant has not specified a method of communication, the Company will communicate and provide the decision in writing via email.
  • Attachments to the Complaint – when applicable.
• 5.3. Clients may submit their Complaints in free-form text, including the information listed above, or by using the form contained in the appendix to this Procedure.
• 5.4. Complaints should be addressed to the Business Operations Department of BFinance 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 will receive an acknowledgment of receipt within 5 business days, along with the reference number under which the Complaint has been registered, including notification to the Complainant as to whether the Complaint is admissible.
• 6.2. If the Complaint does not meet the admissibility requirements set forth in Section 5, the Company shall provide the Complainant with a clear explanation of the reasons why the Complaint has been rejected as inadmissible.
• 6.3. The acknowledgment of receipt of a Complaint contains 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 the Complaint, as well as the date the Complaint was received and registered; information regarding the time limits specified in Section 8 and, when the Complaint is submitted via an electronic form, a copy of the Complaint.

7. Reviewing Complaints

• 7.1. Complaints are reviewed 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 are documented.
• 7.2. In cases where it is objectively necessary, the Company may request additional information from the Complainant regarding the matter.
• 7.3. When communicating with the Complainant, the communication should 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 listed in Section 4.3. Communication shall be conducted in writing via electronic means or, at the Complainant’s request, in hard copy.

8. Deadline for a Response and Decision on the Complaint

• 8.1. A final response will be provided within 15 business days of the Complaint’s receipt.
• 8.2. In cases involving factual or legal complexity, as well as in the cases referred to 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, if a decision on a Complaint cannot be issued within the time limits specified in Sections 8.1 and 8.2, the Company must 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 given Complaint, the Company addresses all issues raised in the Complaint and explains the reasons for the outcome of the investigation.
• 9.2. When issuing a decision on a Complaint, the Company shall take into account any previous decisions relating to similar Complaints, unless BFinance EOOD is able to justify reaching a different conclusion.
• 9.3. If the Company’s decision does not grant the Complainant’s request or grants it only partially, the Company shall clearly state the reasons for its decision and include information on the available legal remedies.
• 9.4. If the Client is not satisfied with the response or resolution to their Complaint, BFinance EOOD shall take the following additional measures:
  • A request for re-examination by the Business Operations Department, as well as an examination by the Compliance Department;
  • Providing an opportunity for alternative dispute resolution (ADR), including out-of-court dispute resolution, where applicable;
  • Filing a Complaint with the competent national supervisory authority;
  • Option for judicial protection;
  • Measures taken by the Company to address the underlying issue (if any).

10. Register and Retention.

• 10.1. The Company maintains an up-to-date register of Complaints.
• 10.2. Every Complaint filed, with the exception of anonymous ones, must be entered in 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.

This procedure has been approved by the Manager of BFinance EOOD and takes effect on June 1, 2026.

APPENDIX:
Sample Complaint pursuant to Delegated Regulation (EU) 2025/294: