This Complaints Handling Policy explains how clients and potential clients of Ronin EM Limited (the "Company", "we", "us") can submit a complaint and how we will handle it.

The Policy applies to:

• existing clients; and
• potential clients who have interacted with us or attempted to use our services.

The aforementioned right concerns exclusively complaints related to our crypto-asset services provided under the provisions of the Regulation (EU) 2023/1114 and the supervision of the Cyprus Securities and Exchange Commission ("CySEC").

Clients can submit a complaint free of charge.

For the purposes of this Policy:

Complaint means any written statement of dissatisfaction addressed to us by a client or potential client, where the person alleges that they have suffered or may suffer financial or non- financial loss, or that we have failed to fulfill a legal, regulatory or contractual obligation.

Complainant means any natural or legal person who is eligible to lodge a complaint and has lodged a complaint with us.

You may submit a complaint if you are:

• an individual client or potential client;
• a legal entity (for example, a company) that is or wishes to become a client; or
• a duly authorised representative acting on behalf of a client or potential client, subject to provision of satisfactory proof of authority.

You may submit a complaint in any of the following ways:

1. Online Form: You may complete and submit the Client Complaint Form available in the "Complaints" section of our website (em.ron.in).
2. Post: You may send a signed letter to our registered office address as stated on our website.

For regulatory and record-keeping purposes, complaints should normally be submitted in writing.

If you initially contact us by phone or chat, we will ask you to file your complaint in writing using one of the methods above.

Complaints must be submitted in English or Greek language.

To enable us to handle your complaint efficiently and fairly, please provide the following information, to the extent available:

• Your full legal name or company name (if applicable);
• Your contact details (email, phone number, postal address);
• Your client ID or account number (if any);
• The date and time of the event(s) you are complaining about;
• A clear description of what happened and why you believe you have suffered a loss or that we failed to meet an obligation;
• Any supporting documentation (e.g., screenshots, trade confirmations, correspondence); and
• The resolution you are seeking.

When we receive your written complaint, it will be immediately registered in our Complaints Register and assigned a unique reference number.

We will acknowledge receipt of your complaint in writing (e.g., by email) within five (5) business days from the date we receive it.

The acknowledgement will:

• confirm that we have received your complaint;
• provide your unique complaint reference number; and
• provide the contact details of the person or department handling your complaint.

Your complaint will be reviewed by the appropriate department or by the Complaints Officer, who will investigate the issues raised fairly and impartially.

We may contact you to request additional information or clarification during the investigation. Please respond promptly to help us conclude our investigation quickly.

If we are unable to issue a final response within fifteen (15) business days of receiving your complaint, we will send you a holding letter explaining the delay. The holding letter will:

• state clearly the reasons for the delay;
• provide a status update; and
• give you an expected timeframe for completion.

In any event, we will make reasonable efforts to complete our investigation and issue a final response no later than three (3) months from the date we received your complaint. During the process, we will keep you reasonably informed of progress.

Once our investigation is completed, we will send you a written response including:

• The outcome of our investigation;
• Whether we accept or reject your complaint and the reasons for our decision; and
• Where applicable, any offer of redress or compensation (financial or non-financial).

If you are not satisfied with our final response, or if we fail to send you a final response within the three (3) month maximum timeframe (as described in Section 6.4), you may have the right to refer your complaint to an alternative dispute resolution body.

Eligible retail clients may have the right to refer your complaint to the Office of the Financial Commissioner (Ombudsman) of the Republic of Cyprus, an independent body responsible for resolving certain disputes between financial firms and their clients.

Further information about the Office of the Financial Commissioner of the Republic of Cyprus, including eligibility criteria, procedures and time limits, is available on the website: https://financialombudsman.org.cy.

You may also submit a complaint to Cyprus Securities and Exchange Commission, the competent supervisory authority. CySEC generally does not resolve individual disputes or award compensation but may use complaint information for supervisory purposes. Information on how to submit a complaint to CySEC is available on the website: cysec.gov.cy.

The use of our internal complaints procedure or referral to the Financial Ombudsman does not affect your right to seek legal remedies, including by commencing legal proceedings in a court of competent jurisdiction.

We may not be able to process a complaint if:

• It does not relate to our crypto-asset services regulated under the Regulation (EU) 2023/1114 (MICAR);
• It is not submitted by an eligible client or potential client (or their authorised representative);
• It is submitted anonymously or is frivolous, vexatious, or clearly without merit; or
• You have failed to provide sufficient information to enable us to investigate the matter.

We treat all complaints and related information as confidential and handle them in accordance with applicable data protection laws and our Privacy Notice.

Your personal data will be used only for the purposes of:

• receiving, investigating and resolving your complaint;
• complying with our legal and regulatory obligations (including reporting aggregated complaint data to competent authorities); and
• monitoring and improving our services and internal controls.

We will retain records of complaints and their handling for at least five (5) years or for a longer period where required by law or by competent authorities.

We monitor complaints on an ongoing basis in order to identify recurring or systemic issues, potential legal or operational risks, and opportunities to improve our products and services.

In particular, we:

• analyse the causes of individual complaints to identify any common root causes;
• consider whether such root causes may affect other processes or clients who have not complained; and
• implement reasonable corrective and preventive measures where appropriate.

We review this Complaints Handling Policy at least annually and whenever there are relevant changes to our business, services, legal or regulatory requirements, or supervisory guidance.

If you have any questions about this Complaints Handling Policy or wish to submit a complaint, please contact us using the details below or the contact details available on our website (em.ron.in).