Complaints Policy

1. Introduction

Meridian S.A. is committed to handling complaints in a fair, transparent, and timely manner.

This Complaints Policy explains how Users may submit complaints relating to the Meridian Platform, the Services, or their interactions with Meridian.

This Policy should be read together with the:

• Terms of Service
• Privacy Policy
• AML & Compliance Policy
• Fees Policy

2. Scope

This Policy applies to complaints relating to:

• Accounts
• Digital Asset custody
• Loan Products
• Transactions
• withdrawals
• deposits
• fees
• identity verification
• customer support
• Platform functionality
• privacy matters
• security matters
• other Meridian Services

This Policy does not limit any legal rights available to Users under Applicable Law.

3. What Is a Complaint?

For purposes of this Policy, a complaint is an expression of dissatisfaction concerning Meridian's Services, operations, products, or conduct.

Examples include concerns relating to:

• account access
• delayed Transactions
• withdrawal issues
• deposit issues
• Loan Products
• liquidation of Collateral
• billing
• fees
• customer support
• technical issues
• privacy
• compliance procedures

General questions, feature requests, or product suggestions are not normally treated as complaints.

4. How to Submit a Complaint

Complaints should be submitted through Meridian's official communication channels published on the Platform.

Where available, Users should use the designated complaint submission process.

Submitting duplicate complaints regarding the same matter may delay review.

5. Information to Include

To assist Meridian in reviewing a complaint efficiently, Users should include where applicable:

• full name
• Account identifier
• contact information
• description of the issue
• relevant dates
• transaction identifiers
• Loan identifier where applicable
• supporting documentation
• screenshots where available
• desired resolution

Meridian may request additional information where reasonably necessary.

6. Acknowledgement

Meridian seeks to acknowledge receipt of complaints within a reasonable period.

Acknowledgement of a complaint confirms only that the complaint has been received.

It does not imply that Meridian agrees with the complaint or that compensation will be provided.

7. Investigation

Each complaint is reviewed individually.

The investigation may involve:

• review of Account records
• Transaction history
• blockchain data
• communications
• internal audit logs
• security records
• compliance records
• technical information
• other relevant evidence

Where appropriate, multiple internal teams may participate in the review.

8. Additional Information

Meridian may request additional documentation or clarification where necessary to investigate a complaint.

Failure to provide reasonably requested information may delay review or prevent Meridian from fully investigating the complaint.

9. Communication During Review

Meridian may communicate with the User during the investigation to:

• request information
• clarify facts
• provide status updates where appropriate
• explain the outcome of the review

Certain information may not be disclosed where doing so would:

• violate Applicable Law
• compromise security
• interfere with an investigation
• disclose confidential compliance procedures
• affect the rights of third parties

10. Complaint Resolution

Following its review, Meridian may determine that:

• no further action is required
• additional information is needed
• corrective action should be taken
• technical issues require remediation
• account adjustments are appropriate
• fees should be corrected where applicable
• operational improvements should be implemented
• the complaint is not substantiated

Each complaint is assessed based on its individual facts and the information reasonably available to Meridian.

11. Review Timeframes

Meridian seeks to investigate and resolve complaints within a reasonable period, taking into account:

• the complexity of the matter
• the volume of supporting information
• technical investigations
• blockchain-related analysis
• compliance reviews
• involvement of third-party service providers
• legal or regulatory requirements

Certain complaints may require additional time where further investigation is reasonably necessary.

Where appropriate, Meridian may provide updates regarding the status of the review.

12. Escalation

If a User believes that a complaint has not been appropriately addressed, the User may request an internal review through Meridian's designated communication channels.

An escalated review may involve:

• additional personnel
• senior management
• compliance personnel
• legal personnel
• technical specialists
• other appropriate internal teams

Submission of an escalation request does not guarantee a different outcome.

13. Complaints That May Not Be Accepted

Meridian may decline to investigate or may close a complaint where:

• insufficient information has been provided
• the complaint is duplicated without new information
• the matter has already been fully reviewed
• the complaint is clearly abusive, threatening, or frivolous
• the complaint concerns matters outside Meridian's control
• the complaint relates to services not provided by Meridian
• Applicable Law prevents Meridian from providing further information

Where reasonably practicable, Meridian may explain why a complaint cannot be reviewed.

14. Fraudulent or Abusive Complaints

Meridian expects complaints to be submitted honestly and in good faith.

Meridian may take appropriate action where a complaint involves:

• knowingly false information
• fraudulent documentation
• impersonation
• abuse of the complaint process
• harassment of Meridian personnel
• repeated submissions intended to disrupt operations

Nothing in this section limits Meridian's obligations under Applicable Law.

15. Record Retention

Meridian may maintain records relating to complaints, including:

• complaint submissions
• supporting documentation
• correspondence
• investigation records
• internal findings
• actions taken
• final outcomes

Records may be retained in accordance with Applicable Law and Meridian's internal record retention procedures.

16. Relationship with Other Policies

This Complaints Policy should be read together with the following Meridian legal documents:

• Terms of Service
• Privacy Policy
• AML & Compliance Policy
• KYC Policy
• Digital Asset Custody Policy
• Digital Asset Risk Disclosure
• Digital Asset Loan Terms
• Digital Asset Loan Risk Disclosure
• Fees Policy
• Cookie Policy
• Prohibited Use Policy
• Legal Requests Policy

Where another Meridian policy specifically governs a particular subject matter, that policy shall apply together with this Complaints Policy.

17. Changes to this Policy

Meridian may amend this Complaints Policy from time to time to reflect:

• changes in Applicable Law
• regulatory guidance
• operational improvements
• technological developments
• new Platform features
• business developments

Updated versions become effective upon publication unless a later effective date is specified.

Where required by Applicable Law, Meridian will provide reasonable notice before material amendments become effective.

Continued use of the Platform after publication constitutes acceptance of the updated Policy.

18. Contact Information

Complaints should be submitted through Meridian's official communication channels published on the Platform.

Users should provide sufficient information to allow Meridian to identify the relevant Account, Transaction, Loan Product, or Service involved.

Questions regarding this Complaints Policy may also be submitted through Meridian's official support channels.

19. Effective Date

This Complaints Policy is effective from the date stated above and remains in force until amended or replaced by Meridian S.A.