Complaints Handling Policy

Effective: May 2025 · Last Updated: July 2025 (Version 1.2)

1. Overview

Seapoint Finance Limited and its subsidiaries commit to addressing customer concerns through a formal complaints process. This policy applies to all employees, contractors, board members, and managers. This framework should be read alongside applicable UK or EEA contracts.

2. What Constitutes a Complaint?

UK Definition (FCA DISP)

“Any oral or written expression of dissatisfaction…about provision of, or failure to provide, a financial service” where the complainant has suffered or may suffer financial loss, material distress, or material inconvenience.

EMD Complaintsmust also concern “rights and obligations arising under Part 5 of the Electronic Money Regulations” regarding issuance and redeemability of electronic money.

Ireland/EEA Definition (Consumer Protection Code)

Grievance or dissatisfaction expressed orally or in writing regarding provision or failure to provide products or services by a regulated entity.

MiFID Complaints follow FCA DISP standards for investment services provided through WealthKernel Limited partnership.

3. Time Limits for Filing

• UK: Within six years following the conduct or incident, or three years from when you realised there was a problem. Complaints about prior Seapoint responses must be filed within six months.
• Ireland/EEA: Within six years after the conduct or incident.

Late complaints are rejected without further review, though Seapoint provides written explanation.

4. What Is Not a Complaint

Negative feedback not requiring formal resolution falls outside this policy. Such feedback can be directed to support@seapoint.co.

5. Who Can Complain

Only Seapoint Customers or prospective Customers qualify as Complainants. Third parties making payments are excluded. Non-customer complaints follow standard support processes.

6. How to Submit a Complaint

Email: complaints@seapoint.co

UK Mail

Ireland Mail

Required Information

• Complainant name and contact details
• Account number (where applicable)
• Nature of complaint with dates
• Supporting documentation

7. Complaint Process

Seapoint investigates thoroughly before responding. Complaints may be closed if they fail to meet complaint criteria or if another party is responsible, with referral to that party.

7.1 Response Timelines

EMD Complaints

• Acknowledgment: within 5 business days
• Final response: within 15 business days
• Exceptional cases: up to 35 business days
• Post-investigation response: up to 40 business days total

MiFID Complaints

• Acknowledgment: within 5 business days with point of contact
• Summary resolution: within 3 business days if possible
• Final response: within 8 weeks of receipt
• Complex cases: extended timeline with notification

7.2 Final Response Components

Seapoint’s written response will either:

• Accept the complaint and offer redress or remedial action
• Offer redress without accepting the complaint
• Explain rationale for rejection

Redress is delivered promptly. Complaints are closed if no reply is received or acceptance is indicated.

7.3 Ombudsman Referral

If unresolved, customers may escalate to:

UK — Financial Ombudsman Service

Website: www.financial-ombudsman.org.uk

Ireland — Financial Services and Pensions Ombudsman

Website: www.fspo.ie
Address: Lincoln House, Lincoln Place, Dublin 2, D02 VH29
Phone: +353 1 567 7000
Email: info@fspo.ie

MiFID Complaints

Financial Ombudsman Service — within 6 months of final response
Email: complaint.info@financial-ombudsman.org.uk
Phone: 0800 023 4567
Post: Exchange Tower, London, E14 9SR

8. Record Retention

All complaint records are retained for minimum 5 years. MiFID complaints maintain comprehensive FCA-compliant records including subject matter, handling details, outcome, and any redress provided.