Complaints Handling Procedure

Complaints Handling Procedure

Monolith Private Wealth Limited

Regulated by the Financial Services Commission of Mauritius

1. Background and Purpose

Monolith Private Wealth Limited (“MPW” or the “Company”) is a company incorporated in Mauritius and licensed by the Financial Services Commission (“FSC”) as an Investment Dealer (Full Service Dealer, excluding Underwriting) and as an Investment Adviser (Unrestricted), pursuant to the Securities Act 2005 (Section 29), the Securities (Licensing) Rules 2007, and the Financial Services (Consolidated Licensing and Fees) Rules 2008.

MPW provides its services to retail and professional clients through multiple channels, including face-to-face client interactions, an online platform accessible via the Internet, and a smartphone mobile application. The Company is committed to handling all complaints promptly, fairly, transparently and consistently, and to using complaints as a constructive source of information to support the ongoing improvement of its services, systems and client experience.

• This Complaints Handling Procedure (the “Procedure”) sets out:

• The channels through which complaints may be submitted to MPW;

• The internal process for receiving, acknowledging, investigating, and responding to complaints;

• The roles and responsibilities of MPW staff in handling complaints;

• The differentiated treatment applied to complaints depending on the category of the complainant (retail vs professional);

• The escalation rights of clients, including to the FSC and the Office of the Ombudsperson for Financial Services; The internal record-keeping, reporting, and monitoring obligations; and

• The governance arrangements for this Procedure.

A current version of this Procedure is published on the Company's website and made available within the mobile application. A copy of this Procedure shall also be provided to any client on request, free of charge.

2. Regulatory Framework

This Procedure is adopted in compliance with, and shall be read in conjunction with, the following principal instruments:

• Securities Act 2005 — Establishes the licensing framework and the obligations of investment dealers including fair treatment of clients.

• Financial Services Act 2007 — Sets out the FSC's regulatory mandate, the Office of the Ombudsperson for Financial Services, and licensee conduct obligations.

• FSC Code on the Conduct of Business (the “CoB”) — Binding conduct standards for FSC licensees, including complaint-handling requirements and fair treatment of clients.

• Securities (Licensing) Rules 2007 — Licensing conditions including conduct requirements applicable to investment dealers.

• Data Protection Act 2017 — Governs the processing of personal data of complainants.

• Office of the Ombudsperson for Financial Services Act 2018 — Establishes the Office of the Ombudsperson for Financial Services as an independent body to resolve disputes between financial institutions and their clients.

• MPW Internal Policies — The Internal Operations Manual / Procedures Manual, the AML/CFT Manual, and the Client Categorisation Policy, all of which are cross-referenced where relevant.

3. Definitions

For the purposes of this Procedure, the following terms shall have the meanings ascribed below:

“Business Day” Any day other than a Saturday, Sunday, or public holiday in Mauritius.

“Compliance Officer” The person appointed by the Board of Directors of MPW to oversee compliance with applicable regulatory requirements, including the management of this Procedure.

“Complaint” Any expression of dissatisfaction, whether justified or not, addressed by an Eligible Complainant to MPW in respect of the provision of, or failure to provide, a financial product or service. A Complaint may be made orally or in writing, including by electronic communication.

“Eligible Complainant” Any of the following persons may submit a Complaint under this Procedure: (i) any current Client of MPW (whether categorised as retail or professional); (ii) any former Client whose relationship with MPW has ended in the preceding twenty-four (24) months; (iii) any prospective Client whose account application has been received but not yet finalised; and (iv) any other person who has been directly affected by a service provided by MPW and whom the FSC or the Office of the Ombudsperson recognises as having standing to complain.

“FSC” The Financial Services Commission of Mauritius, established under the Financial Services Act 2007.

“MLRO” The Money Laundering Reporting Officer of MPW, as designated under the FSC AML/CFT Handbook and the Financial Intelligence and Anti-Money Laundering Act 2002. The MLRO is responsible for handling complaints that involve allegations of AML/CFT-related matters.

“Ombudsperson” The Office of the Ombudsperson for Financial Services of Mauritius, established under the Office of the Ombudsperson for Financial Services Act 2018.

“Regulatory Complaint” A Complaint that relates to MPW's conduct of regulated activities, including (without limitation) suitability of advice, execution of orders, fees and charges, client communications, breaches of mandate, or any allegation of misconduct.

“Service Complaint” A Complaint that relates to operational matters such as platform availability, customer service, communication delays, or administrative errors, but which does not allege a breach of MPW's regulatory obligations.

4. Scope and Application

4.1 Scope

This Procedure applies to all Complaints received by MPW from Eligible Complainants in respect of any of the services provided by MPW, namely:

• Investment Advisory Services (under the Investment Adviser Licence);

• Management of portfolios of clients for securities transactions under a defined mandate (discretionary or non-discretionary);

• Intermediation in securities transactions; and

• Reception, transmission, and execution of securities orders on behalf of clients (under the Investment Dealer Licence).

This Procedure applies regardless of the channel through which the service was provided (online platform, mobile application, or otherwise) and regardless of the channel through which the Complaint is submitted.

4.2 Minimum Standard

This Procedure sets out the minimum complaint-handling standards applicable to all Eligible Complainants. In the event of any conflict or inconsistency between this Procedure and the FSC Code on the Conduct of Business, or any other applicable legal or regulatory requirement, the provision imposing the higher standard of protection, fairness or regulatory compliance shall prevail.

4.3 No Fees

No fee, charge or penalty shall be imposed on any Complainant in connection with the submission, handling or resolution of a complaint under this Procedure, or in connection with any escalation of such complaint to the FSC, the Ombudsperson or any other competent authority.

5. Channels for Submitting a Complaint

MPW makes available multiple channels to ensure that submitting a Complaint is accessible, convenient, and secure. Complainants may use any of the following channels:

Note: Where a Complaint is made orally (by telephone, in person, or via voice messaging), the receiving staff member shall make a written contemporaneous note of the Complaint, capture all material details, and within twenty-four (24) hours forward the note to the Compliance Officer.

6. Categorisation of Complaints

Upon receipt, the Compliance Officer (or designated complaints handler) shall categorise each Complaint as set out below. Categorisation determines the responsible function for first-line investigation, the severity level, and the target resolution timeframe.

6.2 Independence of Investigators

Where appropriate, the Compliance Officer shall assign the Complaint to a staff member who has not been directly involved in the matter complained of or being investigated to maintain fairness and transparency. For Regulatory Complaints of High or Critical severity, the investigation shall be conducted by, or under the direct supervision of, the Compliance Officer or the MLRO (as applicable).

6.3 Conflicts of Interest in Complaint Handling

Where the Compliance Officer is the subject of a Complaint, the matter shall be referred to the Chief Executive Officer for investigation. Where the Chief Executive Officer is the subject of a Complaint, the matter shall be referred to the Board of Directors.

7. Complaint Handling Process

7.1 Initial Receipt and Routing

Upon receipt of a Complaint through any channel, the receiving staff member shall:

1. Acknowledge to the Complainant that the Complaint has been received (where the channel permits immediate acknowledgement);

2. Capture all material details of the Complaint, including the date and time of receipt, identity of the Complainant, channel used, and substance of the Complaint;

3. Forward all details to the Compliance Officer within as soon as possible, or, where the Complaint involves AML/CFT matters, to the MLRO, within 24 hours of receipt;

4. Refrain from making any admission of liability or any commitment as to redress before the Complaint has been formally investigated.

7.2 Formal Acknowledgement

Unless the Complaint is of a simple nature and can be resolved by the close of the following Business Day, a formal written acknowledgement shall be sent to the Complainant no later than:

• Three (3) Business Days from receipt for Complaints submitted via in-app or online form;

• Five (5) Business Days from receipt for Complaints submitted by email, telephone, post, or in person.

The acknowledgement letter or email shall include:

Confirmation of the date the Complaint was received;

• A unique Complaint reference number;

• The name, job title, and contact details of the person responsible for handling the Complaint;

• The expected timescale for resolution (or a date by which the Complainant will receive an update); and

• A statement of the Complainant's rights, including the right to escalate the Complaint to the FSC or the Ombudsperson if not resolved to the Complainant's satisfaction.

7.3 Investigation

The Compliance Officer (or designated investigator) shall conduct a prompt, fair, and thorough investigation. The investigation may involve:

• Reviewing the relevant account history, communications, and trading activity;

• Interviewing relevant staff members;

• Reviewing the applicable Client Agreement, Risk Disclosure, and other relevant documentation;

• Consulting with external advisers (legal, technical, or other) where appropriate; and

• Requesting additional information or documentation from the Complainant where necessary.

The Complainant shall be kept informed of progress in accordance with Section 7.4 below.

7.4 Target Resolution Timeframes

MPW aims to resolve Complaints within the following indicative timeframes:

Maximum Timeframe: In no circumstances shall a Complaint remain unresolved for more than ninety (90) calendar days from the date of receipt without a clear written justification provided to the Complainant. Where ninety (90) days has elapsed, the Compliance Officer shall expressly inform the Complainant of their right to escalate the matter to the Ombudsperson or the FSC.

7.5 Interim Updates

If a Complaint has not been fully resolved within the target timeframe applicable to its severity, the Compliance Officer shall send the Complainant a written update letter or email setting out:

• The current status of the investigation;

• The reason for the delay (if any);

• Any further information required from the Complainant; and

• A revised estimated date for resolution.

7.6 Final Response

Once the investigation is complete, MPW shall issue a Final Response letter or email to the Complainant. The Final Response shall include:

• A summary of the Complaint as understood by MPW;

• A summary of the investigation carried out;

• MPW's findings and conclusions, including whether the Complaint is upheld in whole, in part, or rejected;

• Where the Complaint is upheld in whole or in part, the redress proposed (see Section 9 below);

• Where the Complaint is rejected, the reasons for the rejection in sufficient detail to allow the Complainant to understand the outcome;

• A clear statement of the Complainant's rights to escalate the matter to the Ombudsperson or the FSC (see Section 11), including the relevant contact details and deadlines; and

• Where redress is proposed, a copy of the full-and-final settlement declaration to be signed by the Complainant (see Section 9.3).

8. Investment Performance

A Complaint solely about investment performance, in the absence of any allegation of unsuitability, misrepresentation, mis selling, breach of mandate, conflict of interest, or service failure, is not viewed as a Regulatory Complaint and shall be handled by the relevant investment adviser or relationship manager in the ordinary course of the client relationship.

However, where any of the following elements are present, the Complaint shall be treated as a Regulatory Complaint and handled under this Procedure in full:

• Allegation that the investment was unsuitable for the client's profile;

• Allegation of misrepresentation of the product or its risks;

• Allegation of mis-selling or that material information was withheld;

• Allegation of breach of the client's mandate (discretionary management);

• Allegation of breach of best execution obligations;

• Allegation of conflict of interest affecting the recommendation or transaction; or

• Any allegation of misconduct by MPW or its employees.

Important: Where there is any doubt as to whether a Complaint about performance also involves any of the above elements, the Compliance Officer shall treat the Complaint as a Regulatory Complaint and apply this Procedure in full. The default position is enhanced protection for the Complainant.

9. Redress

9.1 Principles

Where MPW upholds a Complaint in whole or in part, redress shall be offered that aims to put the Complainant, so far as reasonably possible, in the position they would have been in had the act or omission not occurred. Redress shall be fair, reasonable, and proportionate to the loss or harm suffered. Forms of redress may include:

• Financial compensation for direct losses;

• Reversal of disputed transactions;

• Refund of fees, commissions, or charges incorrectly applied;

• Goodwill payments where appropriate;

• Correction of records;

• Written apology; and

• Procedural undertakings (e.g., changes to processes affecting the Complainant).

9.2 Approval

No financial compensation may be paid by MPW unless:

Compensation up to MUR 50,000 (or equivalent) — approved by the Chief Executive Officer;

Compensation between MUR 50,000 and MUR 250,000 — approved by the Chief Executive Officer with notification to the Board;

Compensation exceeding MUR 250,000 — approved by the Board of Directors.

9.3 Settlement Declaration

When communicating the level of redress to the Complainant, MPW shall provide a clear explanation of how the amount has been determined. The Final Response shall include a settlement declaration for the Complainant to sign and return. The declaration shall:

• State that the proposed redress is offered in full and final settlement of the Complaint;

• Set out the scope of the matters covered by the settlement;

• Confirm that acceptance of the settlement does not affect the Complainant's statutory rights or their right to lodge a Complaint with the FSC or the Ombudsperson where the law so permits; and

• Be drafted in language appropriate to the Complainant (avoiding excessive legalese).

Payment of redress shall not be made until the signed declaration has been returned by the Complainant (except where MPW determines, in its discretion, that immediate restorative action is appropriate).

10. Differentiated Treatment — Retail vs Professional Clients

Under the FSC framework, retail clients benefit from enhanced procedural protections compared to professional clients. MPW applies the following differentiated approach, while ensuring that this Procedure establishes the minimum standard available to all Eligible Complainants regardless of category:

Default Principle: Where there is doubt as to whether a Complainant should be treated as Retail or Professional for the purposes of this Procedure, MPW shall apply Retail Client protections. Categorisation under the Client Categorisation Policy does not reduce the procedural protections under this Procedure unless expressly inconsistent with applicable FSC regulation.

11. Escalation Rights

If a Complainant is dissatisfied with MPW's Final Response, or if MPW has not provided a Final Response within the maximum timeframe set out in Section 7.4, the Complainant has the right to escalate the Complaint to one or more of the following external bodies.

11.1 Office of the Ombudsperson for Financial Services

Established under the Office of the Ombudsperson for Financial Services Act 2018, the Ombudsperson is an independent body that resolves disputes between financial institutions and their clients in Mauritius.

Office of the Ombudsperson for Financial Services

Address: Ground Floor, SICOM Tower, Wall Street, Ebene 72201, Mauritius

Telephone: +230 460 0473 or +230 460 0474

Email: ombudspersonfs@ofsmauritius.org

Website: https://ofsmauritius.govmu.org/

Eligibility: Eligible Complainants who have received an unsatisfactory Final Response from MPW, or who have not received a Final Response within the maximum timeframe applicable.

Cost to Complainant: Free of charge.

11.2 Financial Services Commission (FSC)

Where a Complaint involves an alleged breach of regulatory obligations by MPW, the Complainant may submit the matter to the FSC for regulatory review. The FSC's role is supervisory and the FSC does not adjudicate compensation disputes between licensees and clients.

Financial Services Commission, Mauritius

Address: FSC House, 54 Cybercity, Ebène, 72201, Mauritius

Telephone: +230 403 7000

Email: fscmauritius@fscmauritius.org

Website: https://www.fscmauritius.org

11.3 Other Avenues

Complainants retain all rights to seek redress through the courts of Mauritius, alternative dispute resolution, or any other mechanism available under Mauritius law. The use of this Procedure, the Ombudsperson, or the FSC does not waive any such rights.

12. Roles and Responsibilities

13. Record Keeping

13.1 Complaints Register

The Compliance Officer shall maintain a central Complaints Register. The Register shall be maintained in a secure electronic format and shall record, for each Complaint, at a minimum:

• Unique Complaint reference number;

• Date and time of receipt;

• Channel through which the Complaint was received;

• Identity and contact details of the Complainant;

• Category of the Complainant (retail or professional);

• Category of the Complaint (per Section 6.1);

• Severity rating;

• Summary of the Complaint;

• Person(s) responsible for investigation;

• Key milestones with dates: acknowledgement, updates, Final Response, settlement;

• Outcome (upheld in whole / in part / rejected);

• Redress provided (if any);

• Whether the Complaint was escalated to the Ombudsperson, FSC, or any court; and

• Any lessons learned and resulting process improvements.

13.2 Retention

All Complaint records (including the Register, supporting documentation, internal investigation notes, communications with the Complainant, and Final Response) shall be retained for a minimum of seven (7) years from the date of the Final Response, in accordance with the record-keeping obligations under the IOM (Section 4.9.1), the FSC AML/CFT Handbook, and Section 17(b) of FIAMLA 2002.

13.3 Confidentiality and Data Protection

All Complaint records contain personal data and may contain sensitive information. They shall be:

• Stored securely with access restricted to authorised personnel (Compliance Department, MLRO, senior management, and external auditors as required);

• Processed in compliance with the Data Protection Act 2017 and MPW's Privacy Policy;

• Shared only with the FSC, the Ombudsperson, the FIU, judicial authorities, or other regulators where required by law or legitimate request; and

• Subject to the same retention, deletion, and security measures as other client personal data.

14. Reporting and Monitoring

14.1 Internal Reporting

The Compliance Officer shall:

• Through CO reports, also include a reporting detail of complaints received and changes brought to the Complaints Register for the Board of Directors, including trends analysis, root-cause findings, and recommended remedial actions;

• Include in the CO reports, details on complaints reported for the Board of Directors, including a comprehensive review of complaints handling effectiveness and proposed amendments to this Procedure.

14.2 Regulatory Reporting

The Compliance Officer or his/her absence, the MLRO shall submit such complaints reports to the FSC as may be required from time to time under the FSC's reporting obligations applicable to investment dealers, and shall promptly notify the FSC of any:

• Complaint that has been referred to law enforcement or judicial authorities;

• Complaint that may evidence a systemic issue affecting multiple clients;

• Complaint that involves a suspected breach of regulatory obligations; or

• Any other Complaint required by the FSC to be notified.

14.3 Root-Cause Analysis and Continuous Improvement

The Compliance Officer shall conduct periodic root-cause analyses of Complaints data with the objective of identifying:

• Recurring issues that may indicate systemic weakness in MPW's processes, systems, or staff capabilities;

• Training needs for any function or individual;

• Required updates to internal policies, client communications, or product information; and

• Opportunities to improve the online platform or mobile application based on user feedback.

Findings shall be reported to senior management and used to drive continuous improvement of MPW's services.

15. Training and Awareness

All MPW employees shall receive training on this Procedure:

• On induction, before being assigned to any client-facing or operational role;

• Annually, as part of the Company's mandatory compliance training programme; and

• On an ad-hoc basis where this Procedure is materially amended.

Training shall cover:

• Recognition of Complaints, including atypical or implicit expressions of dissatisfaction;

• Channels for receiving and forwarding Complaints;

• The need for forwarding complaints to the Compliance Officer within a reasonable timeframe and as soon as possible, unless it pertains to suspicious information where it should be forwarded to the MLRO in accordance with the timeframe prescribed in the Compliance Manual;

• Prohibitions on making admissions of liability or commitments to redress;

• Confidentiality obligations relating to Complaints data; and

• Specific guidance for handling AML/CFT, cybersecurity, and data protection Complaints.

• In case complaints relate to Data Breaches, the matter shall be referred to the designated Data Protection Officer.

Training records shall be maintained by the Compliance function and shall be subject to audit.

16. Governance, Review and Updates

This Procedure shall be reviewed at least annually by the Compliance Officer and approved by the Board of Directors. The Procedure shall be reviewed earlier upon the occurrence of any of the following:

• Any material amendment to the Securities Act 2005, Financial Services Act 2007, FSC Code on the Conduct of Business, or other applicable Mauritius regulation;

• Issuance of any relevant Dear CEO letter, circular, or guidance note by the FSC or the Ombudsperson;

• Material findings from an internal audit, FSC inspection, or external review;

• Material changes to MPW's business model, product range, or distribution channels;

• A material increase in complaints volume or severity, indicating that the Procedure may not be operating effectively; or

• Recurring root-cause findings indicating the need for procedural change.

Material amendments to this Procedure shall be approved by the Board of Directors and communicated to all employees through the Compliance function. The current version shall always be published on the Company's website and made available in the mobile application.

17. Legal Disclaimer

This Procedure has been prepared to comply with MPW's obligations under applicable Mauritius law and FSC regulation. It does not constitute legal advice and does not purport to be an exhaustive statement of all obligations of MPW or of all rights of Complainants. Where any conflict arises between this Procedure and applicable law or FSC regulation, the applicable law or FSC regulation shall prevail. Clients are encouraged to seek independent legal advice if uncertain about their rights.

Annex A — Complaints Register Schema

The following data fields shall be captured for each Complaint recorded in the Complaints Register. The Register shall be maintained in an electronic format that supports filtering, sorting, and reporting.

Annex B — Indicative Complaint Handling Flow

This Complaints Handling Procedure supersedes any previous version of the Procedure circulated within MPW. All employees are required to read and confirm understanding of this Procedure as part of their onboarding and annual compliance training.