1. OBJECTIVE

1.1 LBank Exchange FZE (“LBank” or the “Company”) is a licensed ‘Exchange Service Provider’ by the Dubai Virtual Assets Regulatory Authority (“VARA”) and facilitates spot trading in permitted virtual assets. LBank provides services to retail and qualified investors.

1.2 LBank realizes that in the course of provision of its services, although LBank will provide its services to all its customers in accordance with the best performance standards and treat all customers fairly, it is possible that customers could have certain grievances or dissatisfaction.

1.3 It is LBank’s motive to mitigate any dissatisfaction and provide the best services to all its customers and has accordingly formulated this Complaints Handling Policy (“Policy”) with a view to resolve all complaints effectively in a prompt, consistent and fair manner and improve its systems and performance based on any complaints received. This Policy has been developed in line with VARA’s regulatory framework including, inter alia, the Virtual Assets and Related Activities Regulations 2023 (“VARA Regulations”) and accompanying rulebooks (“Rulebooks”).

1.4 The responsibility for maintaining, developing, executing, and updating this Policy lies with the Compliance Officer & Money Laundering Reporting Officer (“CO/MLRO”), and the formulation or any amendments to this Policy shall finally be approved by the board of directors of Lbank (“Board”).

2. COMPLAINTS

2.1 Filing complaints:

1. 

2. 

2.1. 

2.1.1. A customer may file a complaint with LBank via any of the below mentioned channels: 

(i) in person by visiting the Company’s office at Unit GF-115, Zentral Building, Dubai World Trade Centre, Sheikh Zayed Road, Dubai, PO. 9633;

(ii) by letter addressed to Maleesha Gunawardana at Unit GF-115, Zentral Building, Dubai World Trade Centre, Sheikh Zayed Road, Dubai, PO. 9633;

(iii) by e-mail to customersupport@lbankae.com; or

(iv) filling the form set out at Annexure 1 (Complaints Form) and also available on the Company’s website.

In case of complaints made in accordance with (i) to (iii) above, the customer service executives under the Operations Department of the Company (“Customer Service Team”) will document the complaints in accordance with the form set out at Annexure 1 (Complaints Form) on behalf of the complainant and attach any associated documents alongside the complaints form. For complaints made in accordance with (iv) above, the same will be automatically emailed to LBank’s Customer Service Team.

2.2 Contents of complaints:

In order to conduct an efficient evaluation of the complaint, any customer making a complaint is required to fill all details in the form set out at Annexure 1 (Complaints Form) or provide the following details:

(i) Name of the complainant;

(ii) Account details;

(iii) Nature of complaint;

(iv) Date on which the issue first arose;

(v) Details of service;

(vi) Details of complaint;

(vii) Action sought by the complainant; and

(viii) Supporting documents like proof of payment.

2.3 Receipt of complaints:

A complaint will be considered to be duly made, when delivered to LBank’s office and receiving an acknowledgement of delivery in case of personal delivery, receiving a delivery confirmation if the complaint is made via email or post, or by submitting the duly filled form on LBank’s website.

2.4 Review of complaints: 

On receiving any complaints, LBank shall issue an acknowledgment of receipt to the complainant within a period one (1) week from the complaint being made. Following the aforesaid, LBank will promptly begin an investigation with the aim of resolving the complaint as soon as reasonably possible. LBank shall not take longer than four (4) weeks from the complaint being made to resolve the complaint. However, in case of extraordinary circumstances if LBank is unable to provide a resolution within four (4) weeks, LBank shall within four (4) weeks of the complaint being made, issue a status update to the complainant specifying the reasons for the delay, and in either case, resolve the complaint within eight (8) weeks from when the complaint was made.

LBank strives to provide resolutions to every complaint in a fair and satisfactory manner. To this effect, LBank shall as part of its resolution, provide the customer with a detailed response of the resolution offered including details of the reasoning behind the same in clear language. While LBank strives to provide resolutions that will satisfy the grievances of its customers, LBank acknowledges that not all customers may be satisfied with the resolutions offered. In such cases of dissatisfaction or disputes, the customer may seek recourse in accordance with the dispute resolution mechanism set out in the client agreement entered into between the customer and LBank.

All complaints filed, shall be reviewed by the Customer Service Team consisting of trained customer service executives. The Customer Service Team will be supervised by the Head of Operations Department. In case of any complaints against the Head of Operations Department or any other senior executives of the Company, the Customer Service Team will report such complaints directly to the Board who shall oversee the resolution of such complaints.

2.5 Complaints against third-parties:

LBank may from time to time, partner with or utilize the services of third-party entities in the provision of any of its services, in accordance with applicable law. Should a customer have any grievances in relation to such services offered by the third-parties, LBank shall facilitate the handling of such complaints between the customers and such third-party entities and retain responsibility for resolution of such complaints. In case of such complaints, the customers can address these complaints directly to LBank and LBank shall forward them to the concerned third-party. Further, LBank shall intimate the customer that the complaint submitted has been shared with the third-party and provide details of the third-party to the customer. Additionally, LBank will liaise with the complainant and the third-party as necessary and ensure that the customer receives a resolution within the time-frames set out in this Policy.

2.6 Fees for complaints handling:

LBank does not impose any fees on the customers for handling of any complaints, either directly or on behalf of the customer where such complaints are related to any third-parties that have been hired or partnered with LBank.

3. REVIEW AND ANALYSIS

LBank understands that receipt of complaints is not only an opportunity to address its customers’ concerns, but also to remedy any recurring customer discrepancies to ensure such issues are mitigated completely.

Accordingly, LBank shall train its Customer Service Team to periodically review all complaints received and identify any repetitive complaints. Once LBank identifies any recurring or systemic problems, it shall analyze the causes of complaints to determine the common root causes of complaints and assess whether such root causes may also affect other processes and services (related or unrelated to virtual assets) or products, including those not directly complained of. After completing its assessment, the Customer Service Team shall intimate the Board of their findings along with the proposed measures for correction of such root causes. Upon receipt of Board approval, the Customer Service Team will work in accordance with the remedy plan.

4. RECORDS

As required under applicable law, LBank shall maintain a record of all complaints made and resolutions offered for at least eight (8) years from the date of receipt of a complaint. The records will reflect the details of the complaint and complainant, resolution offered and any other outcome if applicable. LBank will take reasonable measures to protect against unauthorized access to or use of the information contained in the complaints and related documentation. Complaints and related documentation are considered confidential. However, LBank may provide this information to government authorities, regulators, or competent courts upon request, as allowed or required in accordance with the applicable laws and regulations.

5. POLICY UPDATES AND DISCLOSURES

To ensure best practices in relation to handling of complaints, LBank shall review this Policy annually or earlier in case of any changes in applicable law. This Policy shall be updated in accordance with all applicable law including the VARA Regulations and accompanying Rulebooks, and LBank’s internal practices, with a clear noting of any amendments made to this Policy.

 LBank shall ensure that an up-to-date version of this Policy is always available on its website and that this Policy is drafted in a clear and easy to understand manner. 

ANNEXURE 1

COMPLAINTS FORM