Complaint Handling Procedure

Vertex Capital & Tech Limited — Trading as Vorum Capital

1. INTRODUCTION AND PURPOSE

Vertex Capital & Tech Limited ("the Company"), trading as Vorum Capital, is committed to providing high-quality services to its clients. When things go wrong, the Company is committed to handling complaints promptly, fairly, consistently, and transparently.

This Complaint Handling Procedure ("Procedure") has been established to ensure that:

(a) Clients have clear and accessible routes to submit complaints;

(b) All complaints are treated seriously and investigated thoroughly;

(c) Complaints are resolved within defined timeframes;

(d) Clients are kept informed throughout the process;

(e) Complaint data is used to identify and address service deficiencies;

(f) The Company's complaint handling meets the standards expected of a responsible financial services provider.

This Procedure applies to all complaints from clients and prospective clients received through any channel. It applies to all personnel of the Company, including third-party agents and Introducing Brokers acting on the Company's behalf.

2. DEFINITION OF A COMPLAINT

2.1 What Constitutes a Complaint

A complaint is any expression of dissatisfaction — whether oral or written — made by, or on behalf of, a client or prospective client about:

• The Company's trading services, platform, or products;
• The conduct of the Company's personnel, agents, or Introducing Brokers;
• The Company's decisions regarding accounts, transactions, or access to services;
• The Company's communications or marketing materials;
• Any other aspect of the Company's operations that has caused or may cause detriment to the complainant.

A complaint exists even if the client does not use the word "complaint" — if the communication clearly implies dissatisfaction and a request for resolution or redress, it is treated as a complaint.

2.2 What Does Not Constitute a Complaint

The following are not complaints for the purposes of this Procedure, though they are handled with the same promptness:

• Simple requests for information or account assistance;
• Technical support enquiries resolved at the point of first contact;
• Requests for account statements or trade confirmations;
• Requests to change account settings or personal details.

If an enquiry initially treated as a non-complaint later reveals client dissatisfaction that is not resolved immediately, it shall be re-classified as a complaint and this Procedure applied.

3. HOW TO SUBMIT A COMPLAINT

3.1 Submission Channels

The Company accepts complaints through the following channels:

Primary Channel — Written (Recommended):

Email: compliance@Vorumcapital.com

Subject line format: `COMPLAINT — [Account Number] — [Brief Description of Issue]`

In Portuguese (for Brazilian and Portuguese-speaking clients):

Email: suporte@Vorumcapital.com

Subject: `RECLAMAÇÃO — [Número da Conta] — [Descrição Breve]`

Verbal complaints received by telephone will be acknowledged verbally and converted to a written record by the Company's staff. The complainant will receive a written acknowledgment confirming the details as recorded.

3.2 Information Required to Submit a Complaint

To enable efficient processing of your complaint, please provide:

Providing complete information at the outset allows the Company to process your complaint more efficiently. Incomplete submissions will be acknowledged and the Company will request additional information.

4. COMPLAINT HANDLING PROCESS

Stage 1 — Receipt and Acknowledgment

Upon receipt of a complaint, the Company will:

(a) Register the complaint in the Company's Complaints Register, assigned a unique complaint reference number (format: COMP-[YEAR]-[SEQUENTIAL NUMBER]);

(b) Send a written acknowledgment to the complainant within 5 business days of receipt, confirming:

• The complaint reference number;
• The name and contact details of the person handling the complaint;
• The complaint handling process and timeframes;
• An invitation to provide additional information if required.

Where a complaint is received outside business hours, the receipt date is the next business day.

Stage 2 — Assessment and Triage

Within 2 business days of registration, the Complaints Handler will:

(a) Review the complaint to assess its nature, complexity, and urgency;

(b) Categorise the complaint:

(c) Assign the complaint to the appropriate handler:

• Category A and B: Senior client services representative;
• Category C: Compliance Officer;
• Category D: Compliance Officer; escalated to Board if required.

(d) Confirm that the assigned handler has no personal involvement in the subject matter of the complaint.

Stage 3 — Investigation

The assigned handler conducts a thorough investigation, which includes:

(a) Gathering all relevant information:

• Account history and trading records;
• Platform access logs and timestamps;
• Internal system logs and audit trails;
• All correspondence between the client and the Company;
• Call recordings (where applicable and where client was notified of recording);
• Reports from technical, risk management, or trading teams as required.

(b) Reviewing the facts:

• Establishing a chronological timeline of events;
• Identifying what, if anything, the Company did incorrectly or contrary to its obligations;
• Assessing what impact any error had on the client.

(c) Seeking expert input:

• For pricing or execution complaints: obtaining a report from the trading/technology team with reference to independent market data from reputable sources;
• For technical complaints: obtaining a report from the IT/infrastructure team;
• For legal or regulatory complaints: obtaining the CO's legal analysis.

(d) Assessing the complaint:

• Was the Company's conduct in accordance with the Client Agreement, Terms and Conditions, and applicable policies?
• Was the client adequately informed of the relevant risks, terms, and conditions?
• Did the Company's conduct cause measurable financial detriment to the client?
• Is the client's desired outcome reasonable and proportionate?

Stage 4 — Interim Communications

Where a complaint cannot be fully resolved within 15 business days of acknowledgment, the Company will:

• Contact the complainant before the 15 business-day mark to explain the reason for the delay;
• Provide a revised expected completion date;
• Offer interim updates at least every 10 business days until the complaint is resolved.

Stage 5 — Final Response

The Company will issue a written final response within 30 business days of receipt of the complaint. In exceptional cases of high complexity (Category C or D), this period may be extended to a maximum of 60 business days, with the complainant notified in writing of the extension and the reason.

The final response will contain:

(a) A clear summary of the complaint as understood by the Company;

(b) A summary of the investigation conducted;

(c) The Company's conclusion — whether the complaint is upheld, partially upheld, or not upheld;

(d) The reasons for the conclusion, with specific reference to the relevant facts and applicable terms;

(e) Where the complaint is upheld or partially upheld: the remedy offered (see Section 5);

(f) Where the complaint is not upheld: a clear explanation of the reasons and, where appropriate, an acknowledgment of the client's right to escalate;

(g) Information about the complainant's right to refer the matter to arbitration if dissatisfied with the resolution.

5. REMEDIES

5.1 Range of Remedies

Where a complaint is upheld, the Company may offer one or more of the following remedies, depending on the nature and severity of the issue:

5.2 Calculation of Financial Remedy

Financial remedies will reflect the actual, demonstrable loss suffered by the client as a direct result of the Company's error. The Company will not make speculative or hypothetical payment of profits that might have been earned but for the error. Remedies are made without prejudice to any other rights the client may have.

5.3 Remedy Acceptance

Remedies are offered without admission of liability. The client is under no obligation to accept the remedy. Where the client accepts a financial remedy, the Company may request a signed acknowledgment that the remedy is accepted in full and final settlement of the complaint.

6. ESCALATION AND EXTERNAL RECOURSE

6.1 Internal Escalation

Where a complaint cannot be resolved at the Complaints Handler level, it is escalated to:

Level 2 — Compliance Officer: compliance@vorumcapital.com

The CO reviews the complaint file, the investigation conducted, and the conclusion reached.

6.2 Arbitration

If you remain dissatisfied with the Company's final response, you may refer the dispute to arbitration as provided in the Client Agreement (Section 11) and Terms and Conditions (Section 18).

Arbitration is conducted under the UNCITRAL Arbitration Rules, with:

• Seat of arbitration: Saint Lucia;
• Language of arbitration: English;
• Governing law: Laws of Saint Lucia;
• The arbitral award being final and binding.

The costs of arbitration are shared between the parties unless the arbitral tribunal orders otherwise.

6.3 Notice for Brazilian Clients

Aviso para clientes brasileiros: A Vorum Capital não é regulada pela CVM do Brasil nem pelo Banco Central do Brasil. Consequentemente:

• Não há ombudsman financeiro brasileiro com jurisdição sobre esta empresa;
• Não há mecanismo de resolução de disputas do Sistema Financeiro Nacional (SFN) aplicável;
• O Procon e os juizados especiais cíveis brasileiros podem não ter jurisdição sobre disputas com esta empresa;
• A arbitragem conforme prevista no Acordo de Cliente é o mecanismo de resolução de disputas disponível.

Clients from Brazil who are dissatisfied with the Company's resolution are encouraged to seek independent legal advice in Brazil regarding any rights they may have under applicable Brazilian law.

7. COMPLAINTS REGISTER

7.1 Content of the Register

The Company maintains a Complaints Register that records for each complaint:

• Unique complaint reference number;
• Date received;
• Channel of receipt;
• Client name and account number;
• Nature of complaint (category and brief description);
• Date of acknowledgment;
• Assigned handler;
• Date(s) of investigation activities;
• Date of interim communication(s) (if applicable);
• Date of final response;
• Outcome (upheld / partially upheld / not upheld);
• Remedy offered and whether accepted;
• Total calendar days from receipt to final response.

7.2 Use of Complaint Data

The Compliance Officer reviews the Complaints Register:

• Monthly: to monitor open complaints and ensure timeframes are met;
• Quarterly: to identify patterns, trends, and systemic issues;
• Annually: to produce an Annual Complaints Report for the Board.

The Annual Complaints Report includes: total number of complaints received, categorisation by nature, average resolution time, uphold rate, remedies provided, and root cause analysis of recurring issues.

7.3 Retention

Complaint records, including all correspondence, investigation notes, and final responses, are retained for a minimum of 5 years from the date of closure of the complaint.

8. ROOT CAUSE ANALYSIS AND SERVICE IMPROVEMENT

Where analysis of complaint data identifies a pattern of issues relating to a particular product, process, system, or member of staff, the Compliance Officer shall:

(a) Conduct or commission a root cause analysis within 30 days of identifying the pattern;

(b) Report findings and proposed remediation to the Board;

(c) Implement approved remediation measures with defined timelines;

(d) Monitor the effectiveness of remediation through ongoing complaint data analysis;

(e) Report on remediation effectiveness at the next Board meeting following implementation.

The Company treats complaints as a valuable source of business intelligence and client feedback, not merely as a compliance obligation.

9. CONFIDENTIALITY

All complaint files and associated correspondence are treated with strict confidentiality. Access is limited to:

• The assigned complaints handler;
• The Compliance Officer;
• The Board (for escalated cases);
• External legal advisers (where engaged);
• Regulatory authorities (where required by law).

Complaint information is never shared with Introducing Brokers, affiliates, or third parties except as required by law or with the explicit written consent of the complainant.

10. CONTACT

Complaints (primary): compliance@Vorumcapital.com

Client support: support@vorumcapital.com

Postal address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia