PROCEDURE FOR RESOLVING OBJECTIONS AND COMPLAINTS REGARDING CUSTOMER TRANSACTIONS

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1. INTRODUCTION

CLTS Kripto Varlık Alım Satım Platformu A.Ş. (the "Company") takes transparency, trust, and customer satisfaction as the basis of the services it provides to its customers. The purpose of this Procedure is to ensure that all complaints received from customers are handled fairly, promptly, and effectively.

The Company treats customer complaints as a feedback mechanism and incorporates them into its continuous-improvement process to enhance service quality. The Board of Directors is ultimately responsible for establishing and implementing the complaints-management system.

Independence: Impartiality is essential in handling complaints, and personnel involved in the transactions that are the subject of a complaint do not participate in its review. The review and resolution are carried out by persons independent of the relevant units.

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2. SUBMISSION OF COMPLAINTS

Customers may submit their complaints through the following channels:

• The Company's official website,
• Email,
• Telephone or written application,
• Electronic communication tools (mobile application, in-platform messaging, etc.).

Complaints submitted by telephone or verbally are documented in writing by the relevant personnel.

3. RECORDING OF COMPLAINTS

Each complaint:

• Is entered into the complaints-recording system together with the date, customer information, subject, and responsible personnel,
• Is assessed to determine whether it indicates an internal-control or process failure,
• Is considered within the scope of root-cause analysis if it is recurring or similar to other complaints.

All complaint records and related documents are retained for at least 5 years.

4. RESOLUTION OF COMPLAINTS

• Initial Review: Where possible, the Operations team attempts to resolve the complaint within 2 business days.
• Independent Review: Unresolved complaints are referred, depending on their subject, to Compliance, Legal, Risk Management, Operations, IT, or other relevant units. Ultimate responsibility rests with the Compliance Officer and the General Manager/CEO.
• Acknowledgement: Receipt of every complaint is confirmed to the customer no later than within 1 week.
• Resolution Period: Complaints are resolved within 4 weeks under ordinary circumstances. In extraordinary circumstances, the customer is provided with regular updates and a final response is issued no later than within 8 weeks.
• Content of the Response: The customer is informed in writing of the measures taken to resolve the complaint and any corrective or preventive actions.

5. MONITORING AND REPORTING

• All complaints are monitored regularly by the Compliance Unit and reported to the Board of Directors.
• Root-cause analyses of complaints are performed and measures are taken to prevent recurrence.
• Findings obtained from complaints are considered for the purpose of improving internal-control and risk-management processes.

6. RECORD-KEEPING

All correspondence, documents, and records relating to complaints are retained electronically.
They are submitted to the CMB or other competent authorities where required.

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