3.1 Lexim may receive Customer Complaints through any of the channels set out at Clause 3.5(a) below. As such, Lexim provides its clients with multiple channels for submitting complaints and ensures that these channels are easily accessible.

3.2 Verification of Customer identity: The Complaint Handling Team will request the user ID, registered name, date of birth, and email address to verify the identity of the Customer, or correspond directly with the Customer using their registered email.

3.3 Lexim will take reasonable steps to identify and remedy any recurring or systemic problems arising from complaints. This includes:
(a) Conducting a thorough investigation to determine the root cause of the issue, distinguishing between Customer errors and errors attributable to Lexim as the service provider;
(b) Analysing the causes of complaints to identify common root causes that may affect not only the specific issue raised but also other services, products, or processes, including those related to virtual assets activities;
(c) Once the investigation is complete, Lexim will promptly address the issue through an appropriate resolution method, correcting any identified root causes to prevent recurrence; and
(d) If the complaint is determined to be invalid due to a lack of evidence or is found to result from a Customer’s error, Lexim will communicate this decision clearly to the Customer, providing a detailed explanation of the findings.

3.4 Monitoring and Recognition of Complaints:
(a) Complaints may be submitted through channels mentioned in section 3.1 of this Policy.
(b) Lexim will monitor these channels regularly to ensure the timely recognition of complaints.
(c) A complaint will be recognised when received through any of the designated channels and acknowledged by the Complaint Handling Team.
(d) Lexim will maintain a record (as per Clauses 3.5(h) and 3.14 of this Policy) of all complaints received, including their submission medium, date of receipt, and acknowledgment timeline, to ensure proper tracking and resolution.

3.5 Handling Customer Complaints:
(a) Customers may submit complaints through any of the following channels:
     i. Email: support@lexim.gold;
     ii. Telephone: +971 (0)4 375 1987;
     iii. Online Complaint Form: https://lexim.digital/submit-complaints;
     iv. Post: Lexim Trading DMCC, Mazaya Business Avenue 2201, Tower AA1, First Al Khail St Jumeirah Lake Towers, Dubai, United Arab Emirates.

(b) All complaint channels are actively monitored during Lexim’s business hours (Monday to Friday, 08:00–18:00 GST) by Lexim's Complaints Handling Team.
(c) Lexim's Complaints Handling Team will acknowledge all complaints submitted through the channels in Clause 3.5(a) above within one (1) week of receipt. Acknowledgement of a customer's complaint will be made in writing via email. A complaint is deemed formally made once Lexim has issued such acknowledgment.
(d) The Complaints Handling Team will review and assess each complaint with due care, ensuring that the customer’s concerns are understood.
(e) Lexim will aim to resolve all customer complaints within four (4) weeks from its acknowledgement of the complaint.
(f) If Lexim is unable to resolve a complaint within four (4) weeks from its acknowledgement of the complaint, the Complaints Handling Team will provide the customer with an update on the status of their complaint and explain the reasons for the delay. In such cases, Lexim will ensure the complaint is resolved no later than eight (8) weeks from the date of acknowledgment.
(g) Lexim will aim to address complaints involving third-party entities (such as banks or payment vendors) within the timeframes set out above. Further detail on how Lexim will manage such complaints can be found in Clause 3.15 below.
(h) All complaints received via the channels in Clause 3.5(a) above are promptly logged and tracked in Lexim’s internal complaints management system. This system records the time of receipt, channel of submission, acknowledgment, actions taken, and resolution status to ensure effective monitoring and follow-up.
(i) In the event that a Customer chooses to pursue legal action through litigation or other formal legal proceedings regarding the subject matter of their Complaint, Lexim will suspend the internal Complaints handling process for that particular Complaint.
i. Upon receiving notification or evidence that the Customer has initiated litigation, the Company will promptly inform the customer that the internal Complaints process is suspended.
ii. The Complaints handling process may be reinstated if both parties agree to withdraw from or resolve the legal proceedings, allowing the matter to continue through the internal resolution process.
iii. Where appropriate, Lexim may suggest alternative dispute resolution mechanisms (e.g., mediation) to the Customer, even during litigation, in an attempt to reach an amicable resolution.
iv. In cases where a serious Complaint is upheld and deemed to have regulatory implications, Lexim may promptly notify the appropriate regulatory authority in accordance with applicable legal and regulatory requirements. This notification may occur if the nature of the Complaint suggests a potential breach of regulatory obligations, or where regulatory reporting is otherwise required.

3.6 Service Level Agreement ("SLA"):
(a) Acknowledge and respond to all Complaints within one (1) week; and
(b) Resolve Complaints within four (4) weeks, with the option of an eight (8) weeks resolution timeline in extraordinary circumstances, accompanied by updates to the Customer.

3.7 Service Guarantee:
(a) The Complaint Handling Team will send an email to confirm the Complaint’s resolution within seventy-two (72) hours since the last email was sent;
(b) If the problem persists, the Complaint Handling Team will send a reminder email within 72 hours since the first reminder email was sent; and
(c) If no further communication is received, the Complaint will be considered resolved, and the Customer will be advised to open a new email for future Complaints.

3.8 Contact Information: The Complaints Handling Policy and Lexim's website clearly state Lexim's contact information, including phone number, email address, and postal address.

3.9 Document Review:
(a) The board of directors will periodically review on the Complaint handling processes to ensure their effectiveness and compliance with the Policy and applicable regulations.
(b) The outcomes of investigations will be documented and communicated to relevant stakeholders, including affected Customers, management, and the board. If necessary, appropriate actions will be taken based on investigation findings, including process improvements.
(c) Senior management will conduct and document an annual assessment of the complaint handling framework’s effectiveness, and provide an attestation to VARA confirming compliance with Part III of the Market Conduct Rulebook.

3.10 Compliance with Regulations: Comply with all relevant laws and regulations related to Customer Complaints, including any requirements to report Complaints to regulatory bodies or other authorities. Lexim will notify the appropriate regulatory authority without delay and no later than five (5) business days from identifying a notifiable Complaint.

3.11 Confidentiality: Treat all Customer Complaints and related information with the utmost confidentiality, following Lexim's Privacy Policy and applicable laws and regulations.

3.12 Training and Development: Provide ongoing training and development for the Complaint Handling Team and the Complaint Handling Officer to enhance their skills and knowledge in effectively handling Customer Complaints and improving Lexim's service systems.

3.13 Continuous Improvement: Commit to continuously improving the Complaint Handling procedure and service systems to achieve the highest level of Customer satisfaction.

3.14 As noted in Clause 3.5(g), Lexim shall keep a record of:
(a) all complaints received from their clients;
(b) all measures they have taken in response to complaints; and
(c) the resolution of all complaints,

    in its internal complaints management system.

3.15 Handling Complaints Involving Third-Party Entities:
(a) Complaint Handling Team will receive and acknowledge Complaints involving third-party entities on behalf of the Customer;
(b) Promptly communicate and liaise with the relevant third-party entity to address the Complaint;
(c) Ensure timely updates on the progress and resolution of the Complaint to the Customer; and
(d) Maintain oversight and accountability for the handling and resolving of Complaints involving third-party entities in compliance with applicable regulations and laws.
(e) Where the provision of services relating to virtual assets activities involves any third-party entities, Lexim shall remain responsible for the resolution of such complaints, ensuring that customers receive a fair and timely resolution.