TERMS OF DISPUTE RESOLUTION & CONSUMER COMPLAINTS POLICY

1. Introduction

AURUM NEO-BANK sp. z o.o., with its registered headquarters at:

Ul. Długa 29,
00-238 Warsaw,
Mazowieckie,
Republic of Poland,

operating under the trading name Polex (the “Company” or the “Platform”), provides crypto-asset exchange services in accordance with applicable European Union and Polish law, including the Markets in Crypto-Assets Regulation (“MiCA”).

This Policy establishes transparent, fair, and effective procedures for handling client complaints and resolving disputes in compliance with MiCA requirements applicable to crypto-asset service providers.

The Company is committed to:

  • Fair treatment of clients;
  • Prompt and impartial handling of complaints;
  • Transparent communication;
  • Proper documentation and supervisory reporting where required.

2. Scope

This Policy applies to:

  • All retail and professional clients of the Platform;
  • Any complaint concerning crypto-asset exchange services provided by the Company;
  • Disputes relating to transactions, account access, fees, service interruptions, or operational decisions.

The Policy applies regardless of the user’s jurisdiction, subject to mandatory local consumer protection rules.

3. Definition of a Complaint

A Complaint is any expression of dissatisfaction, whether oral or written, from a client relating to:

  • The provision of crypto-asset services;
  • The execution or non-execution of transactions;
  • Alleged financial loss;
  • Operational conduct of the Company or its staff;
  • Alleged breach of contractual obligations.

Routine support inquiries or requests for clarification do not automatically constitute formal complaints unless dissatisfaction is explicitly expressed.

4. Informal Resolution Procedure

4.1 Initial Contact

Clients are encouraged to first contact customer support at:

support@polex.io

The submission should include:

  • Full name and account details;
  • Transaction ID(s);
  • Description of the issue;
  • Supporting documentation;
  • Requested resolution.

Incomplete submissions may delay processing.

4.2 Preliminary Review

Upon receipt, the Company will:

  • Acknowledge the complaint promptly;
  • Assess the matter objectively;
  • Request additional information where necessary;
  • Attempt to resolve the issue informally.

Clients must cooperate in good faith during this process.

5. Formal Complaint Handling (MiCA-Aligned Procedure)

If the matter is not resolved informally, the client may escalate it to a Formal Complaint.

5.1 Submission of Formal Complaint

Formal complaints must be submitted in writing to:

support@polex.io

The complaint must clearly state:

  • Nature of the dispute;
  • Timeline of events;
  • Evidence;
  • Financial impact (if any);
  • Remedy sought.

5.2 Complaint Handling Principles

In accordance with MiCA standards applicable to crypto-asset service providers, the Company ensures that:

  • Complaints are handled fairly, consistently, and impartially;
  • The process is free of charge to the client;
  • Conflicts of interest are identified and mitigated;
  • The handling function is operationally independent from the business function concerned.

5.3 Investigation Process

The Company will:

  • Conduct a structured internal review;
  • Examine internal transaction logs and blockchain records;
  • Consult Compliance, Risk, Legal, and IT departments;
  • Document findings and decisions.

Where necessary, additional documents may be requested from the client.

5.4 Timeframes

The Company aims to:

  • Acknowledge complaints without undue delay;
  • Provide a substantive response within a reasonable timeframe;
  • Notify the client if additional time is required due to complexity.

If resolution cannot be completed promptly, the client will be informed of:

  • The reason for delay;
  • Expected timeline for final response.

5.5 Final Response

Upon completion of the investigation, the Company will provide:

  • A written explanation of its decision;
  • Clear reasoning;
  • Any corrective measures (if applicable);
  • Information on further escalation options.

6. Interim Protective Measures

Where necessary to prevent harm, fraud, or asset loss, the Company may implement temporary measures including:

  • Account restrictions;
  • Freezing of disputed funds;
  • Additional identity verification;
  • Enhanced transaction review.

These measures are precautionary and do not imply fault.

7. External Escalation Rights

If the client remains dissatisfied after receiving the final response, they may:

  • Seek independent legal advice;
  • Initiate arbitration in accordance with Section 9;
  • Submit a complaint to the competent supervisory authority.

Supervisory authority:

Polish Financial Supervision Authority

This Policy does not limit statutory consumer protection rights under EU or Polish law.

8. Alternative Dispute Resolution (ADR)

Where applicable under Polish consumer protection law, clients may seek alternative dispute resolution through eligible ADR bodies.

Participation in ADR shall:

  • Be voluntary unless required by law;
  • Be conducted in good faith;
  • Respect confidentiality obligations.

9. Arbitration

9.1 Initiation

If informal and formal resolution processes fail, disputes may be referred to binding arbitration by mutual agreement.

Notice must be submitted within fourteen (14) days following final response.

9.2 Conduct

Arbitration shall:

  • Be conducted in Warsaw, Poland;
  • Be governed by Polish arbitration rules;
  • Be conducted in English or Polish unless otherwise agreed.

The arbitrator’s decision shall be final and binding.

9.3 Costs

Each party bears its own legal costs.
Arbitration fees are shared equally unless determined otherwise by the arbitrator.

10. Record-Keeping

The Company maintains:

  • A complaints register;
  • Records of investigations and outcomes;
  • Documentation of corrective measures;
  • Records retained for at least five (5) years or longer if required by law.

Complaint records are made available to the Polish Financial Supervision Authority upon request.

11. Governance and Oversight

The Compliance Function:

  • Oversees complaint handling procedures;
  • Reports complaint statistics to senior management;
  • Identifies systemic risks or recurring issues;
  • Recommends operational improvements.

The Board reviews aggregated complaint data periodically as part of governance oversight.

12. Waiver of Class Actions

To the extent permitted by law, disputes shall be resolved on an individual basis.

This clause does not override mandatory consumer protection rights.

13. Amendments

The Company reserves the right to amend this Policy.

Material changes will be communicated to users.
Continued use of the Platform constitutes acceptance of updated terms.

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