Last updated: 27/09/2025

1. Overview

Scintilla Network FZE (“Scintilla”) is committed to treating clients fairly and resolving complaints promptly, transparently, and in line with the Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks.

A complaint refers to any expression of dissatisfaction relating to Scintilla’s products, services, employees, management, or performance.

2. How to File a Complaint

You may submit a complaint to Scintilla using one of the following channels:

a. By Email: contactus@scintillanetwork.com

Subject: Official Complaint

Please include your full name, registered email address, phone number, and the details of your complaint.

The complaint form template is attached.

b. By Phone: +971 (0) 4 770 0495

Monday to Friday, 8:00 am – 5:00 pm (UAE time)

Scintilla’s staff are trained to:

• acknowledge your concern and apologise for inconvenience;

• attempt to resolve the issue immediately, where feasible;

• confirm that your complaint will be formally logged and investigated;

• provide you with a timeline for follow-up and resolution

3. Complaints Process

• Acknowledgement: Scintilla will confirm receipt of your complaint within 2 business days.

• Investigation: All complaints are reviewed by the Compliance team. If an employee is the subject of the complaint, another staff member will be assigned to investigate.

• Resolution: A formal response, including findings and any remedial action, will be provided within 4 weeks of the complaint being made. In the event of extraordinary circumstances, Scintilla will provide the client an update on the status of the complaint, and explain the extraordinary circumstances delaying its resolution within four (4) weeks of the complaint being made and resolve the complaint no later than eight (8) weeks from when the complaint was made.

• Escalation: If you are unsatisfied with the resolution, you may escalate your complaint directly to VARA.

4. Complaints Relating to Token Issuance

Scintilla recognises that investors in token issuances (if applicable) may have specific concerns, including:

• whitepaper accuracy or disclosures;

• allocation, lock-ups, or distribution processes;

• redemption or settlement delays;

• governance and investor rights attached to tokens. Such complaints (if applicable) will be:

• logged in a dedicated Issuance Complaints Register;

• assessed by the Compliance Officer and escalated to the Audit, Risk and Compliance Committee for oversight;

• reported to VARA immediately if they involve misrepresentation, fraud, or disclosure failures;

• resolved within the same timelines (acknowledgement within 2 business days, resolution within 30 calendar days).

If unresolved, issuance-related complaints may also be referred to VARA or other competent UAE authorities.

5. Record Keeping and Oversight

• All complaints are recorded in a Complaints Register maintained by the Compliance Officer.

• Records are retained for at least 8 years in line with VARA Rulebooks.

6. Data Protection

Scintilla handles all complaint information in accordance with its Privacy Policy and Cookie Policy, ensuring compliance with the UAE Personal Data Protection Law (PDPL) and the VARA Rulebooks.

All personal data provided in relation to a complaint will be:

• used solely for the purpose of complaint resolution;

• stored securely in the Complaints Register;

• retained for at least 8 years in line with regulatory requirements;

• shared only with relevant authorities where required by law or regulation.

7. Our Commitment

Scintilla handles all complaints:

• Fairly – every client receives impartial treatment.

• Consistently – complaints are handled according to a defined process.

• Promptly – issues are resolved without unnecessary delay.

• Confidentially – details are treated with discretion and only shared where required by law or regulation.

8. Related Policies

Further information about Scintilla’s governance and client protection can be found in:

• Conflicts of Interest Policy

• Whistleblowing Policy

• Code of Conduct

• Best Execution Policy

• Privacy Policy

• Cookie Policy

These can be requested by email: contactus@scintillanetwork.com.

8. Contact Us

By email: contactus@scintillanetwork.com

By phone: +971 (0)4 770 0495

Complaints handling

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