Complaints Policy

• GC Exchange Limited (United Kingdom)
• GC Exchange Fondsmæglerselskab A/S (Denmark)
• GC Exchange A/S (Denmark), trading as GCEX and GlobalBlock

About GlobalBlock and GCEX

GlobalBlock is a trading name of GC Exchange A/S, a company incorporated and registered in Denmark (CVR 43088777). GC Exchange A/S is authorised by the Danish Financial Supervisory Authority (FTID 45020) as a Currency Exchange and registered as a Virtual Asset Service Provider (FTID 17524) under the Danish Act on the Prevention of Money Laundering and Financing of Terrorism.
GC Exchange A/S operates under both the GCEX brand and the GlobalBlock trading name. Both form part of the GCEX Group, which also includes GC Exchange Limited in the United Kingdom and GC Exchange FZE in Dubai. All client relationships under the GlobalBlock name are therefore managed and serviced by GC Exchange A/S, under the same regulatory framework and internal governance standards applied across the GCEX Group.
GCEX does not serve retail clients. This Policy is designed specifically for professional clients. It ensures that complaints are addressed fairly, transparently, and efficiently, reflecting the complexity of the services provided to professional clients.
The Policy aligns with the regulatory requirements of MiCA, the Financial Conduct Authority’s (FCA) Dispute Resolution: Complaints sourcebook (DISP), and Article 26 of the MiFID II Delegated Regulation (EU) 2017/565, while taking into account the specific needs and expectations of professional clients.

Scope
This Policy applies to all clients of GCEX, including clients onboarded under the GlobalBlock trading name, who wish to file a complaint regarding any service related to financial or crypto-asset products provided by the Company.
It is aligned with the requirements set out in Article 71 of the MiCA Regulation (EU) 2023/1114 and the related Regulatory Technical Standards (RTS) on Complaints Handling, the FCA’s DISP rules, and Article 26 of the MiFID II Delegated Regulation (EU) 2017/565.

Complaints Definition

For the purpose of this Policy, a complaint is defined as any statement of dissatisfaction expressed by a client in relation to the provision of one or more services provided by the relevant Group Company. A complaint may relate to issues such as service delays, transaction disputes, security incidents, or any other matter that negatively impacts the client’s experience with the services provided.

Admissibility of Complaints

For a complaint to be admissible, it must meet the following conditions:
• The complaint must relate to a service provided by one of the GCEX Group companies.
• The complainant must be a registered client of GCEX (including GlobalBlock clients).
• The complaint must be filed within a reasonable timeframe after the issue occurred (typically within three months). For market exposure or trading-related matters, the complaint should be filed as soon as reasonably practicable (typically no later than the following trading day).
• The complaint must contain sufficient detail, including the nature of the issue, relevant dates, and supporting evidence.
Complaints that do not meet these criteria will be deemed inadmissible, and the complainant will be informed of the reasons for rejection in clear and understandable language.

How to File a Complaint

Complaints can be submitted through the following channels:
• Email: compliance@gc.exchange or clientservices@gc.exchange
• Complaint Form: A standard complaint form is available upon request from the Client Services Team (Annex). Use of this form is optional but recommended to ensure all necessary information is provided.

Each complaint should include:
• The complainant’s name and contact details
• A description of the complaint
• The date of the incident (if applicable)
• Supporting documentation or evidence (if available)
Complaints must be submitted in English.

Acknowledgement of Receipt and Admissibility Check

Upon receiving a complaint, GCEX will:
• Acknowledge receipt within 24 hours.
• Assess whether the complaint is admissible.
• If inadmissible, provide the complainant with reasons for rejection.
The acknowledgement will include:
• Contact details of the person or department handling the complaint.
• An indicative timeline for investigation and resolution.
• Details of any additional information required from the complainant.

Complaint Investigation Process

Once a complaint is deemed admissible:
1.    Clarification and Information Gathering: If needed, GCEX will contact the complainant for further details, ensuring no unnecessary information is requested.
2.    Investigation: The complaint will be promptly investigated, relevant records reviewed, and the appropriate departments consulted.
3.    Progress Updates: The complainant will be kept informed of the investigation’s progress, including any delays.

Decision and Response

• Response Time: GCEX aims to resolve all complaints within one month of receipt. If a delay occurs, the complainant will be informed promptly, with reasons and a revised timeline. Trading-related complaints will typically be resolved within 24 hours.
• Decision Communication: The outcome will be communicated in writing via email (or post upon request) and will include:
•    A clear explanation of the result.
•    The reasons for the decision, addressing all relevant points.
•    Information on remedies or escalation options available.

Remedies and Escalation

If a complaint is not resolved to the complainant’s satisfaction, GCEX will provide guidance on how to escalate the matter.

Referral to Relevant Authorities:
Depending on which Group Company the client has contracted with, the complainant may refer the issue to:
• The Danish Financial Supervisory Authority (Finanstilsynet / Danish FSA), or• The UK Financial Conduct Authority (FCA).
GCEX will provide details for contacting these authorities and the process for submission.

Referral to the European Securities and Markets Authority (ESMA):

If a complainant has concerns about GCEX EU entities and feels their national authority has not resolved the matter, they may escalate it to ESMA, which ensures MiCA is applied consistently across the EU.

Information on Remedies:
If the complaint is upheld, GCEX will inform the complainant of any available remedies, which may include:
• Financial compensation.
• Corrective measures or operational adjustments.
• Amendments to internal procedures to prevent recurrence.
If the complaint is not upheld, the complainant will be provided with full reasoning and information on how to pursue further review or external resolution.

Timely Notification of Remedies
The complainant will be promptly informed of any available remedies and the process for accessing them, including escalation routes. GCEX is committed to a transparent and fair resolution process.

Record-Keeping and Data Management
All complaints will be logged and tracked using a secure electronic system. Records will include:
• Complaint details and supporting documents.
• Dates of receipt, investigation, and resolution.
• Communication history.
• Actions taken in response.
Records are retained in compliance with the GDPR, UK GDPR, and applicable data protection laws for a minimum of five years.

Resources and Personnel

Complaints are managed initially by the Client Services Team and the Compliance Team, both equipped with the necessary expertise and resources. Complex or escalated complaints will be reviewed by Senior Management to ensure robust oversight.

Ongoing Monitoring and Improvement
GCEX regularly analyses complaint data to identify trends and improve service quality. This includes:
• Response times at each stage.
• Complaint categories and outcomes.
• Instances where standard response times were exceeded.
Findings are used to enhance internal controls, compliance procedures, and client experience.

Management Oversight and Review

The Compliance Team and Management Body review this Policy periodically. Complaint statistics are presented as management information and discussed at quarterly board meetings. Senior management ensures adequate resources and adherence to this Policy.
16. Publication of Complaints Procedure
This Policy, together with the standard complaint form, is available on the GCEX and GlobalBlock websites in English and can also be requested through client service channels.