Complaints Handling Policy

Seapoint Finance Limited

July 2025

1. Overview

Seapoint Finance Limited and Seapoint Finance UK Limited (collectively, ‘Seapoint’, ‘we’, the ‘Company’) and all its entities and subsidiaries expect our full or part-time employees, contractors, board members, officers and other senior managers (‘Employees’) to maintain the highest standards of ethics and compliance with applicable laws and rules. We are committed to addressing the needs and concerns of our customers. By this, we mean the entity or person who registered with Seapoint and is listed as an account opener or holder (‘Customer’), or a prospective Customer.

This Complaints Handling Policy (the ‘Policy’) outlines our handling of complaints made against Seapoint Finance Limited. This Policy should be read in conjunction with the Seapoint contract for the United Kingdom (‘UK’) or your applicable European Economic Area (‘EEA’) country.

Seapoint values the information and feedback it receives through the complaints process and is committed to investing in continuous improvements. We are committed to ensuring that all customers, including those who may be in vulnerable circumstances, receive fair treatment and appropriate support throughout the complaints process.

2. What is a complaint?

For the purposes of this Policy, Seapoint’s definition of a complaint aligns with the legal definitions used in the UK or Ireland:

For Customers in the UK, as defined in the Dispute Resolution: Complaints Sourcebook or DISP by the Financial Conduct Authority:

Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, claims management service or a redress determination, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.

Complaints that satisfy the above and following clause both are ‘EMD complaints’. The definition of an EMD complaint is defined under the European Union’s (‘EU’) Electronic Money Directive or ‘EMD’, implemented in the UK by the Electronic Money Regulations 2011. It states that, in addition to the above, an EMD complaint must also be:

concerning the rights and obligations arising under Part 5 of the Electronic Money Regulations.

Part 5 of the Electronic Money Regulations 2011 are in regards to the issuance and redeemability of electronic money.

For Customers in Ireland and the EEA, as defined under the Irish Consumer Protection Code (CPC):

An expression of grievance or dissatisfaction by a consumer, either orally or in writing, in connection with: a) the provision or the offer of the provision of a product or service to a consumer by a regulated entity; or b) the failure or refusal of a regulated entity to provide a product or service to a consumer.

Seapoint’s Customers are considered consumers, as per the above definitions. Seapoint notes that complaints may be in written or verbal format, but encourages Customers to make any complaint in writing.

For MiFID Complaints (Investment Services), as defined in the FCA's Dispute Resolution: Complaints Sourcebook (DISP):

• Any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of, a person about the provision of, or failure to provide a financial service, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.

MiFID complaints relate to investment services provided by Seapoint Finance UK Investments Limited in connection with WealthKernel Limited, who acts as our Principal Firm for these services.

3. When is it too late to complain?

Complaints should be made:

• United Kingdom: within the time limits for referral to the Financial Ombudsman Service, which is more than six (6) years following the conduct or incident resulting in your complaint, or more than three (3) years following when you realized or should have realized there was a problem. Seapoint will also reject any complaints that arise more than six months following a final response related to the same complaint from Seapoint.

• Ireland and the EEA: within the time limits for referral to the Financial Services and Pensions Ombudsman, which is more than six (6) years after the conduct or incident resulting in your complaint.

Otherwise, Seapoint is within its rights to reject the complaint without further review. However, you will still receive a response that explains why this course of action was taken. Complaints that may be rejected include those received more than six years after the conduct or incident resulting in your complaint.

4. What is not a complaint?

Seapoint may receive negative feedback that does not require a resolution or a formal response, and is not covered by this Policy. Seapoint values this feedback even if we cannot respond in all instances.

Where you have feedback that you feel is not covered by this Policy, please consider sharing that with Seapoint via support@seapoint.co.

5. The Complainant

A ‘Complainant’ for the purposes of this Policy is a Seapoint Customer or prospective Customer. This Policy does not cover complaints brought by entities or persons that are not Seapoint Customers or prospective Customers, including those who make payments to you. In the event that Seapoint receives a complaint from one of your customers, who is not also a Seapoint Customer, we will follow our normal support process.

6. How to make a complaint

To make a complaint, submit a written complaint to complaints@seapoint.co.

For UK customers, complaints can also be sent via mail to:

1st Floor 8 Bridle Close

Kingston Upon Thames

London, United Kingdom

KT1 2JW

For Irish customers, complaints can also be sent via mail to:

6 Mount Street Upper,

Dublin, D02 VF44

Ireland

Please ensure your complaint includes the following details:

• Name of Complainant

• Contact details

• Seapoint Customer details, to include account number (where relevant)

• The nature of the complaint, to include when the conduct or incident occurred; and

• Copies of any documentation that supports the complaint.

7. Complaint process

Seapoint will carefully consider your complaint, investigating the conduct or incident while taking into account all relevant factors, before providing a response.

If Seapoint considers that the information received does not qualify as a complaint, Seapoint may close the complaint with a final response detailing reasons for the complaint’s rejection. An example would be that the conduct or incident was identified to be an error on the part of the Customer, or that the information otherwise fails to meet the parameters of a complaint.

Similarly, we may find that another party is responsible for the conduct or incident. In such a case, Seapoint will redirect a Complainant to that party but will not share the complaint directly.

7.1. When you will receive a response

After receiving your complaint, Seapoint will:

For EMD Complaints (E-Money Services)

• Acknowledge your complaint promptly and within five (5) business days of Seapoint’s receipt of the complaint;

• Provide a point of contact in relation to the complaint;

• Provide a final response within 15 business days of Seapoint’s receipt of the complaint.

• In exceptional circumstances, where we are unable to reach a final conclusion within 15 business days, Seapoint will respond with a rationale and indication as to when a final response can be expected, which will be within 35 business days of Seapoint receiving the complaint.

• When we have completed our investigation, we will issue our final response within five (5) business days. This may mean that, in exceptional circumstances, a final response will be received up to 40 business days from Seapoint receiving the complaint.

This reflects the shorter timelines required under the EU’s Payment Services Directive, as implemented in the UK by the Payment Services Regulations 2017, for EMD complaints. Seapoint observes the shorter timelines for all complaints.

For MiFID Complaints (Investment Services):

• Acknowledgement: We will acknowledge your complaint within five (5) business days of receipt and inform you who is handling your complaint. *

• Summary Resolution: Where possible, we will attempt to resolve your complaint within three (3) business days. If resolved within this timeframe, you will receive a summary resolution communication instead of a separate final response.

• Investigation and Final Response: If we cannot resolve your complaint within three business days, we will send you a final response within eight (8) weeks of receiving your complaint, outlining our investigation and outcome.

• Extended Investigation: If your complaint is complex and we cannot reach an outcome within eight weeks, we will inform you of the reasons for the delay and when you can expect our detailed response.

For MiFID complaints, we will notify our Principal Firm, WealthKernel Limited, providing at minimum: the customer's name, address and contact details; details of any third parties linked to the complaint; the reason for the complaint; and any redress requested by the customer.

Seapoint does note that for non-EMD complaints it may issue a final complaint up to eight weeks following the receipt of a complaint, but this exception requires confirmation of applicability and approval by Seapoint’s Compliance Team.

7.2 Our final response

Prior to our final response, Seapoint may seek additional information from you that will support us in making a final conclusion.

Seapoint’s final response will be in writing and via email, with the exception of responses received via post (which will be responded to via post).

Seapoint’s final response will:

• Accept the complaint and, where appropriate, offer redress or remedial action; or

• Offer redress or remedial action without accepting the complaint; or

• Explain Seapoint’s rationale in the event that we reject the complaint.

Where Seapoint offers redress or remedial action, Seapoint will deliver on this offer promptly.

If Seapoint does not receive a reply to its final response, or if you indicate you accept the final response, Seapoint will consider the complaint resolved and closed.

7.4. Referral to the Ombudsman

As part of our final response, Seapoint will also provide you with details for the appropriate Ombudsman. An Ombudsman is a program under which certain disputes may be resolved quickly and with minimum formality by an independent person.

• UK: Financial Ombudsman Service
  • www.financial-ombudsman.org.uk/

• Ireland: Financial Services and Pensions Ombudsman
  • https://www.fspo.ie/
  • Address: Lincoln House, Lincoln Place, Dublin 2,D02 VH29
  • Phone:+353 1 567 7000
  • Email: info@fspo.ie

Please note that you are expected to engage with us first and support us in issuing a final response before you seek the support of an Ombudsman.

The UK’s Financial Ombudsman Service notes, for example, that “You should give the financial business you’re unhappy with a chance to sort things out before bringing your complaint to us.” Similarly, Ireland’s Financial Services and Pensions Ombudsman notes that “Before bringing your complaint to the FSPO, you must give your provider a chance to sort out the problem.”

In the result that you are still not satisfied, you can follow the steps provided by your relevant Ombudsman above.

For MiFID Complaints

If you are dissatisfied with our final response, or if we have been unable to resolve your complaint within eight weeks, you have the right to refer your complaint to the Financial Ombudsman Service free of charge within six (6) months from when you receive our response. You can contact them at: -

• Email: complaint.info@financial-ombudsman.org.uk

• Phone: 0800 023 4567

• Post: Financial Ombudsman Service, Exchange Tower, London, E14 9SR

• Website: www.financial-ombudsman.org.uk/

Principal Firm Information:

For complaints relating to investment services, WealthKernel Limited acts as our Principal Firm. You can view their complaints policy at: https://www.wealthkernel.com/complaints

8. Record retention

Complaints and records associated with each accepted and rejected complaint are kept for a minimum of five (5) years in accordance with Seapoint's record retention policy.

For MiFID complaints, Seapoint complies fully with the FCA's Complaints Record Rule under DISP, maintaining comprehensive records including the subject matter of each complaint, how the complaint was dealt with, whether the complaint was upheld or rejected, and details of any redress or remedial action taken.

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