Complaints Policy

Objective

MiFinity Malta Limited, herein after referred to as ‘MML’  or ‘the Company’ is required to have in place a clear and effective procedures for the reasonable and prompt handling of complaints, in compliance with the applicable regulation.

Each Client is important to MiFinity, and for this reason it believes that one should have the right to a fair, swift and courteous service at all times. This document sets out the complaints handling procedures that MiFinity will follow if an individual makes a formal complaint.

Scope

The scope of this document is there so that the MiFinity employees within the Customer Service department understand the importance and have the knowledge on how to handle any compliant that comes there way.

This document will assist them with a Step by Step guideline.

Definition of a Complaint

For the purpose of regulatory requirements on complaints procedures, a complaint is any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the financial services provider provision of, or failure to provide, a financial services activity. A complaint must involve an allegation that the complainant has suffered, or may suffer, financial loss, material inconvenience or material distress.

All complaints submitted by clients or prospective clients shall be handled free of charge. The Company will not impose any fees or charges in relation to the receipt, assessment, or resolution of complaints, ensuring that individuals are able to raise concerns in an accessible, fair, and transparent manner without financial barriers.

Procedure to Make a Complaint

MiFinity Malta Limited is committed to handling complaints promptly, fairly, consistently and transparently. If you are dissatisfied with any service or crypto-asset service provided by MiFinity Malta Limited, you may submit a complaint to us free of charge using any of the channels set out below.

You may submit your complaint by electronic means or in paper form. Complaints may be submitted using the standard complaint form made available by MiFinity Malta Limited, but you are not required to use that form and your complaint will not be rejected solely because it was submitted in another format.

Available complaint channels

Online: Please complete the online complaint form available at: https://mifinity.com/legal/complaints-policy-eea/
By email: Please send your complaint to: [email protected]
By post: LEVEL 3 (SUITE 2507), TOWER BUSINESS CENTRE, TOWER STREET, SWATAR BIRKIRKARA MALTA BKR 4013

By telephone: You may also raise your complaint by phone using +356 2034 5600

Where a complaint is raised orally, MiFinity Malta Limited may ask you to confirm relevant details in writing so that the complaint can be investigated efficiently and fairly.

MiFinity Malta Limited makes available the standard complaint form / harmonised template for filing complaints at: https://mifinity.com/legal/complaints-policy-eea/

You may use this form if you wish, but complaints submitted without using the standard form will still be accepted provided they contain sufficient information for us to assess and handle them.

Information to include in your complaint
To help us investigate your complaint as quickly and effectively as possible, please include the following information where available:

• your full name,
• your registered account jurisdiction,
• your email address,
• your telephone number,
• the topic of your complaint,
• the date on which the issue occurred,
• a description of the complaint,
• and any supporting documents or evidence you would like us to consider.

The current MiFinity webpage already requests substantially this information through its online complaint form. For more information, this Policy includes this form in Annex I.

If we require further information in order to investigate your complaint properly, we may contact you without undue delay to request clarification or supporting material.

Languages

You may submit your complaint in:

• the English language, or
• the official language(s) of MiFinity Malta Limited’s home Member State (Maltese).

Once we receive your complaint, MiFinity Malta Limited will acknowledge receipt without undue delay. For more information, this Policy includes Annex II. In that acknowledgement, we will also:

• confirm whether the complaint is being reviewed as admissible;
• provide the contact details of the person or department responsible for handling your complaint and answering any queries; and
• provide an indicative timeframe within which you can expect a decision.

If MiFinity Malta Limited concludes that your complaint is inadmissible, we will inform you of that decision without undue delay and explain the reasons for the inadmissibility.

How we investigate complaints

MiFinity Malta Limited investigates complaints in a timely and fair manner. We assess whether the complaint is clear, complete and contains the information necessary for handling it, gather and review the relevant information, and consider all points raised by the complainant before reaching a decision. Complaints are handled in a way designed to ensure fairness, consistency and equal treatment.

MiFinity Malta Limited dedicates adequate resources to complaints handling. The resources responsible for complaints handling have access to the information necessary to investigate complaints properly, and the person in charge of complaints handling reports directly to the management body on the implementation and effectiveness of the complaints-handling procedures and the measures taken or to be taken in response to complaints.

When you will receive a decision

MiFinity Malta Limited will communicate its decision on your complaint without undue delay, as soon as possible within the indicative timeframe previously provided to you, and in any event within two months from the date on which MiFinity Malta Limited received your complaint.

If, in an exceptional situation, MiFinity Malta Limited is unable to provide a decision within that timeframe, MiFinity Malta Limited will inform you without undue delay of:

• the reasons for the delay; and 
• the date by which you can expect the decision.

In its decision, MiFinity Malta Limited will address the points raised in your complaint and explain the reasons for the outcome of the investigation. Where the decision does not fully satisfy your complaint, the response will also set out information on the remedies available to you.

How we communicate with you

MiFinity Malta Limited will communicate with you in clear and plain language that is easy to understand. Our communications regarding acknowledgement, requests for additional information, investigation progress and the final decision will be made in writing by electronic means, or, if you request it, in paper form. Communicatiions will be provided in the language in which you filed your complaint, provided that the language is one of the languages accepted by MiFinity Malta Limited for complaints.

Records and oversight

MiFinity Malta Limited keeps a record of all complaints received and of the measures taken in response to those complaints. Complaints data is used to support consistent handling, identify recurring issues, improve client outcomes and strengthen internal controls. The management body receives reporting on complaints handling and the effectiveness of the complaints-handling procedures.

Optional additional remedies section for the webpage

If you are dissatisfied with MiFinity Malta Limited’s final response, or if MiFinity Malta Limited does not provide a final response within the timeframes described above, you may have the right to refer your complaint to the relevant competent authority or other available dispute resolution or redress mechanism, depending on the nature of the service and your location. MiFinity Malta Limited should complete this section with the relevant external escalation details applicable to its EEA complaints framework.

Course of Action Once a Complaint is Received

The Company has established formal complaints-handling procedures that ensure complaints are investigated, responded to and, where appropriate, remedied within reasonable and clearly defined timeframes. The timelines are designed to ensure prompt, fair and consistent treatment of complainants while allowing sufficient time for a thorough investigation of the issues raised.
Upon receipt of a complaint, the Company records the complaint in its Complaints Register and provides an acknowledgement of receipt to the complainant within five (5) business days. The acknowledgement confirms receipt of the complaint, provides the complaint reference number, outlines the complaints-handling process and identifies the contact details through which the complainant may obtain updates regarding the progress of the investigation.
Following acknowledgement, the complaint is assessed and assigned to an appropriately qualified complaints handler. An initial review is performed to determine the nature, complexity and potential impact of the complaint and to identify any immediate remedial actions that may be required.
The Company aims to complete its investigation and issue a substantive response to the complainant within fifteen (15) business days from receipt of the complaint. The response will set out:

• the findings of the investigation;
• the Company ‘s assessment of the issues raised;
• any corrective or remedial measures proposed;
• details of any redress offered, where applicable;
• information regarding further escalation options available to the complainant

Where the nature, complexity or circumstances of the complaint prevent the Company from providing a final response within fifteen (15) business days, The Company will inform the complainant before the expiry of that period, explaining the reasons for the delay and providing an expected timeframe for completion of the investigation. In these situations, the provider must exercise prudence and foresight and:

1.  inform the customer of this and of the reasons for the delay; and
2. provide an indication as to when a Final Decision is likely to be provided.

In all circumstances, the Company seeks to provide a final response within thirty-five (35) business days from receipt of the complaint. Where additional time is exceptionally required due to factors outside the Company’s control, the complainant will be kept informed of the progress of the investigation and the reasons for the delay.
The complainant must also be informed that s/he has a right to complain to the Office of the Arbiter for Financial Services (OAFS). Mailing and electronic addresses, and contact numbers of the OAFS should be provided, in accordance with Chapter 7 of this Policy.
In the event that the Customer decides to escalate the case to the OAFS, MiFinity has 20 calendar days from date of delivery of a complaint to submit its response to the OAFS. Replies may be submitted by registered mail or email, as applicable. Failure to submit a reply (on time or none at all) would likely render the provider contumacious and the Arbiter may decree inadmissible any late submission of such a response.
Where a complaint is upheld, in whole or in part, the Company will implement any agreed corrective or remedial measures without undue delay following the issuance of the final decision. Such measures may include correction of operational errors, reimbursement of fees, compensation where appropriate, amendments to internal procedures, staff training, or other actions necessary to address the root cause of the complaint and prevent recurrence.

Investigation of a Complaint

MiFinity will investigate the complaint fairly, consistently and promptly, and determine whether the complaint should be upheld, and (if appropriate) determine remedial action and / or redress. MiFinity will set out our conclusions in a final response to the individual filing the complaint. The Final Decision should include the following:

1.  include a short description of the complaint and of the outcome of the provider’s investigation;
2. set out the provider’s final view on the issues raised in the complaint; and
3. include details of any redress that is being offered, if considered appropriate.

In case MiFinity decides that redress is appropriate, the company will aim to provide the individual with fair compensation for any acts or omissions for which the company is responsible. If the individual accepts the companies offer, the company will promptly provide the compensation to the individual.
Course of Action if Complaint is not satisfaction
If you are dissatisfied with MiFinity Malta Limited’s final response, or if MiFinity Malta Limited does not provide a final response within the timeframes described above, you may have the right to refer your complaint to the relevant competent authority or other available dispute resolution or redress mechanism, depending on the nature of the service and your location. MiFinity Malta Limited should complete this section with the relevant external escalation details applicable to its EEA complaints framework.

The client has the right to refer their complaint to the Office of the Arbiter for Financial Services (OAFS). The Final Decision issued by the Company shall include clear information on this right, in accordance with Chapter 5 of this Policy, including details on how and where the complaint may be escalated to the OAFS.
Office of the Arbiter for Financial Services

N/S in Regional Road, Msida MSD 1920, Malta
[email protected]
+356 2124 9245 / +356 7921 996

Recording of Complaints

A Complaints Register is kept and updated by the Customer Service Manager and the Compliance Function. The Customer Service Manager shallstore this information in line with MiFinity’s GDPR policy. The register shall contain information about the customer and the case, this also includes information regarding to the escalation of the case to the OAFS and the Final Decision, in the event that the customer used that option.
All personal data collected in connection with your complaint will be processed in accordance with applicable data protection law and MiFinity Malta Limited’s privacy notice. The current MiFinity webpage already includes a privacy statement referring to the GDPR and the applicable privacy framework, and that statement should be retained or updated as appropriate on the revised page.

Monitoring and Review

The Complaints Manager will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. The Compliance Function, acting as a Second Line of Defence, performs regular oversight of the Complaints Register to ensure accuracy, completeness, and adherence to MFSA‑mandated timelines. While no fixed frequency is prescribed by regulation, the Register is reviewed periodically and at least quarterly for reporting to Senior Management and the Board, in line with good governance and supervisory expectations.

The Compliance Function monitors adherence to these timelines through periodic reviews of the Complaints Register and escalates overdue or high-risk complaints to senior management. Complaints handling metrics, including response times, resolution times and outstanding complaints, are reported periodically to senior management and the Board to ensure effective oversight of the complaints-handling framework.

This policy does not form part of any employee’s contract of employment and it may be amended at any time however it is a requirement that this policy is read by each employee and acknowledged as being understood.