Complaints Handling Policy and Procedure (English)

Thousand Whales Technology (BVI) Limited

Thousand Whales Technology (BVI) Limited (“TWTL”) provides an online trading platform through its website(s) www.xwhale.com to be launched from time to time (collectively known as the “Xwhale Platform”) on which its products and services are offered.

TWTL is responsible for the acts or omissions of its employees and agents in respect of the conduct of its business, and recognizes that complaints require resolution. TWTL has in place effective and transparent procedures for the reasonable and prompt handling of complaints.

TWTL is committed to delivering high quality services and welcomes customer feedback on its products, services, performance and employees as a means of monitoring and improving service delivery to customers as well as enhancing organizational effectiveness and efficiency.

TWTL is also committed to ensuring that all customer complaints are managed in a responsive, efficient and fair manner. Complainants will be treated with respect and will receive a professional level of service throughout the complaints management process.

You should file the complaint direct to your Relationship Manager who will generally be best placed to resolve your complaint in a timely and satisfactory manner.

If you are dissatisfied with the handling of your complaint you can: Email our Compliance department at Compliance@xwhale.com

It would help our investigation if you could set all the details clearly in your communication, including the following information:-
- name and address of the person or organization making the complaint, unless the Complainant wishes to complain anonymously;
- details of the complaint;
- an explanation of the reasons for the complaint; and
- description of what the Complainant considers a satisfactory outcome in relation to the complain

TWTL value all complaints and treat all complaints, including anonymous complaint, seriously and will take action to consider them further, wherever this is appropriate.

Generally, TWTL will consider anonymous complaints if there is in our discretion reasonably sufficient information in the complaint to enable us to make further enquiries. If, however, an anonymous complaint does not provide enough information to enable us to take further action, TWTL may decide not to pursue it further.

Complaints that are raised anonymously will be considered at the discretion of TTWL and will take into account the seriousness of the complaint, the credibility of the complainant and the likelihood of confirming the complaint from sources that can be verified. For the purposes of this procedure, a complaint that is made by an anonymous or unidentifiable person or by a person who cannot be contacted will be handled as if it is an anonymous complaint.

We will promptly acknowledge your complaint in writing. In this acknowledgement we will provide the name and title of the person within our firm who will handle your complaint (the ‘complaint handler’). This individual will have the authority necessary to investigate and settle the complaint and will not be the person whose actions gave rise to your complaint.

Your complaint will be investigated by the complaint handler in a competent, diligent and impartial manner. During this internal assessment stage, the complaint handler will assess the complexity, severity, urgency and of the complaint and certain calls made to TWTL may be used to assist in the investigation of any complaints. The complaint handler may also contact you for further information as they investigate your complaint.

We aim to resolve your complaints at the earliest possible opportunity. If we are able to resolve the complaint within seven business days following the day it was received, we will send you a written Summary Resolution Communication.

If further investigation is required, we will send you a letter acknowledging your complaint within seven business days following the day it was received and will continue to keep you updated on our progress. As soon as we have completed our investigations, we will send you our final response. We may take up to two months to resolve your complaint and send you our final response. However, if for any reason we are unable to resolve your complaint within this time, we will send you a written explanation and we will complete our investigation and send you a full response.

Once the complaint handler has completed their investigations, they will summarize their investigation of your complaint and confirm if your complaint is being upheld (either fully or partially) or rejected. If the complaint handler decides that your complaint should be upheld we will aim to put you back in the position you should have been in, but where this is not possible we will provide you with an offer of alternative, but fair, redress. If you accept our proposal, we will act promptly to take the actions in our offer and confirm to you when this is complete.

If the complaint handler has not responded to you within a reasonable time or if you are not satisfied with the decision, you may request the complaint handler to review the decision by providing new material information or evidence or refer the matter to other relevant regulators or relevant authorities.

The document will be reviewed every 3 years and updated whenever there is a material change in the firm’s business model or organizational structure.

The latest Update: July 2023