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1. PURPOSE AND SCOPE OF THIS POLICY

Keytech Limited, with registration number 8430672-1, registered at CT House, Office 9A, Providence, Mahé, Seychelles (referred to in this document as the 'Company'), aims to deliver a fair, transparent and high-quality service to every client and financial consumer it deals with. The Company treats complaints as valuable feedback and undertakes to deal with each one quickly, impartially and at no cost to the person raising it.

This document (the 'Policy') sets out how the Company meets its obligations under the Financial Consumer Protection Act, 2022 (Act 6 of 2022), the Financial Consumer Protection (Complaint Handling) Regulations, 2024 (S.I. 110 of 2024), the Financial Services Authority Act, 2013, and any other sector-specific legislation the Financial Services Authority of Seychelles ('FSA') administers from time to time.

It applies to every employee, agent and third party who deals with financial consumers on the Company's behalf, and the Company will ensure each of them understands and follows its requirements.

A copy of the Complaint Form appears at the end of this Policy; it can also be downloaded from the Company's website or obtained on request.

2. LEGAL BASIS

This Policy gives effect to the following laws and regulatory instruments:

  • the Financial Consumer Protection Act, 2022 (Act 6 of 2022) (the 'FCPA'), notably sections 8, 11, 15, 16, 29, 35 and 36;
  • the Financial Consumer Protection (Complaint Handling) Regulations, 2024 (S.I. 110 of 2024), which set out requirements for acknowledgement, investigation, response deadlines, registers and reporting;
  • the Financial Services Authority Act, 2013, under which the Company must cooperate with the FSA and respond to its enquiries;
  • any sector-specific legislation, codes of conduct, guidance or directions the FSA issues from time to time.

The Company will comply at all times with its regulatory obligations on consumer protection, fair treatment and complaint handling. Where any part of this Policy conflicts with the law, the law takes precedence.

3. INTERPRETATION AND KEY TERMS

Unless the context requires otherwise, the terms below carry the meanings given to them in the FCPA and the 2024 Complaint Handling Regulations, or the meanings set out in the table below:

Term What It Means
Complaint Any expression of dissatisfaction from a financial consumer about the Company's products, services, or conduct in providing them, where the consumer expects a response or resolution (as defined under the FCPA and the Regulations).
Complainant The financial consumer, or someone properly authorised to act for them, who raises a complaint with the Company.
Financial Consumer Anyone who has obtained, or intends to obtain, financial products or services from the Company.
Financial Consumer Dispute A civil disagreement between a financial consumer and the Company concerning a product or service.
Complaints Handling Officer The individual appointed by the Company to manage and oversee the complaint-handling function (the 'CHO').
Competent Authority The FSA, in its capacity as the Competent Authority under Part B of the Schedule to the FCPA.
Frivolous Complaint A complaint with no factual or legal basis.
Vexatious Complaint A complaint made to harass or cause difficulty rather than to resolve a genuine issue.
Vulnerable Consumer A person who, because of their personal situation or prevailing market conditions, faces a heightened risk of harm or disadvantage in commercial dealings.
Holding Response An interim written update telling the complainant that their complaint has been received and that more time is needed to complete the review.
Final Response The Company's concluding written reply, stating its final position and explaining the complainant's right to escalate the matter further.

4. CORE PRINCIPLES

Under section 35 of the FCPA and the Complaint Handling Regulations, the following principles apply to the Company's handling of every complaint.

Our complaint handling will be: cost-free—we never charge a complainant for raising or pursuing a complaint; impartial—every complaint is assessed objectively, without favouritism; consistent—similar complaints receive similar treatment; timely—we work within the regulatory deadlines to resolve matters efficiently; confidential—information gathered during the process is kept strictly private; transparent—complainants are updated on progress and told the outcome; free from retaliation—no one is penalised or disadvantaged for complaining; accessible—open to all consumers, including those who are vulnerable.

Where a complainant is a vulnerable consumer, the Company will take their particular needs into account and make reasonable adjustments so they are not put at a disadvantage. Nothing in a contract can reduce or remove the Company's obligations under this Policy (section 19, FCPA).

5. ROLES, RESPONSIBILITY AND OVERSIGHT

Responsibility for receiving, investigating and responding to client complaints sits with the Complaints Handling Officer (CHO). If a complaint concerns, or is made against, the CHO personally, it is instead handled by the Representative Officer or a Senior Manager, so that it is reviewed independently.

The Company runs its complaints function as a combination of internal and outsourced support: routine intake, logging and first-level triage may be carried out by the Company's outsourced compliance service provider, but every step remains subject to the CHO's supervision and sign-off, and the CHO alone carries ultimate accountability for the function.

If the CHO cannot resolve a complaint at first instance, it is passed to Senior Management for review; Senior Management decides the Company's final position before any final response is issued to the complainant.

The Company has temporarily approved its Compliance Officer, Ms. Elsia Madeleine, as its Complaints Handling Officer. A permanent CHO will be appointed before the Company begins operating (targeted for mid-August 2026). Once appointed, the CHO's name and contact details will be published on the Company's website and shared with the FSA.

To support this, the Company will make sure that:

  • the CHO is given the authority, resources and training needed to carry out the role effectively;
  • staff who are the subject of a complaint, or who have any stake in its outcome, take no part in investigating or deciding it (section 35(3), FCPA);
  • all staff can recognise a complaint, know where to direct it, and understand this Policy;
  • agents and third parties acting for the Company are contractually held to equivalent standards, with compliance monitored (section 7, FCPA); and
  • the Board keeps oversight of the complaints framework and receives regular reporting on it (section 15(5), FCPA).

6. SUBMITTING A COMPLAINT TO THE COMPANY

Consistent with section 16(3) of the FCPA, the Company makes clear to every financial consumer how to raise a complaint. To do so, complete the Complaint Form at the back of this Policy (also available on our website) and send it through one of the channels below:

Method How It Works
Email Send your complaint by email (email address to be confirmed before the Company begins operations).
Client Portal Log in to the Company's secure client portal and submit your complaint there (details to follow before launch).
Website Complaints Form Complete the online complaints form on the Company's website (link to be published before launch).

You may write to us in English or French; complaints in any other language should be accompanied by a translation into one of these. We reserve the right not to process complaints containing offensive or abusive language.

To investigate properly, the CHO may ask for further information or documents, including updated KYC records where relevant, and complainants are expected to cooperate fully with such requests.

7. CATEGORISING COMPLAINTS

The Complaints Handling Officer shall classify each complaint upon receipt according to its nature, complexity, and potential regulatory impact. The categories of complaints that may arise include, but are not limited to:

Type of Complaint What This Covers
Service Quality Poor customer service, delayed responses, inadequate or inaccurate advice.
Transaction Execution Errors in execution of instructions, unauthorised transactions, delays.
Disclosure & Transparency Failure to provide required information, misleading or unclear communications, advertising complaints.
Fee & Charge Disputes Fees charged without prior agreement, unexplained charges, overcharging.
Contract Terms Unfair, unclear or disputed contract terms; cooling-off period disputes.
Employee Conduct Unprofessional, dishonest or inappropriate conduct by staff or agents.
Data & Confidentiality Unauthorised disclosure or misuse of consumer data (sections 29–32, FCPA).
Regulatory Compliance Alleged failure to comply with applicable laws, regulations or FSA requirements.
Vulnerable Consumer Concerns Concerns raised by or on behalf of a consumer identified as vulnerable.
Abusive or Unfair Practices Alleged prohibited acts, unfair contract terms, abusive debt recovery (sections 24–28, FCPA).
Other Any other matter giving rise to dissatisfaction in relation to the Company's products or services.

Where a complaint appears to involve a regulatory breach, fraud, or serious harm to a consumer, it is escalated straight to Senior Management.

8. OUR COMPLAINT-HANDLING PROCESS AND KEY DEADLINES

Every complaint we receive goes through the steps below. The deadlines shown are set by the Complaint Handling Regulations, 2024, and are mandatory, not discretionary.

Step Stage What Happens Deadline
1 Receipt & Registration The CHO logs the complaint in the Complaints Register, issues a unique reference number, and checks that it falls within scope (i.e., not frivolous, vexatious, or already subject to court proceedings). Immediately upon receipt
2 Acknowledgement We write to confirm receipt, share the reference number and the handling officer's name, and outline the next steps. Within 2 business days of receipt (Regulation 4)
3 Initial Assessment The CHO categorises the complaint by type and complexity and identifies whether more information is needed from the complainant. Within 5 business days of receipt
4 Investigation A full, impartial review takes place; further details may be sought from the complainant or relevant staff, and all findings are documented. Ongoing from receipt
5 Holding Response (if required) If a decision is not ready within 21 business days, we send a holding response explaining the delay and giving an expected resolution date. By day 21, if the final response is not yet possible
6 Final Response – Standard Non-complex complaints receive a final written response. Within 21 business days of receipt (target); by day 60 at the latest (Regulation)
7 Final Response – Complex For grossly complex cases, we send a written notice explaining the extension and the revised expected date. Extended to a maximum of 90 business days (Regulation)
8 Closure & Recording We record the outcome in the Register, review the root cause, and put any needed corrective action in place. Upon the issue of the final response
Important – Regulatory Timelines (Mandatory) Acknowledgement: within 2 business days of receiving the complaint. First determination / holding response: within 21 business days. Final response (standard complaint): within 60 business days from the date of submission. Final response (grossly complex complaint): extended to a maximum of 90 business days; the Company must notify the complainant in writing of the extension.

9. HOW WE CONCLUDE A COMPLAINT

Every final response is provided in writing and takes one of the following forms:

  • upheld—the Company accepts the complaint and offers appropriate redress, which may include an apology, corrective action, compensation, or a combination of these;
  • partly upheld—the Company accepts part of the complaint, offers partial redress, and explains why the remainder was not upheld;
  • goodwill gesture—redress offered as a gesture of goodwill, without formally accepting the complaint, in the interest of an amicable outcome; or
  • not upheld—the complaint is declined, with a clear explanation and the evidence behind the decision.

Whatever the outcome, every final response tells the complainant they may escalate to the FSA if unhappy with the decision, and includes the FSA's contact details (section 35(4), FCPA).

10. ESCALATION TO THE FINANCIAL SERVICES AUTHORITY (FSA)

Under section 35(4) of the FCPA and the FSA's own Complaints Handling Guidelines, a complainant who is not satisfied with the Company's final response may take the matter to the FSA. Before doing so, they must first:

  • have already submitted the complaint to the Company and allowed at least 21 business days for a decision; and
  • provide the FSA with a copy of the Company's final response (or holding response, if a final response has not yet been issued within the required period).

The FSA will only take on an escalated complaint once satisfied that the complainant has already tried to resolve matters with the Company and that this has not worked.

Please note: the FSA is a regulator, not a court—its decisions are administrative, made within the scope of the FCPA and the FSA Act. A complainant who disagrees with an FSA decision may appeal to the FSA Appeals Board within 90 days, or take legal action before the Supreme Court within 30 days (section 46, FCPA).

Financial Services Authority (FSA) – Contact Details Address: Bois de Rose Avenue, P.O. Box 991, Victoria, Mahé, Republic of Seychelles Telephone: (+248) 438 08 00 Fax: (+248) 438 08 88 Email (Complaints): [email protected] Website: https://fsaseychelles.sc/complaint-handling

11. MAINTAINING THE COMPLAINTS REGISTER

For every complaint received, the Company keeps a Complaints Register recording at least the following:

  • a unique reference number for the complaint;
  • the date the complaint was received;
  • the complainant's name, contact details and account number, where relevant;
  • the nature and category of the complaint;
  • the name of the officer handling it;
  • a summary of the investigation carried out;
  • the dates of acknowledgement, any holding response, and the final response;
  • the outcome, and any redress offered or given;
  • any corrective action taken; and
  • the date the complaint was closed.

The Complaints Register shall be maintained in a secure and accessible format and shall be made available to the FSA upon request. The register shall be used to identify complaint trends, systemic issues and areas for improvement.

12. REGULATORY REPORTING TO THE FSA

As required by section 8 of the FCPA, the Company reports to the FSA twice a year on its consumer protection activities, covering:

  • the number, type and outcome of complaints handled during the period;
  • steps taken to monitor compliance with this Policy;
  • financial education and consumer awareness initiatives carried out;
  • activities carried out by agents or third parties on the Company's behalf; and
  • how the Company monitored those agents or third parties.

The first-half report is due by 15 July; the second-half report is due by 15 January of the following year.

Any material complaint involving a regulatory breach, fraud, significant misconduct or serious consumer harm is escalated straight to Senior Management, so it can consider whether the FSA needs to be notified.

13. LEARNING FROM COMPLAINTS: ROOT CAUSE REVIEW

If a complaint points to a weakness in the Company's systems, controls, processes, products or staff conduct, the Company will:

  • carry out a root cause review to establish what really went wrong;
  • put proportionate corrective measures in place to prevent recurrence;
  • check whether other clients were affected by the same issue and, where appropriate, offer proactive remediation; and
  • report the findings and action taken to Senior Management, and to the FSA where the law requires it.

14. CONSUMER DATA PROTECTION AND CONFIDENTIALITY

All information obtained during the complaint handling process is kept strictly confidential and used only to investigate and resolve that complaint, in line with sections 29–32 and 37 of the FCPA.

The Company will:

  • keep all non-public consumer data collected during the process confidential;
  • not share complainant information with third parties unless the law, a regulatory direction, a court order, or the complainant's written consent requires or permits it;
  • maintain suitable technical, organisational and physical safeguards over complaint records; and
  • follow the FSA's confidentiality rules under section 37 of the FCPA throughout any proceedings.

Submitting a complaint means the complainant agrees that the Company may share relevant information with the FSA or other competent authorities, as far as the law requires.

15. HOW LONG WE KEEP YOUR RECORDS

In line with section 11 of the FCPA, the Company retains all complaint records—the original complaint, correspondence, investigation notes, evidence, decisions and corrective actions—for at least seven (7) years from the date the complaint is closed, or longer where the law or a regulatory direction requires it.

These records are kept securely, whether in physical or digital form, and can be produced for FSA inspection on request. Failing to meet these record-keeping requirements can attract an administrative penalty of up to SCR 50,000 under the FCPA.

16. BOARD-LEVEL GOVERNANCE

In accordance with sections 15(4) and 15(5) of the Financial Consumer Protection Act, 2022 ('FCPA'), the Board of Directors shall:

  • oversee the Company's complaints handling framework and satisfy itself that it is operating effectively, fairly, and in accordance with applicable legal and regulatory requirements;
  • receive and review complaints handling reports at least quarterly, covering complaint volumes, the nature of complaints received, significant or unresolved complaints, complaint trends, root cause analyses, and corrective or remedial actions taken;
  • ensure that the Company allocates adequate resources, systems, and appropriately trained personnel to enable the effective management and resolution of complaints;
  • oversee the implementation of appropriate remedial actions arising from complaints and monitor recurring issues to ensure that underlying causes are identified and addressed;
  • promote the fair treatment of financial consumers as an integral part of the Company's governance framework, culture, and decision-making processes; and
  • periodically review the effectiveness of the Company's complaints handling arrangements and ensure that the Complaints Handling Policy remains appropriate and up to date.

17. USEFUL INFORMATION FOR COMPLAINANTS

  • Your complaint should be clear, accurate and supported by relevant facts and documentation.
  • The Company may request additional information and/or KYC documentation during the investigation. Your full cooperation is required.
  • Complaints should be submitted as soon as reasonably practicable after the occurrence of the relevant event. The Company will make every effort to address all complaints; however, it reserves the right not to investigate complaints that are excessively outdated (generally where the event occurred more than one year before submission), having regard to the availability of relevant information.
  • Complaints that are frivolous or vexatious will not be processed. The complainant will be informed in writing.
  • The complaints handling process is provided free of charge to all complainants.
  • The complainant has the right to be informed of the outcome of their complaint and to escalate to the FSA if dissatisfied with the Company's final response.

18. STAFF TRAINING AND CONSUMER PROTECTION AWARENESS

In accordance with section 15(6) of the Financial Consumer Protection Act, 2022 ('FCPA'), the Company shall:

  • provide periodic training to relevant staff to enable them to identify, receive, escalate, and handle complaints effectively, and to ensure an appropriate understanding of consumer protection principles and applicable regulatory obligations;
  • prominently display information relating to its complaints handling and dispute resolution procedures at its business premises and on its website, in accordance with section 16(3)(b) of the FCPA;
  • make this Policy and the Company's Complaint Form readily available to consumers upon request and publish them on the Company's website; and
  • promote financial education and awareness amongst both its staff and consumers to support fair treatment of consumers and enhance understanding of the Company's products, services, and complaints handling procedures.

19. POLICY REVIEW

The Complaints Handling Officer shall review this Policy at least annually, and more frequently where there is a material change in applicable legislation, regulatory requirements, guidance issued by the Financial Services Authority, or the Company's operations that may affect its complaints handling framework.

Any material amendments to this Policy shall be submitted to the Board of Directors for review and approval prior to implementation. Once approved, the updated Policy shall be communicated to all relevant staff and, where appropriate, made available to financial consumers.

The Company shall maintain a version control register for this Policy, and all superseded versions shall be retained for a minimum period of seven (7) years in accordance with the Company's record retention obligations.