Complaints Policy

Apexx Capital is the trading name of Veltrix Global Ltd., an international business company incorporated under the laws of the Republic of the Marshall Islands.

• Company Name: Veltrix Global Ltd.
• Trading Name: Apexx Capital
• Registration Number: 139285
• Registered Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960
• Registered Agent: The Trust Company of the Marshall Islands, Inc.
• Website: apexx-capital.com
• Support Email: support@apexx-capital.com

For the purposes of this Complaints Policy, the terms "Company," "Apexx Capital," "we," "us," or "our" refer to Veltrix Global Ltd., operating under the trading name Apexx Capital.

The terms "Client," "you," "your," or "user" refer to any person or legal entity that accesses the website, opens an account, uses the platform, submits a complaint, or otherwise uses the services.

The purpose of this Complaints Policy is to provide a clear process for clients to submit complaints and for Apexx Capital to review and respond to complaints in a fair, consistent, and timely manner.

This Policy is designed to:

• Provide a clear complaint submission process
• Ensure complaints are recorded and reviewed
• Allow clients to explain their concerns
• Support fair internal investigation
• Provide written responses where appropriate
• Maintain records of complaints
• Improve internal procedures where necessary
• Support transparency in client communications

A complaint is any expression of dissatisfaction made by a client or prospective client relating to the services, website, client area, trading platform, account handling, payments, withdrawals, verification, trading conditions, communications, or conduct of Apexx Capital.

A complaint may relate to, among other things:

• Account opening
• Verification or KYC review
• Deposits
• Withdrawals
• Payment delays
• Trading platform access
• Platform performance
• Order execution
• Pricing or spreads
• Swaps or fees
• Account restrictions
• Account closure
• Customer support
• Marketing communications
• Terms and policies
• Risk disclosures
• Data handling
• Any other service-related issue

A general question, request for information, technical support request, or account service request may not be treated as a formal complaint unless it clearly expresses dissatisfaction or requests complaint handling.

Clients may submit complaints by email.

Complaints Email: support@apexx-capital.com

The subject line should include the word:

Complaint

Clients are encouraged to provide as much detail as possible so that the Company can review the matter properly.

To help us investigate a complaint, the Client should include:

• Full name
• Registered email address
• Account number, if available
• Phone number
• Country of residence
• Date of complaint
• Description of the issue
• Relevant dates and times
• Relevant transaction IDs
• Relevant trade IDs or order numbers
• Deposit or withdrawal references
• Screenshots, where applicable
• Copies of relevant communications
• Documents supporting the complaint
• The outcome or resolution requested

If the Client does not provide enough information, Apexx Capital may request additional details before proceeding with the review.

Failure to provide requested information may delay the complaint review.

Apexx Capital will aim to acknowledge receipt of a complaint within 5 business days after receiving it.

The acknowledgement may be sent by email or another appropriate communication method.

The acknowledgement may include:

• Confirmation that the complaint has been received
• A summary of the complaint
• A request for additional information, if required
• An estimated response timeframe
• The contact point handling the complaint

If a complaint can be resolved quickly, the Company may provide a final response without sending a separate acknowledgement.

After receiving a complaint, Apexx Capital may conduct an initial review to determine:

• Whether the matter is a complaint
• Whether the complaint relates to Apexx Capital
• Whether the complainant is a client or authorised representative
• Whether additional documents or information are required
• Whether urgent action is required
• Which internal team or person should review the matter
• Whether the matter involves compliance, AML, payment, legal, trading, platform, or support issues

If the complaint does not relate to Apexx Capital or cannot be reviewed due to lack of information, the Company may notify the Client accordingly.

Apexx Capital may investigate complaints by reviewing relevant information, including:

• Client account records
• KYC and verification records
• Deposit and withdrawal records
• Trading history
• Order logs
• Platform logs
• Pricing data
• Payment provider records
• Support communications
• Email records
• Phone or chat records
• Internal notes
• Relevant policies and terms
• Third-party provider information
• Any documents submitted by the Client

The Company may contact the Client during the investigation to request additional information or clarification.

The Company may also contact third-party service providers, payment processors, platform providers, compliance providers, or other relevant parties where necessary.

Apexx Capital will aim to provide a final written response within 30 business days after receiving a complete complaint.

A complaint is considered complete when the Company has received enough information to review the matter properly.

Some complaints may require more time due to:

• Complex trading issues
• Payment provider reviews
• Banking delays
• AML or KYC reviews
• Third-party platform checks
• Technical investigations
• Legal review
• Multiple transactions
• Missing documents
• Disputed facts
• Security concerns
• Fraud or chargeback reviews
• Market data or execution analysis

If the Company cannot provide a final response within 30 business days, it may notify the Client of the delay and provide an estimated response timeframe.

The Company will aim to provide a final response within 60 calendar days for complex complaints where reasonably possible.

A final response may include:

• A summary of the complaint
• The Company's understanding of the issue
• The information reviewed
• The Company's findings
• Whether the complaint is accepted, partially accepted, or rejected
• Any proposed corrective action
• Any proposed goodwill adjustment, if applicable
• Any explanation of relevant terms, policies, or trading conditions
• Any next steps available to the Client

The final response will be provided in writing, usually by email.

Apexx Capital may reject a complaint where it determines that the complaint is unsupported, incorrect, outside the Company's responsibility, inconsistent with the Terms and Conditions, or not justified based on available records.

Depending on the complaint and the investigation, Apexx Capital may take one or more of the following actions:

• Provide an explanation
• Correct an administrative error
• Update account information
• Request additional documents
• Escalate the matter internally
• Improve internal procedures
• Provide technical guidance
• Reprocess a request where appropriate
• Adjust fees where justified
• Correct a transaction affected by manifest error
• Make a goodwill adjustment where appropriate
• Reject the complaint
• Close the complaint file

Any goodwill adjustment made by the Company is not an admission of liability unless expressly stated in writing.

Certain complaints may be treated as urgent where they involve:

• Suspected unauthorised account access
• Payment fraud
• Identity theft
• Security concerns
• Incorrect personal data affecting account access
• Time-sensitive platform access issues
• Potentially serious operational error
• Legal or compliance risk

Apexx Capital may prioritise urgent complaints based on internal assessment.

The Client should clearly mark urgent complaints in the subject line and explain why urgent handling is required.

Submitting a complaint does not automatically suspend the Client's trading obligations, payment obligations, margin obligations, open positions, account responsibilities, or compliance obligations.

The Client remains responsible for:

• Monitoring open positions
• Maintaining sufficient margin
• Managing account risk
• Reviewing platform activity
• Responding to document requests
• Complying with the Terms and Conditions
• Complying with AML/CFT procedures
• Protecting account login credentials

Apexx Capital may restrict trading, payments, withdrawals, or account access during a complaint review where required for compliance, security, AML, fraud prevention, payment, legal, or risk management purposes.

Complaints relating to trading execution should include:

• Instrument name
• Trade ID or order number
• Date and time of trade
• Order type
• Requested price
• Executed price
• Screenshots where available
• Description of the issue
• Any related platform messages

The Client acknowledges that execution may be affected by market conditions, volatility, liquidity, slippage, gapping, latency, platform performance, data feeds, and third-party execution conditions.

Not every unfavourable trading outcome is an error.

Apexx Capital will review execution complaints based on available platform records, order logs, pricing data, market conditions, and applicable terms.

Complaints relating to deposits or withdrawals should include:

• Payment method
• Payment date
• Payment amount
• Currency
• Transaction reference
• Bank or payment provider confirmation
• Screenshots where available
• Withdrawal request ID, if applicable
• Description of the issue

The Client acknowledges that deposits and withdrawals may be affected by verification checks, AML reviews, payment provider delays, bank delays, blockchain network conditions, incorrect payment details, chargeback reviews, security checks, and other third-party or compliance factors.

Apexx Capital may request additional documents before reviewing or resolving payment-related complaints.

Complaints relating to verification, KYC, AML, compliance review, sanctions screening, payment verification, account restriction, or security review may involve confidential internal procedures.

The Company may not be able to disclose all details relating to:

• AML alerts
• Sanctions screening results
• Fraud prevention rules
• Payment provider reviews
• Security investigations
• Internal risk scoring
• Compliance escalation
• Suspicious activity reviews
• Third-party provider findings
• Legal or regulatory reporting

The Company will provide as much information as it reasonably can without compromising compliance, security, legal obligations, payment provider requirements, or internal risk procedures.

A complaint may be submitted by an authorised representative on behalf of the Client.

Before communicating with a representative, Apexx Capital may require:

• Written authorisation from the Client
• Proof of identity of the representative
• Proof of authority
• Power of attorney, where applicable
• Additional verification documents

The Company may refuse to discuss account details with a representative unless proper authorisation is provided.

Apexx Capital may keep records of complaints and related documents for legal, compliance, AML, audit, dispute resolution, fraud prevention, payment, security, business, and internal review purposes.

Complaint records may include:

• Complaint submission
• Client details
• Account details
• Supporting documents
• Communications
• Internal notes
• Investigation records
• Trading records
• Payment records
• Final response
• Resolution details
• Escalation records
• Related compliance records

Complaint records may be retained after account closure where required or permitted by law, internal policy, payment provider requirements, AML procedures, or dispute resolution needs.

Personal data submitted as part of a complaint will be processed in accordance with the Privacy Policy.

The Company may process complaint-related data for:

• Complaint handling
• Account review
• Legal analysis
• Compliance review
• AML and fraud prevention
• Payment review
• Internal investigation
• Dispute resolution
• Recordkeeping
• Business improvement
• Legal claims

The Company may share complaint-related data with third-party service providers, payment processors, banks, platform providers, legal advisers, compliance advisers, auditors, authorities, courts, or other parties where required or permitted.

If the Client is not satisfied with the initial complaint response, the Client may request an internal escalation.

The escalation request should be submitted by email to: support@apexx-capital.com

The subject line should include:

Complaint Escalation

The Client should explain why they disagree with the response and provide any additional evidence or information.

Apexx Capital may review escalated complaints internally, but it is not required to reopen a complaint where no new information, evidence, or valid reason is provided.

Apexx Capital is operated by Veltrix Global Ltd., an international business company incorporated in the Republic of the Marshall Islands.

Unless expressly stated otherwise in writing, the Company does not hold a financial services licence and is not regulated by a financial authority, ombudsman scheme, compensation scheme, or external dispute resolution body in the Client's jurisdiction.

Clients may not have access to a local financial ombudsman, investor compensation scheme, deposit protection scheme, or regulatory complaint body in relation to services provided by the Company.

If the Client remains dissatisfied after the Company's final response, the Client may seek independent legal advice.

Any legal dispute shall be handled in accordance with the governing law and jurisdiction provisions set out in the Terms and Conditions.

This Complaints Policy shall be governed by and construed in accordance with the laws of the Republic of the Marshall Islands.

Any dispute, claim, action, suit, proceeding, or matter arising out of or relating to this Complaints Policy, the services, the account, the platform, or the relationship between the Company and the Client shall be handled in accordance with the governing law and jurisdiction provisions in the Terms and Conditions.

The Client must not submit complaints that are knowingly false, abusive, misleading, fraudulent, threatening, defamatory, repetitive, vexatious, or made in bad faith.

If the Company determines that a complaint is abusive, fraudulent, or submitted for improper purposes, the Company may:

• Restrict communication channels
• Limit repeated submissions
• Close the complaint file
• Suspend account access
• Terminate the account where permitted
• Retain records
• Take legal action where appropriate
• Report fraud or abuse where required or appropriate

This does not prevent clients from submitting genuine complaints in good faith.

Apexx Capital will not penalise a Client solely for submitting a genuine complaint in good faith.

However, the Company may still take necessary action where the complaint reveals or relates to:

• Breach of Terms and Conditions
• Fraud risk
• AML concerns
• Sanctions issues
• Payment disputes
• Chargebacks
• Market abuse
• Security concerns
• False information
• Account misuse
• Legal or compliance concerns

Apexx Capital aims to handle complaints fairly and consistently.

Where a complaint involves a potential conflict of interest, the Company may assign the complaint to an appropriate person, team, adviser, or reviewer to support a fair internal review.

The Company may use external legal, compliance, payment, platform, or technical advisers where appropriate.

Apexx Capital may review complaint records and complaint trends to improve internal procedures, website information, platform functionality, client communications, account processes, and service standards.

Complaint information may be used for internal training, operational improvements, compliance monitoring, and risk management.

Apexx Capital may update, amend, replace, or modify this Complaints Policy at any time.

Updates may reflect changes in:

• Company procedures
• Legal requirements
• Operational processes
• Payment provider requirements
• Platform services
• Compliance standards
• Contact details
• Business operations
• Internal complaint handling processes

The updated version will be published on the website with a revised "Last Updated" date.

Continued use of the website, client area, platform, account, or services after publication of an updated Complaints Policy constitutes acknowledgement of the updated Complaints Policy.

Complaints should be submitted to:

Suggested subject line:

Complaint - [Your Account Number or Registered Email]

By opening an account, accessing the website, using the platform, submitting a complaint, or continuing to use the services, the Client acknowledges and agrees that:

• They have read and understood this Complaints Policy.
• They will submit complaints in good faith.
• They will provide accurate and complete information.
• They will provide supporting documents where available.
• They understand that complaints may require investigation.
• They understand that complaint reviews may be delayed where information is missing or third-party checks are required.
• They understand that submitting a complaint does not remove trading, payment, margin, compliance, or account obligations.
• They understand that the Company may not be able to disclose confidential AML, fraud, payment, security, or compliance review information.
• They understand that legal disputes are subject to the Terms and Conditions.