Complaints Policy

Varni Labs FZE (“Varni Labs”, “Roma”, “we”) is committed to providing high-quality products and services. We value feedback from our clients, including complaints, as an opportunity to improve. This policy outlines the process for submitting, handling, and resolving complaints in a fair, consistent, and timely manner.

A complaint is: “An expression of dissatisfaction made to or about Varni Labs FZE, related to our products, services, staff, or our handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.”

You may submit a complaint through any of the following channels:

• Complaint form: file it here
• Email: support@roma.global, with the subject line “Official Complaint about Varni Labs FZE”
• Any designated relationship contact

Key components to include: your full name, the email address and phone number registered with Varni Labs FZE, the completed complaint form, and any other relevant materials. To help us resolve it quickly, please provide as much detail as possible.

Third-party involvement: Some of our services involve third-party providers, including our banking partner and our conversion/liquidity providers. Where the services you used involve such third parties, you can raise the complaint directly with us. We will ask you for the details of your complaint (and may request further information if what you provide is insufficient for us to assess it), coordinate with the relevant third party as needed, and keep you updated. Varni Labs FZE shall ultimately remain responsible for the resolution of those complaints.

Acknowledgement:

• Verbally submitted complaints: acknowledged in the same manner and followed up in writing within 24 hours or as soon as practicable.
• Written complaints (email or complaint form): acknowledged in writing within one week or as soon as practicable thereafter.

Investigation: If immediate resolution is not possible, further investigation may be required, and additional information may be requested from you.

A written response (OCR) will be provided if the complaint is not resolved within one week, or if you request a written response.

• Standard complaints: resolved within 4 weeks.
• Extraordinary circumstances: we will update you within 4 weeks with the reasons for the delay, and resolve no later than 8 weeks.

Our OCR will include: identification of the issues raised; findings on the relevant facts; and sufficient detail for you to understand our decision and whether to escalate.

An OCR is not required if the complaint is resolved to your satisfaction within 4 weeks and no OCR is requested, or where an explanation and/or apology is provided when no further action is possible.

If you are not satisfied with our response or resolution, you have the right to escalate your complaint to the Virtual Assets Regulatory Authority (VARA).

No fees or charges are imposed for submitting or handling complaints. Where a resolution requires a change to the scope of the product or service offered to you, we will make you aware of it and, should you opt for it, your explicit consent will be sought and documented.

We maintain records of all complaints received, the measures taken in response, and their resolution, and retain these records for at least 8 years.

The Compliance Officer is responsible for resolving complaints. Varni Labs FZE’s Responsible Individuals are Amit Jain and Raghav Saraf.

We take reasonable steps to identify and remediate recurring or systemic issues by analysing the causes of complaints, considering their impact on other processes, services or products, and correcting root causes to improve continuously.

Varni Labs FZE establishes effective procedures for the prompt, fair and consistent handling of complaints in accordance with Rule III.A of the VARA Market Conduct Rulebook. We will acknowledge complaints within one week and resolve them within four weeks, except in extraordinary circumstances (resolution no later than eight weeks).

Varni Labs FZE — Authorised and supervised by the Virtual Assets Regulatory Authority (VARA) in Dubai | Licence No. VL/23/10/001