Introduction to the Policy
Purpose and Objective
The Complaints Handling Policy at ATLAS AI LABS FZE serves as an essential component of the company’s commitment to client protection, regulatory compliance, and continuous improvement. The objective of this policy is to ensure that all clients and stakeholders have clear and accessible channels through which concerns can be raised regarding service quality, operational matters, virtual asset issuance processes, or any aspect of their interaction with Atlas. Atlas provides multiple avenues for submitting complaints, including designated email addresses, online submission forms, and direct communication with authorized personnel. These channels ensure that clients can easily raise concerns and receive timely responses. The policy sets out a systematic process for handling complaints: from initial receipt and acknowledgment, to thorough investigation, resolution, and follow-up. Atlas prioritizes transparency and fairness throughout this process, keeping clients informed of progress and expected timelines. Beyond resolving individual issues, Atlas is committed to learning from complaint data. Trends and recurring issues are analyzed to identify root causes and implement corrective actions to enhance service delivery, system robustness, and internal procedures. Ultimately, the Complaints Handling Policy at ATLAS AI LABS FZE fosters a culture of accountability, responsiveness, and continuous improvement. By treating client feedback as a critical asset, the company aims to build lasting relationships founded on trust, reliability, and strong consumer protection standards. All complaints shall be handled fairly, impartially, and consistently, without discrimination or retaliation. Atlas AI Labs FZE ensures that no client or individual is disadvantaged for submitting a complaint in good faith. Atlas ensures that complaint submission channels are easily accessible, clear, and available to all clients, and that no unreasonable barriers exist to prevent or discourage the submission of complaints.Scope and Applicability
This policy applies across ATLAS AI LABS FZE and is aligned with relevant local and regulatory requirements, including those issued by VARA. All Atlas employees, contractors, consultants, and associated personnel regardless of function or seniority are required to comply with this policy. In the event of any conflict between this policy and local laws/regulations, the more stringent standard shall apply. Any amendments required to ensure compliance with applicable laws must be approved by the Chief Compliance Officer (CCO). The Compliance Officer is responsible for maintaining this policy, conducting periodic reviews, and updating it annually or whenever operational, regulatory, or business changes necessitate revisions. Material amendments require approval from the CCO.Requirements
All employees of ATLAS AI LABS FZE must adhere to the standards, obligations, and procedures outlined in this policy without exception. This requires:- Understanding the content and purpose of the policy
- Applying the prescribed procedures in all relevant interactions
- Upholding regulatory and internal compliance requirements
- Handling client communications professionally and transparently
- Protecting sensitive information and maintaining confidentiality
Compliance
Every employee within ATLAS AI LABS FZE plays a vital role in maintaining a culture of compliance. This includes following internal policies, industry standards, and all legal and regulatory obligations under VARA and UAE law. Employees must:- Stay informed about regulatory updates relevant to their roles
- Ensure their conduct meets ethical and legal expectations
- Accurately document, record, and escalate issues when required
Reporting
Reporting is a critical element of Atlas’s compliance culture. Employees are expected to report any violations, concerns, or suspicious activities, including but not limited to:- Misconduct
- Conflicts of interest
- Fraud or suspicious transactions
- Breaches of policies or laws
Substance of a Complaint
Definition of a Complaint
A complaint is defined as:Any oral or written expression of dissatisfaction, justified or not, submitted by a client, prospective client, or former client concerning the delivery or non-delivery of services.Complaints may pertain to:
- Service quality
- Delays or operational errors
- Decisions or actions of Atlas staff
- Communication issues
- Virtual asset issuance processes
- Perceived lack of information
Complaint Channels
Complaints may be received via the following methods:
For the purpose of regulatory timelines, a complaint is considered to have been made at the earlier of:
- the time it is received by Atlas via any of the channels listed above; or
- the time it is first logged by an Atlas representative as a client complaint.
Categories of Complaints
Categorizing complaints enables Atlas to analyze trends and enhance service quality. Complaints may include, but are not limited to, the categories set out below, each of which follows a defined handling process:
These categories help prioritize responses and identify operational enhancements.
Complaint Risk Ratings
All complaints undergo a risk assessment based on severity and potential impact:- Low Risk (1): Minor issues with limited impact and no regulatory implications.
- Moderate Risk (2): Potential regulatory relevance, recurring issues, or limited financial impact.
- High Risk (3): Significant financial, regulatory, operational, or reputational implications; may require escalation to VARA.
Response Times
Unless otherwise prescribed by law, Atlas will follow the below standards:- Written complaints will be acknowledged within seven (7) days, including requests for additional documentation.
- Investigations will be completed and a final response issued within four (4) weeks, unless exceptional circumstances apply.
- If additional time is required:
- The client will be notified within the initial 4-week period
- Monthly updates will be provided
- A reasonable expected resolution date will be communicated
Response Methods
Complaints will be responded to using the same method by which they were received unless the complainant requests otherwise. If a complaint is resolved to the complainant’s full satisfaction and no written response is requested, Atlas is not obligated to send a formal final response (except where regulatory obligations require otherwise).Complaints Oversight
Atlas will maintain a comprehensive log of all complaints, including:- Category
- Nature of issue
- Communication channel
- Risk rating
- Date received
- Date resolved
- Actions taken
- Jurisdiction (if applicable)
- Conduct regular analysis of complaints
- Analyse the root causes of complaints, especially recurring or high-risk themes
- Assess whether such root causes may affect other clients that have not been directly complained of
- Provide quarterly reports to senior management
- Present complaint trends to the Board of Directors at least quarterly
- Ensure that appropriate corrective and preventative actions are implemented and tracked to completion
Regulatory Requirements
ATLAS AI LABS FZE is committed to full compliance with applicable laws and regulations governing complaints handling, including:- Virtual Assets Regulatory Authority (VARA) rulebooks
- UAE Consumer Protection Law (Federal Law No. 15 of 2020)
- UAE Data Protection Law (Federal Decree-Law No. 45 of 2021)
- Any additional regulatory requirements applicable to VA Issuance activities