Complaints Procedure

Notice. This procedure is informational and does not limit rights available to you under law or under the Rulebook. For Clearing Members, the disciplinary and appeals procedures set out in the Rulebook apply in addition to this procedure.

\u00a7 1. Scope

This procedure applies to all formal complaints about Wavestar’s services, staff, or conduct, raised by Members, Observers, Operators, vendors, counterparties, and the public. Consumer complaints that fall under a different statutory scheme may be routed to the specialist team appropriate for that scheme; we will confirm routing in our acknowledgment.

\u00a7 2. How to raise a complaint

Email complaints@wavestar.space with the subject line “Formal complaint”. Include your name, relationship to Wavestar, a description of what happened and when, the outcome you are seeking, and any relevant supporting information.

If you are a Clearing Member, you may alternatively raise the complaint through your relationship manager or the Member services portal. All routes flow into the same complaints register.

\u00a7 3. Service level

\u00a7 4. Escalation within Wavestar

If you are not satisfied with the case-handler’s response, you may escalate to the Head of Compliance within 15 business days of the response. The Head of Compliance will review the case, engage an independent reviewer where appropriate, and issue a final written position within 30 calendar days.

Beyond the Head of Compliance, the final internal escalation is to the Chief Executive Officer, whose decision is final for internal purposes. The CEO route is reserved for matters that raise significant governance, regulatory, or reputational issues.

\u00a7 5. Independent escalation

You may escalate outside Wavestar at any time, before or after internal escalation. Your options include:

• Regulator. For regulated activity, contact the appropriate regulator directly — FinCEN, SEC, CFTC, FCC, or a state authority — through their published complaint channel.
• Arbitration. Under the Dispute Resolution policy, disputes may be submitted to binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules.
• Courts. Nothing in this procedure prevents you from seeking injunctive relief or pursuing a claim in a court of competent jurisdiction for matters carved out of the arbitration clause.

\u00a7 6. Confidentiality and retaliation

Complaints are handled confidentially within the investigating team and those who need to know. We do not tolerate retaliation against complainants acting in good faith. Retaliation is treated as a separate and serious breach under our Code of Conduct.

\u00a7 7. Records

We maintain a complaints register that records the nature, outcome, and handling time of every complaint. The register is produced to regulators on request and is summarised anonymously in our annual Transparency Report.