Complaints management and customer service procedure

Version: 1.0 (LATAM Regional Compliance)
Last Updated: [12/11/2025]
Scope: Global with local application in Latin American jurisdictions

I. PURPOSE AND SCOPE

Diversidad Financiera Consultores (hereinafter, the “Company” or the “Controller”) aims to provide world-class wealth management solutions accompanied by personalized service of the highest level.

We understand that excellence is demonstrated not only when everything goes well, but in how we respond when something does not meet expectations.

This procedure establishes a formal, free-of-charge, and transparent mechanism to channel, investigate, and resolve any dissatisfaction, ensuring respect for the Right of Petition and the rights of financial consumers and data subjects in the region.

1.1. Operational Definitions

For the purposes of this procedure:

• Complaint or Claim: Any expression of dissatisfaction, written or oral, made by a client or legitimate third party, related to the provision (or lack of provision) of a service, alleging financial loss, material damage, significant inconvenience, or dissatisfaction with the processing of their personal data.
• Simple Request (Inquiry): A routine request for information, documentation, or clarification regarding products (e.g., request for a bank statement or address update) that does not imply a conflict nor allege a prejudice. These are handled through regular customer service channels and do not trigger the formal complaint investigation procedure.
• Complainant (Data Subject): A natural or legal person who uses the Company’s services, or any legitimately affected third party who files the complaint.

II. GUIDING PRINCIPLES

Claims management at Diversidad Financiera Consultores is governed by fundamental guarantees aligned with consumer protection and habeas data standards in Latin America:

• Gratuitousness: The filing of complaints and the exercise of the right of petition are at no cost to the Complainant.
• Impartiality and Diligence: Each complaint is investigated by competent personnel (Compliance or Privacy Officer) who act with objectivity, seeking the material truth of the facts without bias in favor of the Company.
• Root Cause Analysis: We do not only resolve the individual case; we use the complaint to identify systemic failures, correct processes, and prevent their recurrence (Continuous Improvement).
• Transparency and Simplicity: We communicate in clear language, avoiding unnecessary legal technicalities, and keep the Complainant informed regarding the status of their request.

III. INTERNAL MANAGEMENT PROCEDURE

We have designed a three-phase process to ensure efficient resolution.

PHASE 1: Submission and Acknowledgment of Receipt

• Official Channel: Complaints must be formally addressed to our Compliance team via email: info@diversidadfinanciera.com
• Requirements: To expedite the investigation, the Complainant must provide:
  • Complete identification and contact details.
  • Clear and precise description of the facts (what happened, when, and where).
  • Supporting evidence (documents, previous emails, screenshots).
  • Expected solution (relief sought).
• Acknowledgment of Receipt: The Company will confirm receipt of the complaint in writing within the following three (3) business days. This acknowledgment will include a reference number or ticket for tracking.

PHASE 2: Investigation and Deadlines

• Person Responsible: The Compliance Officer (or the Data Protection Officer, if applicable) will lead the investigation, collect internal evidence and interview the employees involved if necessary.
• Resolution Term: We commit to issuing a Final Response within a maximum period of twenty (20) business days counting from the complete receipt of the information.
  • Note: This term seeks to harmonize the different legal terms of the region (which generally vary between 15 and 30 days). If the local law of your country requires a shorter period (e.g., 15 days for ARCO Rights in certain jurisdictions), we will apply the term most favorable to the Complainant.
• Exceptional Extension: If the case is of high technical or legal complexity, the Company may extend the term once, notifying the Complainant before the original expiration, explaining the reasons for the delay and the definitive date of response.

PHASE 3: The Final Response

The Company will issue a formal closing document which will contain:

• Summary: Recount of the points claimed.
• Investigation: Description of the actions taken to verify the facts.
• Reasoned Decision:
  • If upheld: Acceptance of the complaint, redress measures (economic or administrative), and corrective actions taken.
  • If rejected: Detailed and grounded explanation of the reasons for the rejection, attaching the corresponding evidence.

IV. RIGHTS OF EXTERNAL ESCALATION

If the Complainant is not satisfied with our Final Response or if the Company does not respond within the established legal terms, they have the right to resort to external bodies:

• Personal Data Protection: If the claim involves the misuse of your information or lack of attention to ARCO Rights, you may turn to the National Data Protection Authority of your country (e.g., INAI in Mexico, SIC in Colombia, ANPD in Brazil, DINARDAP in Ecuador).
• Financial Consumer Protection: For claims regarding the service or contractual terms, you may turn to the Financial Client Ombudsman (if applicable) or the local Consumer Protection Agency.
• Judicial Pathway: The Complainant retains intact their right to exercise civil, criminal, or constitutional actions before the competent courts of justice to claim damages.