# 1. Overview and Scope
This Complaints Handling Policy (the "Policy") sets forth the procedures by which Adjacent Markets, Inc. ("Adjacent") receives, investigates, and responds to complaints relating to its prediction market index activities. Adjacent is committed to providing services to a high standard and to conducting its business with integrity. This Policy provides a mechanism by which existing and potential clients and other stakeholders may submit complaints arising in connection with the activities of Adjacent's index business.
For purposes of this Policy, a "complaint" is any written or verbal expression of dissatisfaction received by Adjacent relating to the provision of, or failure to provide, services delivered by the Adjacent index business, where the complainant alleges that they have suffered or may suffer:
- Financial loss
- Material distress
- Material inconvenience
Complaints may generally pertain to, but are not limited to:
- Whether a specific Index level or constituent determination is representative of the underlying prediction markets
- A proposed or completed change to an Index methodology
- The application of a methodology in relation to a specific Index determination
- The handling of a data error, correction, or restatement
- Other decisions pertaining to the Index determination process
Any expression of dissatisfaction that is unclear as to whether it qualifies as a complaint under this Policy shall be escalated to the CEO and COO for review and determination. Expressions of dissatisfaction that are determined not to constitute a complaint under this Policy will be addressed through Adjacent's standard client communication processes.
This Policy covers index complaints only. For general inquiries about Adjacent's indexes, please contact Adjacent at governance@adjacentresearch.xyz.

# 2. Submission of Complaints
Complaints may be submitted by email to governance@adjacentresearch.xyz. All complaints should include sufficient detail to permit review and investigation, including:
- The name of the individual submitting the complaint
- The legal entity name of the associated client or organization, if applicable
- Preferred contact details of the complainant
- The name of any relevant Index
- A sufficiently detailed description of the facts and circumstances giving rise to the complaint, including a timeline of associated events
Where insufficient information is provided, Adjacent may be unable to adequately investigate the complaint and may request further information from the complainant or related parties.
Adjacent will endeavor to process any personally identifiable information linked to a complaint in accordance with applicable privacy legislation and Adjacent's privacy policies.

# 3. Investigation of Complaints
Adjacent has established procedures to process, investigate, and communicate complaints in a timely and fair manner:
1. Adjacent will make reasonable efforts to issue a written acknowledgment to the complainant promptly upon receipt of a complaint.
2. Complaints will be reviewed by the CEO and COO, with input from the Index Committee ("AIC") as appropriate. Any person directly involved in the subject matter of a complaint shall be recused from the review process.
3. The complaint will be escalated to the full AIC where the subject matter relates to an Index determination, methodology application, or data error.
4. If a material change to an Index is warranted as a result of the investigation, any such change will be handled in accordance with the Index Methodology Change Policy.
5. Adjacent will determine whether it considers the complaint to be upheld and, in the affirmative case, will determine what remedial action is appropriate.
6. Adjacent will communicate the outcome of the investigation to the complainant in writing within a reasonable period, unless such communication would be contrary to applicable law or public policy.
7. A complainant who is dissatisfied with the response received may request a review by the CEO and COO, who will conduct a final review and issue a final written response to the complainant.

# 4. Recordkeeping
All complaints and related responses are documented and retained.

# 5. Approval and Review
This Policy is reviewed by the AIC and the CEO and COO as required if there are any material changes to applicable law or regulation. Amendments require approval by the CEO and COO of Adjacent Markets, Inc.
Questions or correspondence regarding this Policy may be directed to governance@adjacentresearch.xyz.