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Rules on investigation of complaints SatchelPay

I. GENERAL PROVISIONS

1. These rules on investigation of complaints (the Rules) establish the rules and procedures followed by SatchelPay, UAB (the Company) while investigating clients or potential clients (the Applicant) complaints regarding financial services provided by the Company and/or concluded agreements (the Complaint).

2. The Rules are prepared in accordance with the Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania, as amended and Resolution No 03 – 105 ,,Regarding the Rules on Handling the Complaints Received by Financial Market Participants” of the Board of the Bank of Lithuania, as of 6 June 2013, as amended, and other applicable legal acts of the Republic of Lithuania.

II. SCOPE OF COMPLAINT

3. The Rules shall be applied to all Complaints received by the Company (its representatives) via communication channels stated in Section III “COMPLAINT SUBMISSION PROCEDURE” of the Rules.

4. The following types of messages shall not be considered as Complaints:

4.1. complaints concerning the Company’s activity which is not regulated by the special laws and is not supervised by the supervisory authority;

4.2. complaints concerning activity for the performance of which the Company is not responsible;

4.3. requests for identification of payment or payment remitter / subject depositing funds on the client’s account;

4.4. requests for mediation of payment return or for payment recipient identification;

4.5. requests for a copy of payment or transaction document;

4.6. requests for data about payment remitter or payment specification;

4.7. suggestions for adjustment or improvement of the Company’s services;

4.8. suggestions for modification of documents issued and (or) proposed by the Company in relation to the service provision.

5 In case the Company is not responsible for the performance of the activity indicated in the complaint, the Company shall reply to the client by indicating reasons for a refusal to accept and examine the complaint, as well as, if possible, specifying the person responsible for dealing with such complaints.

III. COMPLAINT SUBMISSION PROCEDURE

6. The Complaint shall be provided to the Company within 3 months from the date when the Applicant has or should have become aware about the violation of his rights.

7. The Complaint shall include the following information:

7.1. for natural persons – name, surname, birth date, contact details (e-mail and / or telephone number). For legal persons – name of the entity, registered code, registered address, contact details (e-mail and telephone number);

7.2. moment of breached rights of the Applicant (the moment when the Applicant thinks his rights were breached);

7.3. dispute matter. Clear description of the actions of the Company which led to the Complaint;

7.4. description of circumstances which led to the Complaint.

8. Complaint shall be submitted in Lithuanian or English language and shall be duly signed by the Applicant or his authorized representative.

9. The Applicant is responsible for certainty (i.e. correctives) of the personal and contact data provided in the Complaint and agrees that the Company will present all the information related to the Complaint handling process by using contact details provided in the Complaint. For the sake of clarity, if the Applicant specifies his e­mail address, the Company has the right to provide information and further communication by e-mail.

10. The Complaint must be submitted by the Applicant personally or by his representative. The representative of the Applicant together with the submitted Complaint must provide identity and authorisation evidencing documents: copy of an ID/ passport of authorised person and written copy of power of attorney evidencing the right to represent the Applicant or any other document evidencing authorisation to act on behalf of the Applicant.

11. The Company may refuse to investigate a complaint if it was filed not according to the procedures and rules set herein. The client will be informed about such refusal within 7 business days after the complaint was received by the Company.

12. The filling of Complaint and Complaints handling process at the Company is free of charge.

13. In case the Applicant submit a complaint on the same circumstances or grounds that were submitted and solved by the Company to the same Applicant before, the Company has a right to refuse investigating this kind of Complaint and inform about it the Applicant.

14. The Complaint shall be submitted via:

14.1. Registered mail sent to the Gostauto g. 40-1, Vilnius, Lithuania;

14.2. E-mail info@satchelpay.com;

14.3. Online form https://www.satchelpay.com/en/customer-complaint-form/.

IV. REGISTRATION OF COMPLAINTS

15. All Complaints, which are received in the manner set out in these Rules, are recorded in the Complaints’ registration journal of the Company. The Complaints shall be registered on their receipt date or the first following business day if the complaint was submitted at non-business day/after working hours.

16. Initial registration of the Complaint shall be made by the employee of the Company who has received/accepted the complaint. Afterwards the complaints log shall be supplemented by the employee assigned responsible for handling the complaint and preparation of the reply to the client.

17. The following information shall be recorded in Complaint journal:

17.1. information stated in paragraph 7.1 of the Rules;

17.2. representative details (if applicable);

17.3. date and method of receipt of Complaint;

17.4. a brief description of Complaint;

17.5. services and / or actions of the Company which are appealed;

17.6. date of response of the Company to the Applicant;

17.7. decision of the Company and further actions.

V. INVESTIGATION OF THE COMPLAINTS AND DECISION MAKING

18. Complaints shall be investigated following the principles of justice, fairness, reasonableness, objectivity, impartiality and with respect to the human rights. The investigation process of Complaint shall be duly documented.

19. The Complaints shall be investigated by the Customer Support Department of the Company. Customer Support Department representative may ask for co-operation of another structural units of the Company if needed. Customer Support Department is entitled to take a final decision by his own discretion. The Customer Support Department shall ask for confirmation of the decision regarding Complaint only in case the Complaint:

19.1. contains a claim of over €1000 (or equivalent);

19.2. alleges fraud, AML/CFT gross negligence by the Company;

19.3. poses a material reputational risk to the Company;

19.4. alleges breach of information security or privacy laws.

20. The Company does not investigate the Complaint that do not comply with the requirements set in the Rules, are written in other than Lithuanian or English language, are disorder and unreadable, the identity of the Applicant is not clear.

21. In case the submitted Complaint lacks information needed for the investigation, the Company has the right to ask the Applicant to eliminate the shortcomings of the Complaint by specifying the essence of the Complaint or providing additional documents or data needed for the Complaint’s investigation. In such case the Company sets a reasonable time limit, which cannot be shorter than 7 calendar days to eliminate the shortcomings of the Complaint. If the Applicant eliminates the shortcomings within the set deadline, the Complaint is considered to be provided on the date the shortcomings were eliminated, i.e. the day when the specified Complaint or needed documents were provided to the Company.

22. If the Complaint does not comply with the requirements indicated herein, the Company does not investigate the Complaint and returns it to the Applicant or its representative.

VI. SUBMISSION OF RESPONSE TO THE APPLICANT

23. The Complaint is investigated and the response is provided as soon as possible, but not later than within: (i) 14 calendar days from the date of receipt of the Complaint from the Applicant – a consumer; and (ii) 30 calendar days from the date of receipt of the Complaint from the other Applicants, which are not considered to be consumers. The term commences from the date of receipt of the Complaint. Exceptionally, when the Complaint cannot be investigated within the term set in this provision, the Company must inform the Applicant and specify the circumstances and the new term within which the Complaint will be investigated and response provided.

24. The Company investigates the Complaint in accordance with the laws that are in force and makes one of the following decisions:

24.1. to satisfy the request of the Applicant;

24.2. to partially satisfy the request of the Applicant;

24.3. to reject the Complaint.

25. When the Complaint is rejected or only partially satisfied, the Company in its response to the Applicant specifies arguments of rejection to fully satisfy the Complaint and if the Applicant is a natural person and shall be considered as a consumer – the right of the Applicant to file a complaint to the Bank of Lithuania.

26. Decision of the Company regarding the Complaint is recorded in the Complaints’ registration journal and sent to the Applicant via registered mail and/or e-mail indicated by the Applicant.

VII. FINAL PROVISIONS

27. The Policy must be reviewed at least annually by the 1st of March. Any modifications and amendments to the Policy shall be made in writing and become effective once approved by the resolution of respective management body.

28. The Customer Support Department shall prepare and introduce the quarterly reports to the management of the Company, describe the main issues in the process of handling the Complaints and propose the measures for enhancement.

29. The Company in order to determine shortcomings of its activities and potential legal or operational risk constantly assesses the Complaints’ investigation results. By performing this assessment the Company:

29.1. collects information on similar Complaints related to certain services or products, performs an analysis of this information in order to identify the main reasons of these Complaints, also to determine priorities for the elimination of these reasons;

29.2. assesses whether essential reasons of certain Complaints might lead to new Complaints regarding other services or products;

29.3. assesses whether essential reasons of certain Complaints might be eliminated and determines methods of their elimination;

29.4. eliminates main determined reasons of Complaints, if needed;

29.5. assures that the repetitive or systemic reasons of Complaints would be regularly communicated to the Managing Director of the Company and that the Managing Director could effectively perform its functions and ensure that similar Complaints would not occur.

30. The Company’s Customer Support Department is responsible for the proper implementation of this Policy. The representative of this Department shall monitor and ensure that the Company‘s complaints handling process is efficient and, if necessary, update it, also ensure that any shortcomings shall be remedied. Breaches of the Policy must be reported to the Managing Director as soon as possible.

31. The Rules, including its amendments, comes into force from the day of their approval. The employees of the Company must comply with the Rules from the moment the employee is introduced to the Rules. Employees are introduced to the Rules in writing and must follow their requirements properly.

32. The Company must submit to the Bank of Lithuania within 2 months from the end of the calendar year, by electronic means, information about the number of complaints received during the year (by filling in a special form approved by the Bank of Lithuania under Resolution No 03-105 of 6 June 2013 Regarding the Approval of the Rules on Examination of Complaints Received by Financial Market Participants adopted by the Board of the Company of Lithuania), as well as copies of records of analysis and decisions taken by the Management Board under Management reporting clause.

33. Representative of Customer Support Department is responsible for reporting to the Bank of Lithuania. The Company must store information about the number of complaints received, classified by the reasons of complaint and examination results (number of the complaints received, examined, satisfied, and partially satisfied) and submit such information to the Bank of Lithuania upon request.

34. The Company stores the Complaints, data related to the investigation, documents which provide a particular result of the investigation and response provided to the Applicant at least 3 years from the date of providing the final response to the Applicant. All information and documents are stored in the manner set by the Lithuanian law.