Customer complaints management policy

August 2023

Version Tracking:

Author

Description

Date

GPS

Initial draft

August 2023

Recipients:

• Board of Directors

• Senior Management

• IT Officers

• Staff

• Outsourcing Providers

CONTENTS

1. Customer Complaint…………...…………..……………..……………….………..4

2. Reasons and Categories of Complaints…………………………………...……….4

2.1. Complaints in writing…………………………………...………..…….…….….4

2.2. Complaints orally…………………………………………….…….….….……..4

2.3. Complaints through Institutional Bodies and by Legal Measures.……….……..5

3. Basic Principles and Complaints Management Tools………………………….....5

3.1. Support Department…………...……….……………….………………….…….5

3.2. Regulatory compliance………..………….…………….…………………...…...7

3.3. Counsel…………………………………….………………………….…...…….7

3.4. Statistics………………………………….………………………..…..…..……. 8

1. Customer complaints

An oral or written expression of a Customer's dissatisfaction / complaint is due to a failure to

meet his or her expectations of a service or product in the context of his or her in connection

with the Foundation, which is associated with consumer disparity, damage or other harmful

consequences. As a complaint, in no case is a Customer's request arising from the exercise of

the Foundation's business policy, satisfied through specific procedures and managed

exclusively by the Unit responsible for each Customer. Indicatively mentioned:

• Request for pricing policy

• Request for data (copies of document transactions, etc.)

• Transaction request

2. Reasons and Categories of Complaints

Indicatively, the following can be a cause for complaint:

• Inconsistency of terms between pre-contractual information and the actual

execution of a transaction

• Insufficient, incomplete or incorrect information of the trader and creation of

incorrect expectations.

• Possible errors in the execution of transactions, or the execution of customer

orders and other manipulative errors.

• Delays or lower than the expected level of service

• Disagreement over the legality of terms of transactions or contracts

• Absence of Professional Staffing Behavior.

2.1 Complaints in writing

The complaints submitted by the customer through a letter, which is received via mail, fax,

e-mail (email) are defined. The resolution of such complaints is completed in any case by

means of a reply letter, which is sent to the customer.

2.2 Complaints orally

Complaints are defined which the customer submits orally and not through a written letter.

These complaints are recorded, investigated and processed in the same way as in written

complaints, with the only difference being that their resolution does not require written

notice to the customer. They can also be solved by notifying the customer by phone, via a

recorder and if the customer is informed that the conversation is being recorded. Then, each

category is analyzed according to the way and the reason for submitting the complaint (oral

or written) and per product / service in order to be settled.

2.3 Complaints through Institutional and Legal Measures

Complaints received through Institutional Bodies (eg Central Bank of Cyprus, Ministry of

Development, the Consumer Ombudsman, etc.) are defined and addressed by the Regulatory

Compliance Officer. The resolution of such complaints shall be completed in any case by

means of a reply letter, which shall be sent to the Agency.

3. Basic Principles and Complaints Management Tools

3.1 Support Department

If you feel that GPS - Global Payments Solutions Ltd have not met your expectations in the

delivery of our Services, in the first instance contact the GPS - Global Payments Solutions

Ltd using the contact email address for complaints support@transfermatch.eu.

The Support Department is responsible for handling customers' complaints. Particularly:

• The department must disclose its contact details, as well as the contact details of

the relevant officials, as well as any changes that will occur to them, in the Bank of

Lithuania or Central Bank of Ireland, notified to the Regulatory Compliance Unit.

• Defines in cooperation with the Regulatory Compliance Officer and the Legal

Adviser the procedures for resolving complaints.

• Receives mail related to customer complaints

• It is responsible for archiving the Company's complaints. It maintains a special

Complaints file, which complies with all the complaints submitted to the Company,

with the following information:

➢ The way it was submitted.

➢ The initial information of the recipient of the complaint, to the Department

that reports the data of the complaint.

➢ The customer's letter (if it is a written complaint).

➢ The corrective actions that may have been taken.

➢ The final outcome (customer satisfaction, or not).

➢ The response to the customer and / or the agency that mediated.

➢ Any other information, or document used to investigate the case.

• If the customer's complaint letter has reached the Association of Institutional

Bodies, the reply letter is also notified to the Regulatory Compliance Unit, in order

for the latter to respond to the Agency.

• Monitors the process of resolving customer complaints, compliance with

procedures and deadlines, until the final closure of cases. The Department will

respond to your complaint in writing or using another Durable Medium within 15

(fifteen) Business Days after the receipt of complaint. In exceptional cases, due to

reasons which are beyond its control, the Department may send you a preliminary

response by indicating reasons for delay and the term by which you will receive its

final response. In any case the term for provision of final response will not exceed

35 (thirty-five) Business Days after the receipt of complaint. Handling of

complaints is free of charge. The claims shall be submitted, handled and responded

to in English, unless use of another language is agreed between the customer and

GPS – Global Payments Solutions Ltd.

• Collaborates and provides instructions on how to manage complaints to the

involved operational units of the Foundation and, where necessary, coordinates

actions to investigate and finalize complaints.

• Checks the answers and actions of those responsible for resolving the complaint

that must be answered in writing. It compiles the reply letter to the customer, taking

special care of the style and structure of the letter so that all the customer's questions

/ complaints have been answered in an understandable way. If she deems it

appropriate, she cooperates with the Legal Adviser and the Head of Regulatory

Compliance.

• Informs the Administration regarding the complaints received.

• Suggests improvement in areas where problems have been identified.

• Maintains a special Complaints Register, in which all complaints are registered by

serial number, date and customer code (registry number). The Complaints Register

includes, among other things, the date of submission of the complaint (opening

date) as well as the date of informing the customer to resolve it (closing date). As

soon as he is informed of the submission of a complaint, he opens a portion for it

in the Complaints Archive and registers it in the Complaints Register, as "Open

Complaint". Monitors all Open Complaints, in continuous reviews, Until these are

resolved and the "Closed" indication is registered in the Register. It ensures that all

the relevant units meet the deadlines for resolution and goes where it deems

necessary.

• Should the customer has not been satisfied with GPS’s final response, or should

GPS – Global Payments Solutions Ltd fail to respond to the customer within 15

Business Days from receiving the claim, the customer shall have the right to apply

to the Bank of Lithuania, the FCA or the Central Bank of Ireland in three different

ways: (1) through the electronic dispute settlement facility E-Government

Gateway, (2) by completing a consumer application form and sending it to the

Supervision Service of the Bank of Lithuania at Žalgirio str. 90, LT-09303 Vilnius,

email: [email protected] or to the Supervision Service of the CBI at N Wall Quay, North

Dock, Dublin, D01 F7X3 email: [email protected], or (3) by filling out a

free-form application and sending it to the Supervision Service of the Bank of

Lithuania, Žalgirio str. 90, LT-09303 Vilnius, email: [email protected] or to the

Supervision Service of the CBI at N Wall Quay, North Dock, Dublin, D01 F7X3

email: [email protected]. Whichever way the customer chooses to submit

the claim, it must be in the official language of the country, i.e. Lithuanian or

English. The customer may only apply to the Bank of Lithuania or the CBI within

1 year after he received from GPS a response that is not satisfactory, or after the 15

Business Days for responding has passed and GPS did not respond. Addressing

GPS first is a precondition for the customer applying to the Bank of Lithuania or

the CBI. The decision of the Bank of Lithuania or the CBI is not mandatory for

GPS or the customer and the customer, even after the dispute was solved by the

Bank of Lithuania or the CBI, shall have a right to apply to the court.

• In case the customer generally is not satisfied with GPS - Global Payments

Solutions Ltd or its services, where there is no claim or disagreement between the

customer and GPS - Global Payments Solutions Ltd, the customer may always

approach the Bank of Lithuania, the FCA or the CBI by addressing a complaint to

the Bank of Lithuania at Totorių str. 4, LT-01121 Vilnius, email: inf[email protected], or to

the Supervision Service of the Bank of Lithuania, Žalgirio str. 90, LT-09303

Vilnius, email: [email protected] or to the Supervision Service of the CBI at N Wall Quay,

North Dock, Dublin, D01 F7X3 email: [email protected].

• If you are unhappy with either our updated or final response, you may contact the

European Ombudsman Service, an independent and impartial service that looks to

settle disputes between financial services firms and their customers.

Please note, however, that the European Ombudsman Service will not be able to help

you with your complaint until our complaint’s procedure has been exhausted. We will

of course aim to resolve your complaint quickly and efficiently and will begin our

investigation immediately.

3.2 Regulatory compliance

The Head of Regulatory Compliance receives the cases of complaints through the

Institutional Bodies, for the investigation and resolution of which he directly

cooperates with the Support Department. The reply letter to the respective

Institutional Body is drawn up by the Head of Regulatory Compliance, audited by the

Legal Adviser and finally sent to the Institutional Body by the Head of Regulatory

Compliance. The Support Department receives a copy of the case in order to have a

complete picture of the complaints submitted to the Company.

It is noted that at the beginning of each year, the Regulatory Compliance Officer with

the Bank of Lithuania, the FCA or the CBI sends the annual complaint report, which

shows all the incoming complaints of the previous year and their analysis by

category, their resolution time and number. cases that are ongoing and have not been

resolved.

In addition, he gives an opinion on the Company's reply letters to the customers,

when requested.

3.3 Counsel

• Gives an opinion during the management of the case and approves from a legal

point of view the draft of the reply letter where it is deemed necessary.

• Depending on the cause or severity of the complaint, he may write the entire reply

letter.

• Collaborates with the Support Department in the investigation of complaints cases

with legal measures (out of court) and prepares the relevant response.

• Presents at meetings with the competent bodies for out-of-court settlement of

complaints, if necessary.

3.4 Statistics

The Support Department issues the Annual Complaints Report, which it sends to the

Regulatory Compliance Officer for review, in order to be forwarded to the Bank of

Lithuania or the CBI. This report includes the following information:

• Complaints Number per Complaint Category

• Complaints Solution Time Analysis, In the following data:

➢ Average Time (days)

➢ Maximum Time (days)

➢ Minimum Time (days)

• Number of Programs in Evolution (ie cases that have not yet been resolved)