CUSTOMER COMPLAINT HANDLING POLICY & PROCEDURES

1. This procedure sets out how Centrexcard Limited handles customer complaints in a fair, consistent, and timely manner in line with applicable regulatory requirements and global best practices. It also ensures that complaints are used as a tool to improve our services and customer outcomes while maintaining regulatory compliance, particularly with FCA DISP requirements.

CONTENTS

Definition of a Complaint
A complaint is any expression of dissatisfaction, whether oral or written, from or on behalf of a customer in relation to our services. A complaint is considered upheld where the firm accepts fault, or redress/remedy is provided (financial or non-financial), including partial resolution. Scope
This policy applies to all employees, all business units, all customer interactions and channels. It covers complaints relating to payment services, electronic money issuance, customer service, operational errors, or any dissatisfaction expressed by a customer Complaint Channels
Customers may submit complaints via: • Email: compliance@transferboss.com • Post: 48 West George Street, Suite 2/3, Glasgow, G2 1BP, UK All complaints received through any channel are treated equally and recorded. Responsibility for Complaint Handling
• Complaints are handled by the Compliance Function, with support from relevant operational staff where required. • The complaint handler will be sufficiently independent from the subject matter of the complaint to ensure fairness. • Final decisions are reviewed/approved by senior management where necessary. Acknowledgement
• Complaints are acknowledged promptly, typically within 3–5 business days. • The acknowledgement will confirm: • Receipt of the complaint • Reference number • Expected timelines Investigation
• Each complaint is assessed on its own merits. • The investigation may include: • Review of account records and transactions • Review of internal communications • Discussions with relevant staff • We ensure that all investigations are conducted fairly, consistently, and without bias. Outcome Determination
Outcomes may include:
• Complaint upheld • Complaint partially upheld • Complaint not upheld Where complaints are upheld, appropriate redress is provided, including::
• Refunds • Compensation • Corrective actions Response Timeframes
• We aim to resolve complaints as soon as possible. • A final response will be issued within 8 weeks of receipt. • Where this is not possible, the customer will be informed of the delay and the reason for it. Final Response
Our final response will:
• Clearly set out our findings • Confirm whether the complaint is upheld or not upheld • Provide a clear explanation of our decision • Where appropriate, outline any corrective action or redress • Inform the customer of their right if dissatisfied to refer the complaint to the Financial Ombudsman Service(within 6 months) including their contact details.
Complaints Register
• All complaints are recorded in a central complaints log maintained by Compliance. • The log includes: • Complaint ID • Date received • Customer details • Nature of complaint • Outcome (upheld/not upheld) • Resolution date Training
• Staff involved in complaint handling receive: • Initial training on complaint handling and DISP requirements • On-the-job guidance from Compliance including identifying complaints and customer communication. • Refresher training is conducted periodically, particularly where issues or trends are identified.
48 West George Street, Suite 2/3, Glasgow, Scotland, G2 1BP +44 1322 787288
Monitoring and Review
• Complaints are reviewed on at least a quarterly basis. • The review includes: • Trends and root cause analysis • Timeliness of responses • Consistency of outcomes • Findings are discussed with senior management. Root Cause Analysis
The firm will categorize complaints (e.g., operational, fraud, service), identify recurring issues and implement corrective actions such as process improvements, staff retraining and system upgrades Learning and Improvements
Outcomes of complaints and any decisions from the Financial Ombudsman Service are used to:
• Improve internal processes • Update procedures and policies where necessary • Enhance staff awareness and training Record Retention
• Complaint records are retained for a minimum of 3 years. • Records are maintained in a format that can be readily provided to regulators upon request. Regulatory Reporting
The firm will:
• Submit accurate complaints data to regulators • Ensure correct classification of upheld complaints • Maintain audit trail of submissions Governance and Oversight
• Senior management has and ensures oversight of complaint handling. • Any significant issues or recurring themes are escalated promptly. The firm adopts the following principles in complaints handling: Accessibility - Easy for customers to complain
Fairness - Impartial investigation
Transparency - Clear communication
Timeliness - Prompt resolution
Consistency - Standardized approach
Accountability - Clear ownership
Continuous Improvement - Learning from complaints
Policy Review
This policy is reviewed annually, or upon regulatory changes or significant incidents