1. PURPOSE

1.1 This Complaints Policy sets out the framework by which Digital Capital Ltd (“we”, “us”, “our”) receives, investigates, manages and resolves complaints.

1.2 This Policy is designed to ensure:

• fair and consistent treatment of customers

• compliance with applicable regulatory requirements, including FCA DISP rules

• effective identification and remediation of issues

• continuous improvement of services

2. REGULATORY FRAMEWORK

2.1 This Policy is aligned with:

• FCA Dispute Resolution (DISP) rules

• Electronic Money Regulations 2011

• Payment Services Regulations

2.2 Complaints handling is subject to regulatory oversight and audit.

3. SCOPE

3.1 This Policy applies to:

• all complaints received from customers

• complaints relating to payment services

• complaints relating to electronic money

• complaints relating to card services

• complaints relating to Partner interactions where relevant

3.2 This Policy applies to:

• individual customers

• business customers

• authorised users

4. DEFINITION OF A COMPLAINT

4.1 A complaint is any expression of dissatisfaction, whether oral or written, relating to:

• the provision of a service

• a failure to provide a service

• the manner in which a service has been delivered

5. TYPES OF COMPLAINTS

Complaints may include, but are not limited to:

5.1 Payment-related complaints

• delayed payments

• failed transactions

• incorrect execution

5.2 Account-related complaints

• account access issues

• restrictions or suspensions

5.3 Card-related complaints

• declined transactions

• chargebacks

• unauthorised card use

5.4 Service-related complaints

• customer support issues

• communication failures

5.5 Fraud and security complaints

• suspected fraud

• unauthorised transactions

6. COMPLAINT VS QUERY CLASSIFICATION

6.1 A query is a request for clarification or information.

6.2 A complaint involves:

• dissatisfaction

• expectation of corrective action

6.3 Where there is doubt, the matter will be treated as a complaint.

7. COMPLAINT IDENTIFICATION

7.1 Complaints may be received via:

• email

• customer support channels

• Partner platforms

7.2 Staff must:

• identify complaints accurately

• escalate appropriately

8. COMPLAINT OWNERSHIP

8.1 Each complaint will be assigned an owner responsible for:

• investigation

• communication

• resolution

8.2 Ownership ensures accountability.

9. VULNERABLE CUSTOMERS

9.1 We recognise that some customers may be vulnerable.

9.2 Where vulnerability is identified, we will:

• adjust communication

• provide additional support

• ensure fair treatment

10. RECORDING OF COMPLAINTS

10.1 All complaints will be recorded.

10.2 Records will include:

• complaint details

• date received

• category

• actions taken

• outcome

11. PRIORITISATION

11.1 Complaints may be prioritised based on:

• severity

• potential financial impact

• vulnerability of the customer

• regulatory implications

12. INTERNAL ESCALATION

12.1 Complaints may be escalated internally where:

• complexity is high

• risk is significant

• regulatory concerns arise

12.2 Escalation may involve:

• compliance function

• senior management

13. CONFIDENTIALITY

13.1 Complaint data will be handled confidentially.

13.2 Access is restricted to authorised personnel.

14. COMPLAINT RECEIPT

14.1 Complaints may be submitted through:

• email

• customer support channels

• Partner interfaces (where applicable)

14.2 Complaints may be submitted:

• verbally

• in writing

14.3 All complaints must be logged upon receipt.

15. ACKNOWLEDGEMENT

15.1 We will acknowledge receipt of a complaint promptly.

15.2 Where appropriate, acknowledgement may include:

• confirmation of receipt

• explanation of next steps

• request for additional information

16. INITIAL ASSESSMENT

16.1 Upon receipt, each complaint will be assessed to determine:

• category of complaint

• complexity

• potential impact

• urgency

16.2 Complaints may be categorised as:

• standard

• complex

• high-risk

17. INVESTIGATION PROCESS

17.1 Complaints will be investigated thoroughly and fairly.

17.2 Investigation may include:

• review of transaction records

• review of account activity

• internal system checks

• communication with relevant teams

• communication with third parties (where required)

17.3 We may request additional information from the customer.

18. INTERACTION WITH THIRD PARTIES

18.1 Where complaints involve:

• payment schemes

• banks

• merchants

• Partners we may need to liaise with those parties.

18.2 This may affect investigation timelines.

19. TIMELINES — FCA REQUIREMENTS

19.1 We aim to resolve complaints as quickly as possible.

19.2 In accordance with FCA DISP rules:

·         A final response will normally be provided within 15 business days

19.3 In exceptional circumstances:

·         We may extend this to 35 business days

19.4 Where an extension is required, we will:

• inform you of the delay

• explain the reasons

• provide an updated timeframe

20. ONGOING COMMUNICATION

20.1 We will keep you informed where:

• investigations are ongoing

• delays occur

20.2 Communication will be clear and transparent.

21. FINAL RESPONSE

21.1 Our final response will include:

• a summary of the complaint

• the outcome of the investigation

• our decision

• any corrective action taken

21.2 Where appropriate, we will:

• provide remediation

• explain next steps

22. REMEDIATION

22.1 Where a complaint is upheld, we may:

• provide a refund

• correct an error

• take operational action

22.2 Remediation will be proportionate to the issue identified.

23. REJECTION OF COMPLAINTS

23.1 Where a complaint is not upheld, we will:

• explain the reasons

• provide supporting information where appropriate

24. FINANCIAL OMBUDSMAN SERVICE (FOS)

24.1 If you are not satisfied with our final response, you may refer your complaint to:

Financial Ombudsman Service

https://www.financial-ombudsman.org.uk

24.2 You must refer your complaint within the time limits specified by the FOS.

25. ELIGIBILITY FOR FOS

25.1 The FOS is available to:

• individual customers

• micro-enterprises

• eligible complainants under FCA rules

26. COMPLAINTS INVOLVING FRAUD OR PAYMENTS

26.1 Complaints involving fraud or unauthorised transactions may:

• require additional investigation

• involve third parties

26.2 Resolution timelines may be impacted by:

• scheme processes

• evidence requirements

27. RECORD KEEPING

27.1 We maintain detailed records of complaints.

27.2 Records include:

• complaint details

• investigation steps

• communications

• outcome

27.3 Records are retained in accordance with regulatory requirements.

28. QUALITY ASSURANCE

28.1 Complaints handling may be subject to:

• internal review

• compliance oversight

• audit

29. REGULATORY REPORTING

29.1 We may be required to:

• report complaint data to regulators

• provide summaries and statistics

30. TRAINING

30.1 Staff handling complaints receive appropriate training.

30.2 Training includes:

• regulatory requirements

• customer fairness

• escalation procedures

31. COMPLAINTS GOVERNANCE

31.1 Complaints handling is subject to governance and oversight.

31.2 Responsibility for complaints management lies with:

• operational teams (first line)

• compliance function (second line)

• senior management oversight

31.3 Complaints handling forms part of the firm’s overall risk management framework.

32. ROLES AND RESPONSIBILITIES

32.1 Staff handling complaints are responsible for:

• accurate classification

• fair investigation

• timely communication

32.2 The compliance function is responsible for:

• oversight of complaints handling

• regulatory alignment

• escalation of material issues

32.3 Senior management is responsible for:

• ensuring adequate resources

• reviewing complaint trends

• approving remediation actions

33. ROOT CAUSE ANALYSIS

33.1 We analyse complaints to identify underlying causes.

33.2 Root cause analysis may include:

• process failures

• system issues

• human error

• third-party dependencies

33.3 Where root causes are identified, we will:

• implement corrective actions

• monitor effectiveness

34. THEMATIC ANALYSIS

34.1 We review complaints on a thematic basis.

34.2 This includes identifying:

• recurring issues

• emerging risks

• patterns across products or services

35. MANAGEMENT INFORMATION (MI)

35.1 We produce management information on complaints, including:

• number of complaints

• categories of complaints

• resolution times

• outcomes

35.2 MI is used to:

• support decision-making

• identify trends

• improve services

36. ESCALATION TO SENIOR MANAGEMENT

36.1 Material complaints may be escalated to senior management where:

• regulatory risk exists

• financial impact is significant

• systemic issues are identified

37. CONTINUOUS IMPROVEMENT

37.1 We use complaints as a tool to improve:

• customer experience

• operational processes

• product design

37.2 Improvements may include:

• system enhancements

• process changes

• staff training

38. INTERACTION WITH RISK AND COMPLIANCE FUNCTIONS

38.1 Complaints data is integrated into:

• risk management processes

• compliance monitoring

38.2 Complaints may trigger:

• internal reviews

• audits

• policy updates

39. THIRD-PARTY AND PARTNER ISSUES

39.1 Where complaints relate to third parties or Partners:

• we will coordinate investigation

• responsibility will be assessed

39.2 We remain responsible for regulated services.

40. CUSTOMER FAIRNESS

40.1 We aim to treat customers fairly at all times.

40.2 This includes:

• clear communication

• fair outcomes

• proportionate decisions

41. VULNERABLE CUSTOMERS (ENHANCED)

41.1 Additional care will be taken where customers are identified as vulnerable.

41.2 Measures may include:

• adapted communication

• additional support

• flexible handling

42. RECORDING AND AUDIT TRAIL

42.1 We maintain an audit trail for each complaint.

42.2 This includes:

• actions taken

• decisions made

• communications

43. INTERNAL AUDIT AND REVIEW

43.1 Complaints handling may be subject to:

• internal audit

• compliance reviews

43.2 Findings may result in:

• remediation actions

• policy updates

44. REGULATORY EXPECTATIONS

44.1 We align our complaints handling with:

• FCA expectations

• applicable laws and regulations

44.2 We may update this Policy to reflect changes.

45. POLICY REVIEW

45.1 This Policy is reviewed periodically.

45.2 Updates may reflect:

• regulatory changes

• operational developments

• identified risks