1. PURPOSE

1.1 This Fees and Limits Schedule sets out how fees, charges, pricing components and usage limits apply to services provided by Digital Capital Ltd.

1.2 The purpose of this document is to ensure:

• transparency of fees

• clarity of pricing structure

• consistency between legal terms and user interface

• compliance with applicable regulatory requirements

• fair treatment of customers

2. SCOPE

2.1 This Schedule applies to:

• all customers (individual and business)

• all payment services

• all card services

• all associated features

2.2 It applies across:

• UK and EEA operations

3. PRICING PRINCIPLES

Digital Capital applies the following pricing principles:

3.1 Transparency

Fees must be:

• clearly disclosed

• understandable

• visible before confirmation

3.2 No hidden fees

Customers must not be subject to:

• undisclosed fees

• unexpected charges

3.3 Pre-transaction disclosure

Customers must be shown:

• full cost

• before confirming a transaction

3.4 Consistency

Fees must be consistent across:

• legal documentation

• user interface

• operational systems

3.5 Fairness

Fees must not:

• mislead customers

• create unfair outcomes

4. PRICING STRUCTURE

4.1 Pricing may consist of:

• transaction fees

• FX margin

• card-related fees

• service fees

5. TOTAL COST MODEL

5.1 The total cost of a transaction may include:

• base fee

• FX margin (if applicable)

• third-party fees (if applicable)

5.2 Customers must be able to understand:

• the full cost

• before confirming

6. FX PRICING MODEL

6.1 Where currency conversion applies:

• a rate is applied

• a margin may be included

6.2 The rate may differ from mid-market rate.

7. FX TRANSPARENCY

7.1 Where FX applies, customers must be shown:

• exchange rate

• FX margin (where applicable)

• resulting amount

8. USER INTERFACE ALIGNMENT

8.1 The pricing shown in the user interface must match:

• this Schedule

• actual charges

8.2 Any inconsistency is treated as a control issue.

9. PRE-TRANSACTION DISCLOSURE

9.1 Before confirming a transaction, the user must be shown:

• amount sent

• fee

• exchange rate (if applicable)

• amount received

10. EXAMPLE DISCLOSURE FORMAT

Example:

• You send: €1,000

• Fee: €5

• FX rate: 1.085

• Recipient receives: $1,079.58

11. THIRD-PARTY FEES

11.1 Third parties may apply fees, including:

• intermediary banks

• ATM operators

• card scheme participants

11.2 These fees may not be controlled by Digital Capital.

12. LIMITS PRINCIPLES

12.1 Limits may be applied to:

• transactions

• balances

• withdrawals

12.2 Limits may be:

• risk-based

• dynamic

13. DYNAMIC PRICING

13.1 Fees may vary based on:

• risk profile

• volume

• usage

14. PARTNER MODEL (PRICING)

14.1 Where a Partner is involved:

• fees may include a Partner component

14.2 Partner economics must not:

• affect regulatory obligations

• reduce transparency

15. DISCLOSURE OF CHANGES

15.1 Fee changes will be:

• communicated

• reflected in this Schedule

16. REGULATORY POSITION

16.1 Pricing must comply with:

• consumer protection requirements

• transparency standards

17. GOVERNANCE

17.1 Pricing is subject to governance and review.

18. CONTROL FRAMEWORK

18.1 Controls must ensure:

• correct fee application

• correct disclosure

19. MONITORING

19.1 Fees are monitored through:

• MI

• audit

• compliance reviews

20. CONTACT

20.1 For fee-related queries:

info@digi-capital.co.uk

21. OVERVIEW

21.1 This section describes how fees apply in practice.

21.2 It includes:

• payment fees

• card fees

• FX application

• real-world scenarios

22. PAYMENT FEES — GENERAL

22.1 Fees may apply when:

• sending payments

• receiving payments

• processing cross-border transfers

22.2 Fees depend on:

• payment rail (FPS, SEPA)

• currency

• destination

23. FASTER PAYMENTS (UK)

23.1 Faster Payments may:

• be processed near real-time

• be subject to limits

23.2 Fees may:

• be fixed

• be variable

24. SEPA PAYMENTS

24.1 SEPA payments may include:

• SEPA Credit Transfer

• SEPA Instant

24.2 Fees may vary based on:

• speed

• geography

25. CROSS-BORDER PAYMENTS

25.1 Cross-border payments may include:

• FX conversion

• intermediary costs

25.2 These may affect:

• total cost

• timing

26. PAYMENT SCENARIO — DOMESTIC

Example:

• Customer sends £1,000 via Faster Payments

• Fee: £0–£X

• Recipient receives: £1,000 (if no fee)

27. PAYMENT SCENARIO — FX

Example:

• Customer sends €1,000

• Fee: €5

• FX rate applied

• Recipient receives converted amount

28. FAILED PAYMENTS

28.1 Fees may apply where:

• payment fails

• payment is returned

28.2 Causes include:

• incorrect details

• bank rejection

29. CARD FEES — GENERAL

29.1 Fees may apply for:

• card issuance

• replacement

• usage

30. CARD USAGE

30.1 Card transactions may include:

• point-of-sale

• online

• ATM withdrawals

31. ATM WITHDRAWALS

31.1 ATM usage may:

• incur fees

• include third-party charges

32. INTERNATIONAL CARD USE

32.1 Transactions outside base currency may:

• involve FX

• include additional charges

33. FX APPLICATION — DETAILED

33.1 FX applies when:

• transaction currency differs

33.2 FX includes:

• exchange rate

• margin

34. FX DISCLOSURE

34.1 Customers must be shown:

• rate

• fee

• final amount

35. FX SCENARIO

Example:

• Send €1,000

• FX margin applied

• recipient gets converted value

36. DISPUTES AND CHARGEBACKS

36.1 Fees may apply for:

• dispute handling

• chargeback processing

37. EDGE CASE — OFFLINE CARD TRANSACTIONS

37.1 Some card transactions may be processed later.

37.2 This may affect:

• timing

• available balance

38. EDGE CASE — PRE-AUTHORISATION

38.1 Pre-authorisation may:

• reserve funds

• differ from final amount

39. EDGE CASE — DUPLICATE PAYMENTS

39.1 Duplicate payments:

• are user responsibility

40. EDGE CASE — THIRD-PARTY CHARGES

40.1 Third parties may charge:

• ATM fees

• bank fees

41. LIMITS — GENERAL

41.1 Limits may apply to:

• transaction value

• daily usage

42. DYNAMIC LIMITS

42.1 Limits may change based on:

• risk

• behaviour

43. HIGH-RISK TRANSACTIONS

43.1 High-risk transactions may:

• incur additional controls

• be restricted

44. TRANSPARENCY REQUIREMENT

44.1 Customers must be able to:

• understand fees

• before confirming

45. CONSISTENCY CHECK

45.1 Fees must match:

• UI

• backend

46. ROUNDING

46.1 Rounding may apply.

47. TAXES

47.1 Taxes may apply where required.

48. MONITORING

48.1 Fee application is monitored.

49. ERROR HANDLING

49.1 Errors must be corrected.

50. CONTACT

50.1 Fee queries:

info@digi-capital.co.uk

51. USER INTERFACE (UI) ALIGNMENT

51.1 All fees presented to customers must be consistent with:

• this Fees and Limits Schedule

• actual charges applied

51.2 The user interface must not display:

• misleading information

• incomplete pricing

51.3 Any inconsistency between:

• UI

• backend

• legal documentation must be treated as a control failure.

52. PRE-TRANSACTION DISCLOSURE CONTROL

52.1 Before confirming any transaction, customers must be shown:

• the amount to be sent

• the applicable fee

• the exchange rate (if applicable)

• the amount the recipient will receive

52.2 This information must be:

• clear

• accurate

• complete

53. DISCLOSURE VALIDATION

53.1 Systems must ensure that:

• displayed fees match actual fees

• FX rates are correctly applied

• calculations are accurate

53.2 Validation controls must be implemented.

54. ERROR PREVENTION

54.1 Controls must prevent:

• incorrect fee calculation

• incorrect FX application

• inconsistent display

55. ERROR DETECTION

55.1 Errors must be identified through:

• monitoring

• audit

• customer feedback

56. ERROR CORRECTION

56.1 Where an error occurs:

• it must be corrected promptly

• affected customers must be treated fairly

57. CUSTOMER COMMUNICATION

57.1 Where pricing errors affect customers:

• communication must be clear

• remediation must be appropriate

58. GOVERNANCE OF PRICING

58.1 Pricing is subject to governance oversight.

58.2 This includes:

• approval of pricing changes

• monitoring of pricing consistency

59. PRICING CHANGE CONTROL

59.1 Any change to pricing must:

• be reviewed

• be approved

• be documented

60. CHANGE IMPLEMENTATION

60.1 Changes must be:

• implemented consistently

• reflected in all systems

61. ALIGNMENT WITH OTHER DOCUMENTS

61.1 This Schedule must align with:

• Account Terms

• Card Terms

• Fraud Policy

• Website disclosures

62. AUDIT AND MONITORING

62.1 Pricing must be subject to:

• compliance monitoring

• internal audit

63. MANAGEMENT INFORMATION (MI)

63.1 Pricing MI may include:

• fee revenue

• discrepancies

• customer complaints

64. REGULATORY COMPLIANCE

64.1 Pricing must comply with:

• consumer protection requirements

• transparency obligations

65. PARTNER PRICING CONTROLS

65.1 Where Partners are involved:

• pricing must remain transparent

• customer disclosure must not be affected

65.2 Partner economics must not:

• introduce hidden fees

• create misleading pricing

66. THIRD-PARTY FEE DISCLOSURE

66.1 Where third-party fees may apply:

• customers must be informed

• uncertainty must be disclosed

67. LIMITS GOVERNANCE

67.1 Limits must be:

• controlled

• monitored

67.2 Changes must be:

• justified

• documented

68. TRAINING

68.1 Staff must understand:

• pricing structure

• disclosure requirements

69. DOCUMENTATION

69.1 All pricing decisions must be documented.

70. FINAL PROVISIONS

70.1 This Schedule forms part of the overall legal framework.