1.1 This document explains your rights and obligations in relation to:

• fraud

• unauthorised payments

• reimbursement

1.2 It forms part of the Account and Payment Services Agreement.

2. PURPOSE

2.1 The purpose of this document is to:

• provide clarity on fraud-related risks

• explain how unauthorised transactions are handled

• set out your responsibilities

• describe our obligations

3. TYPES OF FRAUD

Fraud may include, but is not limited to:

3.1 Account takeover

• unauthorised access to your account

• misuse of credentials

3.2 Card fraud

• stolen or lost cards

• unauthorised card use

3.3 Payment fraud

• manipulation of payment instructions

• impersonation scams

3.4 APP fraud (Authorised Push Payment)

• where you are deceived into making a payment

• social engineering scams

3.5 Identity fraud

• use of false or stolen identity information

4. CUSTOMER RESPONSIBILITIES

4.1 You must:

• keep your credentials secure

• not share authentication details

• use services responsibly

5. SECURITY OBLIGATIONS

You must:

• protect passwords and PINs

• secure devices

• avoid phishing and scams

6. REPORTING OBLIGATIONS

6.1 You must notify us immediately if:

• you suspect fraud

• your account is compromised

• your card is lost or stolen

7. DELAY IN REPORTING

7.1 Delays in reporting may:

• increase losses

• affect your rights

8. COOPERATION

8.1 You must cooperate with investigations, including:

• providing information

• submitting documentation

9. FAILURE TO COMPLY

9.1 Failure to comply with your obligations may:

• limit your rights

• result in liability

10. FRAUD PREVENTION MEASURES

10.1 We may implement:

• transaction monitoring

• authentication controls

• account restrictions

11. RISK-BASED CONTROLS

11.1 We may apply controls based on:

• transaction behaviour

• risk profile

• regulatory requirements

12. TEMPORARY RESTRICTIONS

12.1 We may:

• delay transactions

• block payments

• suspend accounts

13. COMMUNICATION

13.1 We may contact you regarding:

• suspicious activity

• verification requests

14. LIMITATIONS

14.1 Fraud prevention measures may:

• affect transaction speed

• result in declined payments

15. UNAUTHORISED PAYMENTS — DEFINITION

15.1 A payment is considered unauthorised where:

• it was executed without your consent

• you did not approve the transaction

• the payment was initiated fraudulently

16. CUSTOMER OBLIGATION TO NOTIFY

16.1 You must notify us without undue delay if:

• you become aware of an unauthorised payment

• your credentials have been compromised

16.2 Failure to notify promptly may affect your rights.

17. OUR OBLIGATION TO REFUND

17.1 Subject to applicable law, we will:

• refund the amount of an unauthorised payment

• restore your account to the position it would have been in

17.2 Refunds will be processed as soon as reasonably practicable.

18. CONDITIONS FOR REFUND

18.1 A refund will be provided where:

• the transaction is confirmed as unauthorised

• you have complied with your obligations

19. EXCEPTIONS TO REFUND

19.1 We may refuse a refund where:

• you acted fraudulently

• you intentionally authorised the transaction

• you failed to comply with security obligations

20. CUSTOMER LIABILITY

20.1 You may be liable for losses where:

• you acted fraudulently

• you failed to protect your credentials with gross negligence

20.2 In all other cases, liability is limited in accordance with applicable law.

21. SECURITY BREACHES

21.1 Where a payment occurs due to a security breach:

• liability will be assessed based on your conduct

• and the circumstances of the transaction

22. AUTHORISED TRANSACTIONS

22.1 A transaction is authorised where:

• you provided consent

• authentication was completed

22.2 Authorised transactions are not considered unauthorised, even if:

• you later dispute the outcome

• you were dissatisfied with the transaction

23. REFUNDS FOR AUTHORISED PAYMENTS

23.1 You may be entitled to a refund for certain authorised payments where:

• the amount was not known at the time of authorisation

• the amount exceeds what could reasonably have been expected

23.2 This may apply to:

• certain card transactions

• recurring payments

24. REFUND REQUEST REQUIREMENTS

24.1 You must provide:

• transaction details

• supporting information

24.2 We may request additional documentation.

25. TIME LIMITS FOR CLAIMS

25.1 You must notify us within a reasonable timeframe after becoming aware of an issue.

25.2 Delayed claims may impact your rights.

26. INVESTIGATION PROCESS

26.1 We will investigate:

• transaction data

• authentication records

• device and session data

• third-party information

27. PROVISIONAL REFUNDS

27.1 We may provide provisional refunds while investigations are ongoing.

27.2 Such refunds may be reversed if:

• the claim is not upheld

28. REVERSAL OF REFUNDS

28.1 If a refund is granted in error, we may:

• reverse the refund

• recover the amount

29. THIRD-PARTY INVOLVEMENT

29.1 Investigations may involve:

• banks

• payment schemes

• merchants

29.2 Outcomes may depend on third-party processes.

30. FRAUDULENT CLAIMS

30.1 If a claim is found to be fraudulent, we may:

• reject the claim

• take further action

• report to authorities

31. DISPUTES AND ESCALATION

31.1 If you disagree with the outcome:

• you may raise a complaint

• you may escalate to the Financial Ombudsman Service

32. REGULATORY FRAMEWORK

32.1 This section reflects applicable regulatory requirements.

32.2 Where required by law, regulatory provisions take precedence.

33. AUTHORISED PUSH PAYMENT (APP) FRAUD

33.1 APP fraud occurs where:

• you are deceived into authorising a payment

• the payment is made voluntarily but under false pretences

33.2 This may include:

• impersonation scams

• invoice fraud

• investment scams

• social engineering

34. NATURE OF APP FRAUD

34.1 APP fraud differs from unauthorised transactions because:

• you provide consent

• authentication is valid

34.2 As a result, APP fraud is treated differently under applicable law.

35. CUSTOMER RESPONSIBILITIES IN RELATION TO SCAMS

35.1 You must take reasonable steps to:

• verify payment details

• confirm recipient identity

• exercise caution when instructed to make urgent payments

35.2 You should be particularly cautious where:

• payment instructions are changed unexpectedly

• requests are made under pressure

• communication appears suspicious

36. WARNING AND PREVENTION MEASURES

36.1 We may implement measures to prevent scams, including:

• transaction warnings

• confirmation prompts

• additional authentication steps

• payment delays

36.2 You must consider such warnings carefully before proceeding.

37. REPORTING APP FRAUD

37.1 You must notify us immediately if you suspect:

• you have been scammed

• a payment was made under deception

37.2 Early reporting increases the likelihood of recovery.

38. INVESTIGATION OF APP FRAUD

38.1 We will investigate APP fraud cases, including:

• reviewing transaction details

• analysing communication patterns

• contacting receiving institutions where possible

38.2 Investigations may involve third parties.

39. RECOVERY OF FUNDS

39.1 We may attempt to recover funds where possible.

39.2 Recovery depends on:

• timing of the report

• recipient account status

• cooperation of third parties

39.3 Recovery is not guaranteed.

40. REIMBURSEMENT FOR APP FRAUD

40.1 Reimbursement for APP fraud is not automatic.

40.2 Eligibility for reimbursement depends on:

• applicable regulations

• the circumstances of the transaction

• your conduct

40.3 We will assess each case individually.

41. LIMITATIONS ON REIMBURSEMENT

41.1 Reimbursement may be refused where:

• you ignored clear warnings

• you acted with gross negligence

• you failed to take reasonable care

42. INTERACTION WITH PAYMENT SCHEMES

42.1 APP fraud cases may involve:

• payment scheme processes

• interbank cooperation

42.2 Outcomes may depend on scheme rules.

43. OPERATIONAL RESPONSE TO FRAUD

43.1 We may take immediate action where fraud is suspected, including:

• blocking transactions

• freezing accounts

• restricting access

43.2 These actions may occur without prior notice.

44. ACCOUNT RESTRICTIONS

44.1 We may apply restrictions where:

• fraud risk is identified

• investigations are ongoing

44.2 Restrictions may include:

• payment limitations

• account suspension

45. COOPERATION WITH AUTHORITIES

45.1 We may:

• report fraud to authorities

• share information with regulators

45.2 This may occur without your prior consent where required by law.

46. CUSTOMER SUPPORT

46.1 We aim to support customers affected by fraud.

46.2 Support may include:

• guidance

• investigation updates

• assistance with reporting

47. EDUCATION AND AWARENESS

47.1 We may provide information to help customers:

• recognise scams

• avoid fraud

48. FINAL DETERMINATION

48.1 The outcome of a fraud investigation will depend on:

• evidence available

• applicable law

• regulatory requirements

48.2 Our decision may be subject to review through the complaints process.