Complaints Handling Policy

Pan-Asia Payment Company Limited (泛亞收付通有限公司) (the "Company") values feedback from customers and the public. This Policy explains the channels, procedures and timeframes through which the Company receives, handles and responds to complaints, and the avenues available to you if you are dissatisfied with our handling of a matter.

Establishing and publishing a complaints handling mechanism also forms part of the Company's response to the supervisory expectations of the Hong Kong Customs and Excise Department in relation to the internal controls of money service operators. This Policy is a unilateral public disclosure and is not a contract. It creates no rights or obligations beyond those arising under applicable law and any written agreement executed between the Company and its customers.

For the purposes of this Policy, a complaint is any expression of dissatisfaction by any person concerning the Company's services, procedures, charges, staff conduct or handling of a matter, where a response or action from the Company is expected, including without limitation:

• delay in, error in, or failure to execute the processing of a transaction;
• charges levied or exchange rates applied that differ from the customer's understanding;
• objection to the suspension of an account, the refusal of a transaction or the termination of a business relationship;
• dissatisfaction with the service attitude, professional standard or communication of the Company's staff;
• dissatisfaction with the way the Company handles personal data;
• questions as to the accuracy of information published by the Company, including website content.

You may submit a complaint through any of the following channels:

• Email: [email protected] (please mark the subject line "Complaint");
• Post: Unit 519, 5/F, East Ocean Centre, 98 Granville Road, Kowloon, Hong Kong (please mark the envelope "Complaint");
• Relationship manager: existing customers may also raise a complaint directly with their relationship manager, who is required by this Policy to refer it to the responsible department for registration.

So that we can deal with your complaint effectively, please provide so far as possible:

• your name and contact details (email and telephone);
• if you are a customer, the company name and the account or customer number;
• a description of the matter complained of, including the date and sequence of events;
• where a specific transaction is involved, the transaction date, amount, currency and transaction reference number;
• any relevant supporting documents or correspondence;
• the outcome or resolution you are seeking.

The Company handles complaints in accordance with the following procedure and timeframes:

• Step 1 — Acknowledgement (within 2 business days of receipt): registration of the complaint in the complaints register, allocation of a complaint reference number, and acknowledgement to you identifying the department handling the matter;
• Step 2 — Investigation (within the response timeframe): review of relevant transaction records, correspondence and system logs; enquiries with relevant departments and staff; where necessary, enquiries with correspondent banks or service providers;
• Step 3 — Review (within the response timeframe): review by a person not involved in the matter complained of; complaints concerning a compliance decision are reviewed by the Compliance Officer;
• Step 4 — Written response (within 30 days of receipt): a written response (by email or letter) setting out the findings, the facts and reasons relied on, the action proposed, and the escalation avenues available if you remain dissatisfied;
• Step 5 — Closure and follow-up (after the response is issued): recording of the outcome and any remedial measures taken, and filing of the case.

The Company applies the following principles in handling complaints:

• Fairness and objectivity: complaints are handled on the basis of facts and records, without preconception;
• Independent review: a complaint is not finally determined by the person directly responsible for the matter complained of; complaints concerning compliance decisions are reviewed independently by the compliance function;
• No charge: the Company does not charge any fee for handling a complaint;
• Confidentiality: the contents of a complaint and your personal data are used only for handling the complaint and discharging legal obligations, and are handled in accordance with the Company's Privacy Policy;
• No retaliation: the Company will not treat any person adversely because that person has made a complaint; where an investigation reveals that a complaint involves false statements or abuse of process, the Company reserves the right to take appropriate action;
• Consistency: complaints of the same nature are handled to consistent standards.

If you are dissatisfied with our first response, you may request a review in writing within 30 days of receiving it, setting out the specific reasons why you do not accept it. The review will be conducted by the Compliance Officer or a senior officer designated by management, who will respond to you in writing within 30 days of receiving the request for review.

At whatever stage the Company's internal procedure has reached, you are entitled to raise the matter with the bodies below. Nothing in this Policy restricts your right to pursue legal remedies:

• Hong Kong Customs and Excise Department (Money Service Supervision Bureau): matters concerning the Company's operations and compliance as a licensed money service operator;
• Office of the Privacy Commissioner for Personal Data (www.pcpd.org.hk): matters concerning the collection, use, disclosure or security of personal data;
• Consumer Council (www.consumer.org.hk): where you raise a dispute in the capacity of a consumer;
• Hong Kong Police Force: where possible criminal conduct such as fraud is involved;
• The courts, or a mediation / arbitration body agreed by the parties: disputes concerning contractual rights.

The Company maintains a complaints register recording, for each complaint, the date of receipt, the complainant, the matter involved, the course of the investigation, the outcome, the date of response and any remedial measures taken. Complaint records are retained for not less than five years from the date of closure, to support regulatory review, licence renewal review and internal audit.

The compliance function reports periodically (at least annually, or more frequently at management's request) to management and the board on the number, categories and trends of complaints and any systemic issues they reveal, together with recommendations for improvement.

You may submit a complaint in Chinese or English, and we will respond in the same language. This Policy is provided in both Chinese and English. In the event of any ambiguity or inconsistency between the two versions, the Chinese version shall prevail.

The Company reviews this Policy at least annually and amends it where required by changes in law, supervisory expectations or internal processes. The amended version takes effect upon publication on the Company's website, and the effective date will be stated at the beginning of the document.