Customer Grievance Redressal Policy

A. INTRODUCTION

A.1 Les Amis Private Limited (“LAPL”) is engaged in the business of providing technological support and infrastructure for cross-border payments and related compliance requirements and runs a cross border payments platform by the brand name ‘EximPe’.

A.2 The Reserve Bank of India (“RBI”) vide notification dated October 31, 2023 “Regulation of Payment Aggregator – Cross Border” (“PA-CB Guidelines”) issued vide CO.DPSS.POLC.No.S-786/02-14-008/2023-24 read with the “Guidelines on Regulation of Payment Aggregators and Payment Gateways, 2020” issued vide DPSS.CO.PD.No.1810/02.14.008/2019-20, 17 March 2020, (the "PA Guidelines”) has laid out regulations for all Payment Aggregators – Cross Border (“PACB”) to ensure that a suitable mechanism is in place for receiving and addressing complaints from its customers with specific emphasis on resolving such complaints fairly and expeditiously regardless of source of the complaints.

A.3 This Grievance Redressal Policy has been formulated in light of the above-mentioned laws read with ‘Harmonization of Turnaround Time and customer compensation for failed transactions using authorized Payment Systems dated September 20, 2019’ and ‘ODR System for Digital Payments dated August 6, 2020’ and Integrated Ombudsman Scheme, 2021 to provide Customers adequate facilities to lodge and escalate their grievances, concerns and queries with EximPe and to provide a speedy and effective redressal mechanism for the same.

B. DEFINITION

In this Grievance Redressal Policy, the following words and expressions shall have the following meanings, unless the context otherwise requires:

• B.1 Customers: An end-consumer who makes payment to a merchant via EximPe's payment platform.
• B.2 Merchants: An Indian or foreign seller whose payments are processed through EximPe.
• B.3 Grievance: Any discrepancy between the service levels promised by EximPe and what is actually delivered, encompassing both technical issues and communication errors.

C. PRINCIPLES AND OBJECTIVES OF GRIEVANCE REDRESSAL

• Human-Centric Innovation: EximPe is committed to innovating with a focus on the needs and experiences of our Customers. This dedication guides our development of secure and efficient solutions.
• Prompt & Courteous Handling: : We ensure all grievances are addressed quickly, aiming for initial response times within 24 hours, and handled with the utmost respect and courtesy.
• Efficient Resolution: EximPe pledges to resolve issues effectively and within clearly defined timelines, ensuring Customer satisfaction
• Fair & Equal Treatment: EximPe practices fairness and impartiality in handling all Customer issues, ensuring an unbiased approach in every interaction.
• Clear Channels: Customers are informed about the various channels available for submitting and escalating complaints through our website and Customer communications.
• No Charges for Filing Complaints: Lodging a complaint is free, emphasizing our commitment to accessible service.
• Continuous Improvement in Grievance Handling: We consistently seek to innovate and enhance our grievance redressal mechanisms for quicker and more effective resolutions
• Employee Commitment: Our team is trained to act in good faith, prioritizing customer interests, and upholding the highest standards of service integrity

D. APPLICABILITY

The Grievance Redressal Policy outlines a structured grievance redressal mechanism for the resolution of the grievances of the Customers on EximPe and informs the Customers of this mechanism of grievance redressal. This policy outlines the grievance redressal procedures for disputes that may arise during the course of the business conducted by EximPe. The 3 (three) levels of grievance redressal are:

• The Customer Service Team
• The Operations Head
• The Nodal Officer
• The RBI Integrated Ombudsman

The policy is relevant to all EximPe Customers and covers all products and services offered by EximPe in the realm of cross-border payment aggregation. This ensures a uniform approach to grievance handling across various EximPe company levels and customer interactions, maintaining consistency and efficiency in our service standards

E. TEAM SENSITIZATION ON HANDLING COMPLAINTS

EximPe is committed to exceptional grievance handling through comprehensive team training. Our training modules focus on empathy, effective communication, problem-solving, and in-depth understanding of company policies. We conduct these sessions regularly to keep our team updated with the latest in customer service excellence.

We also integrate customer feedback into our training programs, enabling continuous improvement. The performance of our team in addressing grievances is closely monitored, and insights gained are used to refine training strategies

This training regimen is aimed at achieving first-time resolution of customer issues, thereby building trust and enhancing overall customer satisfaction. The impact of this training is evident in both our operational efficiency and the quality of our customer interactions.

F. GOVERNANCE FRAMEWORK

F.1 Grievance Redressal Committee

The Grievance Redressal Committee at EximPe plays a pivotal role in maintaining high standards of customer service. Comprised of members from key areas of EximPe, the committee convenes monthly to meticulously review customer complaints and suggestions.

Their tasks incllude

• (a) Analyzing Complaints: Studying the nature, number, and patterns of complaints to identify systemic issues and trends.
• (b) Improving Service Quality: Developing strategies and action plans based on these insights to enhance overall customer service.
• (c) Ensuring Accountability: Reviewing staff responses to complaints to ensure effective resolution and accountability
• (d) Management Reporting: Regularly reporting findings and recommendations to senior management for further action.
• (e) Incorporating Feedback: Integrating customer feedback into their analyses to continually refine customer service practices.

F.2 Nodal Officer

At EximPe, the role of the Nodal Officer is assigned to the Key Account Manager. This position entails:

• (a) Leadership in Complaint Handling: Ensuring the implementation of customer service and complaint handling guidelines as directed by senior committees.
• (b) Representative Role: Acting as the primary point of contact for the Ombudsman and other external entities in matters related to customer complaints.
• (c) Accessibility to Customers: The Key Account Manager’s contact information will be clearly displayed on the website, providing customers with a direct line for grievance escalation
• (d) Reporting and Coordination: Regularly updating senior management about grievance handling status and any significant customer issues.
• (e) Collaboration with Customer Service: Working closely with the Customer Service Team to ensure efficient and effective resolution of customer grievances.

G. REGISTRATION AND TRACKING OF COMPLAINTS

EximPe enables its Customers to register a complaint using any of the following mechanism:

G.1 Information Required from Customers

Customers will be required to necessarily provide the following details while communicating with EximPe:

• (a) Customer Full Name
• (b) Email Address
• (c) Transaction ID
• (d) Transaction Date
• (e) Merchant Name
• (f) Amount
• (g) Issue Type
• (h) Issue Details

G.2 Unique Reference Number

Each complaint is assigned a unique reference number and shared with the Customer for future reference and monitoring.

G.3 Resolution Coordination

Appropriate steps will be taken via coordination with technology, risk, acquiring bank, and merchant partners as applicable.

G.4 Redirection & Status

For Customer grievances that cannot be addressed by EximPe, the Customer shall be redirected to the relevant Bank/Payment Gateway for appropriate action. These complaints could be related to product liability, delivery, fraud claims (i.e., matters beyond the scope of EximPe)

Complaints are tracked through various statuses including Open, Investigation, Pending Customer, Resolved, and Escalated to ensure transparency and accountability

If a customer does not respond to requests for additional information within the specified timeframe, the complaint may be deemed closed. Customers retain the right to reopen such complaints by providing the required information.

H. GRIEVANCE REDRESSAL AND RESOLUTION

EximPe shall have a three-tier escalation mechanism for handling Customer grievances.

Note: Complaints are automatically escalated to the next level if the turnaround time is exceeded. The Customer can approach the Ombudsman if appropriate resolution is not received within 30 days in line with RBI Integrated Ombudsman Scheme, 2021.

H.1 Level I (Primary Level) – Customer Service Team

EximPe has a Customer Service Team responsible for handling Customer complaints. Customers can contact the team on any channels in Section H. The helpline is available 10AM–6PM on business days.

• (a) Acknowledgement: Complaints received by email, Freshdesk support ticket, Whatsapp or through the helpdesk numbers (channels mentioned above in Section H) shall be acknowledged within 24 hours by an immediate system generated response or via individual emails to the extent possible. The customer will also be kept informed of the action taken, the progress while redressing grievances, and/or, the reasons for delay if any, in redressing. The turnaround time or expected time for resolution will also be communicated to the Customer A ticket reference number will be created for the customer complaint. The customer can track updates on their request using the link attached to the ticket number that will be mentioned in the communication E-mails.
• (b) Resolution: The Customer Service Team shall initiate follow up queries (if needed) within 48 hours of complaint being registered. All complaints received will be resolved within 3 working days. In case any complaint takes more than the specified resolution time, the Customer will be intimated accordingly and kept updated on the progress / status of the complaint on a periodic basis till such time that the complaint is not resolved. All of this would be available within the complaints reference number in our systems.
• (c) Escalation: In case the customer does not receive a response within the specified time at Level I or if the customer is unsatisfied with the response received from the organization, the customer may escalate the complaint to the next level as indicated below.

H.2 Level II (Secondary Level) – Operations Head

Unresolved or unsatisfactory complaints can be escalated to the Operations Head (primary mode: escalation form).

• (a) Acknowledgement: All escalations received would be acknowledged within 24 hours. The customer will also be kept informed of the action taken, the progress while redressing grievances, and/or, the reasons for delay if any, in redressing. The turnaround time or expected time for resolution will also be communicated to the Customer.
• (b) Resolution: A resolution for all escalations would be provided within 10 working days. In case any escalation takes more than the specified resolution time, the customer will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is not resolved. All of this would be available within the escalation reference number in our systems.
• Note: Note: Customer will be required to approach Level II with a previous Ticket Request Number. The complaint history will be accessible by the team using such Ticket Request Number.
• (c) Escalation: In case the customer does not receive a response within the specified time at Level II or if the customer is unsatisfied with the response received from the organization, the customer may escalate the complaint to the next level as indicated below.

H.3 Level III (Third Level) – Nodal Officer

The Nodal Officer can be contacted via phone (during business hours: 10AM-6PM), email, written correspondence, or walk-in support. All communications are logged in the grievance tracking system.

• (a) Acknowledgement: All escalations received would be acknowledged within 24 hours. The customer will also be kept informed of the action taken, the progress while redressing grievances, and/or, the reasons for delay if any, in redressing. The turnaround time or expected time for resolution will also be communicated to the Customer.
• (b) Resolution: A resolution for all escalations would be provided within 10 working days. In case any escalation takes more than the specified resolution time, the customer will be intimated accordingly and kept updated on the progress / status of the escalation on a periodic basis till such time that the escalation is not resolved. All of this would be available within the ticket reference number in our systems

Note: Since this is a Level III escalation, giving a first call resolution on the phone might not be possible. Customer will be required to approach Level III with a previous ticket Request Number. The complaint history will be accessible by the team using such ticket Request Number.

H.4 RBI Integrated Ombudsman

The customer may appeal to the RBI Ombudsman under the RBI Integrated Ombudsman Scheme, 2021 if resolution is not achieved within 30 days or the customer remains unsatisfied. EximPe will acknowledge Ombudsman complaints within stipulated timeframes, provide comprehensive written responses within 15 days, and ensure full compliance with Ombudsman awards within 30 days.

For additional details and FAQs, please click: RBI Integrated Ombudsman Scheme, 2021

Further, a complaint can be registered on: https://cms.rbi.org.in/cms/indexpage.html#eng.

I. GRIEVANCE REDRESSAL MECHANISM FOR FAILED TRANSACTIONS

I.1 EximPe has put in place a process to address all customer grievances in relation to failed transactions due to failure in communication links, time-out of sessions etc. (transactions charged to Customer / Buyer but not returned to the EximPe and, in turn, to Customer, hence no services are rendered). However, if failure can be attributed to the Customer, then the same shall not qualify as a failed transaction. The Customer should ensure that the credentials are kept secure and confidential. Grievances related to failed transactions can be lodged through email or website. In the event of a consumer encountering a failed transaction, the Customer is advised to try again after some time provided money has not been debited from the account balance.

In instances of failed transactions where an account has been debited, Customers are advised to promptly report the issue to EximPe. EximPe will adhere with and where EximPe utilizes a payment gateway provider for executing domestic transfers, it is the responsibility of this provider to adhere to the RBI's guidelines on 'Harmonization of Turnaround Time (TAT) and Customer Compensation for Failed Transactions' as outlined in the RBI circular DPSS.CO.PD No. 629/02.01.014/2019-20 dated September 20, 2019. As per the RBI guidelines, the payment gateway provider shall initiate auto-reversal of failed transactions within T+5 days (where T is the transaction date) for all payment methods including Card, UPI, and Net Banking. In case of delay beyond T+5 days, compensation of ₹100/- per day shall be automatically credited to the customer's account

Customers should use the established complaint registration channels and escalation matrix as detailed in Sections H and I of this document. EximPe collaborates closely with the payment gateway provider to ensure timely resolution of these issues, in compliance with the specified RBI timelines. Customers are advised to wait for T+5 days for auto-reversal before lodging a complaint. If auto-reversal and applicable compensation are not received within the prescribed timeline, customers should immediately escalate through the channels mentioned in Section H

Use complaint channels and escalation matrix in Sections H and I. EximPe collaborates with gateway providers to ensure timely resolution within RBI timelines.

J. CHARGEBACK RESOLUTION

J.1 A chargeback is a charge for goods or services not received by the buyer and his bank debited to his UPI/Credit/Debit Account. The buyer has the option to file a chargeback for the same with his card issuing bank.

J.2 Chargebacks are high priority issues and are handled as detailed hereinafter. Broadly, where a customer has reached out to the Issuing Bank/other institution and has disputed the transaction made by them using his/her payment mode/mechanism on the merchant site, the following process is followed:

• (a) The acquiring partner sends us a dispute notification to determine the validity of the transaction and we create a dispute corresponding to such transaction(s) in our system.
• (b) Upon receiving such notification from the bank, EximPe notifies the merchant with the dispute details to submit such supporting documents. The list of type of disputes and documents needed is mentioned in Annexure 2.
• (c) Once the merchant uploads such documents for evaluation, EximPe further submits them to the banks for their review.
• (d) The banking partner analyses the evidence/documents and determines whether the services are delivered by the merchant as promised.

J.3 Chargeback Outcomes

Dispute reason codes and categories: see Annexure 1.

K. REFUNDS

Customers may request a refund from the merchant due to reasons such as the non-delivery of goods or poor service quality. Merchants can initiate refunds against transactions with EximPe, which are posted to the original method of payment unless otherwise agreed by the end Customer. Credits for such refunds or reversals shall be routed back through partner PA’s Escrow account or EximPe’s escrow account (as applicable).

K.2 Refund Processing Timelines

• (a) Refund requests are not accepted after 120 days from transaction date unless supported by acquiring partners.
• (b) Once initiated with the bank, refunds generally reflect in 5–7 working days; actual timelines vary by stakeholders.

K.3 Refund Process Flow

When a merchant requests a refund for a transaction, the following process is followed:

1. Merchant Request: The merchant submits a refund request to EximPe for the specific transaction.
2. Notification to Domestic PA: EximPe informs its domestic Payment Aggregator (PA) partner about the refund request.
3. Bank Intimation: The domestic PA notifies its acquiring bank to initiate the refund.
4. Refund to Customer: The acquiring bank processes the refund amount and routes it back to the customer through the original method of payment (e.g., card, UPI, net banking).
5. Confirmation from PA: Once the bank confirms that the refund has been processed successfully, this confirmation is shared with the domestic PA, who then communicates it back to EximPe.
6. Merchant Settlement Adjustment: After receiving the confirmation, EximPe notifies the merchant regarding the completed refund. The refund amount is then deducted from the next settlement to the merchant and adjusted with the relevant parties involved in the transaction.

L. SOME REGULARLY OCCURRING ISSUES AND THE PROCESS OF DEALING WITH THEM

• (a) Poor-quality product not meeting expectations
• (b) Wrong product delivered
• (c) Extra charges levied for services
• (d) Billing errors
• (e) Fraudulent/unauthorized transaction

All the above go through the chargeback and refund resolution process in Sections J and K.

M. REPORTING REQUIREMENTS

Following reports shall be submitted to the Board on an annual basis:

• (a) Statement of all complaints with analysis
• (b) Root cause analysis of top five complaint categories
• (c) Results of annual customer satisfaction survey
• (d) Gaps in implementing customer service code of conduct
• (e) Recommended changes in products/services/procedures
• (f) Position of complaints with Banking Ombudsman / Consumer Courts (if any)
• (g) Any adverse media reporting related to customer service
• (h) Customer service impact due to unplanned IT downtime or BCP failures

N. RECORD KEEPING

In line with Master Direction – Know Your Customer (KYC) Direction, 2016, EximPe shall preserve records of Customer complaints and the resolution offered shall be maintained for a minimum period of five years from the date of resolution. EximPe shall evolve a system for proper maintenance and preservation of complaint records in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.

O. POLICY REVIEW

The policy is reviewed on an annual basis and updated to incorporate changes as per RBI Guidelines. All updates/changes to the Policy will be communicated to the relevant staff/relevant stakeholders on a periodic basis. All such changes /modifications will be reported to the Board for approval.

In the event of any conflict between the provisions of this policy and applicable RBI guidelines or any other statutory enactments, rules, the provisions of the applicable RBI guidelines or statutory enactments, rules shall prevail over and automatically be applicable to this policy and should be read in tandem with the provisions of the policy. The relevant provisions of the policy would be amended/modified in due course to make it consistent with the applicable law. Any deviations from the procedures specified in this policy shall be permitted only with the approval of Nodal Officer, the details of the deviation shall in the immediately following Board meeting be placed before the Board for scrutiny. However, no approvals shall be granted where such a deviation results in breach of any circular, direction, order or guidelines issued by any regulatory authority including the RBI.

ANNEXURE 1 — Reason Codes for Various Supported Networks

(A) VISA Reason Codes

(B) MASTERCARD Reason Codes

(C) AMEX Reason Codes

(D) DINERS Reason Codes

(E) DISCOVER Reason Codes

(F) RUPAY Reason Codes

(G) UPI Reason Codes