Complaint Handling & Escalation Policy

Last Updated: April 1, 2026

1. Purpose

The purpose of this Complaint Handling & Escalation Policy is to establish a structured, transparent, and fair framework for receiving, investigating, resolving, and documenting complaints relating to TransactBridge’s services.

As a global Merchant-of-Record and cross-border payments platform operating in a regulated financial environment, TransactBridge is committed to:

• Ensuring complaints are handled promptly and objectively
• Maintaining accountability and internal oversight
• Complying with applicable financial services, consumer protection, and data protection laws
• Identifying and mitigating systemic risks through complaint analysis
• Promoting trust, integrity, and responsible financial operations

This Policy supports TransactBridge’s broader risk management, compliance, and governance framework.

2. Scope

This Policy applies to all complaints relating to TransactBridge’s services, operations, or decisions in connection with its Merchant-of-Record, payment processing, compliance, risk management, and related activities.

It applies to complaints submitted by:

• Customers (end users purchasing through TransactBridge-powered checkout)
• Merchants and merchant applicants
• Business partners and service providers
• Individuals whose Personal Data is processed by TransactBridge
• Other stakeholders interacting with TransactBridge

This Policy covers complaints concerning, but not limited to:

• Payment processing errors or transaction issues
• Refund handling and settlement matters
• Chargebacks and dispute management
• Account restrictions, suspensions, or terminations
• Compliance, KYC/KYB, AML, or sanctions-related decisions
• Data protection or privacy concerns
• Service quality related to TransactBridge’s regulated role

This Policy does not apply to purely commercial disputes between a merchant and its customer that do not involve TransactBridge’s payment or compliance functions.

3. Definition of a Complaint

For the purposes of this Policy, a complaint is any expression of dissatisfaction, whether oral or written, from a customer, merchant, applicant, partner, or other stakeholder, relating to:

• A product or service provided by TransactBridge;
• A decision made by TransactBridge (including compliance, underwriting, risk, or account actions);
• The failure to provide a service; or
• The conduct, communication, or operational performance of TransactBridge or its representatives.

A complaint may be submitted through any communication channel, including email, support tickets, written correspondence, or other documented means.

The following are generally not considered complaints under this Policy:

• Routine service inquiries or status requests;
• Requests for information or clarification;
• Technical support questions not involving dissatisfaction;
• Commercial disputes solely between a merchant and its customer that do not relate to TransactBridge’s regulated payment or compliance functions.

Where there is uncertainty as to whether a matter constitutes a complaint, TransactBridge will exercise reasonable judgment in determining whether it should be handled under this Policy.

4. How to Submit a Complaint

TransactBridge accepts complaints through the following channels:

Email: support@transactbridge.com

Website: www.transactbridge.com

Complaints should include sufficient information to enable proper investigation, including:

• Full name of the complainant
• Contact details (email and/or phone number)
• Merchant ID, Transaction ID, or account reference (if applicable)
• A clear description of the issue
• Relevant dates and supporting documentation

Incomplete information may delay investigation.

Complaints may be submitted by an authorized representative, provided appropriate authorization documentation is supplied.

Anonymous complaints may be reviewed; however, the absence of identifying information may limit our ability to investigate or respond fully.

TransactBridge may require identity verification before disclosing account-specific information to protect data privacy and security.

5. Complaint Handling Process

TransactBridge maintains a structured internal process to ensure complaints are handled fairly, consistently, and in accordance with applicable legal and regulatory requirements.

5.1 Receipt & Logging

Upon receipt of a complaint:

• The complaint will be formally logged in TransactBridge’s internal complaint register.
• A unique reference number may be assigned.
• The date of receipt, complainant details, and nature of the complaint will be recorded.

Complaints are classified based on subject matter (e.g., payments, compliance, underwriting, data protection, fraud, service quality) and risk level.

5.2 Acknowledgment

TransactBridge aims to acknowledge receipt of a complaint within 2–5 business days.

The acknowledgment may include:

• Confirmation of receipt
• The assigned reference number
• An outline of next steps
• An estimated timeframe for response

5.3 Investigation

Each complaint is reviewed objectively and independently by appropriate personnel, which may include:

• Customer support
• Risk management
• Compliance team
• Finance or settlement operations
• Legal team (where necessary)

The investigation may involve:

• Reviewing transaction logs and system records
• Assessing contractual terms
• Reviewing compliance documentation
• Consulting acquiring banks or payment partners
• Requesting additional information from the complainant

Where the complaint relates to regulatory obligations (e.g., AML or sanctions), certain information may be legally restricted from disclosure.

5.4 Resolution & Response

TransactBridge aims to provide a substantive response within:

• 15 business days for standard complaints;
• Up to 30 business days for complex, cross-border, or compliance-related matters.

If additional time is required, the complainant will be informed of the reason for the delay and the expected response timeframe.

The final response will generally include:

• A summary of the investigation
• The decision reached
• Any corrective action taken (if applicable)
• Information regarding escalation options

5.5 Documentation & Recordkeeping

All complaints and related communications are documented and retained in accordance with TransactBridge’s Data Retention Policy and applicable regulatory requirements.

Complaint data may be analyzed to:

• Identify systemic issues
• Improve operational controls
• Strengthen compliance processes
• Monitor risk trends

Senior management may periodically review complaint metrics as part of governance oversight.

6. Escalation Process

If a complainant is dissatisfied with the initial response provided by TransactBridge, the complaint may be escalated for further review in accordance with the process outlined below.

6.1 Internal Escalation

A complainant may request escalation within 14 calendar days of receiving the initial response.

Upon escalation:

• The complaint will be reviewed by a senior member of the Compliance, Risk, or Legal team who was not directly involved in the initial investigation (where reasonably practicable).
• A secondary review of all relevant documentation, system records, and applicable contractual terms will be conducted.
• Additional information may be requested from the complainant if necessary.

TransactBridge aims to provide a final internal response within 15–30 business days, depending on complexity.

The outcome of the escalation review will be communicated in writing and will generally represent TransactBridge’s final position.

6.2 Regulatory & External Escalation

If the complainant remains dissatisfied after internal escalation, they may have the right to pursue external remedies, including:

• Filing a complaint with a competent financial services regulator in the relevant jurisdiction;
• Submitting a complaint to a data protection authority (for privacy-related matters);
• Seeking resolution through consumer protection agencies, ombudsman schemes (where applicable), or courts of competent jurisdiction.

Nothing in this Policy restricts or limits any statutory or regulatory rights available to the complainant under applicable law.

6.3 AML & Regulatory Restrictions

Where a complaint relates to:

• Anti-Money Laundering (AML) investigations;
• Sanctions screening outcomes;
• Suspicious activity reporting;
• Regulatory reporting obligations;

TransactBridge may be legally prohibited from disclosing certain information. In such cases:

• Decisions made pursuant to mandatory legal obligations may not be reversible through the complaint process;
• Disclosure may be limited to what is legally permissible;
• Regulatory reporting decisions are handled in accordance with applicable financial crime laws and are not subject to negotiation.

7. Regulatory & AML Restrictions

TransactBridge operates within a regulated financial environment and is subject to applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), sanctions, fraud prevention, tax reporting, and other regulatory obligations across multiple jurisdictions.

Where a complaint relates to:

• Account suspension or termination
• Transaction blocking or reversal
• Sanctions screening outcomes
• Suspicious activity monitoring
• Enhanced due diligence (EDD) requirements
• Regulatory reporting or law enforcement requests

TransactBridge may be legally restricted from disclosing certain information.

In particular:

• We may be prohibited from informing individuals whether a suspicious activity report (SAR) or equivalent filing has been made.
• We may not disclose specific fraud detection methodologies, internal risk scoring criteria, or sanctions screening logic.
• Certain decisions required by law, regulation, card network rules, or financial institution partners may not be subject to reversal through the complaint process.

Where disclosure is legally limited, TransactBridge will provide as much information as permitted under applicable law while maintaining compliance with confidentiality and regulatory obligations.

Nothing in this Policy overrides TransactBridge’s legal duty to comply with applicable financial crime, sanctions, or regulatory requirements.

8. Complaint Records & Reporting

TransactBridge maintains formal complaints register in which all complaints are recorded, tracked, and monitored in accordance with applicable regulatory and governance standards.

8.1 Complaint Register

For each complaint received, TransactBridge records, where applicable:

• Date of receipt
• Complainant details
• Nature and category of complaint
• Associated account or transaction reference
• Risk classification
• Actions taken during investigation
• Resolution outcome
• Date of final response

Records are maintained in a secure environment with restricted access controls.

8.2 Retention of Complaint Records

Complaint records are retained in accordance with TransactBridge’s Data Retention Policy and applicable financial, regulatory, and statutory requirements. Retention periods may vary depending on jurisdiction and the nature of the complaint.

8.3 Regulatory Reporting

Where required by law or regulatory obligation, TransactBridge may:

• Report complaint statistics to competent authorities;
• Disclose complaint information during regulatory audits or supervisory reviews;
• Maintain records to demonstrate compliance with consumer protection and financial services requirements.

8.4 Monitoring & Governance Oversight

Complaint data is periodically reviewed by senior management and/or compliance personnel to:

• Identify systemic or recurring issues;
• Detect operational or compliance weaknesses;
• Improve internal controls and risk management frameworks;
• Enhance customer and merchant experience.

Complaint trends may be incorporated into broader risk management and compliance reporting processes.

9. Non-Retaliation

TransactBridge is committed to ensuring that individuals who submit complaints in good faith are treated fairly and without retaliation.

Submitting a complaint will not, by itself, result in:

• Account suspension or termination;
• Adverse commercial treatment;
• Denial of services otherwise lawfully available; or
• Discriminatory or punitive action.

All complaints are assessed objectively and independently of the complainant’s relationship with TransactBridge.

However, this commitment does not prevent TransactBridge from taking legitimate action where:

• Fraudulent, abusive, or malicious conduct is identified;
• There is a breach of applicable Terms, agreements, or Acceptable Use Policies;
• Regulatory or legal obligations require action (including AML, sanctions, or risk controls).

Any such actions are based solely on objective risk, compliance, or contractual considerations and are not taken in retaliation for submitting a complaint.

10. Continuous Improvement

TransactBridge is committed to continuously improving its complaint handling framework as part of its broader governance, risk management, and compliance program.

Complaint data is periodically analyzed to:

• Identify recurring or systemic issues;
• Detect operational, technical, or compliance weaknesses;
• Improve internal controls and procedures;
• Enhance customer and merchant experience;
• Strengthen fraud prevention and risk mitigation measures.

Where material trends or control gaps are identified, corrective actions may include:

• Process enhancements;
• Staff training and awareness programs;
• Policy updates;
• System improvements;
• Risk framework adjustments.

Senior management and relevant compliance personnel may review complaint metrics and trends as part of ongoing oversight and governance reporting.

This continuous review process supports TransactBridge’s commitment to regulatory compliance, operational resilience, and responsible financial services practices.

11. Policy Updates

TransactBridge may update this Complaint Handling & Escalation Policy from time to time to reflect:

• Changes in applicable laws, regulations, or regulatory guidance;
• Updates to internal governance, risk management, or compliance frameworks;
• Operational or structural changes within TransactBridge;
• Enhancements to complaint handling procedures.

The most current version of this Policy will be published on our website with an updated “Last Updated” date.

Where required by applicable law or regulatory obligation, TransactBridge may provide additional notice of material changes.

Continued use of TransactBridge’s services after publication of an updated Policy constitutes acknowledgment of the revised version, subject to any mandatory legal requirements.