CLIENTS CLAIMS PROCEDURE


1.1 GENERAL REGULATIONS

AltPay would ensure that at least two different channels are available for complainants to submit their complaints of alleged infringement of Directive (EU) 2015/2366 and that at least one of these channels is easily accessible for all types of complainants.

Company would ensure that at least one of the channels is digital and accessible online, such as an email (info@altpay.uk) or a web form (https://altpay.uk/contacts).

1. AltPay ensures examination of a Customer’s Claim according to Compliance laws, regulations and standards regulating AltPay business sector.
2. This Procedure shall be regularly examined in order to ensure its topicality and compliance to the Compliance laws, regulations and standards. Amendments to this Procedure shall be are approved by the AltPay executive board.
3. When performing obligations under the Procedure, the AltPay employee shall observe not only the internal normative documents of the AltPay but also the Compliance laws, regulations and standards, particularly Law on Payment Service and Electronic Money.
4. When fulfilling obligations under the Procedure, the AltPay employees shall perform their obligations in such a way that does not violate the internal normative documents and the Compliance laws, regulations and standards.
5. The AltPay board shall appoint the Designated employee.
6. The Designated employee is responsible for fulfillment of the requirements set in this Procedure.
7. Procedure of complaint examination:
a. All Customers’ claims must be handled according to this Procedure.
b. The Customer shall submit the Claim to the AltPay in writing. If the AltPay receives a written Claim from the Customer, it examines it and provides the motivated reply according to the below mentioned requirements:
i. The reply to the received Claim must be sent to the Customer not later than within 30 days from the day on which AltPay received the Claim. The said term may be extended if Compliance laws, regulations and standards so allow;
ii. Any Claim, dispute, disagreement or claim deriving from the contractual relationship between the Customer and the AltPay, shall be finally settled by a mutual agreement in writing.


1.2 PROCEDURE OF CLAIM EXAMINATION

Information to be requested from complainants:

AltPay would request from complainants to provide, where possible, information which includes but is not limited to:

1. the identity and contact details of the complainant.
2. an indication of whether the complainant is a natural or a legal person.
3. an indication of whether or not the complainant is a payment service user.
4. the identity of the payment service provider(s) that has/have given rise to the complaint of an alleged infringement of Directive (EU) 2015/2366; and
5. a description of the situation that gave rise to the complaint of an alleged infringement of Directive (EU) 2015/2366.

AltPay would record the information provided by the complainants. Company would make means available for complainants to submit any documentary evidence in support of the complaint, such as a copy of their contract with the AltPay, any correspondence exchanged with the payment service provide and information related to their payment account if relevant.

The Administration registers the Claim on the day when it is received in the AltPay.

The Designated employee:


1. Ensures that the Claim is settled in writing;
2. Ensures due preparation and submission of the replies (not later than within two working days until the end of term for reply submission) to the AltPay executive board member for signing
3. Ensures that the replies to the Claims.
4. Examines the Claims and prepares the reply together with the other employees of the AltPay structural unit (employees) that may give explanations regarding the facts (violations) indicated in the Claim;
5. Establishes and maintains a separate register, where the information on the measures taken regarding the Claims is re

gistered;
6. The reply signed by the AltPay executive board member shall be passed to Administration not later than on the day of reception.
7. All replies to the Claims shall be signed by the AltPay executive board member.
8. The Administration sends the AltPay replies to the customer not later than on the next day after it has received and registered the replies.
9. The Designated employee ensures that the information determined below of the Procedure is available in summarized way in the AltPay and on home page of the AltPay (when it is established) in internet.
Reply to complainants:

When responding to the complainants and, where appropriate, informing them of the existence of alternative dispute resolution procedures in accordance with Article 99(2) of Directive (EU) 2015/2366, AltPay would also provide:

1. an acknowledgment of receipt of the complaint;
2. information on the general competence of the competent authority in respect of the procedure for complaints of alleged infringements of Directive (EU) 2015/2366;
3. information on whether the company has forwarded the complaint to another authority or body, which may be located in the same or in another Member State, and including the name and contact details of that authority or body; and
4. information on either the timing and form of any further communication with the complainant on the alleged infringement of Directive (EU) 2015/2366, or if the reply represents the end of the complaints procedure with the company.

AltPay would send the reply to the complainant without undue delay.

Aggregate analysis of complaints

Company would have a complaints procedure in place that allows for the aggregate analysis of complaints of alleged infringements of Directive (EU) 2015/2366 and enables competent authorities to identify, understand and assess, for a given timeframe:

1. the total number of complaints of alleged infringements of Directive (EU) 2015/2366 received;
2. the nature of the most common types of complainants;
3. the identity of the payment service providers that are most often complained about;
4. the issues and, where possible, the provisions of Directive (EU) 2015/2366 most complained about;5. the payment services most complained about, where possible; and
5. the most common measures taken by the competent authority in response to the complaints received to ensure effective compliance with Directive (EU) 2015/2366.

Company would take into account the aggregate analysis of complaints to ensure and monitor effective compliance according to Directive (EU) 2015/2366.

Documentation of complaints procedures

Company would document its complaints procedures by outlining the procedure for the receipt of complaints submitted by payment service users and other interested parties and the internal governance of that procedure.




Public information on complaints procedures

Company would make publicly available information on its procedures for complaints of alleged infringements of Directive (EU) 2015/2366. This information would be up to date and easily accessible, and include but not be limited to:

1. the objective and scope of the complaints procedures;
2. the channels through which complaints can be submitted, and how to access them;
3. the information that complainants are requested to provide;
4. the sequential steps of the complaints procedures and any deadlines that may apply;
5. the general competence of the competent authority in respect of the procedure for complaints of alleged infringements of Directive (EU) 2015/2366; and
6. the various measures available to the competent authority to ensure and monitor effective compliance with Directive (EU) 2015/2366.

1.3 REGULATORY REQUIREMENTS ON CUSTOMER COMPLAINT HANDLING

Besides the adequate incorporation of the complaint handling with the AltPay’s policies and customer dealing, AltPay ensures following specific parts of the FCA handbook adapted to its company structure and policies.

For the purpose of inc

lusion in the public record maintained by the FCA, AltPay must:

• provide the FCA, at the time of its authorization, with details of a single contact point within the firm for complainants; and
• notify the FCA of any subsequent change in those details when convenient and, at the latest, in the firm's next report under the complaints reporting rules.

AltPay will freely and openly communicate the possibility of the Financial Ombudsman with all customer care correspondents and on its customer support web-site. It will obey to the procedures laid out which comes out of the FCA’s and the Ombudsman’s findings of collected complaints of the company.

As state in the FCA handbook:

These procedures should, taking into account the nature, scale and complexity of the respondent's business, ensure that lessons learned as a result of determinations by the Ombudsman are effectively applied in future complaint handling, for example by:

• relaying a determination by the Ombudsman to the individuals in the respondent who handled the complaint and using it in their training and development;
• analysing any patterns in determinations by the Ombudsman concerning complaints received by the respondent and using this in training and development of the individuals dealing with complaints in the respondent; and
• analyzing guidance produced by the FCA, other relevant regulators and the Financial Ombudsman Service and communicating it to the individuals dealing with complaints in the respondent.

An additional important part of the regulatory requirements is the record keeping of complaints.