Complaints Policy

1. Policy Statement

The Company is committed to maintaining the highest standards of customer service, regulatory compliance, and operational integrity. This Complaints Policy establishes a formal process for receiving, documenting, investigating, and resolving complaints in accordance with Canadian regulatory expectations, including FINTRAC guidance and applicable provincial consumer protection requirements.

2. Purpose

The purpose of this policy is to:

• Provide a clear and accessible mechanism for customers to submit complaints.
• Ensure complaints are handled promptly, fairly, and transparently.
• Maintain compliance with all applicable laws and regulatory obligations.
• Support continuous improvement through monitoring and analysis of complaint trends.

3. Scope

This policy applies to:

• All customers and users of the Company’s services.
• All employees, directors, contractors, and agents.
• All business lines, including currency exchange, remittance, payment services, and digital financial services.

4. Definitions

• Complaint: Any expression of dissatisfaction regarding the Company’s services staff, conduct, fees, delays, or operations.
• Complainant: The individual or entity submitting the complaint.
• Resolution: A formal written response outlining findings and corrective actions.

5. Guiding Principles

• Accessibility: Multiple channels available for submitting complaints.
• Fairness: Objective and unbiased handling of all complaints.
• Timeliness: Acknowledgement and resolution within defined timeframes.
• Transparency: Clear communication throughout the process.
• Compliance: Alignment with FINTRAC, privacy laws, and internal controls.

6. Complaint Submission Channels

Complaints may be submitted through any of the following:

• Email: compliance@acexpay.com
• Telephone: +44 7801 760401
• Mail: Condor House, The street, Bredhurst, Gillingham, Kent, ME7 3JY

Complainants should provide:

• Full name and contact information
• Description of the issue
• Relevant dates, transaction numbers, or supporting documents

7. Complaint Handling Process

7.1 Acknowledgement (Within 5 Business Days)

Upon receipt, the Company will issue an acknowledgement containing:

• Complaint reference number
• Assigned staff member
• Expected timeline for review

7.2 Investigation (Within 14 Business Days)

The Company will:

• Review all relevant documentation
• Contact the complainant for clarification if required
• Consult internal records, staff, or third parties
• Assess any regulatory implications (e.g., AML/ATF concerns)

7.3 Resolution (Within 28 Business Days)

A written resolution will be provided outlining:

• Investigation findings
• Corrective actions taken
• Any remediation or compensation (if applicable)
• Escalation options

If additional time is required, the complainant will be notified in writing.

8. Escalation Options

If the complainant is dissatisfied with the resolution, they may escalate to:

• Senior Management / Compliance Director
• External Ombudsman or Consumer Protection Agency (where applicable)
• FINTRAC for AML/ATF-related concerns
• Provincial regulatory authorities for licensing matters

Contact details will be provided upon request.

9. Record Keeping

The Company will maintain complete records of all complaints for a minimum of 6 years, including:

• Complaint details
• Investigation notes
• All correspondence
• Final resolution
• Any regulatory reporting

Records will be stored securely in accordance with Canadian privacy legislation.

10. Reporting & Oversight

The Compliance Director will conduct quarterly reviews of complaint trends. Significant complaints (fraud, AML concerns, privacy breaches) must be escalated immediately to senior management. Annual summaries will be incorporated into compliance reporting and used to strengthen internal controls.

11. Policy Review

This policy will be reviewed annually, or sooner if required due to regulatory changes, operational updates, or audit findings.

12. Approval