Grievance Redressal Policy

Introduction

Effective Date: [●]

Last Updated: [●]

GlocalPe [FULL LEGAL ENTITY NAME] (“GlocalPe”, “we”, “us” or “our”) is committed to handling complaints fairly, transparently and within reasonable timeframes.

This Policy applies to complaints relating to GlocalPe Services, including:

• cross-border payments;
• international collections;
• transaction processing;
• FX and currency conversion;
• settlement and payouts;
• transaction failures;
• refunds and reversals;
• account access;
• KYC / KYB;
• transaction restrictions;
• fees and charges;
• technical issues;
• security concerns;
• other Services provided through GlocalPe.

1. PURPOSE

The purpose of this Policy is to provide a clear mechanism for:

• receiving complaints;
• acknowledging complaints;
• investigating complaints;
• coordinating with relevant Payment Partners;
• communicating outcomes;
• providing escalation mechanisms;
• identifying recurring issues;
• improving GlocalPe Services.

2. OUR COMMITMENT

GlocalPe seeks to ensure that complaints are:

• accessible to customers;
• acknowledged appropriately;
• handled objectively;
• investigated based on available information;
• resolved within applicable timelines;
• communicated clearly;
• escalated where appropriate.

Customers will not be charged merely for submitting a grievance to GlocalPe.

3. WHO MAY RAISE A GRIEVANCE

A grievance may be raised by:

• a GlocalPe customer;
• an authorised representative;
• a merchant;
• a business user;
• an authorised employee of a business customer;
• another person directly affected by a GlocalPe Service, where appropriate.

Where a complaint is submitted by a representative, GlocalPe may request evidence of authority to act on behalf of the customer or business.

4. WHAT MAY BE COMPLAINED ABOUT

Complaints may relate to:

Payments

• failed transactions;
• delayed transactions;
• rejected transactions;
• incorrect transaction status;
• transaction reversals;
• payment discrepancies.

Collections

• missing collections;
• unmatched funds;
• reconciliation issues;
• collection delays.

Settlement

• delayed settlement;
• incorrect settlement amount;
• payout failure;
• settlement discrepancies.

FX

• exchange-rate concerns;
• FX calculations;
• currency conversion;
• FX-related charges.

Fees

• transaction fees;
• service charges;
• settlement fees;
• other disclosed charges.

Account and Access

• account access;
• account suspension;
• technical issues;
• API access.

Compliance

• KYC/KYB concerns;
• transaction holds;
• verification requests;
• account restrictions.

Security

• suspected unauthorised activity;
• account compromise;
• API-key compromise;
• suspected fraud.

5. HOW TO RAISE A COMPLAINT

Customers may raise a complaint through the designated GlocalPe support channels:

Email: [support@glocalpe.com]

Grievance Email: [grievance@glocalpe.com]

Support Portal: [●]

Phone: [●]

Registered Office: [●]

Where a dedicated grievance email or portal is provided, customers are encouraged to use that channel for formal complaints.

6. INFORMATION TO INCLUDE

To help GlocalPe investigate a complaint efficiently, customers should provide, where applicable:

• name;
• registered email address;
• registered mobile number;
• business name;
• transaction reference;
• transaction date;
• transaction amount;
• currency;
• payer details;
• beneficiary details;
• description of the issue;
• relevant documents;
• screenshots or supporting evidence;
• relief or resolution requested.

Customers should not include unnecessary passwords, API secrets, OTPs, card PINs or other confidential authentication credentials in a complaint.

7. COMPLAINT ACKNOWLEDGEMENT

GlocalPe will provide an acknowledgement or complaint reference number where appropriate.

The acknowledgement may include:

• complaint reference;
• date of receipt;
• summary of the complaint;
• expected next steps;
• contact information for follow-up.

8. COMPLAINT REFERENCE NUMBER

Customers should retain the complaint reference number for future correspondence.

The reference number may be used to:

• track the complaint;
• provide additional information;
• request an update;
• escalate the complaint.

9. INVESTIGATION

GlocalPe may investigate a complaint using:

• transaction records;
• account records;
• API logs;
• payment records;
• settlement records;
• communications;
• KYC/KYB information;
• relevant documents;
• Payment Partner records.

GlocalPe may contact the customer for additional information where necessary.

10. THIRD-PARTY / PAYMENT PARTNER ISSUES

Certain transactions may involve:

• banks;
• payment institutions;
• payment networks;
• correspondent banks;
• FX providers;
• Payment Partners;
• other third-party service providers.

Where a complaint relates to a third-party processing stage, GlocalPe may coordinate with the relevant provider to investigate the matter.

The resolution timeline may depend partly on the response of the relevant third party.

11. COMPLAINTS INVOLVING MERCHANTS

Where the complaint concerns goods or services supplied by a GlocalPe merchant, the customer may need to resolve the underlying commercial dispute directly with the merchant.

GlocalPe may assist with payment-related information where appropriate but does not automatically assume responsibility for:

• product quality;
• service delivery;
• merchant warranties;
• merchant cancellations;
• commercial disputes between a merchant and its customer.

12. COMPLAINTS INVOLVING BANKS OR OTHER FINANCIAL INSTITUTIONS

Where a complaint concerns a bank or financial institution outside GlocalPe's control, the customer may also need to raise the complaint directly with that institution.

GlocalPe may provide relevant transaction information or coordinate with the institution where appropriate.

13. COMPLAINT RESOLUTION

Following investigation, GlocalPe may:

• resolve the complaint;
• provide an explanation;
• correct a transaction;
• process an eligible refund;
• correct a settlement;
• provide additional information;
• escalate the matter internally;
• coordinate with a Payment Partner;
• reject the complaint where the available evidence does not support it.

14. COMMUNICATION OF OUTCOME

Where appropriate, GlocalPe will communicate the outcome of the investigation to the complainant.

The response may explain:

• findings;
• action taken;
• corrective action;
• applicable limitations;
• reasons for rejection where applicable;
• further escalation options.

15. EXPECTED RESOLUTION TIMELINE

GlocalPe will seek to resolve complaints within a reasonable period appropriate to their nature and complexity.

Simple operational complaints may be resolved more quickly.

Complaints involving:

• international banks;
• Payment Partners;
• sanctions;
• AML/KYC;
• complex transaction reconciliation;
• regulatory review;
• fraud investigation;

may require additional time.

Where resolution is delayed, GlocalPe may provide an interim update where appropriate.

16. REGULATORY TIMELINES

Where a specific regulatory, payment-network or contractual timeline applies to a particular complaint, GlocalPe will follow the applicable requirement.

Nothing in this Policy overrides a mandatory timeline prescribed by applicable law, regulation, RBI direction, NPCI requirement, card-network rule or Payment Partner requirement.

17. ESCALATION — LEVEL 1

If a customer is dissatisfied with the initial support response, the customer may request escalation through:

Grievance Officer: [NAME / DESIGNATION]

Email: [●]

Phone: [●]

The customer should provide the original complaint reference number.

18. ESCALATION — LEVEL 2

Where the complaint remains unresolved after review by the designated Grievance Officer, it may be escalated internally to the appropriate senior compliance, operations or management authority.

The escalation process may depend on:

• nature of complaint;
• regulatory requirements;
• customer type;
• transaction type;
• applicable contractual arrangements.

19. RBI OMBUDSMAN / EXTERNAL REDRESSAL

Where the GlocalPe legal entity and relevant Service fall within the scope of the applicable RBI Integrated Ombudsman Scheme or another mandatory regulatory grievance mechanism, customers may have access to the applicable external redress mechanism after first approaching GlocalPe.

The Reserve Bank – Integrated Ombudsman Scheme, 2026 (RB-IOS 2026) came into effect on 1 July 2026 and provides a cost-free alternate grievance mechanism for eligible complaints involving covered RBI Regulated Entities.

Coverage under RB-IOS 2026 depends on the legal entity and regulated-entity category. It should therefore not be assumed that every GlocalPe Service or entity is automatically covered.

Where GlocalPe is covered by RB-IOS 2026 or another applicable RBI mechanism, the relevant statutory information and escalation details will be published on the GlocalPe website and/or provided to eligible customers.

20. RBI COMPLAINT REQUIREMENT

Where RB-IOS 2026 applies, customers are generally required to first approach the concerned Regulated Entity.

Under the current RBI framework, an eligible complaint may be taken to the RBI Ombudsman where the customer has not received a response within the applicable period, or is dissatisfied with the response/resolution, subject to the Scheme's maintainability requirements.

Customers should refer to the current RBI Scheme and official RBI instructions for the applicable process and timelines.

21. RBI COMPLAINT CHANNEL

Where applicable, complaints under the RBI Integrated Ombudsman framework may be submitted through the RBI's Complaint Management System:

RBI Complaint Management System

The RBI's current information states that complaints under RB-IOS 2026 may also be submitted through the Centralised Receipt and Processing Centre by email or physical mode, subject to the Scheme's requirements.

22. COMPLAINTS NOT WITHIN GLOCALPE'S CONTROL

GlocalPe may explain where a matter is outside its responsibility.

Examples may include:

• independent merchant disputes;
• actions of a customer's bank;
• actions of a beneficiary bank;
• actions of a correspondent bank;
• third-party product disputes;
• matters determined by a regulator or court.

Where appropriate, GlocalPe will identify the relevant party or channel through which the matter may be pursued.

23. FRAUD AND UNAUTHORISED TRANSACTIONS

Customers should report suspected:

• fraud;
• account takeover;
• unauthorised transactions;
• compromised credentials;
• compromised API keys;

immediately through the designated security/support channel.

Urgent security matters may be prioritised separately from ordinary complaints.

24. CONFIDENTIALITY

GlocalPe will handle complaint information in accordance with applicable confidentiality, privacy and data-protection requirements.

Information may be shared with:

• Payment Partners;
• banks;
• regulators;
• law-enforcement authorities;
• professional advisers;
• service providers;

where necessary, legally permitted or required.

25. NO RETALIATION

GlocalPe will not penalise a customer merely for raising a genuine complaint or seeking redress through an applicable grievance mechanism.

This does not prevent GlocalPe from taking appropriate action against:

• fraudulent complaints;
• abusive conduct;
• threats;
• misuse of Services;
• unlawful activity.

26. ABUSIVE OR FRAUDULENT COMPLAINTS

GlocalPe may take appropriate action where a complaint is:

• knowingly false;
• fraudulent;
• abusive;
• threatening;
• repetitive without new information;
• intended to disrupt operations.

Such action will not prevent legitimate complaints from being considered.

27. NO CHARGE FOR GRIEVANCE REDRESSAL

GlocalPe does not charge customers merely for submitting or escalating a genuine grievance through its designated grievance mechanism.

28. RECORD KEEPING

GlocalPe may maintain records of:

• complaints;
• complaint references;
• communications;
• investigations;
• resolutions;
• supporting documents;
• escalation records.

Records may be retained for periods required or permitted by applicable law.

29. ROOT-CAUSE ANALYSIS

GlocalPe may periodically analyse complaints to identify:

• recurring transaction failures;
• customer-impacting issues;
• operational weaknesses;
• technical issues;
• partner-related problems;
• compliance issues;
• opportunities for Service improvement.

Material recurring issues may be escalated internally.

30. CUSTOMER FEEDBACK

GlocalPe may request feedback regarding the handling and resolution of complaints.

Feedback may be used to improve:

• customer support;
• transaction processes;
• policies;
• technology;
• communication;
• grievance handling.

31. POLICY REVIEW

This Policy may be reviewed periodically to reflect:

• regulatory requirements;
• RBI directions;
• changes in Services;
• Payment Partner requirements;
• customer-support processes;
• operational changes.

32. POLICY UPDATES

GlocalPe may update this Policy from time to time.

The latest version published through the appropriate GlocalPe channel will apply from its stated effective date.

33. CONTACT DETAILS

GLOCALPE [FULL LEGAL ENTITY NAME]

Customer Support: [●]

Grievance Officer: [NAME / DESIGNATION]

Grievance Email: [●]

Phone: [●]

Registered Office: [●]

Website: [●]

Support Portal: [●]

Policy Version: [●]

Effective Date: [●]

Last Updated: [●]