Merchant Onboarding and Due Diligence Policy

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GlocalPe Merchant Onboarding & Due Diligence Policy

Effective Date: 1st November 2026

Operated by Dhaniti Fintech Solutions Private Limited. This policy applies only to the GlocalPe services and activities within its stated scope. Applicable law and binding service-specific agreements govern where relevant.

1. Purpose, scope and service approval

This Policy outlines baseline onboarding and due-diligence expectations for businesses seeking merchant or business services through GlocalPe. Requirements vary by product, provider, jurisdiction, business model and applicable law. This Policy is not a complete checklist or an assurance of eligibility.

Where a service is referred to PayGlocal under the PayGlocal–Dhaniti agreement, that agreement allocates responsibilities between the parties and requires a separate service agreement between PayGlocal and the referred merchant. The merchant’s PayGlocal services are governed by the agreement executed between the merchant and PayGlocal, applicable law and relevant service terms.

2. Dhaniti’s referral diligence

Before referring a merchant to PayGlocal, Dhaniti is responsible for undertaking proper merchant diligence at its end and for ensuring, to the extent required by the applicable agreement and current provider restrictions, that the referred merchant is not engaged in prohibited, illegitimate or restricted goods, services or activities or activity involving a non-permitted jurisdiction.

Dhaniti’s referral review is distinct from the provider’s own regulatory due diligence, KYC/AML verification and onboarding decision. A referral, preliminary review or document collection does not constitute PayGlocal approval, completion of provider KYC, account opening or authorisation to process transactions.

3. Provider review and final decision

Under the PayGlocal–Dhaniti agreement, PayGlocal retains responsibility for merchant onboarding approval, KYC/AML verification and regulatory due diligence for PayGlocal Services, subject to applicable law and the merchant’s separate agreement.

For other GlocalPe services, the responsible provider and allocation of duties may differ. The relevant service arrangement governs. A provider may independently approve, decline, condition, limit, suspend or discontinue a merchant or service in accordance with its terms and law.

4. Information and documents

Depending on the service, an applicant may be asked to provide business registration and tax identifiers; registered and operating addresses; legal form; ownership, control and beneficial ownership details; identity and authority information for directors, owners and authorised representatives; bank or beneficiary details; website, sales channels and product/service descriptions; licences or registrations; invoices, contracts or other evidence of the underlying business; countries and counterparties involved; anticipated transaction activity; and information about transaction purpose or source of funds.

Applicants must provide genuine, accurate, current and complete information and promptly correct material inaccuracies. Additional or refreshed documents may be requested by Dhaniti or the provider for onboarding, periodic review, transaction review, risk management, legal or regulatory purposes. The applicable checklist and secure submission channel will be communicated for the relevant service.

5. Consent, information sharing and instructions

Before relevant information is accessed, used, transmitted or disclosed, the necessary notices, authorisations and consents must be obtained as required by applicable law and the service arrangement. For PayGlocal referrals, the PayGlocal–Dhaniti agreement requires Dhaniti to obtain explicit merchant consent for sharing relevant merchant information, including transaction information, with PayGlocal, and explicit consent authorising Dhaniti to issue instructions to PayGlocal on the merchant’s behalf for business transactions, including collection, processing, refund and reversal instructions.

Any instruction issued by Dhaniti on a merchant’s behalf must remain within the scope, duration and conditions of the merchant’s valid authorisation, the provider’s permitted workflow and applicable law. Dhaniti must retain appropriate evidence of consent and authorisation as required by its agreement and law. PayGlocal’s agreement states that PayGlocal is not responsible for verifying the veracity of the consent obtained by Dhaniti; this makes Dhaniti’s own consent controls material.

Data will be handled under the GlocalPe Privacy Policy, relevant provider privacy notices and binding agreements. Sharing will be limited to the purposes and recipients permitted or required for the relevant service.

6. Business models and eligibility review

Review may consider legal form, ownership/control, business activity, products/services, merchant website or sales channels, target markets, countries, payment methods, transaction purpose, source of funds, licences and risk factors. Merchant categories and jurisdictions may be prohibited, restricted or require additional approval under the Prohibited & Restricted Activities Policy and the responsible provider’s current requirements.

Where relevant, applicants may be required to provide customer-facing cancellation, return and refund terms and other business disclosures for assessment. Approval for one service, provider, corridor, payment method or business model does not guarantee approval for another or continued access.

7. Ongoing duties and review

Merchants must notify the relevant service contact promptly of material changes to ownership, control, directors, authorised users, business activity, licences, address, bank details, website, sales channels, countries served or submitted information.

Additional review may be required when information changes, a transaction raises a question, a security or fraud signal occurs, a provider requests review or applicable law requires it. A merchant must cooperate with applicable requests and maintain supporting business and transaction records.

8. Decisions, restrictions and communication

Onboarding or transactions may be delayed, conditioned, rejected, restricted, suspended or terminated where permitted or required because of eligibility, incomplete or inconsistent information, due-diligence results, provider rules, applicable law or service availability. Certain screening or investigation details may not be disclosed where prohibited or where disclosure could compromise security or compliance.

An applicant may contact support@glocalpe.com for process information. An enquiry or referral is not a commitment to approval or service activation.

9. Contact

General onboarding support: support@glocalpe.com. Legal and policy matters: legal@glocalpe.com. The responsible provider, applicable service terms and required process should be identified through the relevant onboarding or service flow.

END OF POLICY