RANAPAY INDIA PRIVATE LIMITED

This Policy establishes a transparent, accessible and documented framework for receiving, registering, investigating, resolving and escalating customer complaints and grievances relating to RanaPay's products and services.

Where a complaint concerns a PPI issuer, bank, payment processor, merchant or other partner, RanaPay shall identify the responsible entity and coordinate resolution in accordance with applicable law, contractual arrangements and the relevant partner's grievance process.

• Provide accessible complaint channels.
• Acknowledge and track complaints.
• Resolve complaints fairly and consistently.
• Provide clear customer communication.
• Escalate unresolved or material complaints.
• Identify recurring issues and improve controls.
• Maintain complete grievance records.

This Policy covers complaints relating to gift cards, vouchers, virtual products, purchase, delivery, activation, redemption, refunds, unauthorised transactions, payment issues, customer service and other RanaPay-supported activities.

• Website/customer-support channel
• Email or other officially published channel
• In-app or digital support channel where available
• Partner escalation channel where applicable
• Written communication to the registered office where accepted

Current contact details and operating hours shall be published through appropriate customer-facing channels.

• Transaction issue
• Gift card/voucher issue
• Delivery issue
• Activation/redemption issue
• Refund/cancellation issue
• Unauthorised transaction
• Fraud complaint
• Payment/settlement complaint
• Service quality complaint
• Privacy/data complaint
• Partner-related complaint

1. Receive complaint.
2. Create complaint/ticket reference.
3. Capture customer and transaction details as required.
4. Categorise complaint.
5. Assign responsible function.
6. Acknowledge customer where applicable.
7. Begin investigation.

Only information reasonably necessary to investigate and resolve the complaint shall be requested. Sensitive credentials such as passwords, PINs or OTPs shall not be requested except through approved secure processes where legally/technically necessary.

Complaints shall be prioritised based on customer impact, financial impact, fraud/security risk, regulatory sensitivity, service disruption and urgency.

• Critical – material fraud/security or significant customer impact
• High – substantial financial/service impact
• Medium – standard transaction/service issue
• Low – general information or minor service concern

The responsible team shall review available transaction records, customer communications, product terms, system records, partner information and other relevant evidence.

Where resolution depends on a PPI issuer, bank, payment processor, merchant or other partner, the case shall be routed through the documented partner escalation mechanism. RanaPay shall track the case until the responsibility is clearly transferred or the matter is resolved, subject to applicable arrangements.

Complaints alleging fraud or unauthorised transactions shall be escalated under the Fraud Prevention & Transaction Monitoring Policy and Unauthorised Transaction Policy, as applicable.

Refund, cancellation and chargeback complaints shall be handled under Policy No. 08 and the relevant partner/payment process.

Customers shall receive clear and understandable updates appropriate to the case. Where a complaint cannot be accepted or resolved, the customer shall be informed of the reason and any available next step, subject to legal and security limitations.

Resolution shall be based on documented facts, applicable product terms, partner rules, applicable law and the customer's actual transaction circumstances. The resolution and supporting basis shall be recorded.

• Complaint not resolved within applicable service timeline
• Material financial impact
• Fraud/security concern
• Repeated complaint
• Regulatory/legal notice
• Potential systemic issue
• Partner failure or delayed response

Material or recurring grievances shall be escalated to Compliance and Management for review, root-cause assessment and corrective action.

Recurring or material complaints shall be analysed to identify process, product, technology, partner, communication or control weaknesses.

Complaint handling timelines shall be defined based on complaint type, partner requirements, applicable law and operational capacity. Where a regulatory or partner-specific timeline applies, that timeline shall be followed.

1. Confirm action taken.
2. Record resolution.
3. Communicate outcome where appropriate.
4. Capture closure date.
5. Record supporting evidence.
6. Reopen/escalate if additional material information is received.

A closed complaint may be reopened where new material information is provided, the customer disputes the resolution or an internal review identifies a continuing issue.

Grievance records shall be protected and processed in accordance with applicable data-protection requirements and RanaPay's Data Protection, Privacy & Retention Policy.

• Complaint reference
• Date/time received
• Customer details as required
• Transaction reference
• Complaint category
• Assigned owner
• Partner communications
• Investigation notes
• Resolution
• Customer communication
• Closure/reopening history

• Complaint volumes
• Category trends
• Resolution time
• Pending/aged complaints
• Repeat complaints
• Partner-related complaints
• Fraud complaints
• Root causes
• Corrective actions

Relevant customer-support and operations personnel shall receive training on complaint registration, communication, escalation, privacy, fraud red flags and partner routing.

Periodic sample reviews may be conducted to assess complaint classification, response quality, resolution accuracy, timelines, records and escalation.

Customers shall not be disadvantaged merely for raising a genuine complaint. Appropriate controls shall be maintained against abusive, fraudulent or deliberately misleading complaints without restricting legitimate customer rights.

Exceptions shall be documented and approved by an authorised function. No exception may override mandatory legal or regulatory requirements.

This Policy shall be reviewed at least annually and whenever there is a material change in applicable requirements, products, partner arrangements, customer channels or complaint trends.