Grievance Policy

1.1: Innoviti Technologies Private Limited is a company incorporated under the Companies Act, 1956, having its registered office at Tower D, 7th Floor, Diamond District, Old Airport Road, Kodihalli, Bangalore 560008, Karnataka (hereinafter referred to as "Company" or "Innoviti").

1.2: Innoviti is engaged in the business of processing payment transactions and providing technology solutions and services including payment aggregator services.

1.3: Innoviti facilitates Merchants (defined hereinafter) to collect payments from their customers in a secure manner.

1.4: Innoviti values all its Merchants and their customers and strives to provide a sincere and transparent approach for the grievance redressal process.

1.5: Innoviti has delineated a policy, duly approved by its Board of Directors, that outlines a structured mechanism for grievance redressal ("Policy").

2.1: This Policy outlines a structured grievance redressal mechanism to inform Merchants and Customers about the various channels for registering complaints with respect to any grievances arising from availing Innoviti's services.

2.2: This Policy is applicable for grievances related to all online services offered by Innoviti, including Innoviti Link Application.

2.3: Innoviti ensures that:

• 2.3.1: Merchants and Customers are treated in a fair manner at all times.
• 2.3.2: Complaints raised by Merchants and/or Customers are attended with courtesy and in a time-bound manner.
• 2.3.3: Customers and/or Merchants are made fully aware of avenues for grievance redressal through this Policy.
• 2.3.4: Customers and/or Merchants are provided with effective resolution within a reasonable time period. The turnaround time for resolution is provided under this Policy.
• 2.3.5: Customers and/or Merchants shall be aware of the avenues to escalate grievances within the Company and their rights to alternative remedy, if they are not satisfied with the response.
• 2.3.6: Information on how to raise grievances shall be available at all offices of the Company and on the website and Innoviti Link Application as well.
• 2.3.7: No fee is and shall be collected from the Customers and/or Merchants for raising complaints and/or upon resolution.
• 2.3.8: It works towards constantly improving the mechanism for handling grievances by analysing feedback from Merchants and Customers to identify gaps, monitoring resolution time, and undertaking trainings for the customer support staff.
• 2.3.9: The employees are made well-aware of the complaint handling process and the Company ensures just and fair ways to redress such complaints.

3.1: "Customer" means the end-user who purchases goods/services from the Merchant(s) onboarded by Innoviti.

3.2: "Failed transaction" means a transaction which has not been fully completed due to any reason not attributable to the Customer such as failure in communication links, time-out of sessions, etc. Failed transactions shall also include the credits which could not be effected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction.

3.3: "Merchant" means an individual or entity who is a merchant and availing online payment aggregation services offered by Innoviti.

3.4: "User" means an individual who is using Innoviti's payment aggregation services either directly (as a Merchant) or indirectly (as a Customer).

4.2.1: To raise a Merchant complaint, the Merchant will have to provide Innoviti with details such as legal name, complaint details and contact number.

4.2.2: To raise a Customer complaint, the Customer will have to provide Innoviti with details such as customer name, contact number, Merchant name, Transaction date, Transaction amount, Transaction mode and Complaint details.

4.3.1: Innoviti has a three-tier escalation mechanism for handling Merchant and Customer grievances.

4.3.2: Resolution of the complaint may get delayed due to operational or technical reasons. In such a scenario, the Company will inform the customer/merchant of the timelines during which the complaint will be addressed.

4.3.3: Complaints related to fraud and risk assessment may take longer given the time taken for investigation. The resolution time in such cases is dependent on the severity and complexity of the case.

4.3.4.1: Merchants and/or Customers can contact the customer service team (i.e., customer care executive) between 7 a.m. to 11 p.m. using any of the channels provided under Section 4.1.1 to register their queries/complaints.

4.3.4.2: Upon receipt of the complaint from the Customer or the Merchant, a ticket is generated, and a unique reference number is allotted to the complaint.

4.3.4.3: The customer service team shall immediately send a response/auto-response acknowledging the complaint along with the registered ticket number.

4.3.4.4: Based on the ticket raised, the Quick Response Team shall analyse and bifurcate the complaints received into different categories as mentioned below:

• 4.3.4.4.1: Application Issues such as Application not working
• 4.3.4.4.2: Payment link issues such as payment link sent but not received by the Customer
• 4.3.4.4.3: WhatsApp message not received
• 4.3.4.4.4: Transaction successful but not settled
• 4.3.4.4.5: Banking – resolution to the merchant which involves coordination with the Bank

4.3.4.5: Resolution TAT: The team will initiate action to resolve the complaint expeditiously, preferably within four hours, and will strive to ensure resolution to complaints within 3 business days from receipt, subject to dependencies from banks. In case of any delay, the Merchant and/or Customer will be kept updated on the progress/status of the complaint on a periodic basis till such time that the complaint is not resolved. The complaint history will be accessible by the relevant team using the registered ticket number.

4.3.4.6: If the merchant or customer is not satisfied with the resolution provided by the customer service team, the merchant can escalate the complaint to the next level. This would be allowed even when the complaint is not resolved within the promised time.

4.3.5.1: Unresolved complaints or complaints with unsatisfactory solution can be escalated to the Customer Care Lead as below: customercare@innoviti.com

4.3.5.2: The Customer Care Head shall refer to the complaint history and then take adequate steps for resolution of the grievance.

4.3.5.3: Resolution TAT: The Customer Care Head will strive to ensure resolution to the concern/query is addressed within 3 business days from receipt of the escalation, subject to dependencies from banks.

4.3.5.4: In case of delay, the Merchant and/or Customer will be kept updated on the progress/status of the complaint on a periodic basis till such time that the complaint is not resolved.

4.3.5.5: The complaint history will be accessible by the Customer Care Head using the registered ticket number.

4.3.5.6: If the Merchant/Customer is not satisfied with the resolution provided by the Customer Care Head, the merchant/customer can escalate the complaint to the next level. This would be allowed even when the complaint is not resolved within the promised time.

4.3.6.1: Unresolved complaints or complaints with unsatisfactory solution can be escalated to the Nodal Officer as below:

4.3.6.2: The Nodal Officer shall refer to the complaint history and then take adequate steps for resolution of the grievance.

4.3.6.3: Resolution TAT: Complaints received shall be resolved within 5 working days. In case of delay, the Merchant and/or Customer will be kept updated on the progress/status of the complaint on a periodic basis till such time that the complaint is not resolved.

5.1 The aforementioned is the indicative Turn-Around-Time ("TAT") to dispose-off complaints/grievances.

5.2 The TAT mentioned above may vary depending on the specific case.

5.3 In certain types of transactions where Innoviti depends on a third party for final resolution, the TAT may be higher. However, all complaints will be resolved within 30 days of being raised with Innoviti.

5.4 Any chargeback dispute or arbitration will be as per the TATs prescribed by the respective Card Network.

Under the Reserve Bank – Integrated Ombudsman Scheme, 2021, Users can escalate complaints to the RBI Ombudsman if unsatisfied with Innoviti's grievance resolution or if the complaint is unresolved after 30 days. Users may lodge grievances on the RBI's 'Complaint Management System' (CMS) portal. Users may approach the RBI Ombudsman only after Innoviti's Nodal Officer has addressed the grievance at Level 3 of the escalation matrix.

For details and procedures on approaching the Ombudsman, refer to: https://cms.rbi.org.in/.

8.1: Received product is defective or damaged

8.2: Duplicate charges for the same order

8.3: Unauthorized or unrecognized transaction

8.4: Merchandise or service not delivered or provided

8.5: If the Customer encounters any issues, they can contact the Merchant directly.

8.6: If the Customer does not receive a satisfactory response, or if the Merchant does not reply within 3-5 business days, the Customer can contact Innoviti for mediation. The Customer should provide the following details for further investigation:

• 8.6.1: Transaction date
• 8.6.2: Transaction amount
• 8.6.3: Transaction and Order ID
• 8.6.4: Description of the complaint
• 8.6.5: Details of communication with the Merchant (such as screenshots and emails of communication).

8.7: Upon receiving a complaint, Innoviti will address the issue according to the specified timeline in the escalation matrix.

9.1: A chargeback is a charge for goods or services not received by the Customer, and his/her bank debited to his/her credit or debit card account. The Customer has the option to file a chargeback for the same with his card issuing bank.

9.2: In this case, the Customer's bank will intimate Innoviti's bank by way of a chargeback. All chargebacks, including their processing, resolution, and associated liabilities, shall be as per the established standard operating procedure of the Company. Any chargeback leading to dispute/arbitration will be resolved as per the TATs prescribed by the respective Card Network.

10.1: All queries relating to the full or partial cancellation of orders will be routed to the Merchant only. Innoviti will initiate refunds after reconciliation is completed. If the order is not generated at the time of the transaction, the Customer will receive the credit in their bank account within 5-7 business days. If this does not occur, they will be able to contact Innoviti for refund-related inquiries.

Note: Order activities will be directly managed by the Merchant. Innoviti's role will be limited to directing the Customer to contact the Merchant.

11.1: The Customer Service team shall undergo regular trainings on handling Merchant and Customer grievances and basic functional queries arising out of day-to-day transactions based on best practices and regulatory requirements.

11.2: Imparting soft skills and functional knowledge for handling grievances shall be an integral part of training programmes.

11.3: The primary focus is timely and quick resolution of all complaints received.

11.4: The primary Nodal Officer is responsible for ensuring the smooth functioning of the established internal Grievance Redressal.

12.1: In line with the RBI Guidelines on Regulation of Payment Aggregators and Payment Gateways, Innoviti has appointed a primary and secondary Nodal Officer responsible for regulatory and customer grievance handling functions.

12.2: Details of the primary Nodal Officer for the responsibility of handling the customer grievance function is prominently displayed on the website and the Innoviti Link Application through this Policy (as per Section 4.3.6.1).

12.3: The primary and secondary Nodal Officers shall report to the senior management of the Company.

12.4: The Customer Service Executives and Technical Resolution Team shall support the primary Nodal Officer.

12.5: The Internal Compliance Committee shall periodically review major areas of customer grievances and measures taken to improve customer service.

13.1 Following reports shall be submitted to the Internal Compliance Committee by the primary Nodal Officer for reviewing the Grievance Redressal mechanism in order to streamline the process:

• 13.1.1 A report on team performance shall be submitted quarterly
• 13.1.2 A summarised customer grievance report containing analysis of the types and number of complaints received, disposed, unattended during a financial year, timeline for resolution, summary of such grievances, top issues emanating from analysis of complaints
• 13.1.3 A report containing inputs/suggestions on Merchant Service thus enabling the senior management to examine them and provide relevant feedback for necessary policy/procedural action
• 13.1.4 A status report of complaints with details such as type of complaint and time taken for resolving the complaint shall be submitted every fortnight
• 13.1.5 Process audit reports and quality findings post audit to be submitted
• 13.1.6 Ageing of outstanding complaints

14.1: The records of the complaints and the redressal offered shall be maintained for a minimum period of 5 years from the date of resolution.

14.2: Innoviti shall ensure availability of data at all times by taking frequent backups of such data.

15.1: The Internal Compliance Committee shall review the policy on an annual basis or at earlier intervals, in case of any regulatory changes necessitating such interim reviews and shall recommend changes to the Board.

15.2: Any such updates/changes to this Policy will be approved by the Board. The new version of the policy shall be circulated to the staff and concerned personnel and updated on the website and Innoviti Link Application.