Complaints Handling Policy

Geloro Pay Ltd (“the Company”) is committed to providing fair, transparent, and efficient handling of all customer complaints. This Complaints Handling Policy explains how clients can submit complaints, how they are managed, and what outcomes may be expected.

The Company operates as a Money Services Business (MSB) registered in Canada and is subject to supervision by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

We aim to resolve all complaints fairly, consistently, and in a timely manner in accordance with applicable regulatory expectations and best practices in financial services.

1. Our Commitment

We treat all complaints seriously and handle them in a fair, transparent, and non-discriminatory manner.

Submitting a complaint will not result in:

• account suspension or termination
• restricted access to services
• additional charges or penalties
• any form of retaliation or disadvantage

All clients are entitled to raise concerns without fear of negative consequences.

2. What is a Complaint?

A complaint is any expression of dissatisfaction regarding our services, including but not limited to:

• transaction processing issues
• account access or verification concerns
• fees or charges
• customer support experience
• service delays or technical issues
• suspected errors or incorrect decisions

A complaint may be submitted verbally or in writing, where a response is expected.

3. How to Submit a Complaint

You may contact us using any of the following methods:

Email: support@octapex.com

📍 1055 West Georgia Street, Suite 2100 Vancouver, BC V6E 3P3, Canada

Where possible, please include:

• your full name and contact details
• account or reference number
• description of the issue
• relevant dates and supporting information
• desired outcome

4. Acknowledgement of Complaints

We will acknowledge receipt of your complaint within 3 business days.

Our acknowledgement will include:

• confirmation that your complaint has been received
• a reference number
• contact details for follow-up
• an expected timeline for resolution

5. How We Handle Complaints

All complaints are reviewed fairly and independently. We follow a structured process:

• Review of the issue and relevant account information
• Internal investigation, including transaction and system review where applicable
• Assessment of findings in line with internal policies and regulatory requirements
• Decision and resolution, including corrective action where necessary

Where required, different internal teams may be involved, including Compliance, Risk, Operations, or IT Security.

If a complaint involves suspected fraud, AML/CTF concerns, or regulatory issues, it is escalated to the appropriate compliance function for independent review.

6. Response Timeframes

We aim to provide a full response within:

• 15 business days for most complaints

In complex cases, we may extend this to:

• up to 35 business days, where further investigation is required

If an extension is needed, we will inform you in advance and explain the reason.

7. Possible Outcomes

Depending on the outcome of our investigation, resolutions may include:

• clarification or explanation of an issue
• correction of account or transaction errors
• reversal or adjustment of charges (where applicable)
• technical or service improvements
• other appropriate remedial actions

Each case is assessed individually based on its facts and evidence.

8. External Escalation Rights

If you are not satisfied with our final response, you may escalate your complaint to external bodies, including:

• Financial Consumer Agency of Canada (FCAC)
• Ombudsman for Banking Services and Investments (OBSI)
• Consumer Protection BC

These organizations provide independent dispute resolution and oversight.

9. Complaint Records and Privacy

All complaints are recorded and securely stored in accordance with applicable legal and regulatory requirements.

We comply with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

Complaint records are:

• securely stored
• access restricted to authorized personnel
• retained for at least 5 years
• used for quality assurance and regulatory compliance

10. Continuous Improvement

We regularly review complaint trends to identify potential improvements in our services, systems, and processes.

Where recurring issues are identified, we implement corrective actions to improve customer experience and reduce future complaints.

11. Contact Information

📍 1055 West Georgia Street, Suite 2100 Vancouver, BC V6E 3P3, Canada

Email: support@octapex.com