> For the complete documentation index, see [llms.txt](https://docs.spendl.money/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.spendl.money/spendl-compliance-pack/spendl-complaints-management-policy.md). # Spendl Complaints Management Policy Version 1.2 1\. Document Control | **Version** | 1.2 | | ------------------ | ------------------------------------------------------- | | **Effective Date** | 1 July 2026 | | **Approved By** | Board of Directors | | **Owner** | Chief Compliance Officer | | **Next Review** | July 2027 or sooner on regulatory or operational change | ### 2. Purpose Light Fusion (Pty) Ltd t/a Spendl Technologies (SPENDL) is committed to resolving complaints fairly, transparently, efficiently and in a way that delivers good customer outcomes. We treat every complaint as an opportunity to learn, strengthen customer trust, and improve our Services. Complaints management is an integral part of Treating Customers Fairly (TCF) as summarised in the Terms and Conditions and detailed in our standalone TCF Policy. This policy is established and maintained in accordance with the FAIS Act, the FAIS General Code of Conduct for Authorised Financial Services Providers and Representatives (Board Notice 80 of 2003, as amended), and the FSCA Conduct Standard 3 of 2020. This policy gives effect to those requirements and is to be read together with the SPENDL Conflict of Interest Management Policy, TCF Policy and Privacy Policy. This policy implements the commitments made in the Terms and Conditions, which provides that SPENDL will acknowledge a complaint within 5 Business Days and aim to resolve it within 30 days. ### 3. Scope and Application This policy applies to all complaints received from B2C Customers and B2B Customers, as well as End Users of B2B Customers whose complaints are escalated to SPENDL. ### 4. Definitions **Complaint:** An expression of dissatisfaction by a person to SPENDL relating to a financial service rendered or refused by SPENDL, which indicates (whether expressly or impliedly) that the complainant has suffered or may suffer financial prejudice or damage, a material inconvenience, or a material distress, and which has not been resolved to the satisfaction of the complainant within the ordinary course of business, as contemplated in the FAIS General Code of Conduct. **Material Complaint:** A complaint that involves a significant financial loss, potential regulatory breach, systemic issue, a PEP or PIP, or a matter that could materially affect SPENDL, the Programme Partner, or the card scheme. **Reportable Complaint:** A complaint that is required to be included in the FSCA reporting return under Conduct Standard 3 of 2020, being every complaint other than one that is upheld immediately on receipt without dispute by SPENDL. All Material Complaints are also Reportable Complaints. **Complainant:** A B2C Customer, B2B Customer, or End User who lodges a complaint. **Resolution Notice:** A written communication from SPENDL setting out the outcome of the investigation and the reasons therefor. Capitalised terms not defined in this policy have the meanings given to them in the Terms and Conditions. ### 5. Complaints versus Queries General queries about products, transactions, fees or support are routed to . These are not Complaints. Where a matter meets the definition of a Complaint in section 4 above, it is handled under this policy. Where a query escalates to dissatisfaction, the matter is reclassified as a Complaint and entered into the Complaints Register. ### 6. Fraud, Phishing and Security Incidents SPENDL takes fraud, phishing and security incidents seriously. Suspected fraud should be reported to or via the lost-or-stolen-card hotline at 011 207 1600. Where you believe SPENDL's conduct contributed to a loss, you may lodge a formal Complaint under this policy and request that it be treated as a Material Complaint. SPENDL will not impose any fee for assisting a customer who is a victim of fraud or phishing. Unauthorised transaction liability is allocated in accordance our Terms and Condition and applicable Network Rules. ### 7. Information Required in a Complaint To enable an effective investigation, please include: * Your full name and SPENDL account, or card reference. * Contact details for correspondence. * A clear description of the Complaint, including how SPENDL is alleged to have contravened an agreement or law, caused harm, or acted unfairly. * Supporting documents (emails, transaction details, timeline). * The outcome you are seeking. * Your permission allowing us to use the information and documentation provided in order to resolve the complaint. Where information is incomplete we will request the missing detail in writing and pause the timeline until we receive it. ### 8. Submission Channels Complaints may be submitted free of charge via: * Email: as specified in the Terms and Conditions. Complaints relating to Personal Information are also routed to the Information Officer at as specified in the Terms and Conditions. Where a privacy complaint reaches another channel, it is escalated to the Information Officer within two Business Days. ### 9. Internal Complaints Process and Timelines SPENDL follows the FSCA-aligned framework for complaints handling, consistent with the commitments of the Terms and Conditions: | **Stage** | **Timeline** | **Detail** | | --------------------- | ---------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------- | | Acknowledgement | 3 Business Days | Written acknowledgement with reference number, assigned investigator, and expected timeline. | | Investigation | Up to 25 Business Days | Gather evidence, interview parties, consult Programme Partner / Network where Card-related. Complex matters may require extension with notice. | | Resolution Notice | Within 30 calendar days of receipt | Written outcome with reasons, remedy (if applicable), and information on further recourse. | | Extension (if needed) | Notice before day 30 | Where 30 days is insufficient due to complexity, SPENDL will notify the complainant of the extended timeline with reasons. | ### 10. Internal Escalation If you are not satisfied with the outcome, you may request an internal review by emailing within 30 days of receiving the Resolution Notice. * Internal review is conducted by a senior officer not involved in the original investigation, typically the Compliance Officer or a designated review officer. * Acknowledged within 1 Business Day of receipt. * Reviewed within 10 Business Days. Complex matters are referred to a Complaints Committee of senior management, which decides within 20 Business Days. * The final internal outcome is communicated in writing with reasons. Please note: before lodging a Complaint with the Ombud, the Complainant is required to lodge the Complaint with SPENDL and only after confirmation that the matter is unable to be resolved internally may it be escalated to the Ombud. ### 11. External Escalation If your matter is not resolved to your satisfaction, the following external escalation routes are available as referenced in the Terms and Conditions: #### 11.1 Ombud for Financial Services Providers (FAIS Ombud) For complaints relating to financial services rendered under FAIS: * Address: Menlyn Central Office Building, 125 Dallas Avenue, Menlyn, Pretoria, 0010 * Telephone: 012 762 5000 / Sharecall 0860 663 274 * Email: * Website: [www.faisombud.co.za](http://www.faisombud.co.za) #### 11.2 National Financial Ombud Scheme Where applicable, complaints may also be referred to the National Financial Ombud Scheme as referenced in the Terms and Conditions. #### 11.3 Information Regulator For complaints under POPIA or PAIA: * Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 * Telephone: 010 023 5200 * Email: / * Website: [www.inforegulator.org.za](http://www.inforegulator.org.za) #### 11.4 Financial Sector Conduct Authority (FSCA) For conduct matters generally: * Website: [www.fsca.co.za](http://www.fsca.co.za) #### 11.5 Whistleblowing Reports of suspected fraud, corruption, bribery, money-laundering, sanctions breaches, market abuse or other unlawful conduct may be made to the whistleblower channel at , as described in the Terms and Conditions. Reports may be made anonymously. SPENDL prohibits retaliation against any person making a report in good faith, consistent with the Protected Disclosures Act 26 of 2000 and PRECCA. ### 12. Card-Specific Disputes Where a complaint relates to a Card transaction (disputed charge, unauthorised transaction, merchant refund), the complaint is processed under Schedule A of the Terms and Conditions and applicable Network Rules. SPENDL will process disputes via the Programme Partner under the scheme's chargeback and dispute resolution procedures. Customers are reminded that chargeback abuse (repeated, unfounded, or fraudulent disputes) may result in consequences as set out in the Terms and Conditions. ### 13. Complaints Register #### 13.1 Recording requirements SPENDL maintains a Complaints Register that records every complaint received, in line with Conduct Standard 3 of 2020 (sections 7 and 8). Each entry must be created within 24 (twenty-four) hours of receipt and must capture, at minimum: * unique reference number, date and time of receipt, and channel through which received; * complainant identifiers (name, account, card reference, contact details, and complainant type - B2C, B2B or End User); * description of the complaint, the Service or product involved, and the financial product or service category; * complaint category in terms of section 13.2 below, and whether the complaint is classified as a Material Complaint or as a Reportable Complaint under section 9 of Conduct Standard 3 of 2020; * assigned investigator, status, applicable internal deadlines, and any extension notices issued; * outcome, remedy and date of final Resolution Notice; * root-cause classification in terms of section 13.3 below, with a short narrative supporting the classification; * any internal escalation, external escalation (Ombud, Information Regulator or FSCA), or referral to a third party (Programme Partner, Network, banking partner); * links to supporting evidence (correspondence, transaction logs, screenshots, Resolution Notice). #### 13.2 Prescribed complaint categories (Conduct Standard 3 of 2020) Every complaint recorded in the Complaints Register is classified into one of the following categories, aligned to section 8 of Conduct Standard 3 of 2020 and the FSCA’s reporting taxonomy. Where a single complaint touches more than one category, the primary category is recorded with a secondary category as a sub-tag: * **Design of the financial product or service** - design or features of the SPENDL Card, B2B Platform, ITT, Treasury, Off-Ramp or Cross-Border Services (e.g. transaction limits, supported assets, settlement timing, conversion mechanics). * **Information provided to customers** - clarity, accuracy, completeness or timing of pre-contractual disclosures, the FAIS Disclosure Notice, Risk Notices, Fee Schedule, statements, transaction confirmations or any other communication. * **Advice** - any complaint alleging that financial advice was rendered, was unsuitable, or was provided in contravention of the FAIS Act. SPENDL does not in the ordinary course render advisory services; any complaint of this nature is automatically a Material Complaint. * **Product or service performance** - the financial product or Service did not perform as the customer was led to expect (e.g. delayed conversion, failed Card transaction, unexpected FX outcome, stablecoin de-peg impact, ITT redemption delay). * **Service to customers** - quality, responsiveness or conduct of customer support, KYC/onboarding service, dispute handling, account servicing, dormancy or off-boarding. * **Fees, charges and rates** - amount, basis, transparency or application of any fee or FX margin set out in the Fee Schedule as per the Terms and Conditions. * **Complaint handling** - conduct of the complaint handling process itself, including acknowledgement timing, escalation, communication during investigation, and the quality of the Resolution Notice. * **Accessibility and fair treatment** - channels, language, format, accommodation of vulnerable customers, or any alleged unfair treatment or discrimination. * **Other** - any complaint that does not properly fall within categories shown above, including data protection, fraud-related allegations, or third-party referrals. #### 13.3 Root-cause taxonomy For every closed complaint, the investigator (with sign-off from the Compliance Officer) records the root cause of the issue using the following taxonomy, which gives effect to the root-cause analysis requirement under section 11 of Conduct Standard 3 of 2020. The intent is to enable systemic and trend analysis, not to allocate blame: * **Process failure** - the documented process was not followed, or a documented process was missing or unclear (e.g. KYC step skipped, escalation not triggered, SLA missed). * **System or technology** - defect, outage, incorrect configuration, mis-routed transaction, integration failure with the Programme Partner, Network, banking partner, KYC vendor or Chainalysis / Sumsub. * **Training or capability** - staff lacked the knowledge, training or authority to handle the matter correctly the first time. * **Third party** - the root cause sits with the Programme Partner, Network, banking partner, liquidity partner, KYC vendor, corridor partner or other third party. SPENDL retains principal responsibility for the customer outcome and engages the third party under the relevant agreement. * **Product or service design** - the issue arises from the design of the product or service itself (e.g. fee structure, limits, mechanics). These findings are referred to the product approval and review process. * **Communication** - ambiguous, incomplete, untimely or misleading communication to the customer (pre- or post-sale), including marketing, statements, notices, app messaging or support correspondence. * **Customer-side** - the issue arose from customer error, misunderstanding or external action (e.g. lost device, phishing victim, incorrect recipient). SPENDL still records the complaint and considers any opportunity to improve communication or controls. * **Regulatory or external change** - a regulatory or market change (e.g. sanctions designation, scheme rule change, exchange-control directive) drove the customer outcome. * **Other / undetermined** - used sparingly and only where the investigation cannot reasonably identify a primary cause. The Compliance Officer reviews all entries in this bucket monthly. #### 13.4 Review of the Register The Complaints Register is reviewed monthly by the Compliance Officer and quarterly by senior management to identify trends, systemic issues, and opportunities for service improvement, consistent with the TCF framework ### 14. Record Keeping Complaints, supporting documents and decisions are retained in the Complaints Register for at least five years from final closure, in accordance with the FIC Act, the FAIS Act, and tax law. Records are available to regulators on request, subject to applicable confidentiality and tipping-off requirements under the FIC Act. ### 15. Reporting The Compliance Officer reports on complaints to the Board on a quarterly basis, covering: volume and trends, resolution rates and timelines, root-cause analysis, systemic issues, Ombud referrals, and any regulatory feedback. This reporting supports SPENDL's obligations under the FAIS General Code and FSCA supervisory expectations. ### 16. Contact Questions regarding this policy may be directed to: * Complaints Officer: * Chief Compliance Officer: * Information Officer (POPIA): * General support: ### 17. Version Control | **Version** | **Effective Date** | **Summary of Changes** | **Reason for Changes** | **Approved By** | | ----------- | ------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------ | | 1.1 | 1 September 2025 | Founding version - initial FAIS Disclosure Notice issued | Initial FSCA/FAIS compliance requirement upon platform launch | Board of Directors | | 1.2 | 1 July 2026 | Full rewrite aligned to FSCA Conduct Standard 3 of 2020 and the FAIS General Code. Scope extended to B2C, B2B and End Users; Material and Reportable Complaint definitions added; timelines restated to match the Terms and Conditions; root-cause and Board reporting provisions; external escalation and contact details updated. | Compliance pack-wide update; alignment with Conduct Standard 3 of 2020, revised Terms and Conditions, and the expanded product perimeter and B2B service model. | Board of Directors |