> 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-treating-customers-fairly-policy.md).

# Spendl Treating Customers Fairly 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. Introduction and Policy Statement

Light Fusion (Pty) Ltd t/a Spendl Technologies (SPENDL), a Financial Services Provider (FSP 53757), is committed to the fair treatment of all Customers. The overriding principle central to SPENDL's culture and ethos is that Customers come first. Delivering optimal customer outcomes is a company-wide responsibility and a business imperative.

This TCF Policy is centred around the guidance provided by the Financial Sector Conduct Authority (FSCA) and gives effect to the TCF framework commitment of the Terms and Conditions. SPENDL is committed to embedding all six TCF outcomes in its conduct of business and applies the highest standards of ethical behaviour during all business activities.

### 3. Purpose and Scope

The purpose of this Policy is to outline SPENDL's commitment to the TCF outcomes-based regulatory and supervisory approach. TCF ensures that specific fairness outcomes for Customers are delivered by financial institutions.

This Policy applies to SPENDL, its employees, representatives, and associates. All staff are required to apply the principles of TCF in their work irrespective of their role. It applies equally to dealings with B2C Customers (natural persons using the SPENDL Card under Schedule A of the Terms and Conditions) and B2B Customers (juristic persons using the B2B Platform under Schedules B to E), and to the treatment of End Users whose transactions flow through the Platform.

### 4. The Six TCF Outcomes

SPENDL is committed to ensuring that Customers experience the following six fairness outcomes, as summarised in the Terms and Conditions:

#### 4.1 Outcome 1 - Culture

Customers are confident that they are dealing with a financial services provider where the fair treatment of customers is central to its culture.

* **Leadership:** Management has formally adopted TCF principles and is responsible for ongoing implementation and governance. TCF implications are considered during strategic planning.
* **Employee Participation:** All employees must understand this Policy and undergo continuous training on TCF principles. All employees are aware of their TCF obligations, which are included in their job descriptions and require them to abide by the relevant FAIS requirements and obligations. Adherence to TCF also forms part of assessment criteria, and meaningful consequences apply for staff who do not achieve TCF deliverables.
* **Governance and Monitoring:** Oversight and monitoring of TCF outcomes is assigned to the Compliance Officer. The Risk Management and Compliance Programme (RMCP, the Terms and Conditions) includes TCF objectives. Management Information (MI) measures are designed for TCF monitoring.

#### 4.2 Outcome 2 - Products and Services

Products and services marketed and sold are designed to meet the needs of identified customer groups and are targeted accordingly.

* **Product Development:** The product development process is anchored on customer outcomes and objectives, starting with identifying the customer need.
* **Target Market:** B2C Customers are segmented into tiers based on needs and compliance requirements, as set out in the Tiered KYC Plans Schedule (Wallet, Smart, Savvy, Guru). B2B Customers are assessed for suitability through the Commercial Agreement and MSA process.
* **Approval and Review:** Senior Management considers TCF outcomes when approving new products. Products and services are continuously evaluated to identify potential risks.
* **Monitoring Mis-selling:** SPENDL monitors to ensure products are provided to the right customer groups and takes steps to mitigate inappropriate distribution.

#### 4.3 Outcome 3 - Clear Information

Customers are given clear information and are kept appropriately informed before, during and after the time of contracting.

* The Terms and Conditions, including the Risk Notice at the front and all Schedules, are designed to provide comprehensive, clear information before contracting.
* The FAIS Disclosure Notice is provided as a pre-contractual disclosure.
* The Fee Schedule (Schedule F) is published on the Website and disclosed before any fees are charged.
* Material Changes to the Services or Terms and Conditions are communicated with at least 30 days' notice (clause 12.1).
* Third-party information is monitored for accuracy and corrected where inaccurate, unclear, unfair, or misleading.

#### 4.4 Outcome 4 - Suitable Advice

Where customers receive advice, the advice is suitable and takes account of their circumstances.

* SPENDL operates under FAIS Category I and does not provide advice directly to Customers. Accordingly, this Outcome’s applicability to SPENDL is explicitly limited to the oversight of suitable advice provided by third parties on SPENDL’s products, and does not extend to advice given by SPENDL itself.
* Due diligence is performed on any FSP or product supplier before contracting.
* Representatives comply with FAIS Fit and Proper Requirements (Board Notice 194 of 2017).
* Feedback and complaints regarding third-party advice are monitored and acted upon.

#### 4.5 Outcome 5 - Performance Expectations

Customers are provided with products that perform as led to expect, and the associated service is of an acceptable standard.

* Clear service standards are defined and communicated.
* Product switching, early termination, and retention data are monitored, with the frequency of monitoring aligned to the risk profile of the relevant product, to identify risks where products are not meeting expectations. The Compliance Officer is responsible for reviewing this data.
* Beta features are clearly labelled and provided on an 'as is' basis.
* Customer data is protected through processes aligned with POPIA and Joint Standards.

#### 4.6 Outcome 6 - Post-Sale Barriers

Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.

* Customers can terminate any Service at any time as per the Terms and Conditions. Residual balances are returned within 30 days.
* The Complaints Management Policy provides an accessible, free, and transparent process as per the Terms and Conditions.
* External escalation routes (FAIS Ombud, National Financial Ombud Scheme, Information Regulator, FSCA) are clearly communicated in the Terms and Conditions.
* B2C Customers' statutory prescription periods and non-excludable rights are fully preserved.
* Dormancy procedures provide at least 30 days' notice before any fee is charged or Account is closed.

### 5. TCF Monitoring and Reporting

The Compliance Officer independently monitors TCF compliance and reports to the Board on a quarterly basis. Reporting covers: customer complaint trends and root causes, product performance data, service standard adherence, information clarity assessments, post-sale barrier metrics, and regulatory feedback. Non-compliance items are escalated and remediated.

### 6. Ownership, Accountability, and Review

Management maintains overall responsibility for this Policy. The Compliance Officer independently monitors compliance and reports on non-compliance. This Policy shall be reviewed annually or when deemed necessary and shall be Board-approved. The review cycle is consistent with the annual policy review commitment as per the Terms and Conditions.

### 7. Contact

* Compliance Officer: <compliance@spendl.money>
* Complaints: <complaints@spendl.money>
* Registered Office: Central Square, Pinelands, Cape Town

### 8. Version Control

This is an updated version of the Policy, revised from the initial version dated September 2025.

| **Version** | **Effective Date** | **Summary of Changes**                                                                                                                      | **Reason for Changes**                                                                 | **Approved By**    |
| ----------- | ------------------ | ------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------- | ------------------ |
| 1.1         | 1 September 2025   | Founding version - initial TCF Policy issued                                                                                                | Initial FSCA/FAIS compliance requirement upon platform launch                          | Board of Directors |
| 1.2         | 1 July 2026        | Added version history; clarified Outcome 1 (HR/culture), Outcome 2 (tiering reference), Outcome 4 (advice scope) and Outcome 5 (monitoring) | Updates reflect Spendl’s revised RMCP, strengthen audit trail and inspection-readiness | Board of Directors |