COMPLAINTS HANDLING RULES

1. General Provisions

1.1. These Complaints Handling Rules (the "Rules") establish the procedures and guidelines adhered to by Superb Payments, UAB (the "Company") for the investigation of complaints (the "Complaint") submitted by clients or potential clients (the "Applicant") regarding the services provided by the Company and/or any agreements concluded with the Company.

2. Definition of Complaint

2.1. The Rules shall be applied to all Complaints received by the Company (its representatives) via communication channels stated in Section 3 “Complaint Submission Procedure” of the Rules.

2.2. The following types of messages shall not be considered as Complaints:

2.2.1. complaints concerning the Company’s activity which is not regulated by the special laws and is not supervised by the supervisory authority;

2.2.2. complaints concerning activity for the performance of which the Company is not responsible;

2.2.3. requests for identification of payment or payment remitter / subject depositing funds on the client’s account;

2.2.4. requests for mediation of payment return or for payment recipient identification;

2.2.5. requests for a copy of proof of transaction;

2.2.6. requests for data about payment remitter or payment specification;

2.2.7. suggestions for adjustment or improvement of the Company’s services;

2.2.8. suggestions for modification of documents issued and (or) proposed by the Company in relation to the service provision.

2.3. If the Company is not responsible for the activity mentioned in the complaint, the Company shall inform the client of its refusal to accept and investigate the complaint, providing the reasons for such refusal. Additionally, where possible, the Company shall identify the party responsible for handling such complaints.

3. Complaint Submission Procedure

3.1. The Complaint must be submitted to the Company within 3 months from the date on which the Applicant became, or ought to have become, aware of the violation of their rights.

3.2. The Complaint shall include the following information:

3.2.1. For natural persons: name, surname, date of birth, and contact details (email and/or telephone number).

3.2.2. For legal persons: entity name, registration code, registered address, and contact details (email and telephone number).

3.2.3. The moment of the alleged breach of the Applicant's rights (the point in time when the Applicant believes their rights were violated);

3.2.4. A clear description of the actions taken by the Company that led to the Complaint;

3.2.5. description of circumstances which led to the Complaint.

3.3. The Complaint must be submitted in either Lithuanian or English and must be duly signed by the Applicant or their authorized representative. The Complaint should be sent from the authorized email address of the client, which has been approved by the Company, or from the authorized (registered) address of the Applicant. If the Applicant wishes to submit the Complaint through other means, the Company reserves the right to refuse the Complaint due to formal deficiencies. Alternatively, the Company may request additional proof and information to verify that the Complaint was indeed prepared and submitted by the Company's client.

3.4. The Applicant is responsible for the accuracy of the personal and contact information provided in the Complaint. The Applicant agrees that the Company will use the contact details specified in the Complaint to communicate all information related to the Complaint handling process. For the sake of clarity, if the Applicant provides an email address, the Company is entitled to use that email address for all subsequent communication.

3.5. The Complaint must be submitted either by the Applicant personally or by their authorized representative. When the Complaint is submitted by a representative, the representative must provide documents evidencing their identity and authorization. This includes a copy of the authorized person’s ID or passport and a written power of attorney, or any other document that verifies the authority to act on behalf of the Applicant. The power of attorney must be duly notarized and apostilled. If the power of attorney is not notarized and apostilled, the Company reserves the right to request additional proof to ensure that the authorization of the third party was properly executed.

3.6. The Company may refuse to investigate a complaint if it was not filed in accordance with the procedures and rules outlined herein. The client will be informed of such refusal within 7 business days of the complaint being received by the Company.

3.7. Filing a Complaint and the Complaint handling process at the Company are free of charge.

3.8. If the Applicant submits a Complaint based on the same circumstances or grounds that were previously submitted and resolved by the Company for the same Applicant, the Company reserves the right to refuse to investigate such a Complaint and will inform the Applicant accordingly.

3.9. The Complaint shall be submitted via:

3.9.1. Registered mail sent to Konstitucijos pr. 26, LT-08131 Vilnius, Lithuania, Superb Payments, UAB;

3.9.2. Email address [_______]

4. Registration of Complaints

4.1. All Complaints received in accordance with these Rules are recorded in the Company’s Complaints registration journal. Complaints shall be registered on the date of receipt or on the next business day if the Complaint is submitted on a non-business day or after working hours.

4.2. The initial registration of the Complaint shall be carried out by the employee of the Company who received or accepted the Complaint. Subsequently, the Complaints log shall be updated by the employee assigned to handle the Complaint and prepare the response to the client.

4.3. The following information shall be recorded in Complaint journal:

4.3.1. Information about the Applicant (its representative), including contact information;

4.3.2. Subject of the Complaint;

4.3.3. Date of Complaint;

4.3.4. Services / actions of the Company which are appealed;

4.3.5. Deadline for response to the Applicant;

4.3.6. Decision of the Company and further actions.

5. Investigation of the Complaints and Decision Making

5.1. Complaints shall be investigated in accordance with the principles of justice, fairness, reasonableness, objectivity, impartiality, and respect for human rights. The Complaint investigation process shall be thoroughly documented.

5.2. The Company reserves the right to not investigate Complaints that do not comply with the requirements set forth in these Rules, are written in a language other than Lithuanian or English, are disorganized or unreadable, or where the identity of the Applicant is unclear.

5.3. If the submitted Complaint lacks the necessary information for investigation, the Company reserves the right to request that the Applicant rectify the deficiencies by clarifying the essence of the Complaint or providing additional documents or data required for the investigation. In such cases, the Company will set a reasonable deadline, which shall not be shorter than 7 calendar days, for the Applicant to address the deficiencies. If the Applicant rectifies the shortcomings within the set deadline, the Complaint will be considered submitted on the date the deficiencies were corrected, i.e., the day when the clarified Complaint or the required documents were provided to the Company.

6. Submission of Response to the Applicant

6.1. The Complaint shall be investigated, and a response provided as promptly as possible, but no later than: (i) 14 calendar days from the date of receipt of the Complaint from a consumer Applicant; and (ii) 30 calendar days from the date of receipt of the Complaint from other Applicants who are not considered consumers. The time period begins on the date the Complaint is received. In exceptional cases, where the Complaint cannot be investigated within the specified time frame, the Company must inform the Applicant, detailing the circumstances and the new deadline by which the Complaint will be investigated and a response provided.

6.2. The Company investigates the Complaint in accordance with applicable laws and may arrive at one of the following decisions:

6.2.1. To fully satisfy the Applicant's request;

6.2.2. To partially satisfy the Applicant's request;

6.2.3. To reject the Complaint.

6.3. When the Complaint is rejected or only partially satisfied, the Company’s response to the Applicant must include the reasons for not fully satisfying the Complaint. Additionally, if the Applicant is a natural person and qualifies as a consumer, the Company must inform the Applicant of their right to file a complaint to the Bank of Lithuania.

6.4. The Company's decision regarding the Complaint shall be recorded in the Complaints registration journal and sent to the Applicant via registered mail and/or email, as indicated by the Applicant.

7. Final Provisions

7.1. The Rules must be reviewed at least annually, no later than the 1st of March. Any modifications or amendments to the Rules must be made in writing and will become effective upon approval by a resolution of the appropriate management body.

7.2. The Customer Service Division of the Company is the responsible structural unit for handling complaints, communication, and maintaining the complaints registration journal. This department shall prepare and present quarterly reports to the Company’s management, highlighting key issues in the complaints handling process and proposing measures for improvement.

7.3. These Rules, along with any amendments, come into effect upon their approval. All employees must comply with the Rules from the moment they are introduced to them in writing and are required to adhere to their provisions.

7.4. If necessary, based on requests, instructions, requirements, or applicable laws, the Customer Service Division shall assume responsibility for the preparation and submission of appropriate reports to supervisory authorities concerning complaints. The Customer Service Division is also responsible for maintaining records of the number of complaints received, categorized by reason and outcome (e.g., number of complaints received, examined, satisfied, and partially satisfied), and shall submit this information to the Bank of Lithuania upon request.

7.5. The Company shall store Complaints, data related to their investigation, documents detailing the results of the investigation, and the responses provided to the Applicant for a minimum of 3 years from the date the final response is given. All information and documents shall be stored in accordance with the requirements set by Lithuanian law.