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Complaints Handling and Alternative Dispute Resolution Policy

1. Introduction and Purpose

This Complaints Handling and Alternative Dispute Resolution Policy (“Policy”) sets out the framework used by Mobile Incorporated Limited (the “Company”, “we”, “us”, or “our”) to manage customer complaints and disputes in a structured, fair, and transparent manner.

The Policy is an integral component of the Company’s governance and compliance system and has been approved by Senior Management. It is designed to ensure alignment with applicable Maltese legislation, Malta Gaming Authority (MGA) regulatory requirements, and applicable consumer protection standards.

This Policy applies to:

  • All users and customers of the Company’s services
  • All gaming, betting, and related activities operated under MGA licensing
  • All employees, contractors, and third-party service providers involved in service delivery or customer support functions

Ultimate responsibility for compliance with this Policy rests with Senior Management and the Board of Directors.

2. Legal and Regulatory Framework

This Policy is implemented in accordance with:

  • The Gaming Act (Chapter 583 of the Laws of Malta)
  • Applicable MGA licence conditions, directives, and regulatory instructions
  • Relevant consumer protection legislation
  • Data protection obligations, including the General Data Protection Regulation (GDPR)

The Company maintains this Policy to ensure:

  • Fair treatment of all customer complaints
  • Accessible and effective complaint submission channels
  • Transparent investigation and resolution procedures
  • Compliance with reporting and audit obligations
  • Proper escalation and dispute resolution pathways

3. Guiding Principles

The Company applies the following principles in handling complaints:

  • Equity – All complaints are assessed objectively and without prejudice.
  • Clarity – Customers are provided with understandable explanations of outcomes.
  • Responsibility – Clear accountability exists at each stage of the process.
  • Independence – Where possible, escalated complaints are reviewed independently of the original decision-makers.
  • Protection of Customers – Special attention is given to vulnerable customers and responsible gambling matters.

Senior Management reviews complaint handling performance and systemic trends on a periodic basis.

4. Internal Capability and Governance Controls

Employees involved in complaint handling receive appropriate training covering:

  • Regulatory obligations under MGA requirements
  • Complaint investigation and assessment procedures
  • Escalation and reporting processes
  • Responsible gambling awareness and intervention indicators

The Company maintains a controlled internal environment through:

  • Defined roles and escalation responsibilities
  • Documented procedures and operational guidelines
  • System access restrictions and audit logging
  • Internal compliance monitoring and periodic audit reviews

5. Complaint Submission Methods

Customers may submit complaints through the following channels:

  • Dedicated complaints email address
  • Customer support chat or online portal
  • Telephone support services
  • Written correspondence to the Company’s registered office

To assist efficient resolution, customers are encouraged to include:

  • Account identification details
  • A description of the issue raised
  • Relevant transaction or game references
  • Any supporting evidence or documentation

Submitting a complaint is free of charge and does not affect the customer’s right to pursue further escalation.

6. Complaint Management Process

6.1 Acknowledgement of Complaint

All complaints are acknowledged within a reasonable timeframe, typically within 48 hours. The acknowledgement includes confirmation of receipt, a reference number, and information on expected timelines and escalation options.

6.2 Investigation and Review

Complaints are assessed in accordance with internal procedures and may be escalated to Compliance, Responsible Gaming, or Senior Management depending on the nature of the issue.

Investigations may include:

  • Review of system and game logs
  • Financial and transaction analysis
  • Review of customer communications
  • Assessment of relevant internal policies and procedures

All actions taken are documented within the Company’s complaints register.

6.3 Outcome and Communication

The Company aims to resolve complaints within 14 business days. Where this is not possible due to complexity or external dependencies, customers will be informed and provided with updates.

Final outcomes are:

  • Based on documented evidence
  • Clearly communicated to the customer
  • Recorded for audit and regulatory purposes
  • Subject to internal governance oversight

Customers may request a written explanation of any decision issued.

7. Escalation and External Dispute Resolution

7.1 Internal Escalation Process

If a customer is not satisfied with the outcome, they may request an internal review. This review is carried out by a senior or independent function not involved in the original decision, where practicable, to ensure impartiality.

7.2 External Escalation Options

If a dispute remains unresolved after internal escalation, customers may refer the matter to:

  • The Malta Gaming Authority (MGA)
  • An Alternative Dispute Resolution (ADR) entity approved by the MGA
  • The competent courts of Malta

The Company will fully cooperate with all external authorities and provide relevant information and documentation where required by law.

8. ADR Process, Legal Consequences, and Right to Judicial Recourse

Where a dispute is referred to an Alternative Dispute Resolution (ADR) entity, customers should be aware of the following:

  • The ADR entity will independently review the dispute and may issue a decision, recommendation, or proposed settlement depending on its mandate.
  • Such outcomes may be non-binding unless expressly accepted by the parties or made binding under applicable legal provisions.
  • Participation in ADR does not remove or limit the customer’s right to seek judicial remedies.

Where the Company makes available non-binding ADR services in accordance with Article 10(2) of Directive 2013/11/EU (as transposed by Directive 5 of 2018), customers will be informed that:

  • the ADR outcome does not constitute a binding legal decision;
  • acceptance of a non-binding ADR outcome may influence how the dispute is subsequently handled; and
  • in order to obtain a binding and enforceable resolution, the customer may need to pursue the matter through the competent courts of Malta or other legally binding adjudicatory bodies.

Customers will be clearly informed of the consequences of ADR participation, including its potential impact on further legal or judicial recourse.

9. Responsible Gambling and Sensitive Cases

Complaints involving responsible gambling issues, including self-exclusion, underage access concerns, or indicators of harm, are treated as high priority.

Such complaints:

  • Are escalated immediately to specialist teams
  • Are prioritised for urgent review
  • Are subject to enhanced compliance oversight

Serious matters may be escalated to Senior Management and included in regulatory reporting where appropriate.

10. Record Keeping and Regulatory Reporting

The Company maintains a secure complaints register for governance and compliance purposes, recording:

  • Complaint category and description
  • Investigation steps and findings
  • Final outcome and reasoning
  • Escalation history

Records are retained for at least five years in line with regulatory obligations.

The Company may also produce periodic reports covering:

  • Complaint volumes and trends
  • Root cause analysis
  • Escalation statistics
  • Responsible gambling-related metrics

Where required, information may be shared with the MGA in accordance with licence conditions.

11. Data Protection and Confidentiality

All complaints are handled confidentially and in compliance with applicable data protection laws.

Access to complaint data is strictly limited to authorised personnel and safeguarded through:

  • Role-based access controls
  • Audit trails and monitoring systems
  • Internal security policies and procedures

12. Policy Review and Governance

This Policy is approved by Senior Management of Mobile Incorporated Limited and forms part of the Company’s governance framework.

It is:

  • Reviewed at least annually
  • Updated in response to regulatory, legal, or operational changes
  • Subject to ongoing Board and Senior Management oversight

All material amendments are formally documented and communicated where necessary.