Grievance Redressal Policy @PayGlocal
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Last updated: January 22, 2024
Background
PayGlocal Technologies Private Limited (hereinafter referred as “PayGlocal” or the “Company” or “We”) is a company incorporated under the Companies Act 2013. It has its registered office at 6048, Prestige Shantiniketan, ITPL Main Road, Whitefield, Bengaluru – 560048, Karnataka.
PayGlocal proposes to offer a transparent, open, and approachable grievance redressal process for end-customers & merchants to connect with PayGlocal and raise valid grievances for their transaction related, onboarding, settlement, integration problems that they face in the course of using payment aggregator services provided by PayGlocal. The Company's Grievance Redressal Policy focuses on improving customer satisfaction by collecting feedback from customers across all business units and actions plans are put in place to address key issues. (“Grievance Redressal Policy” or the “Policy”). The Company provides payment services which includes Payment Aggregator (“PA”) and Payment Aggregator - Cross Border (”PA-CB”). The Company believes in providing best in class services to its customers/ merchants (“customers”).
This Policy is structured for minimizing customer & merchant grievances. The Policy is formed to accept grievances through proper channels and provide review mechanism and prompt redressal of all customer & merchant grievances.
The Company's endeavour is to ensure that all Customer complaints are resolved within 7 (seven) days and maximum upto 30 (thirty) days. The thirty-day period will be reckoned after all the necessary information from the customer is received.
Objective
This Policy has been framed with a purpose to set forth a framework for receiving, handling and responding to any complaints/ grievances against the Company in respect of the services offered to the Customers. Below are the broad objectives set by the Company for handling customer grievances:- To provide fair treatment to all customers
- To have a well-defined and publicly disclosed customer grievance redressal policy.
- To ensure that the Policy is clearly and easily accessible through one or more channels to customers.
- To ensure that all the customer complaints are appropriately managed and resolved within the timelines specified.
- To develop an organizational framework which promptly resolves customer complaints fairly and equitably.
- To provide the customer the facility to keep track of the grievance throughout the resolution process; and
- To have a well-defined escalation matrix with different levels.
Grievance Reporting Channels
PayGlocal accepts grievances through two primary channels:| S.No. | Channels | Details |
|---|---|---|
| 1 | Website | www.payglocal.in |
| 2 | [email protected] |
Once a grievance is received through the above channels, PayGlocal assigns that to its internal team for redressal. In the event a grievance response is not received by the customer/merchant within the prescribed time frame mentioned in this Policy, they can approach the Nodal Officer appointed by PayGlocal for escalation. The escalation matrix is defined below. The customer/merchant is expected to read and understand this process to receive appropriate redressal support from PayGlocal.
Note: Customer/merchant is advised to exhaust the remedy at the numerically preceding level before escalating to a numerically higher level.
Note: Customer/merchant is advised to exhaust the remedy at the numerically preceding level before escalating to a numerically higher level.
Level 1 - Reading FAQs and Reporting a specific Issue
The customer/merchant can visit the PayGlocal website and refer to the customer grievance process. If the customer has any query related to a particular issue, they can also refer to a section available toward the end of the page which describes various possible issues and their resolution process. The customer/ merchant can raise a complaint by writing to PayGlocal on the email ID provided. Further, merchants can reach out to PayGlocal for any query or issue by writing to [email protected] from their registered email ID, along with a detailed description of the issue and supporting details such as merchant MID and transaction details. PayGlocal support staff will acknowledge the request within 1 (One) - 2 (Two) working days.In the event the customer does not receive a response from PayGlocal within the timeline stated herein, the customer can go for the next level of escalation.Customers/merchants are encouraged to provide complete details of their grievance, along with relevant documents (if any), in their complaint. However, in case of any trouble faced by the Customer/merchant in lodging an appropriate complaint, PayGlocal shall endeavor to provide guidance to the Customer/merchant in this regard.Level 2 - Escalation in case of No-response or non- satisfactory response
If the customer does not receive answers/ is not satisfied with the response to their questions from PayGlocal's Level 1 support process, within 5 (Five) working days from filling and submitting the form, the Customer can then escalate their query to [email protected]. This email should contain the customer email ID and 'support request' in the subject line of the email to PayGlocal support staff.Resolution of grievance may depend upon responses and clarification from external stakeholders and would take approximately between 5 (Five) to 7 (Seven).
The Customer/merchant may request for an update and PayGlocal will keep the Customer/ merchant posted if any grievance requires more than the specified time. If the Customer/ merchant is not satisfied with the response provided, they can go for the next level of support and escalate the case to the Grievance Officer:
Grievance Officer:
Nikhil Jain,
PayGlocal Technologies Private Limited
Bangalore Office: 72, Service Road, LRDE Layout, Doddanekundi, Bengaluru, 560037
E-mail : [email protected]
Level 3 - Escalating and Reporting to Grievance Redressal Officer and/or Nodal Officer
In the event the Customer/merchant does not receive a response, within the prescribed timeline of 5 (Five) to 7 (Seven) working days, it may approach the Nodal Officer of PayGlocal, at the following contact details:Nodal Officer:
Ritu Verma,
PayGlocal Technologies Private Limited
Bangalore Office: 72, Service Road, LRDE Layout, Doddanekundi, Bengaluru, 560037
E-mail : [email protected]
The Nodal Officer shall send his/her final response to the customer within 2 working days of lodging the grievance. Such a response may either contain the resolution or an intimation that PayGlocal requires more time to examine the grievance, along with the reason for seeking such extension. The maximum time to resolve the complaint is 30 (Thirty) working days from the date of lodging the grievance.
Level 4 – RBI Ombudsman
If the Company is unable to resolve the issue, then the Company may approach the Ombudsman for Digital Transaction of Reserve Bank of India (“RBI”), in terms of the Ombudsman Scheme for Digital Transactions, 2019 by way of submitting their complaint in the Form-A thereof and clearly state the (a) name and address of the complainant; (b) name and address of the branch or office against which the complaint has been lodged; (c) facts giving rise to the complaint; (d) nature and extent of the loss caused by the complainant; and (e) relief sought for. Such complaints shall be accompanied with the copies of documents, if any, which the Company may rely upon.Guidelines For Failed Transactions
In compliance with the circular DPSS:CO.PD No.629/02.01.014/2019-20 dated September 20, 2019 Turnaround Time (TAT) and Customer compensation for failed transactions using authorized Payment Systems is tabled below for applicable clauses:| S.NO. | Description of the incident | Framework for auto-reversal and compensation | |
|---|---|---|---|
| Timeline for auto-reversal | Compensation payable | ||
| I | II | III | IV |
| 1 | Card Transaction | ||
| a | Card Not Present (CNP) (e-commerce) Account debited but confirmation not received at merchant’s end | Auto-reversal within T+5 days | INR 100/- per day of delay beyond T+5 days |
| 2 | Immediate Payment System | ||
| a | Account debited but the beneficiary account is not credited | If unable to credit to beneficiary account, auto reversal (R) by the Beneficiary bank latest on T+1 day | INR 100/- per day of delay beyond T+1 days |
| 3 | Unified Payments Interface (UPI) | ||
| a | Account debited but the beneficiary account is not credited (transfer of funds) | If unable to credit the beneficiary account, auto reversal ® by the Beneficiary bank latest on T+1 day | INR 100/- per day if delay is beyond T+1 day |
| b | Account debited but transaction confirmation not received at merchant location (payment to merchant) | Auto reversal within T+5 days | INR 100/- per day if delay is beyond T+5 day |
FAQs for customers/ merchants reference
Probable Disputes and Resolutions
PayGlocal defines a robust framework to manage disputes/grievances. This framework gives an overview of the transaction lifecycle of PayGlocal system and handles issues faced by customers and merchants separately, with resolution guidelines specified for each dispute type. The customer/merchant is expected to read and understand the dispute type and resolution ownership of their grievance to receive appropriate redressal support from PayGlocal.Transaction Lifecycle of PayGlocal System
When a customer initiates a transaction, it is first approved by the payment processing engine and then proceeds to get authorization from the customer for funds to be deducted from their account. Once the transaction has been authorized, it is sent for capture by the processing engine, failing which the transaction is reversed and the amount is returned to the customer account. If the customer initiates refund for any transaction, the captured transaction is then sent for refund processing.Based on this transaction lifecycle, PayGlocal has identified possible issues/ disputes that could arise with the customers or merchants and outlined a dispute resolution framework that acts as a guide to support the grievance redressal process.
Customer Level Issues and possible actions
PayGlocal dispute resolution framework classifies customer issues into 5 (Five) types and outlines the guidelines for resolution as per dispute type.| # | Dispute Type | Resolution Ownership | Resolution Steps | Turn Around Time (TAT) |
|---|---|---|---|---|
| 1 | Goods or services issue | Merchant | Resolution by merchant selling the items | Merchant controlled |
| 2 | Transaction Issue | Merchant /PayGlocal | Resolution to be identified between parties participating in transaction flow. Compensate customer as per the RBI circular dated September 20, 2019, and bearing reference no. RBI/2019- 20/67DPSS.CO.PD No.629/02.01.014/2019-20, as the same may be modified or supplemented from time to time (“TAT Circular”). | 5 days |
| 3 | Fraudulent Transaction | Merchant /PayGlocal | Merchant and PayGlocal to implement measures to block future fraud. | 5 days |
| 4 | Suspected Merchant Fraud | PayGlocal | Resolution facilitated by PayGlocal to customer or customer is asked to file a chargeback; action against merchant | 5 days |
| 5 | Chargeback initiated by Customer | Merchant | Merchant is to bear the chargeback. PayGlocal to adhere to the chargeback process required for payment aggregation business. | NA |
For dispute types where the Turn Around Time (“TAT”) is mentioned as 'NA', PayGlocal team will respond to the merchant support request within 1 (One) - 2 (Two) working days and mention the resolution details and TAT accordingly on a case-by-case basis.
Goods or Service Issue
If the customer grievance or dispute is due to any of the following reasons,- Order not delivered.
- SNAD – Items Significantly Not as Described.
- Service not rendered.
- Quality issue – Damaged/ defective items.
- Goods/Service delivered later than expected.
- Future partial service not required.
- Other goods or services related issues.
The customer is advised to resolve this issue with their merchant as the first step. Merchants provide direct support to the customers on their goods and service deliveries since PayGlocal does not take part in shipping or delivering of the products to the customers.
The customer should visit the merchant's website or app and refer to the terms & conditions, shipping policy, refund/exchange/return/cancellation policy and contact the merchant to resolve the issue.
In most cases, the customer must share the details of their transaction such as transaction date, amount, order ID shared by the merchant along with the issue they are facing with the merchant.
Below is a detailed description of how this dispute is handled.
Resolution Owner: Merchant
Turn-around Time (TAT): Merchant Controlled
Merchant is Not RespondingFor a goods or service issue in case the customer does not get a response from their merchant within 15 (Fifteen) working days from the date of transaction made by the customer, then the customer can contact PayGlocal to mediate and amicably resolve the issue. The customer may provide PayGlocal with the following details:
- Merchant Name
- Merchant Website
- Transaction Date
- Transaction Amount
- Transaction ID (if available)
- Order ID (as received from the merchant)
- Issue description
- Details of merchant communication
- Screenshots of calls attempted to the merchant support from phone where no response was received.
- Screenshots of merchant communication and the customer exchanged via email.
the timeline specified for Level 1/ Level 2 support request. Below is a detailed description of how this dispute is handled.Merchant Response is Not Satisfactory
If the customer has received a response back from the merchant and is not satisfied with their response, the customer can raise a chargeback with their issuing bank (for card payments). These chargebacks will be raised with PayGlocal by the customer's issuing bank and PayGlocal will provide support to resolve the issue as per the chargeback guidelines.
If the customer has received a response back from the merchant and is not satisfied with their response, the customer can raise a chargeback with their issuing bank (for card payments). These chargebacks will be raised with PayGlocal by the customer's issuing bank and PayGlocal will provide support to resolve the issue as per the chargeback guidelines.
Transaction Issues
If the customer grievance or dispute is due to any of the following reasons:
If the customer grievance or dispute is due to any of the following reasons:
- Order Failure – Funds deducted but order not placed.
- Refund not processed.
Order Failures
In case of a transaction status mismatch, it could happen that the amount is deducted from the customer's card or account, but the merchant order is not confirmed. In this case, the customer should get the credit in their bank account within 5 (Five) -7 (Seven) business days. In case the customer has not received the amount, the customer may contact the merchant for further details, as the refunds are initiated from merchant's end. Below is a detailed description of how this dispute is handled.
Please note that with respect to TAT of failed transactions (5 (Five) - 7 (Seven) days), wherever financial compensation is involved, the same shall be affected to the customer's account suo moto, without waiting for a complaint or claim from the customer. Customer can also reach out to PayGlocal as per the grievance reporting channels mentioned in this Policy in case of any compensation related issues. Further, with respect to TAT please refer to the TAT Circular.
In case of a transaction status mismatch, it could happen that the amount is deducted from the customer's card or account, but the merchant order is not confirmed. In this case, the customer should get the credit in their bank account within 5 (Five) -7 (Seven) business days. In case the customer has not received the amount, the customer may contact the merchant for further details, as the refunds are initiated from merchant's end. Below is a detailed description of how this dispute is handled.
Please note that with respect to TAT of failed transactions (5 (Five) - 7 (Seven) days), wherever financial compensation is involved, the same shall be affected to the customer's account suo moto, without waiting for a complaint or claim from the customer. Customer can also reach out to PayGlocal as per the grievance reporting channels mentioned in this Policy in case of any compensation related issues. Further, with respect to TAT please refer to the TAT Circular.Refund Not Processed
In case a merchant declines to process the refund to the customer for cases where services/products were not delivered by the merchant and the customer's account was debited, the customer can contact PayGlocal for resolution on the same by raising a Level 1 support request as outlined under Grievance Reporting Channels in this Policy. PayGlocal then evaluates the issue and provides resolution accordingly.
In case a merchant declines to process the refund to the customer for cases where services/products were not delivered by the merchant and the customer's account was debited, the customer can contact PayGlocal for resolution on the same by raising a Level 1 support request as outlined under Grievance Reporting Channels in this Policy. PayGlocal then evaluates the issue and provides resolution accordingly.
Cancellation/ Refund/ Return related Queries
For cancellation of orders/refunds/returns, the customer should directly contact the merchant. Merchants provide the return/refund/cancellation policy on their websites. Note that PayGlocal is a payment system provider and offers payments services to merchants. The delivery of goods and services is managed by merchants and PayGlocal does not handle delivery of products/services.
For cancellation of orders/refunds/returns, the customer should directly contact the merchant. Merchants provide the return/refund/cancellation policy on their websites. Note that PayGlocal is a payment system provider and offers payments services to merchants. The delivery of goods and services is managed by merchants and PayGlocal does not handle delivery of products/services.
Reporting Fraudulent Transactions
In case a customer experiences that their payment instrument such as card or bank account has been used without their permission on a merchant that uses PayGlocal as their payment processing platform, the customer can report the same to PayGlocal fraud management team on email id: [email protected].
For the transaction, PayGlocal will inform the same to the merchant and if merchant has not delivered the product/ services, merchant may cancel the order and refund the amount back to the cardholder. For transactions where refund cannot be initiated, customer may file complaint with law enforcement agency and PayGlocal will support to provide all details to them to carry out investigation of the case.
While reporting Fraudulent transaction to PayGlocal, the customer must put this text in the subject line 'Fraudulent Transaction Reporting' when sending email to [email protected]. The customer must provide as many details about that transaction as they can without actually sharing the card details or other sensitive information with respect to a transaction and the payment instrument used for the fraudulent transaction. Please refer to the PayGlocal FAQ page for more details on specific use cases related to a fraudulent transaction. Please note that for fraudulent transactions, customer queries will be addressed appropriately on [email protected] (as per RBI guidelines)
In case a customer experiences that their payment instrument such as card or bank account has been used without their permission on a merchant that uses PayGlocal as their payment processing platform, the customer can report the same to PayGlocal fraud management team on email id: [email protected].
For the transaction, PayGlocal will inform the same to the merchant and if merchant has not delivered the product/ services, merchant may cancel the order and refund the amount back to the cardholder. For transactions where refund cannot be initiated, customer may file complaint with law enforcement agency and PayGlocal will support to provide all details to them to carry out investigation of the case.
While reporting Fraudulent transaction to PayGlocal, the customer must put this text in the subject line 'Fraudulent Transaction Reporting' when sending email to [email protected]. The customer must provide as many details about that transaction as they can without actually sharing the card details or other sensitive information with respect to a transaction and the payment instrument used for the fraudulent transaction. Please refer to the PayGlocal FAQ page for more details on specific use cases related to a fraudulent transaction. Please note that for fraudulent transactions, customer queries will be addressed appropriately on [email protected] (as per RBI guidelines)Reporting Suspected Merchant Fraud
In case a customer experiences fraudulent activity by a merchant such as selling goods and services not as per their website or their terms and conditions, the customer can report that to PayGlocal via a Level 1 Support request and PayGlocal will attempt to address that in good faith by contacting the merchant and asking them to take corrective measures and addressing the issue in a reasonable timeframe. PayGlocal will keep the customer informed on the course of action taken by the merchant on their complaint until a resolution is received.
If the chargeback rate for a merchant is higher than 0.75%1 per month, PayGlocal will:
In case a customer experiences fraudulent activity by a merchant such as selling goods and services not as per their website or their terms and conditions, the customer can report that to PayGlocal via a Level 1 Support request and PayGlocal will attempt to address that in good faith by contacting the merchant and asking them to take corrective measures and addressing the issue in a reasonable timeframe. PayGlocal will keep the customer informed on the course of action taken by the merchant on their complaint until a resolution is received.
If the chargeback rate for a merchant is higher than 0.75%1 per month, PayGlocal will:- Work with merchant to improve this rate and bring chargeback rate down.
- PayGlocal might stop merchant transactions on the platform if this rate remains high.
- PayGlocal may stop merchant settlement per risk assessment by its merchant risk management team.
Customer Chargeback
A chargeback can be initiated by the customer directly with their issuing bank in case of:
Primarily, all the chargebacks broadly fall under two reasons – fraud chargebacks and service- related chargebacks.
Common reasons for fraud chargebacks are mentioned below and each reason is assigned a reason code to be specified while processing the chargeback:
A chargeback can be initiated by the customer directly with their issuing bank in case of:
- unresolved goods or service issue
- merchant not responding (service not rendered)
- merchant response unsatisfactory (SNAD – items significantly not as described)
- duplicate payment made
- reporting fraudulent transaction
- reporting suspected merchant fraud
Primarily, all the chargebacks broadly fall under two reasons – fraud chargebacks and service- related chargebacks.Common reasons for fraud chargebacks are mentioned below and each reason is assigned a reason code to be specified while processing the chargeback:
- family/friend/employee use of card
- unauthorized transaction
- buyer forgets about the order placed.
- Not received – customer claims that merchandise was never delivered.
- Not as described/ defective – merchandise was damaged or defective or did not match description on the website.
- Returns – the buyer has returned the merchandise and has not received the refund they were expecting.
Merchant Level Issues and possible actions
Outlined below are possible issues/disputes that a merchant can face while using PayGlocal payment aggregator services and guidelines on their speedy resolution.
For dispute types where the TAT is mentioned as 'NA', PayGlocal team will respond to the merchant support request within 1 (One) -2 (Two) working days and mention the resolution details and TAT accordingly on a case-by-case basis.
As merchant issues differ on a case-to-case basis and require extensive support and immediate resolution, merchants are advised to reach out to PayGlocal directly via Level 2 support channel - email to PayGlocal Support as outlined under grievance reporting channels in this Policy.
Outlined below are possible issues/disputes that a merchant can face while using PayGlocal payment aggregator services and guidelines on their speedy resolution.
| # | Dispute Type | Resolution Ownership | Resolution Steps | Turn Around Time (TAT) |
|---|---|---|---|---|
| 1 | Merchant Account Level Issues | PayGlocal | Resolution by PayGlocal upon receiving a Level 2 support request from Merchant | NA |
| 2 | Settlement Related Issues | PayGlocal | Resolution by PayGlocal upon receiving a Level 2 support request from Merchant | NA |
| 3 | Transaction Issues | PayGlocal | Resolution by PayGlocal upon receiving a Level 2 support request from Merchant. | NA |
As merchant issues differ on a case-to-case basis and require extensive support and immediate resolution, merchants are advised to reach out to PayGlocal directly via Level 2 support channel - email to PayGlocal Support as outlined under grievance reporting channels in this Policy.
Merchant Account Level Issues
KYC & Application form submitted, however Account still not Activated. Activation of an account is subject to
PayGlocal team will update the merchant on the activation status of the account upon receiving approval from banking partners.
In case the issue persists after 5 (Five) - 7 (Seven) working days, merchant can contact PayGlocal for resolution on the same as per the grievance reporting channels outlined in this Policy. The merchant is required to write to PayGlocal from their registered email ID as per Level 2 support of grievance reporting channels and PayGlocal will update the Merchant on resolution accordingly.
KYC & Application form submitted, however Account still not Activated. Activation of an account is subject to
- Completion of KYC Form review (for which TAT is 3 (Three)-5 (Five) working days from the date when KYC documents were submitted to PayGlocal)
- Approval from our banking partners
PayGlocal team will update the merchant on the activation status of the account upon receiving approval from banking partners.
In case the issue persists after 5 (Five) - 7 (Seven) working days, merchant can contact PayGlocal for resolution on the same as per the grievance reporting channels outlined in this Policy. The merchant is required to write to PayGlocal from their registered email ID as per Level 2 support of grievance reporting channels and PayGlocal will update the Merchant on resolution accordingly.
Facing Issues while integration
If the merchant faces any issue during the integration, merchant can contact PayGlocal for resolution on the same as per the grievance reporting channels outlined in this Policy. The merchant is required to write to PayGlocal from their registered email ID with a detailed description of the issue and PayGlocal will reach out to the merchant for resolution accordingly.
If the merchant faces any issue during the integration, merchant can contact PayGlocal for resolution on the same as per the grievance reporting channels outlined in this Policy. The merchant is required to write to PayGlocal from their registered email ID with a detailed description of the issue and PayGlocal will reach out to the merchant for resolution accordingly.
Settlement Related Issues
Settlement Hold IssuePayGlocal compliance team and partner banks carry out routine audits of each merchant’s transactions to identify any risky or out of pattern transactions and may temporarily pause merchant settlements during this time. The merchant is advised not to worry as the merchant is informed of the same via an email to the merchant’s registered email ID by PayGlocal team and asked to provide any clarifications required.
Upon receiving merchant' response on clarifications, PayGlocal will be able to release the settlement within 2 (Two) working days and re-enable settlements for the merchant. Please note that the merchant can still accept payments from end-customers.
In case of no resolution within 2 (Two) working days post submission of the requested information, merchant can raise a Level 2 Support Request for grievance reporting as outlined in this Policy. PayGlocal will reach out to the merchant with appropriate resolution.
Merchant has not received the settlement/ Status Shown as Failed
If the merchant has been requested by PayGlocal team to provide any information/ clarification, the merchant is advised to revert to the email with the necessary details.
If not, the merchant is advised to contact PayGlocal for resolution of the same by raising a Level 2 support request for grievance reporting outlined in this Policy. The merchant is required to provide the MID and transaction details with respect to the settlement in the support request email.
PayGlocal team will check the hold-up and revert to the merchant.
If the merchant has been requested by PayGlocal team to provide any information/ clarification, the merchant is advised to revert to the email with the necessary details.
If not, the merchant is advised to contact PayGlocal for resolution of the same by raising a Level 2 support request for grievance reporting outlined in this Policy. The merchant is required to provide the MID and transaction details with respect to the settlement in the support request email.
PayGlocal team will check the hold-up and revert to the merchant.
Transaction Issue
Unable to Refund a paymentIf the current balance in the merchant account is less than the amount that the merchant is trying to refund, the merchant is advised to initiate the refund after receiving further payments or initiate a Level 2 support request with PayGlocal team with their registered email ID along with MID and transaction details. PayGlocal team will respond to the request as per the TAT and dispute type guidelines mentioned in this Policy.
CONTROL REFERENCE
- RBI – Guidelines on Regulation of Payment Aggregators and Payment Gateways, March 2020
- RBI – Regulation on Payment Aggregator – Cross Border (PA – Cross Border), October 31, 2023
- RBI – Harmonization of Turn Around Time (TAT) and customer compensation for failed transactions using authorized Payment Systems, September 20, 2019
Updating of the Policy
PayGlocal has the right to revise, update or amend this Policy from time to time as per the relevant laws. This Policy is a mechanism sought to be initiated for analysis and requisite action at the grass root levels towards rectification of any recurring concerns or grievances that may be identified. In the event any material changes are made to the Policy, PayGlocal will notify you via this platform. The Policy will be approved by the Board of Directors of the Company.
PayGlocal has the right to revise, update or amend this Policy from time to time as per the relevant laws. This Policy is a mechanism sought to be initiated for analysis and requisite action at the grass root levels towards rectification of any recurring concerns or grievances that may be identified. In the event any material changes are made to the Policy, PayGlocal will notify you via this platform. The Policy will be approved by the Board of Directors of the Company.