1. Policy Statement

At MobiPay Limited, we pride ourselves on delivering secure, reliable, and customer-centric financial technology solutions across Malawi and the region. We recognize that issues may occasionally arise, and when they do, we are committed to addressing them fairly, promptly, and transparently. This Complaint Policy outlines how we receive, manage, and resolve complaints, ensuring continuous improvement in our services and maintaining the trust of our clients, partners, and staff.

2. Purpose

This policy serves to:

• Ensure all complaints are handled with professionalism, objectivity, and urgency.
• Establish a standard procedure for receiving, acknowledging, investigating, and resolving complaints.
• Reinforce MobiPay’s commitment to excellence, regulatory compliance, and client satisfaction.
• Provide a structured mechanism for internal and external stakeholders to voice concerns without fear of retaliation.

3. Scope

This policy applies to:

• All external users and clients of MobiPay services (including mobile wallet users, merchants, agents, and corporate clients).
• Internal complaints raised by employees, contractors, or service providers.
• All digital channels, mobile applications, software platforms, customer service touchpoints, and operational workflows offered or managed by MobiPay Limited.

4. Definition of a Complaint

A complaint is a formal expression of dissatisfaction or concern regarding a MobiPay product, service, process, policy, system, employee conduct, or business relationship.

Examples include (but are not limited to):

• Service delays or disruptions (e.g., mobile payments, KYC onboarding, transaction failures).
• Unprofessional behavior by staff or agents.
• Incorrect charges or unauthorized transactions.
• Privacy violations or data breaches.
• Unresolved technical or account-related issues.
• Workplace grievances (for internal staff).

5. Guiding Principles

• Accessibility: Clients and staff can lodge complaints through multiple accessible channels.
• Confidentiality: All information provided is protected in compliance with the Malawi Data Protection Act and MobiPay’s internal policies.
• Responsiveness: Complaints are acknowledged within 2 business days and resolved as quickly as reasonably possible.
• Fairness: Every complaint is investigated without bias or prejudice.
• Accountability: All employees and departments are expected to support complaint resolution and service recovery.
• Continuous Improvement: We analyze complaint trends and implement systemic improvements regularly.

6. Lodging a Complaint

Complaints may be submitted via:

• Email: complaints@mobipay.mw
• Customer Care Line: +265 980 659 222 (Weekdays: 8:00 AM – 5:00 PM)
• WhatsApp Support: +265 980 659 222
• In-Person: MobiPay Head Office, Malipo Complex, 15 Nsangu Street, Njewa, Lilongwe, Malawi
• Web Form: www.malipo.mw/complaints

Complainants are advised to provide:

• Full name and contact details
• Description of the complaint (with relevant reference numbers, dates, screenshots, or other documentation)
• Expected outcome or proposed resolution

7. Complaint Handling Procedure

7.1 Acknowledgement
All complaints will be acknowledged within 3 business days of receipt.

7.2 Assessment
The complaint is categorized based on its severity and assigned to a responsible department or officer.

7.3 Investigation
A thorough review will be undertaken by the Customer Support Team or Compliance Unit, depending on the complaint type. Investigations aim to be completed within 10 business days. Complex complaints may take up to 20 business days, with updates provided regularly.

7.4 Resolution
Once resolved, the complainant will be informed of the findings and proposed actions in writing or via preferred communication channels. In cases of service failure, MobiPay may offer rectification, compensation, or service recovery as deemed appropriate.

7.5 Escalation and Appeals
If unsatisfied with the outcome, the complainant may escalate the issue to:
Head of Customer Experience: escalation@mobipaymw.com
Final appeals: Chief Executive Officer, MobiPay Limited
Where necessary, external escalation can be made to the Reserve Bank of Malawi or other applicable regulatory authorities.

8. Record-Keeping and Monitoring

All complaints are logged and stored securely in accordance with internal data governance protocols. Complaint data will be reviewed monthly for trend analysis and reported quarterly to executive management. Serious or high-risk complaints (e.g., fraud, regulatory breaches) will be immediately escalated and documented separately for audit purposes.

9. Roles and Responsibilities

• All Staff: Act respectfully, report grievances, and support complaint resolution.
• Customer Support Team: Receive, log, and respond to client-related complaints.
• Compliance Officer: Investigate, mediate, and report serious complaints.
• Management: Review trends, approve resolutions, and drive continuous improvement.

10. Regulatory and Legal Compliance

This policy aligns with:

• The Financial Services Act (Malawi)
• The Reserve Bank of Malawi Guidelines on Consumer Protection
• The Malawi Data Protection Act
• MobiPay’s internal policies on ethics, customer service, and digital security

11. Review and Policy Governance

This policy will be reviewed annually or upon significant legal, operational, or regulatory changes. The Compliance and Legal teams are responsible for updates and communication of revised versions.

Effective Date: 1st May 2025

Next Review Date: 1st May 2026

Approved by: Chief Executive Officer, MobiPay Limited