TABLE OF CONTENTS

INTRODUCTION AND SCOPE

Brisk Pay Ltd. ("Brisk Pay" or the "Company"), is committed to handling complaints in a fair, transparent, and timely manner. This Complaints Policy and Procedures (the "Complaints Policy") sets out how the Company receives, investigates, documents, and responds to complaints relating to its services.

The Company is a corporation incorporated under the laws of British Columbia, with physical operations at 22420 Dewdney Trunk Road, Suite 300, Maple Ridge, BC V2X 3J5. The Company offers money services within Canada and the United Kingdom.

Brisk Pay is a registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with the registration number C100000711. The Company adheres strictly to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.

Purpose and Scope

The purpose of this Policy is to ensure that complaints are:

• Easy to submit;
• Handled consistently and objectively;
• Properly documented; and
• Used to identify and remediate operational, compliance, or conduct risks.

Definition of Complaint

For the purposes of this Policy, a Complaint means any expression of dissatisfaction from a client or third party relating to the services provided by the Company, its partners, or any individual acting on its behalf, including acts or omissions, that is submitted through one of the Company's official communication channels, including contact forms, email, telephone, or postal mail.

What is Not Considered a Complaint

General service feedback, technical issues, or minor operational comments that are resolved promptly and do not involve a service failure, financial loss, client rights, or regulatory concern are not treated as formal Complaints, unless the issue persists, escalates, or the client requests further review.

Application of the Policy

The Complaints Policy applies to all clients and third parties who wish to file a Complaint regarding services provided by the Company, including but not limited to, issues related to customer service, transaction processing, account management, and compliance matters.

ROLES AND RESPONSIBILITIES

Brisk Pay maintains a structured and proportionate governance framework to ensure that Complaints are handled independently, objectively, and without conflicts of interest. Responsibility for complaint handling is clearly allocated to ensure appropriate oversight, segregation of duties, and escalation where required, particularly in circumstances involving senior management or potential conflicts.

Governance and Responsibilities

HOW COMPLAINTS MAY BE SUBMITTED

Complaints may be received through any of the following channels:

• Telephone: Complaints received by telephone during normal business hours.
• Email: Complaints received through the Company's designated complaints email address.
• Written correspondence: Complaints received by post or courier at the Company's registered business address.
• Website or electronic contact forms: Complaints submitted through online contact or inquiry forms.
• Verbal complaints: Complaints raised verbally during client interactions.

Current Operational Details

CATEGORIZATION OF COMPLAINTS

Upon receipt, Complaints are assessed and categorised to ensure they are handled in a proportionate, timely, and appropriate manner based on their nature and potential impact.

COMPLAINT HANDLING PROCEDURE

Documentation of Complaints

All Complaints, whether received verbally or in writing, are recorded promptly in the Complaints Register. Where a Complaint is received verbally, the receiving staff member must document the complaint in writing as soon as practicable.

Overview of Procedure Steps

1. Receive and capture: Document name, contact details, issue summary, and outcome requested.
2. Log and assign: Record in the Complaints Register with a unique reference number.
3. Categorise and Triage: Assess urgency (Low, Medium, High).
4. Response: Acknowledge receipt within 1-2 business days.
5. Investigate: Review logs, transaction data, and internal notes.
6. Outcome and Response: Provide a written response (Upheld, Partially Upheld, or Not Upheld).
7. Close and Retain: Close the record and retain for 5 years.

Response Timelines

ESCALATION CHANNELS

Internal Reporting Channels

Complaints involving potential fraud, financial crime, or senior management are escalated to the Risk Officer and/or Compliance Officer.

External Reporting Channels

RECORD KEEPING AND RETENTION

• Complaints Records: Date received, complainant details, category, actions, and outcome.
• Retention Period: Minimum of five (5) years from the date the Complaint is closed.
• Access: Restricted to personnel with legitimate business needs (Compliance, Auditors, Regulators).

TRAINING AND AWARENESS

The Company ensures that relevant personnel receive appropriate training on identifying complaints, documentation, and escalation procedures. Training is provided at onboarding and refreshed periodically.

POLICY REVIEW

This policy is reviewed periodically to align with business model changes or regulatory updates.

Next Scheduled Update: January 1, 2027

APPENDIX A: COMPLAINTS REGISTER