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Complaints Handling and Dispute Resolution Governance Policy

1. Introduction and Scope

This Complaints Handling and Dispute Resolution Governance Policy (“Policy”) defines the standards applied by Mobile Incorporated Limited (the “Company”, “we”, “us”, or “our”) for receiving, managing, and resolving customer complaints and disputes.

The Policy is established to ensure that all complaints are addressed in a fair, consistent, transparent, and timely manner, and forms part of the Company’s broader governance and regulatory compliance framework. It is approved by Senior Management and subject to ongoing oversight.

This Policy applies to:

  • All customers using the Company’s services and platforms
  • All gaming, betting, and related services operated under MGA authorisation
  • All employees, contractors, and outsourced service providers involved in customer interaction or operational support

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

2. Regulatory and Compliance Basis

This Policy is implemented in accordance with:

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

The Company maintains this Policy to ensure:

  • Accessible and well-defined complaint submission channels
  • Fair and evidence-based decision-making processes
  • Proper escalation and independent review structures
  • Compliance with reporting and audit obligations
  • Effective resolution of customer disputes

3. Principles of Complaint Management

The Company applies the following principles when handling complaints:

  • Objectivity – Complaints are assessed based on facts and evidence only.
  • Transparency – Customers are provided with clear and understandable explanations.
  • Responsiveness – Complaints are addressed within defined internal timeframes.
  • Independence – Escalated matters are reviewed separately from initial decision-making where feasible.
  • Customer Protection – Vulnerable customers and responsible gambling concerns are given priority attention.

Senior Management reviews complaint handling performance through periodic governance reporting.

4. Internal Governance and Training

Employees involved in complaints handling are required to complete training covering:

  • Regulatory obligations under MGA requirements
  • Complaint investigation standards and procedures
  • Escalation and reporting structures
  • Responsible gambling awareness and identification indicators

The internal control framework includes:

  • Defined roles, responsibilities, and escalation pathways
  • Documented operational procedures
  • System access controls and audit logging
  • Internal compliance monitoring and audit review processes

5. Complaint Submission Channels

Customers may submit complaints using the following methods:

  • Dedicated complaints email address
  • Customer support live chat or helpdesk system
  • Telephone customer support services
  • Written correspondence to the Company’s registered office

Customers are encouraged to include:

  • Account identification details
  • A clear explanation of the issue
  • Relevant transaction, game, or event references
  • Supporting documentation where available

Complaints are accepted free of charge and do not restrict the customer’s right to further escalation or external review.

6. Complaints Handling Lifecycle

6.1 Receipt and Acknowledgement

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

6.2 Investigation and Assessment

Each complaint is assessed in accordance with internal procedures and may be escalated to Compliance, Responsible Gaming specialists, or Senior Management depending on complexity and risk.

Investigations may include:

  • Review of system logs and technical records
  • Transaction and payment analysis
  • Customer communication history
  • Internal policy and procedure review

All actions taken are recorded in the Company’s complaints management register.

6.3 Outcome and Final Response

The Company aims to resolve complaints within 14 business days. Where this is not possible, customers will be informed of the delay and provided with updates.

Final decisions are:

  • Based on verified evidence and internal records
  • Communicated clearly with supporting reasoning
  • Documented for compliance and audit purposes
  • Subject to internal governance oversight

Customers may request a written statement explaining the outcome at any stage.

7. Escalation and External Resolution Mechanisms

7.1 Internal Escalation

Where a customer is dissatisfied with a decision, they may request an internal review. This review is conducted by a senior or independent function not involved in the original decision, where practicable, to ensure impartiality and procedural fairness.

7.2 External Escalation Options

If a complaint remains unresolved following 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 cooperate fully with all external bodies and provide relevant documentation where required by law or regulatory obligation.

8. ADR Mechanism, Legal Effect, and Access to Judicial Remedies

Where a dispute is referred to an Alternative Dispute Resolution (ADR) entity, the following applies:

  • The ADR body will independently assess the dispute and may issue a decision, recommendation, or proposed resolution depending on its mandate.
  • Such outcomes may be non-binding unless accepted by the parties or made binding under applicable legal provisions.
  • Participation in ADR does not affect the customer’s right to pursue judicial proceedings.

Where the Company provides access to a non-binding ADR process in accordance with Article 10(2) of Directive 2013/11/EU (as implemented by Directive 5 of 2018), customers will be informed that:

  • the ADR process does not result in a legally binding decision by default;
  • acceptance of an ADR outcome may influence the continuation or resolution of the dispute; and
  • to obtain a binding and enforceable decision, customers may be required to pursue the matter before the competent Maltese courts or other legally binding adjudicatory bodies.

Customers will be clearly informed of the implications of ADR participation, including how it may affect subsequent legal and judicial recourse.

9. Responsible Gambling and Priority Complaints

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

Such complaints:

  • Are escalated without delay to specialist personnel
  • Receive expedited assessment and handling
  • Are subject to enhanced compliance oversight

Serious cases may be escalated to Senior Management and included in regulatory reporting where required.

10. Records Management and Reporting Obligations

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

  • Complaint category and details
  • Investigation steps and supporting evidence
  • Outcome and rationale
  • Escalation history and decisions

Records are retained for a minimum of five years in accordance with applicable regulatory requirements.

Periodic reporting may include:

  • Complaint volumes and trends
  • Root cause analysis
  • Escalation metrics
  • Responsible gambling indicators

Where required, information may be submitted to the MGA in line with licence obligations.

11. Confidentiality and Data Protection

All complaints are treated as confidential and processed in accordance with applicable data protection laws.

Access is restricted to authorised personnel and safeguarded through:

  • Role-based access controls
  • Audit logging and monitoring systems
  • Internal information security governance measures

12. Policy Review and Governance Oversight

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 legal, regulatory, or operational changes
  • Subject to ongoing Board and Senior Management oversight

All material amendments are formally documented and communicated where required.

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