1. GENERAL PROVISIONS

1.1. UAB BLUE EMI LT (“Company”), in carrying out the related activities, adheres to the laws of the Republic of Lithuania, resolutions of the Board of the Bank of Lithuania and other applicable legal acts.

1.2. The purpose of the Policy is to outline the process of Client claims (complaints) submission and management fairly and understandably.

1.3. The Policy applies to the complaints concerning the services provided by the Company and/or the contracts concluded with the Company, as far as the Company’s activities are concerned.

1.4. The Policy does not apply to legal claims, actions, requests related to legal disputes, to fulfil the terms and conditions of contracts or provide information, explanations submitted to the Company by customers and/or third parties, as well as in cases where a customer submits a complaint concerning the Company’s activities not regulated by special laws nor supervised by the Bank of Lithuania, etc.

2. TERMS AND DEFINITIONS

2.1. The capitalised terms in this Procedure shall have the following meanings:

2.1.1. Complainant – a person who has submitted a Complaint regarding the services provided by the Company and/or agreements concluded with the Company, i.e. a current or potential Customer or its representative;

2.1.2. Company – UAB BLUE EMI LT, legal entity code: 305682465, registered office address: Antano Tumėno str. 4, Vilnius, Republic of Lithuania;

2.1.3. Complaint – application of the Complainants submitted to the Company in writing (or otherwise on a durable medium) stating that the rights or legitimate interests of a person related to the Services of the Company were violated and/or that the Service contract between the Company and the Customer was violated;

2.1.4. Complaints Register – a written logbook or an equivalent electronic document registration system in which the received Complaints of Complainants are registered;

2.1.5. Consumer – a natural person (private person) who uses the Company’s services for purposes unrelated to his or her business, trade or professional activity;

2.1.6. Customer – natural or legal person to whom the Company provides Services;

2.1.7. Chargeback – Cardholder’s claim against the Company’s client (E-Merchant), disputing a transaction, according to Visa and Mastercard regulations;

2.1.8. Responsible Employee – a person who is responsible for handling Complaints in the Company, i.e. collecting information necessary to handle received Complaints, handling Complaints, making decisions and preparing Responses to Complainants;

2.1.9. Services – electronic money and/or electronic money token issuing and/or redemption services, payment services or other activities offered by the Company to Customers;

2.1.10. Supervisory Authority – Bank of Lithuania, legal entity code 188607684, registered office address Gedimino pr. 6, Vilnius, Republic of Lithuania;

2.1.11. Inquiry – A request for information, clarification, investigation or general assistance that does not express dissatisfaction with the Company’s services, products, or conduct.

2.2. Other terms used in this Procedure shall have the meanings defined in the Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania, the Law on Payments of the Republic of Lithuania, the Resolution No. 03-105 of the Board of the Bank of Lithuania of 6 June 2013 “On Approval of the Regulations for Handling Complaints Received by Financial Market Participants” and other relevant legal acts of the Republic of Lithuania.

3. SUBMISSION OF COMPLAINTS

3.1. If a Customer or any other payment service user considers that the Company provides its Services improperly and/or violates their rights and legitimate interests, they may submit a written Complaint to the Company.

3.2. Complaints to the Company can be submitted by e-mail support@blueemi.com.

3.3. The Complaint must contain at least the following minimum information:

3.3.1. name of the Complainant;

3.3.2. if the Complainant represents another person, the name of the represented person and the basis for representation (by attaching to the Complaint a power of attorney in the form prescribed by legal acts or another document confirming the powers of the Complainant’s representative to act on behalf of the Complainant);

3.3.4. contact details of the Complainant to which it would prefer to receive a response from the Company, unless the Customer files their Complaint;

3.3.5. the essence of the complaint that includes the actions or omissions of the Company complained about;

3.3.6. Complainant’s request;

3.3.7. supplementary documents to be attached to the Complaint, e.g. a power of attorney, proof of violation, etc.

3.4. The Complaint must be complete, neat, legible and drawn up in English or the Lithuanian language.

3.5. If the submitted Complaint is not in conformity with the requirements outlined in this section of the Policy, based on the deficiencies, the Company may not be able to examine the Complaint. In this case, the Company shall notify the Complainant (if possible) about the shortcomings of the Complaint and instruct the Complainant to eliminate them. A Complaint that is returned to the Complainant to eliminate the deficiencies shall be deemed not to have been filed with the Company. Return of the Complaint shall not prevent the Complainant from re-applying to the Company with an identical Complaint after correcting the deficiencies identified.

3.6. If an identical Complaint or a Complaint which is already being examined by another competent authority or court, or for which a decision of the Company has been made, or for which a court decision, ruling or order has entered into force, is submitted to the Company, the Company shall refuse to examine the respective Complaint.

3.7. All written Complaints shall be signed with digital signatures to establish the identity of the Complainant, the Company shall not examine anonymous Complaints.

3.8. Any applications that are not or cannot be classified as official complaints shall not be recorded in the Company’s complaints register irrespective of their titles, subjects or phrasing. Instead, they are classified as Inquiries and are handled as requests for information or assistance, managed through standard customer service or operational processes.

4. REGISTRATION OF COMPLAINTS

4.1. Received (accepted) Complaint shall be registered in the Complaints Register on the same business day (in cases when the Complaint is received on a non-business day, on the following business day).

5. HANDLING OF COMPLAINTS

5.1. An employee appointed by the CEO of the Company (“Responsible Employee”) shall be responsible for examining complaints.

5.2. Complaints shall be examined by the Company by the principles of reasonableness, good faith, fairness, economy, objectivity, impartiality, and respect for human rights, in cooperation with the Complainant, aiming for the most amicable solution possible.

5.3. If the Complaint is related to the actions (omissions) of the Responsible Employee or its close relatives working in the Company, or the employees hierarchically superior to it in the organisational structure of the Company, or other circumstances cause or may cause a conflict of interest, the Responsible Employee must notify the CEO of the Company, who shall appoint another employee of the Company who does not have a conflict of interest in the handling of the Complaint.

5.4. If the Complainant withdraws their Complaint in writing (or otherwise on a durable medium) during the handling of the Complaint, the initiated handling of the Complaint shall be terminated and an appropriate entry shall be made in the Complaints Register regarding the termination of the handling of the Complaint.

5.5. Complaints in the Company shall be handled in writing. In exceptional cases, meetings of the parties may be convened to resolve a dispute amicably. The meeting may be organised by either the Complainant or the Company.

5.6. Complaints shall be handled by the Company free of charge.

5.7. The Responsible Employee must examine the Complaint and provide a detailed, reasoned, documented response to the Complainant, no later than 15 (fifteen) working days from the date of receipt of the Complainant’s Complaint by the Company.

5.8. If due to reasons beyond the Company’s control it is not possible to submit a response within 15 (fifteen) working days, the Company shall send a provisional response, indicating the reasons for the delay in submitting a response to the Complaint, the reasons for extension and the deadline for submitting a final response. In any case, the deadline for submitting the final response may not exceed 35 (thirty five) business days from the date of receipt of the Complaint by the Company.

5.9. The Company shall keep the Complaints of the Complainant, the material related to their examination and the decisions made on the basis thereof as well as the response provided to the Complainant for at least 3 (three) years from the date of submission of the final response to the Complainant.

5.10. Inquiries shall be acknowledged promptly and responded to within 15 (fifteen) working days. Where an inquiry raises concerns that may warrant further investigation or dissatisfaction is subsequently expressed, the matter may be reclassified and recorded as a formal complaint following the Complaints Handling Policy. The Company shall retain copies of all Inquiry submissions and responses in a separate internal system for purposes of quality assurance, compliance monitoring, and evidentiary record-keeping, consistent with applicable data retention and regulatory obligations.

6. SUBMISSION OF A RESPONSE

6.1. The original of the response, along with the attached documents shall be submitted to the Complainant in the manner of its choice: sent by post or e-mail.

6.2. The response to the Complainant shall include, at least:

6.2.1. date of submission of the response;

6.2.2. reasoned response;

6.2.3. list of the attached documents (if any);

6.2.4. full name, position and signature of the person who drew up the response to the Complaint.

6.3. The Company shall consider that the Complaint is resolved when either (a) the Complainant’s demands are satisfied in part or fully and a response has been provided to the Complainant; or (b) when the Company provides the Complainant with a motivated response letter with arguments and reasoning on the requests made in the Complaint.

6.4. In connection to the response to the Complainant, a relevant entry shall be made in the Complaints Register.

6.5. After examining the complaint, the Company makes a decision to acknowledge the Client’s complaint:

6.5.1. satisfied – the Company recognises that the Client’s requirements are legitimate and justified and takes action to fulfil them;

6.5.2. partially satisfied – the Company partially satisfies the Client’s requirements;

6.5.3. rejected – the Client’s requirements are unfounded, therefore they are not satisfied.

6.6. If the Company is not responsible for carrying out the activity specified in the received Complaint, the Company shall inform the Complainant of the reasons for refusing to accept and examine the Complaint as well as, if possible, the financial market participant responsible for handling the respective Complaint.

6.7. If the Complaint is not satisfied or is satisfied in part, the response shall specify other remedies in defending the interests of the Complainant, including, but not limited to, those specified in Clauses 6.6 and 6.8 of the Policy.

6.8. If the Company does not satisfy the Complainant’s requests or satisfies them in part and the Complainant is a Consumer, the Complainant shall be entitled to apply to the Supervisory Authority in writing or electronically, within 1 (one) year from applying to the Company, for resolution of the dispute arising. If the Complainant misses the specified deadline for applying to the Supervisory Authority, it shall lose the right to apply to the Supervisory Authority for the same dispute, i.e. for the same subject matter (claim to the Company) and on the same grounds (circumstances on which the claim is based), regardless of whether it has applied to the Company repeatedly. More information about the procedure of consumer disputes with financial service providers can be found on the website of the Supervisory Authority: https://www.lb.lt/en/dbc-settle-a-dispute-with-a-financial-service-provider.

6.9. If the Company does not satisfy the Complainant’s demands or satisfies them in part and the Complainant is not a consumer, the Complainant shall be entitled to apply to a court in accordance with the procedure established by the laws of the Republic of Lithuania.

7. CHARGEBACKS

7.1. Chargebacks are treated as Complaints against the Company’s clients, managed per VISA/Mastercard rules and in cooperation with the acquiring partner (‘Bank’), which notifies the Company via VISA/Mastercard systems accordingly. Chargeback requests are submitted by the cardholders to their card issuers.

7.2. Upon receipt of a chargeback request, the Responsible Employee shall notify the Merchant and provide an opportunity to respond. The Merchant is responsible for submitting all necessary supporting documents within 10 (ten) calendar days, after which the Chargeback becomes uncontestable.

7.3. The Company collects information from the Merchant regarding their goods and/or services and provides responses via the VISA/Mastercard system to assist dispute resolution. The Company cooperates to resolve disputes but assumes no responsibility for the Merchant or their goods/services. The final decision lies with the card issuer or card scheme.

7.4. If the Chargeback is upheld, the disputed amount and applicable fees shall be debited from the Merchant in accordance with the agreement with the Bank.

8. FINAL PROVISIONS

8.1. The Company shall collect and, at the request of the Supervisory Authority, provide information on the number of Complaints received, broken down according to the reasons for submission and the outcomes of examination.

8.2. The Policy, amendments or supplements thereto shall enter into force upon their approval by the order of the CEO of the Company, unless another date of entry into force of the Policy, amendments or additions thereto is specified therein.