Complaints and Dispute Resolution Governance Policy

1. Policy Statement and Objective

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

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

This Policy applies to:

  • All customers accessing or using the Company’s services
  • All gaming, wagering, and related products operated under the Company’s MGA authorisations
  • All employees, contractors, and third-party service providers involved in operational or customer support functions

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

2. Regulatory Context and Compliance Requirements

This Policy is established in accordance with:

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

The Company maintains this Policy to ensure compliance with regulatory expectations regarding:

  • Fair and transparent complaint handling procedures
  • Effective and accessible customer escalation channels
  • Proper documentation and auditability of decisions
  • Regulatory reporting obligations
  • Protection of customer rights and interests

3. Governance Principles

The Company applies the following governance principles in relation to complaint handling:

  • Impartiality – All complaints are assessed without bias or undue influence.
  • Transparency – Customers are provided with clear reasoning for decisions.
  • Accountability – Responsibilities are clearly assigned at each stage of the process.
  • Consistency – Similar cases are handled in a standardised manner.
  • Customer Safeguarding – Particular attention is given to vulnerable customers and responsible gambling concerns.

Senior Management oversees the effectiveness of the complaints framework through regular reporting and performance review.

4. Organisational Controls and Training

Employees involved in complaint handling receive structured training covering:

  • Regulatory obligations under MGA requirements
  • Complaint assessment and investigation procedures
  • Escalation workflows and governance structures
  • Responsible gambling awareness and intervention indicators

The internal control framework includes:

  • Defined responsibilities and escalation hierarchies
  • Documented procedures and operational standards
  • System access restrictions and audit logging
  • Ongoing compliance monitoring and internal audit review

5. Customer Complaint Channels

Customers may submit complaints using any of the following methods:

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

To facilitate efficient processing, customers are encouraged to include:

  • Account identification information
  • Full description of the issue
  • Relevant transaction or game references
  • Supporting evidence where available

Submission of complaints is free of charge and does not affect the customer’s right to pursue external escalation.

6. Complaint Handling Process

6.1 Receipt and Confirmation

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

6.2 Review and Investigation

Each complaint is assessed in accordance with internal procedures and may be escalated to Compliance, Responsible Gaming specialists, or Senior Management where appropriate.

Investigations may involve:

  • System and gameplay log analysis
  • Transaction and payment record reviews
  • Review of customer communications
  • Assessment of applicable internal rules and procedures

All investigative activity is recorded within the Company’s complaints register.

6.3 Decision and Final Response

The Company aims to resolve complaints within 14 business days. Where additional time is required, customers will be informed and provided with updates.

Final decisions are:

  • Based on verified evidence
  • Clearly communicated with reasoning
  • Recorded for audit and compliance purposes
  • Subject to internal governance oversight

Customers may request a written explanation of any decision issued.

7. Escalation and External Resolution Mechanisms

7.1 Internal Review Process

Where a customer is not satisfied with the outcome, they may request an internal review. This review is conducted by a more senior or independent function not involved in the original decision, where operationally feasible, to ensure impartiality.

7.2 External Dispute Pathways

If a complaint remains unresolved after internal escalation, customers may refer the matter to:

  • The Malta Gaming Authority (MGA)
  • An MGA-approved Alternative Dispute Resolution (ADR) entity
  • The competent courts of Malta

The Company cooperates fully with all external bodies and provides relevant documentation where required by law or regulation.

8. ADR Mechanism, Legal Effect, and Judicial Rights

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

  • The ADR entity will independently assess the dispute and may issue a decision, recommendation, or proposed settlement depending on its framework.
  • ADR outcomes may be non-binding unless expressly accepted by the parties or rendered binding under applicable legal provisions.
  • Participation in ADR does not affect or waive the customer’s right to pursue judicial remedies.

Where the Company offers access to non-binding ADR services under 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 produce a binding enforceable decision by default;
  • acceptance of an ADR outcome may affect the further handling or resolution of the dispute; and
  • to obtain a binding determination, the customer may need to pursue the matter before the competent Maltese courts or other legally binding adjudicatory bodies.

Customers will be clearly informed of the consequences of ADR participation, including its potential impact on subsequent legal and judicial recourse.

9. Responsible Gambling and Priority Complaints

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

Such complaints:

  • Are escalated immediately to specialist teams
  • Receive expedited investigation 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

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

  • Complaint classification and details
  • Investigation steps and findings
  • Outcome and justification
  • Escalation history

Records are retained for at least five years in line with applicable regulatory requirements.

Regular 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 accordance with licence obligations.

11. Confidentiality and Data Protection

All complaints are handled confidentially and in accordance with applicable data protection laws.

Access is restricted to authorised personnel and protected through:

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

12. Policy Review and 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.