Terms & Conditions

last revised: “01” March 2024

Terms and definitions in the Terms and Conditions have a defined meaning as follows:

1. Terms and Definitions

1.1 Application – an online application submitted by Client to the TOMPAY through TOMPAY Website.

1.2 TOMPAY Account - an electronic money account in TOMPAY system that the Client opens and maintains through the Personal Panel.

1.3 TOMPAY – Tompay Ltd, a company incorporated under the laws of England and Wales with registration number 12484741, whose principal place of business is at Mocatta House, Trafalgar Place, Brighton, England, BN1 4DU. TOMPAY is an authorised electronic money institution (AEMI) under the Electronic Money Regulations 2011 under the supervision of the Financial Conduct Authority (FCA). TOMPAY’s FCA Firm reference number is 931509.

1.4 Tompay system - a software solution on the Tompay website and in the Tompay App, managed and administered by Tompay and used to provide Tompay services.

1.5 Business Day - any day other than a Saturday or a Sunday or a public or bank holiday in England, or any other holiday previously announced by TOMPAY.

1.6 Client - the natural person or legal entity who has registered (signs up) in Tompay system and in whose name TOMPAY Account is opened and maintained.

1.7 Customer Service - TOMPAY customer service, which the Client can reach by sending a message through the “Contact Us” facility on the Website.

1.8 Electronic money – funds credited or transferred to a Tompay Account and held on it with the purpose to perform Payment Transactions through the Tompay System.

1.9 FCA - the Financial Conduct Authority of the United Kingdom, which address is 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom; further information on the FCA can be obtained on the FCA’s website at fca.org.uk.

1.10 Fees - the charges payable by the Client to TOMPAY for using TOMPAY services, available on Personal Panel section “Fees”.

1.11 Financial Ombudsman Service - the services provided by the United Kingdom Financial Ombudsman Service, details of which can be found at www.financialombudsman.org.uk and which could be contacted at The Financial Ombudsman Service, Exchange Tower, London, E14 9SR, United Kingdom.

1.12 Top-up service - a service provided by TOMPAY to the clients to add money to the Client’s account

1.13 Payment Transaction - a money transfer or a cash-out operation initiated by the Client.

1.14 Payment Transfer – a payment transaction wherein funds are transferred to a payment account.

1.15 Personal Panel – TOMPAY personal profile that enables the Client to open and maintain TOMPAY Account.

1.16 Privacy Policy - the TOMPAY policy governing the processing of personal data, which is available on the Website, as may be amended from time to time.

1.17 Strong Customer Authentication – verification method based on at least two elements categorised in the Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market.

1.18 Terms and Conditions - the Terms and Conditions, published on the Website that may be amended from time to time.

1.19 Website - the TOMPAY website available at www.tompayment.com

2. Subject and Scope of the Terms and Conditions

2.1 The subject of the Terms and Conditions is to provide the Client with TOMPAY services in order to issue electronic money, send and receive electronic money payments and other services provided by TOMPAY.

2.2 The Terms and Conditions are concluded when the Client submits an Application for TOMPAY Account services.

2.3 The Terms and Conditions is a contract between the Client and TOMPAY. It sets out the terms and conditions that apply to the Client’s use of TOMPAY services. The Client agrees that the Client’s use of TOMPAY services shall constitute the Client’s acceptance of the Terms and Conditions. Before the Client signs up for TOMPAY services, the Client must read any updates of the Terms and Conditions on the Personal Panel. All future changes set out in an update are incorporated by reference into the Terms and Conditions. The changes in the Terms and Conditions will take effect on the date specified by TOMPAY.

2.4 The Terms and Conditions govern the opening, use and closure of TOMPAY Account and other related payment services as referred to herein. Together with agreements concluded, Privacy Policy, and any other conditions and documents (Supplements, Agreements, Rules, Declarations, etc.), including but not limited to, information on the websites, they constitute the legal relationship between the Client and TOMPAY.

2.5 The Client is advised to read the Terms and Conditions carefully. If there is any part of the Terms and Conditions the Client does not understand or wish to clarify, the Client is advised to contact TOMPAY.

2.6 The Client is advised to print or download and keep a copy of the Terms and Conditions and Fees for future reference. The Client can always view the current version of Terms and Conditions on the Website.

2.7 Depending on the type of TOMPAY Account the Client has, additional terms and conditions and agreements may apply.

2.8. The terms of use of Debit Cards are governed by separate DEBIT CARD TERMS AND CONDITIONS published on the website https://www.tompayment.com/.

2.9. Debit Card product is provided by TomPay LTD based on the Mastercard licence and licence authorised by the Financial Conduct Authority as an Electronic Money Institution under the Electronic Money Regulations 2011.

3. TOMPAY Account

3.1 TOMPAY Account is an electronic money account that enables the Client to hold stored value (known as "electronic money" or "e -money"), to send and receive electronic payments. The Client can check the balance of funds and view the transactions carried out on the Client TOMPAY Account via the Personal Panel.

3.2 The electronic money on TOMPAY Account is issued in accordance with the EU Electronic Money Directive (Directive 2009/110/EC of 16 September 2009) and the relevant national legislation of the United Kingdom.

3.3 Subject to section 13, the electronic money held on TOMPAY Account does not expire.

3.4 The Client has the right to withdraw funds from TOMPAY Account at any time. However, the Client may be required to confirm the Client’s identity and present any supporting documentation beforehand. There is no minimum withdrawal amount, but the funds on TOMPAY Account must be sufficient to cover any applicable withdrawal fee.

3.5 TOMPAY Account is issued by TOMPAY and it is not a bank account. Although it is a service / product regulated by the FCA, by accepting the Terms and Conditions, the Client acknowledges that TOMPAY Account and the electronic money stored on it is not covered by the UK’s Financial Services Compensation Scheme. No other compensation scheme exists to cover losses claimed in connection with the TOMPAY Account. Although TOMPAY Account is not covered by the Financial Services Compensation Scheme, TOMPAY ensures that once it receives the Client’s funds they are held in a segregated account, and safeguarded in accordance with the Electronic Money Regulations 2011 and Payment Services Regulations 2017 until they are spent or withdrawn or reimbursed to the Client. If TOMPAY becomes insolvent, funds that the Client loaded onto the Client’s TOMPAY Account will be protected for the Client against the claims of any creditors of TOMPAY as they are held in a safeguarded account.

3.6 The electronic money on TOMPAY Account belongs to the natural person or legal entity, which is registered as TOMPAY Account holder (the Client). No person other than TOMPAY Account holder has any rights in relation to the funds held in TOMPAY Account, except in cases of succession. The Client may not assign or transfer TOMPAY Account to a third party or otherwise grant any third party a legal or equitable interest over it.

3.7 TOMPAY Account may be subject to upload, payment and withdrawal limits, depending on the Client’s country of residence, the verification status of TOMPAY Account and other factors used by TOMPAY to determine such limits from time to time at TOMPAY sole discretion.

3.8 Electronic money held on TOMPAY Account will not earn any interest.

3.9 There is a Private TOMPAY Account (opened by the natural (private) person who uses a TOMPAY Account for his personal purposes) and Corporate TOMPAY Account (opened by the entity who uses a TOMPAY Account for its business, trade or professional activities).

3.9.1 Both of the TOMPAY Account would require the Client to state his identity: name, surname, date of birth, country of residence and both his cell phone number, his email address, provide his audiovisual recording in good quality with appropriate lighting for TOMPAY to identify the Client, good quality photo or scanned copy of ID document or passport of the Client, scanned copy of utility bill, dated within the last 3 months.

3.9.2 Corporate TOMPAY Account requires the Client to submit application form, documents and information set by TOMPAY.

3.10 In case the potential Client has not submitted the requested documents (proof of identity, proof of address and/or others), TOMPAY does not process the application further.

3.11 During the verification of the documents TOMPAY checks that:

3.11.1 document is valid;

3.11.2 there is no obvious signs of forgery (strange smears, document is damaged etc.);

3.11.3 quality of the documentation (regarding the content, quality, possible mistakes) complies with the legislation.

3.11.4 TOMPAY does not process the application further if documents do not include all of the required pages.

3.12. Client confirms that:

3.12.1. provided documents include all necessary pages, grading scales, legends and translations.

3.12.2. the file is complete, that all scanned images are correctly oriented (portrait or landscape) and that all content is readable before submitting to TOMPAY. The Client should ensure that all 4 (four) corners of the document are visible.

3.13 In case if the proof of identity and/or proof of address cannot be accepted for any reason (e.g. ID photo does not look genuine, etc.), TOMPAY has the right to deny the application.

3.14 TOMPAYin case of a reasonable suspect that the Client is carrying out money laundering, terrorist financing or other criminal activities or these activities may be carried out through the Client's Tompay Account, has the right to deny the application or suspend the provision of some or all services without notice to the Client until reasonable suspicions have been completely dissolved or confirmed, as well the right to make a report to NCA (National Crime Agency)..

4. Applying for TOMPAY Account and Opening TOMPAY Account

4.1 In order to use TOMPAY’s services the Client must first create a Personal Panel in TOMPAY system ( remotely register the Client’s details) and submit an Application for TOMPAY ccount opening. As part of the TOMPAY Account opening process, the Client needs to accept the Terms and Conditions and pay document verification Fee for opening an account by choosing one of the payment methods acceptable by TOMPAY (transfer by payment card VISA/MasterCard or by Payment Transfer). The Client must not be in breach of any of the Terms and Conditions. TOMPAY may refuse to provide services to residents of countries mentioned in the FATF blacklist, OFAC Sanctions List and other countries mentioned in various sanction lists or in recommendations of regulating authorities against cooperation.

4.2 If the Client is a private individual, the Client must be at least 18 years old to use TOMPAY services..

4.3 To become a client, the Client must apply for TOMPAY Account by providing all of the information requested on the registration stage of Website. All information the Client provides during the signup process or any time thereafter must be accurate and truthful. The Client must not provide any false, inaccurate, incomplete or misleading information.

4.4. By opening TOMPAY Account the Client represents and warrants to TOMPAY that the Client’s opening of TOMPAY Account does not violate any laws or regulations applicable to the Client. The Client shall indemnify TOMPAY against any losses TOMPAY incurs in connection with the Client’s breach of this section.

4.5 The Client may not be able to open or to use TOMPAY Account or any part of its services until the Client has passed all TOMPAY’s identity and security validation and verification checks, and provided information requested in accordance with anti-money laundering regulations. TOMPAY may check all personal and identity verification information the Client gives us with credit reference or fraud prevention agencies and other organizations. These agencies may keep a record of the Client’s information and the searches done. However, TOMPAY’s does not perform a credit check and any search is for identity verification purposes only. TOMPAY shall keep records of the information and documents TOMPAY obtains to verify the Client’s identity in accordance with all applicable legal and regulatory requirements.

4.6 For additional Account opening possibility Client shall contact TOMPAY customer service.

TOMPAY has the right to refuse opening of additional accounts.

4.7 The Client may only add payment instruments to TOMPAY Account if the Client is the legal holder of that payment instrument. TOMPAY takes any violation of this requirement very seriously and will treat any attempt to add a payment instrument of which the Client is not the legal holder as a fraudulent act.

4.8 During signup, the Client will be asked whether the Client intends to use TOMPAY Account for private or commercial purposes. If the Client has any intention to use TOMPAY Account for commercial purposes, the Client shall inform TOMPAY if the Client also uses the Account for private purposes. If the Client has stated that he will use TOMPAY Account for private purposes only, the Client shall inform TOMPAY immediately, before the Client wishes to use it for commercial purposes at any point in the future, by contacting TOMPAY Customer Service.

The Client is using TOMPAY Account for commercial purposes if the Client is receiving or transferring payments for or in connection with any business activity. TOMPAY reserves the right to determine whether, in TOMPAY reasonable opinion, the Client is using TOMPAY Account for commercial purposes. If the Client is using TOMPAY Account for commercial purposes, in addition to the Terms and Conditions, the Client shall be bound by TOMPAY Corporate Account agreement. If the Client is in any doubt about whether or not an activity amounts to a commercial activity, the Client should contact Customer Service.

5. Maintaining TOMPAY Account

5.1 The Client confirms that the information on TOMPAY Account and Application form is always accurate and up to date and TOMPAY shall not be liable for any loss arising out of the Client’s failure to do so. TOMPAY may ask the Client at any time to confirm the accuracy of the Client’s information or to provide documents or other evidence.

5.2 TOMPAY has the right unilaterally and at its own choice, taking into consideration the specific situation to block Clients TOMPAY Account at any time, suspend the execution of some or all of TOMPAY Services, including one or more Payment Transactions, if the Client not provides requested document (s) or information, or any of the Clients provided documents are out of date, are unreadable, does not look genuine, documents do not include all necessary pages, grading scales, legends and translations etc. If the Client has not provided the needed documents or they do not meet the required criteria mentioned in sections 3 and 5 of the Terms and Conditions, after receiving TOMPAY informative e-mail, the Client has 7 (seven) working days to correct deficiencies.

5.3 In case the Client’s TOMPAY Account has been blocked or has been suspended the execution of some or all of TOMPAY Services after the Client has submitted the needed documents, TOMPAY may unblock the Clients TOMPAY Account or renew the execution of services within 2 (two) working days from the date required documents were received.

5.4 TOMPAY may contact the Client by e-mail or in other ways described in section 19 with information or notices regarding TOMPAY Account. It is the Client’s responsibility to check regularly the proper functioning of the Client’s e-mail address or other methods of communication that the Client has registered with TOMPAY Account and to retrieve and read messages relating to TOMPAY Account promptly. TOMPAY shall not be liable for any loss arising out of the Client’s failure to do so.

5.5 Payment Transactions are displayed in the Client’s online transactions history together with the fees charged. Each transaction is given a unique transaction ID and shown in the transaction history. The Client should quote this transaction ID when communicating with TOMPAY about a particular transaction. The Client should check TOMPAY Account balance and transaction history regularly.

The Client should report any irregularities or clarify any questions the Client has as soon as possible by contacting Customer Service.

5.6 Subject to the provisions of section 7 below, in order to claim a refund for an unauthorised or incorrectly executed payment transaction on TOMPAY Account the Client must notify TOMPAY

without undue delay after becoming aware of the unauthorised or incorrect transaction and in any event no later than thirteen (13) months after the debit date of the transaction.

6. Keeping TOMPAY Account safe

6.1 The Client must take all reasonable steps to keep TOMPAY Account password safe at all times and never disclose it to anyone. Any message the Client receives or website the Client visits that asks for the Client’s password, other than the Personal Panel, should be reported to TOMPAY. If the Client is in doubt whether a website is genuine, the Client should contact the Customer Service. It is advisable to change the Client’s password regularly (at least every three (3) to six (6) months) in order to reduce the risk of a security breach in relation to TOMPAY Account.

TOMPAY also advises the Client not to choose a password that is easily guessed from information someone might know or gather about the Client’s or a password that has a meaning. The Client must never allow anyone to access TOMPAY Account or watch the Client accessing TOMPAY Account.

6.2 If the Client has any indication or suspicion of TOMPAY Account, login details, password or other security feature being lost, stolen, misappropriated, used without authorization or otherwise compromised, the Client is advised to change the password.

The Client must contact Customer Service without undue delay on becoming aware of any loss, theft, misappropriation or unauthorised use of TOMPAY Account, login details, password or other security features. Any undue delay in notifying TOMPAY may not only affect the security of TOMPAY Account but may result in the Client being liable for any losses as a result. If the Client suspects that someone else accessed TOMPAY Account, the Client should also contact the police and report about the incident.

6.3 TOMPAY may suspend TOMPAY Account or otherwise restrict its functionality on reasonable grounds relating to the security of TOMPAY Account or any of its security features or if TOMPAY reasonably suspects that an unauthorised or fraudulent use of TOMPAY Account has occurred or that any of its security features have been compromised. TOMPAY will notify the Client of any suspension or restriction and of the reasons for such suspension or restriction in advance or, where TOMPAY is unable to do so, immediately after the suspension or restriction has been imposed, unless notifying the Client would be unlawful or compromise TOMPAY’s reasonable security interests. TOMPAY will lift the suspension and/or the restriction as soon as practicable after the reasons for the suspension and/or restriction have ceased to exist.

6.4 The Client must take all reasonable care to ensure that the Client’s e-mail address(es) are secure and only accessed by the Client, as the Client’s e-mail address may be used to reset passwords or to communicate with the Client about the security of TOMPAY Account. In case any of the e-mail addresses registered with TOMPAY Account are compromised, the Client should without undue delay after becoming aware of this contact Customer Service and also contact the Client’s e-mail service provider.

7. Uploading Funds

7.1 The Client can transfer funds to TOMPAY Account by Payment Transfer. Notwithstanding section 7.5 below, TOMPAY shall not be responsible for the payment transaction until TOMPAY receives the transferred funds. When the Client transfers funds to TOMPAY Account, the Client permits TOMPAY to receive a transfer of funds on Client’s behalf from Client’s funding source, plus deduct any applicable Fees from those funds for TOMPAY’s account, and then issue electronic money at par value to the funds transferred (net of the applicable Fees) to Client’s TOMPAY Account.

7.2 The Client may be asked to answer security questions or to complete other activities that TOMPAY may reasonably require to ensure proper authorisation of the payment transaction.

7.3 If the Client chooses a transfer method using a payment instrument that may be subject to chargeback rights, the Client declares that the Client will not exercise such chargeback right other than for unauthorised use of the payment instrument or for a breach by TOMPAY of the Terms and Conditions, which would result in the Client having a right to a refund of the transferred amount. Otherwise, the Client may not charge back any payment transaction or allow a chargeback of any payment upload transaction for reasons for which TOMPAY are not responsible, including (but not limited to) disputes with merchants for non-delivery of goods or services or insufficient balance on the payment instrument account. TOMPAY reserves the right to charge the Client fees and expenses TOMPAY incurs in connection with such chargeback and any action undertaken to challenge the same. TOMPAY may also charge the Client an extra fee, according to applicable Fees available on the Personal Panel section “Fees”.

7.4 If a chargeback or reversal of the payment transaction results in a negative balance in TOMPAY Account, the Client will be required to repay such negative balance by transfering sufficient funds into TOMPAY Account. Failure to do so is a breach of the Terms and Conditions. Repayment of the negative balance is due immediately without notice. TOMPAY reserves the right, at any time, to send the Client reminders or to take other debt collection measures including but not limited to mandating a debt collection agency or solicitors or to pursue the claim in court. TOMPAY reserves the right to charge the Client the expenses TOMPAY reasonably incur in connection with any debt collection or enforcement efforts.

7.5 The funds will be credited to TOMPAY Account after TOMPAY has received the funds. Some payment transactions may be credited to TOMPAY Account immediately, but are subject to reversal in case the actual funds do not reach TOMPAY within a reasonable time in which case TOMPAY will deduct such reversed transaction from the balance of TOMPAY Account. If TOMPAY Account balance is insufficient, TOMPAY reserves the right to require repayment from the Client.

7.6 The Client must not make the payment transaction through a payment instrument if the Client is not the legal holder of that payment instrument. TOMPAY will treat any attempt to use a payment instrument of which the Client is not the legal holder as a fraudulent act. Without prejudice to claiming further damages, if TOMPAY is required to return funds transferred from a payment instrument that is not in the Client’s name, TOMPAY may charge a fee per cancellation of transaction, according to applicable Fees.

7.7 Tha payment transactions are subject to payment limits due to security and legal requirements. These limits are set depending on the Client’s TOMPAY Account type.

7.8 Before transfering any funds into TOMPAY Account, the Client must ensure that the Client’s current spending and withdrawing limits meet the Client’s withdrawal and spending requirements as TOMPAY legally cannot allow the Client to exceed these limits.

7.9 The Client should regularly reconcile payment transactions with the Client’s own records.

7.10 According to section 14, payment transactions are subject to fees and currency conversion fees depending on which upload method and payment instrument is chosen.

7.11 After the Client’s action to transfer funds to TOMPAY Account balance, TOMPAY issues emission and transfers to the Client’s TOMPAY Account balance electronic money in an amount equal to the amount of funds (according to actual currency exchange rates available on Personal Panel in section Fees, in case of conversion to other currency) transfered by the Client, except in cases when the Client exceeded the limits established by the Terms and Conditions.

8. Sending Payments and Receiving Funds

8.1 To send a payment the Client is required to authorise the payment with the Client’s login details and password received in Client’s e-mail or sms. TOMPAY may also ask the Client additional security questions relating to the Client or TOMPAY Account. If TOMPAY Account is protected by additional security measures such as Strong Customer Authentication, the Client needs to follow the instructions provided to the Client with such additional security measures. If TOMPAY Account is enabled to make mass payments, the procedure to make such payments will be communicated to the Client in the relevant integration manual. Client is responsible for the safety of its electronic devices and keeping their passwords/access codes/Strong Customer Authentication secret at all times and TOMPAY is not responsible of their theft or use by third parties as a result of Clients negligence, misconduct or including cases when third parties have become aware of password/access code contents and uses it to access Clients TOMPAY Account.

8.2 Every recipient of a payment the Client wishes to send through TOMPAY Account must have a valid means that TOMPAY can use for his or her identification.

8.3 If the Client is asked to provide details of the recipient’s contact information, requisites or other means of identification, where applicable, the Client must take great care to properly type the exact details of who the Client wishes to send money to. TOMPAY uses those details as the unique identifier to determine the intended recipient of the payment, which the Client instructs TOMPAY to process. Other information the Client provides along with the recipient’s means of identification may be disregarded and TOMPAY shall not be liable for any error the Client makes when entering the recipient’s means of identification.

8.4 If the payment details of the intended recipient is registered with TOMPAY, the funds will be instantly credited to TOMPAY Account associated with payment details. Once funds are credited to the recipient’s TOMPAY Account, the transaction becomes irreversible.

8.5 If the recipient’s contact information or requisites are not registered with TOMPAY, TOMPAY cannot send a notification e-mail with instructions on how to claim and receive the payment. If the recipient does not claim the payment within twelve (12) days, the transaction will be cancelled and the funds will be returned to the Client. The Client may also cancel the transaction at any time before the funds have been credited to the recipient’s TOMPAY Account. To cancel a transaction the Client should log into TOMPAY Account, locate the relevant transaction in the Client’s transactions history and select “Cancel”.

8.6 Payments are subject to payment limits due to security and legal requirements. These limits are set depending on the Client’s TOMPAY Account level. The Client can view these TOMPAY Account limits at any time in the relevant section of TOMPAY Account profile. The Client should ensure that the Client’s limits are sufficient to cover the payment the Client intends to make as well as any applicable fees including service fees and currency conversion fees. The Client should be aware that the recipient of a payment may also be subject to spending and withdrawal limits and that this may affect the recipient’s access to the funds the Client intends to send.

8.7 TOMPAY will deduct the value of Client’s transactions from the balance on Client’s TOMPAY Account and any applicable Fees at the time of the transaction. If the Client makes a transaction, any applicable Fees will be added to the amount of the transaction so that the total sum of Client’s transaction amount plus the applicable Fees will be deducted from the Client’s TOMPAY Account balance.

8.8 If the Client is attempting a transaction in excess of the available balance on the Client’s TOMPAY Account at the time the request is made plus any applicable Fees, then the Client’s request will not be processed.

8.9 In the unlikely event, for any reason whatsoever, a transaction is completed when there are insufficient funds on the Client’s TOMPAY Account (a "Shortfall"), the Shortfall shall be reimbursed by the Client unless it is due to an error on the part of the merchant. In this circumstance TOMPAY may seek the Shortfall from the merchant.

8.10 Where the Shortfall must be reimbursed by the Client, the Client will be required to upload funds immediately to reimburse the negative balance of TOMPAY Account. Until TOMPAY is reimbursed the Shortfall amount, TOMPAY may suspend the Client’s TOMPAY Account. If TOMPAY believes the Shortfall has been created intentionally this will be treated as potential Fraud.

8.11 TOMPAY may refuse to process the Client’s transaction:

8.11.1 If sufficient funds are not loaded on the Client’s TOMPAY Account at the time of a transaction to cover the amount of the transaction and any applicable Fees;

8.11.2 The Client fails to pay applicable Fees;

8.11.3 If there is an outstanding Shortfall on the TOMPAY Account;

8.11.4 If TOMPAY has reasonable grounds to believe that the Client is acting in breach of the Terms and Conditions;

8.11.5 If TOMPAY ascertain that a transaction is suspicious or potentially illegal (for example, if TOMPAY ascertain that a transaction is being made fraudulently); or because of errors, failures (whether mechanical or otherwise).

8.12 If TOMPAY refuses to process a transaction because TOMPAY ascertain it is suspicious or potentially illegal, where TOMPAY is permitted to do so by applicable law TOMPAY will contact the Client. If TOMPAY refuses to process a transaction for any other reason, TOMPAY will inform the Client by email without undue delay and in any event by the end of the next Business Day, giving TOMPAY reasons and explaining how the Client can correct any information TOMPAY holds that led to TOMPAY refusing to process the transaction, unless informing the Client would compromise security measures or be unlawful.

8.13 The Client should regularly reconcile outgoing and incoming payments with the Client’s own records.

8.14 According to section 13, sending payments is subject to Fees, including currency conversion fees depending on the type of payment the Client makes and the type of TOMPAY Account the Client holds.

9. Prohibited Transactions

9.1 It is strictly forbidden to send or receive payments as consideration for the sale or supply of: Adult-online live content, webcam, online streaming content and acts of offensive adult content, Adult advertising, Child Pornography, Bestiality, Rape/Hate/Violence, Weapons and Firearms, Unlicensed Gambling, Replica/Copyright infringement, Tobacco, Escort/Massage Pariours, Continuity Suppliers offering memberships or other services that require a negative response from the Customer to avoid automatic renewal, or Suppliers offering services that extend beyond 1 year in length, Direct marketers, who offer sales-incentive-based programs that rely on "breakage" to earn a profit ("breakage" is defined as services paid for by the Customer but never used), multilevel marketing schemes or Suppliers engaged in the practice of "up supplying", Grey market suppliers that are taking advantage of cross-border trading loopholes in national laws (where domestically the activity is legacy grey), Outbound Telemarketing / Inbound Telemarketing/ Phone Solicitation Merchants, Reverse Auctions, Raffles and Prize Draws, Services and/or products that require pyramid type schemes for distribution, Services which may provide peripheral support of illegal activities for business.

TOMPAY reserves the right, in TOMPAY sole discretion, to add categories of prohibited transactions by adding such categories to the Terms and Conditions.

9.2 It is strictly forbidden to make payments to or to receive payments from persons or entities offering illegal gambling services, including (but not limited to) illegal sports betting, casino games and poker games. TOMPAY may suspend or terminate TOMPAY Account at any time or refuse to execute or reverse a transaction if TOMPAY believes that the Client directly or indirectly use or have used TOMPAY Account for or in connection with illegal gambling transactions. This list is not exhaustive and it is the Client’s responsibility to ensure that the Client does not use TOMPAY services for transactions that may be considered illegal in the Client’s jurisdiction.

9.3 The Client may not use TOMPAY services if the Client is residing in any of the countries of FATF blacklist, OFAC Sanctions List and other countries mentioned in various sanction lists or in recommendations of regulating authorities against cooperation. This list is not exhaustive and TOMPAY may decide in its sole discretion to discontinue or restrict TOMPAY’s services in other countries at any time and without prior notice. TOMPAY reserves the right to suspend or terminate TOMPAY Account at any time if TOMPAY reasonably believe to be required to do so by law or in order to comply with recommendations issued by a relevant government authority or recognised body for the prevention of financial crime.

9.4 It is strictly forbidden to use TOMPAY Account for any illegal purposes including but not limited to fraud and money laundering. TOMPAY will report any suspicious activity to the relevant law enforcement agency. The Client is prohibited from using TOMPAY Account in an attempt to abuse, exploit or circumvent the usage restrictions imposed by a merchant on the services it provides.

9.5 If the Client conducts or attempts to conduct any transaction in violation of the prohibitions contained in this section 9, TOMPAY reserves the right to: reverse the transaction; and/or close or suspend TOMPAY Account; and/or report the transaction to the relevant law enforcement agency; and/or claim damages from the Client; and charge the Client a fee according to applicable Fees, in case TOMPAY applies any of the above.

9.6 It is the Client’s and not TOMPAY responsibility to ensure that the Client only sends payments to or receive payments from persons or entities for the sale or supply of goods and services that the Client may provide or receive in compliance with any applicable laws and regulations. The mere fact that a person or entity accepts payments through TOMPAY Account is not an indication of the legality of the supply or provision of their goods and services. If the Client is in doubt as to the legality of a supply or purchase, the Client should not continue with the Client’s payment. It is the Client’s and not TOMPAY responsibility to ensure bank account details are entered correctly to avoid payment errors and any charges.

10. Withdrawing Funds

10.1 The Client can withdraw all or part of the funds held in TOMPAY Account at any time. To do this the Client must log into TOMPAY Account, fill out the payment order, and enter the amount to be withdrawn. Where the withdrawing payment is received by the Client through the involvement of a payment service provider (such as the bank where the Client holds a bank account), TOMPAY shall not be responsible for the withdrawing payment once the Client’s payment service provider receives the withdrawn funds.

10.2 TOMPAY upon Client’s request of withdrawing of all or part of the funds held in TOMPAY Account at any time shall buy back electronic money from the Client subject to limitations and exceptions set by the Terms and Conditions.

10.3 If the Client withdrawing request exceeds the current limit, in any circumstance to comply with regulations or for the safety of TOMPAY Account, TOMPAY may decline the Client’s request and instead require the Client to send TOMPAY documents verifying the Client’s identity and address prior to allowing a withdrawing of funds or to otherwise cooperates with TOMPAY to verify the Client’s identity.

10.4 The Client must not make a withdrawal to a bank account or other payment instrument if the Client is not the legal holder. TOMPAY will treat any attempt to use a payment instrument of which the Client is not the legal holder as a fraudulent act. According to section 13, receiving funds is subject to Fees and currency fees, depending on the type of payment the Client receives and the type of TOMPAY Account the Client has.

10.5 The Client must ensure that the payment details the Client enters when withdrawing funds are correct and complete. TOMPAY will not be liable for withdrawn funds being sent to the wrong payment instrument where this is due to the Client providing incorrect payment details. When withdrawing to a bank account, the Client must ensure that the account number, sort code, IBAN and/or BIC/SWIFT are correct. If the Client has withdrawn funds to the wrong payment instrument, the Client may request that TOMPAY assist the Client in reclaiming the funds, however, TOMPAY will charge the Client a fee according to applicable Fees, for doing so and TOMPAY cannot guarantee that the reclaim efforts will be successful.

10.6 TOMPAY reserves the right to carry out any necessary money laundering, terrorism financing, fraud or other illegal activity checks before authorising any withdrawal of the Client’s funds, including in relation to returning any funds to the Client after the Client has closed TOMPAY Account as set forth in section 13.

10.7 The Client should regularly reconcile withdrawing payments with the Client’s own records.

10.8 According to section 14, withdrawals are subject to withdrawing fees and currency conversion fees depending on which withdrawing method and payment instrument is chosen.

11. Currency Conversion

11.1. The Client may convert the money held in the Client’s TOMPAY’s Account into other currencies TOMPAY supports from time to time. The Client may keep or transfer converted money. The TOMPAY is entitled to carry out only non-cash money conversions.

11.2. The applicable exchange rate is available in the Personal Panel and the Client has to place a currency exchange order via Personal Panel in accordance with our Fees. Transaction history is always available in the Personal Panel.

11.3. Once the Client’s order to carry out the currency exchange has been received by us it cannot be cancelled.

11.4. The TOMPAY bears no responsibility if the Client loses any money as a result of converting currency.

11.5. TOMPAY would not be responsible for any losses:

11.5.1. in the event if TOMPAY cannot provide Payment Transactions in converted currency;

11.5.2. in the event that Payment Transactions with converted currency are returned to the Client. In this case the Client will be able to keep it or convert it back to the original currency, each of these activities are considered as separate transactions.

11.6. The Client agrees and accepts the risks of holding balances in multiple currencies that (i) foreign currency exchange rates are subject to fluctuations which are outside of TOMPAY control and (ii) past movements or trends in the movement of foreign currency exchange rates cannot be taken as an indicator of future movements in exchange rates. The Client agrees to not use TOMPAY services for speculative trading.

12. Top-up Service

12.1 The Client may top up an account via debit or credit card by providing debit or credit card details, and the relevant amount to be transferred. Upon TOMPAY's receipt of confirmation that such debit or credit card transaction has been authorised, TOMPAY will credit the corresponding value of funds. All top-ups are final and cannot be reversed once effected

12.2 TOMPAY provides Top-up services through its third-party providers.

12.3 The Client agrees that only debit cards and/or credit cards which are issued to and/or registered in the Client’s name will be used to effect payment to the TOMPAY for any top-ups to the Account.To use Top-up services the Client can use only it’s own cards. Use of third party cards is prohibited.

12.4 If the Client uses third-party cards to top-up the account, TOMPAY has the right to suspend all Client transactions, up to closing the account in accordance with the provision 13.1 of the Terms & Conditions.

12.5 In case of detection of fraudulent activities related to the provided service, TOMPAY has the right to demand reimbursement of all costs associated with fraudulent activities.

13. Termination, suspension and closing TOMPAY Account

13.1 TOMPAY may suspend or terminate Customer’s Account or Customer’s use of this Site and Services at any time, for any reason or for no reason.

The Client may terminate TOMPAY Account at any time. Different termination provisions may apply if the Client uses TOMPAY Account for commercial purposes as set out in section 4.7 above.

13.2 Together with a termination notice or at any time thereafter TOMPAY may give the Client reasonable instructions on how to withdraw remaining funds.

13.3 If TOMPAY Account is subject to a reserve, termination of TOMPAY Account will not affect TOMPAY’s right to hold the reserve and to make deductions therefrom for the time agreed.

13.4 If the Client’s Account is suspended or terminated the Client will not be able to use any of the functionality of the TOMPAY Account.

13.5 When TOMPAY Account is terminated (closed), TOMPAY will immediately block the Client’s TOMPAY Account so it cannot be used. The Client will remain liable for all obligations relating to the Client’s TOMPAY Account even after TOMPAY Account has been terminated (closed). Terminating (closing) TOMPAY Account does not mean that TOMPAY deletes the personal data that we hold on the Client and TOMPAY will continue to store such data, including the history of the Client’s transactions for a minimum period of five (5) years as required by law.

13.6 If TOMPAY Account holds a balance at the time of its closure, TOMPAY will ask the Client to withdraw the Client’s funds within a reasonable period, during which TOMPAY Account will be accessible for withdrawing the remaining balance only. After the expiry of this period, the Client will not be able to access TOMPAY Account but the Client may withdraw any remaining funds by contacting Customer Service and requesting that the funds be sent to the Client in a manner that is reasonably acceptable for TOMPAY. The Client may do so for a period of six (5) years from the date of closureof TOMPAY Account but TOMPAY suggests that the Client withdraws the Client’s remaining funds as soon as possible as they will not earn any interest while being deposited in TOMPAY Account. The Client’s obligations concerning keeping TOMPAY Account safe as set forth in section 6 shall continue to apply.

13.7 If TOMPAY Account has not been active for the last six (6) months, it is classified as Dormant.This type of TOMPAY Account will be charged according to Fees.

14. Fees

14.1 Fees depend on whether the Client is using TOMPAY Account for personal or commercial purposes.

14.2 Transaction related fees could be viewed at any time on the Personal Panel section “Fees”. Additional fees apply to TOMPAY Account used for commercial purposes in accordance with the applicable terms and conditions referred to in section 4.7 above. The Client should print or download and keep a copy of the Fees section together with a copy of the Terms and Conditions. For clarity, the Fees section forms part of the Terms and Conditions. Fees are subject to change in accordance with section 18. Under certain circumstances, TOMPAY may charge additional fees as set out in these Terms and Conditions.

14.3 The Client’s transactions may be subject to currency conversions. If the Client makes a payment from TOMPAY Account denominated in one currency to TOMPAY Account denominated in another currency, the Client will be asked to make the payment either in the currency of TOMPAY Account or in another currency. If the Client chooses the currency of TOMPAY Account, then the recipient will pay the fee for the conversion into the currency of the recipient’s TOMPAY Account. If the Client chooses the currency of the recipient’s TOMPAY Account, the Client will pay the fee for the currency conversion into the currency of the payment. If the Client chooses a currency, that is neither the currency of TOMPAY Account nor the currency of the recipient’s TOMPAY Account then the Client will pay the fee for the conversion into the currency of the payment, and the recipient will pay the fee for the conversion of the payment currency into the currency of the recipient’s TOMPAY Account.

14.4 For every currency conversion, TOMPAY will apply its own exchange rates that are available on the Personal Panel section “Fees”.

Changes in these exchange rates may be applied immediately and without notice.

14.5 Fees are expressed either as a percentage of the transaction or as a fixed amount in EUR, that may be changed based on the amount and/or currency. Where fixed fee amounts are displayed in a currency other than EUR, this is for information purposes only. If fees are deducted from a balance or a transaction denominated in a different currency, the EUR fee amount will be converted into an equivalent fee in that other currency based on the TOMPAY exchange rates applicable at the time and available on the Personal Panel section “Fees”. TOMPAY will not apply a foreign exchange fee on currency conversions of fees.

14.6 Fees payable by the Client will be deducted from TOMPAY Account balance and the Client hereby authorises TOMPAY to do the same. Transaction fees will be charged when the transaction is executed. If TOMPAY Account balance is insufficient to cover the Fees, TOMPAY may refuse to execute the payment.

14.7 In case the Client does not have sufficient funds on the relevant TOMPAY Account to cover the Fees and does not immediately upload sufficient funds to cover these Fees, TOMPAY has the right to deduct the required amount from any of the Client’s TOMPAY Account.

15. Complaints

15.1. Any complaints of the Client regarding TOMPAY services shall be submitted to the TOMPAY in writing by e-mail: support@tompayment.com. The Client should clearly indicate the date the problem arose, the payment order number(s) and all necessary details if the complaint is about a specific transfer and what the complaint is about.

15.2. The TOMPAY investigate the complaint, and Client will get a response by email in accordance with the provisions of the Terms and Conditions and TOMPAY’s complaints policy.

15.3. TOMPAY complaint handling policy is available on our www.tompayment.com.

16. Client’s Data

16.1 The processing of the Client’s data is governed by the Privacy Policy, which can be found on the Website. By accepting the Terms and Conditions, the Client also agrees to the terms of the Privacy Policy. The Client should print and keep a copy of the Privacy Policy together with the Terms and Conditions.

16.2 As a default, the Client will receive e-mail newsletters that will inform the Client about new product features, events, promotions, special deals etc. By accepting the Terms and Conditions, the Client agrees to receive such e -mail newsletters on a regular basis. If the Client does not wish to receive any newsletters from TOMPAY, the Client can opt out at any time by logging into TOMPAY Account and changing the appropriate setting in TOMPAY Account profile. The Client can also opt out of receiving newsletters by contacting Customer Service. Any e-mail newsletter the Client receives will also give the Client the option to unsubscribe from any future newsletter.

16.3 All relevant Client’s data is updated and stored electronically according to legal requirements.

16.4 The Client agrees that TOMPAY carries out processing of personal and other data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws and regulations. TOMPAY carries out the processing of personal data of the Client, its representatives, authorized persons, representatives, beneficial owners and other third parties related to the Client, including the collection, registration, input, storage, arranging, modification, using, transferring, transmission and disclosure of data, blocking or deletion, and the Client is obliged to obtain consent to all data processing mentioned in this section from all persons whose personal data they have transferred to TOMPAY. The purpose of personal data processing is compliance with local and international laws and regulations, Client registration, the provision, offering and maintenance of TOMPAY products and services, the security of employees, the security of TOMPAY property (assets), the performance of the duties prescribed by law, and the other legal interests of the TOMPAY. The Personal Data Controller is TOMPAY.

17. Liability

17.1 In case of an unauthorised payment or a payment that was incorrectly executed due to an error by TOMPAY, TOMPAY shall at the Client’s request immediately refund the payment amount including all fees deducted therefrom. This shall not apply:

17.1.1 if the Client fails to notify TOMPAY without undue delay of any loss of the Client’s password or other event that could reasonably be expected to have compromised the security of TOMPAY Account after the Client has gained knowledge of such event in which case the Client shall remain liable for losses incurred up to the Client’s notification to TOMPAY;

17.1.2 if the transaction was unauthorised but the Client has compromised the security of TOMPAY Account with intent or gross negligence in which case the Client shall be solely liable for all losses; or

17.1.3 if the Client fails to dispute and bring the unauthorised or incorrectly executed transaction to TOMPAYs attention within 13 months from the date of the transaction.

17.2 Section 16.1.1 shall not apply to transactions made after the Client has notified TOMPAY in accordance with section 6.2 in which case TOMPAY shall remain liable and refund any unauthorised transaction immediately to the Client.

17.3 Without prejudice to the foregoing, the Client is asked to check the transaction history of the TOMPAY Account regularly and frequently and to contact Customer Service immediately in case the Client has any questions or concerns.

17.4 In the case of any incorrect or misdirected payment, TOMPAY shall take reasonable measures to assist the Client with tracing and recovering such payments.

17.5 Subject to the foregoing, TOMPAY shall not be liable for any disruption or impairment of TOMPAY service or for disruptions or impairments of intermediary services on which TOMPAY relies for the performance of TOMPAY’s obligations hereunder, provided that such disruption or impairment is due to abnormal and unforeseeable circumstances beyond TOMPAY’s reasonable control or the control of the intermediary affected.

17.6 TOMPAY shall not be liable for any indirect or consequential losses including but not limited to loss of profit, loss of business and loss of reputation. TOMPAY shall not be liable for any losses arising from TOMPAY’s compliance with legal and regulatory requirements.

17.7 TOMPAY’s obligation under the Terms and Conditions is limited to providing the Client with TOMPAY Account and related payment services and does not make any statement in relation to or endorsement of the quality, safety or legality of any goods or services provided by a TOMPAY customer (including merchant) or intermediary. If the Client has any disputes about purchases made using the Client’s TOMPAY Account, the Client should settle these with the merchant the Client bought the goods or services from. TOMPAY is not responsible for the quality, safety, legality or any other aspect of any goods or services purchased with the Client’s TOMPAY Account. The Client must remember that once the Client has used TOMPAY Account to make a purchase, TOMPAY cannot stop that transaction.

17.8 TOMPAY shall not be liable for the assessment or payment of any taxes, duties or other charges that arise from the underlying commercial transaction between the Client and another TOMPAY customer (including merchant).

17.9 The Client agrees to defend, reimburse or compensate TOMPAY and hold TOMPAY harmless from any claim, demand, expenses or costs (including legal fees, fines or penalties) that TOMPAY incurs or suffers due to or arising out of the Client’s or the Client’s agents' breach of the Terms and Conditions, breach of any applicable law or regulation and/or use of the services. This provision shall survive termination of the relationship between the Client and TOMPAY.

17.10 TOMPAY shall not be liable in contract, tort (including negligence or breach of statutory duty) or otherwise for any indirect or consequential loss or damage of any kind including punitive or exemplary damages or for any loss of profit or loss of contract, loss of goodwill or reputation, loss of opportunity, loss of revenue or third party loss whether foreseeable or otherwise.

17.11 In case the Client is a legal entity, an officer(s) of the entity, who have signatory power, declare to have full control and authorizations to act on behalf of the entity, acknowledges and agrees that TOMPAY will not be used for transactions relating to: 1) Sales made under a different trade name or business affiliation than indicated in this application; 2) Any transactions that violates any law, ordinance, or regulation applicable to the business.

18. Changes to the Terms and Conditions

18.1 The Terms and Conditions and any additional terms and conditions that may apply are subject to change. Changes will be implemented with prior notice from TOMPAY under the procedure set forth in this section.

18.2 TOMPAY is entitled to unilaterally amend the Terms and Conditions from time to time given a prior notice to the Client of any change by sending an e-mail to the primary e-mail address registered with TOMPAY Account.

18.3 The proposed change comes into effect on the day set by TOMPAY. Changes that make the Terms and Conditions more favourable to the Client come into effect immediately if so stated in the change notice. Changes to exchange rates come into effect immediately without notice and the Client shall not have the right to object to such a change.

18.4 The Parties agree that the Client shall be deeded as having agreed with the amendments, unless the Client notifies TOMPAY to the contrary before the date the amendments come to force. If the Client objects to the changes, Client shall contact TOMPAY customer service to mutually resolve this issue, if no agreement can be made between Client and TOMPAY, Client’s TOMPAY Account shall be closed and cooperation terminated. TOMPAY Account will be closed in accordance with the provisions of section 13 above.

18.5 The new version of Terms and Conditions shall replace these Terms and Conditions unless otherwise agreed.

18.6 If TOMPAY introduces new products or services that do not affect or change the Terms and Conditions of Client’s TOMPAY Account, TOMPAY may inform the Client and add the product or service immediately.

19. Communication and Miscellaneous

19.1 TOMPAY communicates to the Client via e-mail or through Personal Panel. For this purpose, the Client at all times must maintain at least one valid e-mail address in TOMPAY Account profile. The Client is required to check for incoming messages regularly and frequently. E-mails may contain links to further communication on the Personal Panel. Any communication or notice sent by e-mail or Personal Panel will be deemed received by the Client on the same day it is sent to the Client’s e-mail inbox before 1.00 pm on a Business Day. If it is sent to the Client’s email inbox after 1:00pm on a Business Day or at any other time, it will be deemed received on the next Business Day.

The Client agrees that TOMPAY shall use the e-mail address, postal address and phone number of the Client indicated in the Application form (if applicable) to inform the Client on services offered by the TOMPAY. Client agrees to provide additional information in the Personal Panel or by other means if TOMPAY requires it in order to specify information indicated.

19.2 Where legislation requires TOMPAY to provide information to the Client on a durable medium, TOMPAY will either send the Client an e-mail (with or without attachment) or send the Client a notification pointing the Client to information on the Personal Panel in a way that enables the Client to retain the information in print format or other format that can be retained by the Client permanently for future reference. The Client is required to keep copies of all communications TOMPAY send or make available to the Client.

19.3 The Client can request a copy of the Terms and Conditions or any other contractual document relevant to the Client by contacting Customer Service.

19.4 TOMPAY will communicate to the Client in English and will always accept communications made to TOMPAY in English. The Client can choose the Client preferred language from the list of supported languages in TOMPAY Account profile and TOMPAY will send the Client automated e-mail notifications and communications regarding changes to the Terms and Conditions in the Client chosen language. For non-standard communication, TOMPAY reserve the right to communicate with the Client in English. Documents or communications in any other languages are for convenience only and shall not constitute an obligation on TOMPAY to conduct any further communication in that language.

19.5 Apart from communicating via e-mail, TOMPAY may contact the Client via letter or telephone, where appropriate. If the Client uses any mobile services, TOMPAY may communicate with the Client via SMS. Any communication or notice sent by post will be deemed received four (4) days from the date of posting for UK post or within seven (7) days of posting for international post. Any communication or notice sent by SMS will be deemed received the same day.

19.6 The Client may contact TOMPAY at any time by sending a message to Customer Service via the “E-Mail Support” facility on the Website or through Personal Panel (web or mobile application).

19.7 No person other than the Client shall have any rights under the Terms and Conditions and the provisions of the Contracts (Rights of Third Parties) Act 1999 are expressly excluded.

19.8 TOMPAY Account is personal to the Client and the Client may not assign any rights under the Terms and Conditions to any third party.

19.9 TOMPAY Account is operated in the United Kingdom and the Terms and Conditions shall be governed by and interpreted in accordance with the laws of England and Wales. Any dispute under the Terms and Conditions or otherwise in connection with TOMPAY Account shall be brought exclusively in the courts of England and Wales except where prohibited by EU law.

19.10 If any part of the Terms and Conditions is found by a court of competent jurisdiction to be invalid, unlawful or unenforceable then such part shall be severed from the remainder of the Terms and Conditions, which shall continue to be valid and enforceable fully permitted by law.

20. Consumer Duty Implementation

20.1. TOMPAY in order to implement the Consumer Duty regulation provides records keeping and shall provide the reports in order to correspond to the Consumer Duty regulation. The Client is informed that TOMPAY in order to fulfil the Consumer duty requirements may provide the personal data to the state authority of the United Kingdom.

20.2. TOMPAY provides the following principles for the implementation of activities: TOMPAY must pay due regard to the interests of its customers and treat them fairly; TOMPAY must pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading; think more about customer outcomes and place customers’ interests at the heart of activities.

20.3. TOMPAY establishes “four outcomes' ' in the course of its activities: the governance of products and services, price and value, consumer understanding, and consumer support.

20.4. When interacting with Clients in case of disputes or problems, TOMPAY undertakes to fulfil the following obligations: adopting, amending or discontinuing a product or service; adapting product or service design, fees or charges; making appropriate changes to the firm’s operations; updating customer support processes or distribution channels; modifying communications to make them more easily comprehensible; providing redress where customers have suffered harm.

20.5. TOMPAY is entitled and shall collect information to monitor the outcomes that customers are receiving. TOMPAY shall provide evidence of the monitoring and assessment of these outcomes and any resulting action, on request.

20.6. TOMPAY board, or equivalent governing body, should review and approve an assessment of whether TOMPAY is delivering good outcomes for its customers which are consistent with the Consumer Duty, at least annually.

20.7. The Company adopts and implements the following policies to meet the requirements in accordance with Consumer Duty requirements: Consumer Care Policy, Transparency Policy, Best Practice Procedures, Product Life Cycle Assessment Policy, Market transparency policy, Fairness and Integrity Policy, Risk assessment procedures, Internal Control and Review Policy, Staff training policy, Monitoring policy and strategies, Compliance Policy, Impact Assessment Policy.

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