Customer Complaints and Dispute Resolution Policy

1. Overview and Purpose

This Customer Complaints and Dispute Resolution Policy (“Policy”) establishes the framework used by Mobile Incorporated Limited (the “Company”, “we”, “us”, or “our”) for the fair and effective handling of customer complaints and disputes.

The Policy is designed to ensure that all complaints are managed consistently, transparently, and within appropriate timeframes. It forms part of the Company’s governance and compliance framework and is subject to approval and oversight by Senior Management.

This Policy applies to:

  • All customers and account holders of the Company
  • All gambling and related services provided under the Company’s MGA licences
  • All employees, contractors, and third parties engaged in customer support or operational services

The Board of Directors and Senior Management retain ultimate responsibility for the implementation and effectiveness of this Policy.

2. Regulatory and Legal Alignment

This Policy is developed in accordance with:

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

The Policy ensures that the Company maintains:

  • Fair and accessible complaint handling procedures
  • Transparent escalation and review mechanisms
  • Proper documentation and audit trails
  • Compliance with regulatory reporting obligations
  • Effective dispute resolution pathways for customers

3. Governance Standards and Operating Principles

The Company applies the following principles in managing complaints:

  • Fair Treatment – All complaints are assessed objectively and without prejudice.
  • Transparency – Customers are provided with clear and understandable explanations of decisions.
  • Accountability – Roles and responsibilities are clearly defined at each stage of the process.
  • Independence – Escalated complaints are reviewed separately from initial decision-making where practicable.
  • Customer Protection – Special consideration is given to vulnerable customers and responsible gambling matters.

Senior Management monitors the effectiveness of the complaints framework through periodic review and reporting.

4. Internal Controls and Training Framework

Employees involved in complaints handling are provided with structured training covering:

  • MGA regulatory obligations and compliance expectations
  • Complaint assessment and investigation procedures
  • Escalation and reporting requirements
  • Identification of responsible gambling indicators

The internal control environment includes:

  • Defined escalation hierarchies and approval levels
  • Documented operational procedures
  • Restricted system access and audit logging
  • Ongoing compliance monitoring and internal audit functions

5. Complaint Submission Options

Customers may submit complaints through the following channels:

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

Customers are encouraged to include:

  • Account or user identification details
  • A clear description of the issue
  • Relevant transaction or gameplay references
  • Any supporting evidence or documentation

Submitting a complaint is free of charge and does not affect the customer’s rights to further escalation or external review.

6. Complaint Handling Procedure

6.1 Acknowledgement Stage

All complaints are acknowledged within a reasonable timeframe, typically within 48 hours. The acknowledgement includes confirmation of receipt, a reference number, and information on expected handling timelines and escalation options.

6.2 Investigation Stage

Complaints are reviewed in line with internal procedures and may be escalated to Compliance, Responsible Gaming, or Senior Management depending on the nature of the issue.

Investigations may involve:

  • Review of system and gaming logs
  • Transaction and payment verification
  • Review of customer communications
  • Examination of internal policies and procedures

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

6.3 Outcome Stage

The Company aims to resolve complaints within 14 business days. Where delays occur due to complexity or external dependencies, customers will be informed and updated.

Final outcomes are:

  • Based on verified evidence
  • Clearly explained to the customer
  • Documented for audit and compliance purposes
  • Subject to internal governance review

Customers may request a written explanation of any decision at any time.

7. Escalation and External Resolution Routes

7.1 Internal Escalation

If a customer is not satisfied with the initial outcome, they may request an internal review. Where possible, this review is conducted by a function independent of the original decision-makers to ensure impartiality.

7.2 External Escalation Options

Where internal resolution does not resolve the dispute, customers may escalate 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 regulation.

8. ADR Process, Legal Consequences, 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 matter and may issue a decision, recommendation, or proposed resolution depending on its mandate.
  • ADR outcomes may be non-binding unless expressly accepted by the parties or made binding under applicable legal mechanisms.
  • Participation in ADR does not limit or remove the customer’s right to pursue judicial remedies.

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

  • the ADR process does not automatically result in a binding and enforceable decision;
  • acceptance of a non-binding ADR outcome may affect the further progression of the dispute; and
  • to obtain a binding decision, the customer may need to pursue the matter before the competent Maltese courts or other legally binding adjudicatory bodies.

Customers will be informed of the consequences of engaging in ADR, including the impact it may have on their ability to pursue further legal or judicial recourse.

9. Responsible Gambling and High-Risk Complaints

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

Such complaints:

  • Are escalated immediately for specialist handling
  • Are prioritised for investigation and resolution
  • Are subject to enhanced compliance oversight

Serious matters may be escalated to Senior Management and included in regulatory reporting obligations.

10. Record Retention and Reporting

The Company maintains a secure complaints register for compliance and governance purposes. Records include:

  • Complaint classification and description
  • Investigation steps and supporting evidence
  • Final outcome and rationale
  • Escalation history

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

Periodic reporting may include:

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

Where required, information may be shared with the MGA in line with licence conditions.

11. Confidentiality and Data Protection

All complaint-related information is 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
  • 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 Board and Senior Management oversight

All material updates are formally documented and communicated where required.