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Complaints Handling and Dispute Resolution Framework

1. Scope and Purpose

This Complaints Handling and Dispute Resolution Framework (“Framework”) defines how Mobile Incorporated Limited (the “Company”, “we”, “us”, or “our”) manages customer complaints and disputes in a consistent, fair, and transparent manner.

The Framework forms part of the Company’s internal governance and regulatory compliance structure and is approved by Senior Management. It is intended to ensure compliance with applicable Maltese legislation, Malta Gaming Authority (MGA) requirements, and broader consumer protection obligations.

This Framework applies to:

  • All customers using the Company’s services
  • All gaming, betting, and related products operated under MGA licences held by the Company
  • Employees, contractors, and third-party service providers involved in customer support or operational delivery

Ultimate accountability for the Framework rests with the Board of Directors and Senior Management.

2. Regulatory Basis

This Framework is established in line with:

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

The Company maintains this Framework to ensure:

  • Fair and transparent treatment of all customer complaints
  • Accessible and clearly communicated complaint channels
  • Proper escalation and review mechanisms
  • Compliance with reporting, audit, and regulatory obligations

3. Governance Approach and Principles

The Company applies the following principles when handling complaints:

  • Fairness – Each complaint is assessed objectively and without bias.
  • Transparency – Customers receive clear explanations of decisions and outcomes.
  • Accountability – Responsibilities for handling and escalation are clearly defined.
  • Independence – Escalated reviews are, where possible, handled separately from the original decision-makers.
  • Customer Protection – Particular attention is given to vulnerable customers and responsible gambling concerns.

Senior Management oversees the effectiveness of the Framework through periodic reporting and governance review.

4. Training and Internal Controls

Employees responsible for complaints handling receive ongoing training covering:

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

The Company’s internal control environment includes:

  • Segregation of duties where practicable
  • Documented procedures and workflows
  • Access controls and system restrictions
  • Internal audit and compliance monitoring activities

5. Complaint Submission Channels

Customers may submit complaints using the following methods:

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

To support timely investigation, customers are encouraged to provide:

  • Account identification details
  • Description of the issue raised
  • Relevant transaction, game, or event references
  • Any supporting documents or evidence

Submitting a complaint is free of charge and does not limit the customer’s right to pursue external remedies.

6. Complaint Handling Procedure

6.1 Receipt and Acknowledgement

All complaints are acknowledged promptly, typically within 48 hours. The acknowledgement confirms receipt, provides a reference number, and outlines indicative timelines and escalation options.

6.2 Assessment and Investigation

Each complaint is reviewed in line with internal procedures and may be escalated to Compliance, Responsible Gaming, or Senior Management where necessary.

Investigations may include:

  • Review of system and game logs
  • Transaction and payment records
  • Customer communication history
  • Internal policy and procedural checks

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

6.3 Decision and Response

The Company aims to provide a final response within 14 business days. Where additional time is required due to complexity or external dependencies, customers are informed and kept updated.

All decisions are:

  • Based on documented evidence
  • Clearly communicated to the customer
  • Recorded for audit and compliance purposes
  • Subject to internal oversight review

Customers may request a written explanation of the decision at any stage.

7. Escalation and External Dispute Options

7.1 Internal Escalation

Where a customer is not satisfied with the outcome, they may request an internal escalation. The review will be conducted by a more senior or independent function not involved in the original decision, where operationally feasible.

7.2 External Recourse

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

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

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

8. ADR Outcomes, Legal Impact, and Judicial Rights

Where a dispute is referred to an Alternative Dispute Resolution (ADR) body, customers should note the following:

  • The ADR body will review the matter independently and may issue a recommendation, determination, or proposed resolution depending on its mandate.
  • Such outcomes may be non-binding unless accepted by the relevant parties or made binding through legal mechanisms.
  • Participation in ADR does not remove or restrict the customer’s right to pursue legal proceedings.

Where the Company offers non-binding ADR services in accordance with Article 10(2) of Directive 2013/11/EU (as transposed by Directive 5 of 2018), customers will be informed that:

  • the ADR process does not result in an automatically binding decision;
  • acceptance of an ADR outcome may influence the further handling of the dispute; and
  • to obtain a binding and enforceable resolution, customers 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 engaging in ADR, including its impact on further legal and judicial recourse.

9. Responsible Gambling and High-Priority Complaints

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

Such complaints:

  • Are escalated for immediate review
  • Are handled by trained specialist personnel
  • Are subject to enhanced oversight procedures

Serious cases may be escalated to Senior Management and included in compliance reporting obligations.

10. Record Keeping and Regulatory Reporting

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

  • Complaint classification and details
  • Investigation steps and findings
  • Final outcome and rationale
  • Escalation history

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

Reporting may include:

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

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

11. Confidentiality and Data Protection

All complaints are handled in a confidential manner and processed in compliance 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 and governance procedures

12. Policy Oversight and Review

This Framework is approved by Senior Management of Mobile Incorporated Limited and forms part of the Company’s governance structure.

It is:

  • Reviewed at least annually
  • Updated in response to legal, regulatory, or operational changes
  • Subject to Board and Senior Management oversight

All material amendments are formally documented and communicated where appropriate.