Draft for legal and processing-partner review. This document is not in effect, has not been approved by counsel or any payment provider, and does not create binding obligations. Bracketed items are unresolved and are tracked in the Launch Decision Register.

Complaints Policy

Version 0.1 — Effective date: not set

1. Who can complain

1.1 Merchants, applicants, customers of merchants and members of the public may complain about Orion Payments's services or conduct.

2. How to complain

2.1 By email to [Complaints contact to be confirmed], or through a support case in the merchant portal (category "Complaint").

2.2 Please include your name, contact details, the business or transaction concerned (order reference or payment ID), what happened and what outcome you are seeking.

3. What we will do

3.1 Acknowledge the complaint promptly (proposed target: within 2 business days; to be confirmed). 3.2 Investigate fairly, by someone not directly involved where practical. 3.3 Respond in writing with our findings, the outcome and reasons (proposed target: within 30 days; to be confirmed). If we need longer, we will explain why and give a new date. 3.4 Keep records of complaints and outcomes to identify recurring issues.

4. Complaints about matters outside Orion's control

4.1 Product complaints are for the merchant, who is the seller. We will direct you to the merchant's contact details. 4.2 Card disputes are made through your card issuer. 4.3 Provider decisions (approvals, declines, holds) are made by the provider. We will explain what we can and, where appropriate, help you contact the provider.

5. Appeals of suspension or decline

5.1 Merchants may ask for review of an Orion suspension or an Orion internal decline. Provide any new information. A different reviewer will consider it.

6. Escalation

6.1 If you are not satisfied, you may have the right to complain to an external body. Which bodies apply (for example, a privacy regulator for privacy complaints, or a regulator relevant to payment services) depends on legal assessments not yet completed. This section will list them once confirmed.