India Customer Grievance Redressal Policy

1.  Introduction:

In accordance with Clauses 5.5 and 9 of the Guidelines on Regulation of Payment Aggregators and Payment Gateways, dated 17 March 2020, issued by the Reserve Bank of India (“RBI”), Boku Network Services IN Pvt. Ltd., CIN U74940MH2009PTC196659 (“Boku IN”) has put in place this Customer Grievance Redressal Policy (“Policy”), which provides details of the regulatory requirements applicable to Boku IN. This Policy does not apply to any other entity in the Boku Group.

This Policy has been adopted by Boku IN’s board of directors (“Board”) in compliance with the applicable laws and regulations. Boku IN shall modify the terms of this Policy on the basis of revisions to the RBI Guidelines, as required, from time to time. The RBI Guidelines shall have overriding effect.

2.  Objective:

This Policy outlines a structured grievance redressal mechanism to inform customers about the various channels available to them to escalate their complaints with respect to any grievances arising from availing the services of Boku IN. 

There are various channels via which a customer can lodge his/ her grievance – in person, by telephone, through website or email. If complaints received by any of the above channels are not resolved within the prescribed time frame or if the customer is not satisfied with the resolution offered, he/ she can approach the Customer Care Head/ Grievance Officer of Boku IN, and if still not satisfied by the response, he/ she can approach the Nodal Officer appointed by Boku IN. In case the customer is not satisfied with the response/ resolution provided by Boku IN, he/ she can register a complaint under the RBI Integrated Ombudsman Scheme, 2021 (as amended from time to time) or resort to other legal avenues for grievance redressal.

Boku IN’s policy on grievance redressal is governed by the following principles: 

1. Customer shall be treated fairly at all times. 
2. Complaints raised by customers shall be attended to with courtesy and in a timely manner. 
3. Customers are provided with effective and satisfactory resolution within an acceptable time period. 
4. Customers are fully informed of avenues to escalate their complaints/ grievances within the organization and their rights to alternative remedy, if they are not fully satisfied with the response to their complaints.

3.  Definitions and abbreviations:

Term	Definition
Account	A formal relationship to provide or engage in services, dealings, or other financial transactions.
Authorised Representative	A person, other than an advocate, duly appointed and authorised in writing to represent the complainant in the proceedings before the Ombudsman.
Centralised Receipt and Processing Centre	The RBI shall establish the Centralised Receipt and Processing Centre at any place as may be decided by it to receive the complaints filed under the RBI Integrated Ombudsman Scheme, 2021 and process them.
Complaint	As per the RBI Integrated Ombudsman Scheme, 2021, ""Complaint" means a representation in writing or through other modes alleging deficiency in service on the part of a Regulated Entity and seeking relief".
Customer	As per the RBI KYC Master Directions, ""Customer" means a person who is engaged in a financial transaction or activity with a Regulated Entity (RE) and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting."
Deficiency in service	Deficiency in service means a shortcoming or an inadequacy in any financial service or such other services related thereto, which Boku IN is required to provide statutorily or otherwise, which may or may not result in financial loss or damage to the customer;
Failed transaction	A 'failed transaction' is a transaction which has not been fully completed due to any reason not attributable to the customer, such as failure in communication links, non-availability of cash in an ATM, time-out of sessions, etc. Failed transactions shall also include the credits which could not be effected to the beneficiary account on account of lack of full information or lack of proper information and delay in initiating a reversal transaction.
KYC	Know Your Customer
OFF-US Transaction	Transaction where the issuing bank and acquiring bank are different entities.
Ombudsman/ Deputy Ombudsman	RBI may appoint one or more of its officers as Ombudsman and Deputy Ombudsman, to carry out the functions entrusted to them under the RBI Integrated Ombudsman Scheme, 2021.
ON-US Transaction	Transaction where the issuing bank and the acquiring bank are the same entity.
RBI	Reserve Bank of India
RE	Regulated Entity means: all Scheduled Commercial Banks (SCBs)/ Regional Rural Banks (RRBs)/ Local Area Banks (LABs)/ All Primary (Urban) Co-operative Banks (UCBs) /State and Central Co-operative Banks (StCBs / CCBs) and any other entity which has been licenced under Section 22 of Banking Regulation Act, 1949, which as a group shall be referred as ‘banks’; All India Financial Institutions (AIFIs);  All Non-Banking Finance Companies (NBFCs), Miscellaneous Non-Banking Companies (MNBCs) and Residuary Non-Banking Companies (RNBCs);  All Payment System Providers (PSPs)/ System Participants (SPs) and Prepaid Payment Instrument Issuers (PPI Issuers);  All authorised persons (APs) including those who are agents of Money Transfer Service Scheme (MTSS), regulated by the Regulator.
R	R is the day on which the reversal is concluded, and the funds are received by the issuer/ originator.
T	T is the day of transaction and refers to the calendar date.

4.  Guidelines:

Boku IN has put in place the following guidelines for handling grievances/ complaints of customers:

1. While handling complaints, record keeping requirements and local laws and regulations must be adhered to. All customer interaction related to complaints should be preserved for future reference. 
2. Customers are provided with a customer reference number to facilitate follow-up with respect to their complaints, if required. 
3. Acknowledgment is provided to the customer for complaints received. 
4. Timelines are defined for the resolution of complaints. 
5. No fee is collected from the customers for filing complaints or upon resolution.
6. Communication of resolution of complaints to the customer. 
7. Periodic reporting of complaints to, and review by, the senior management of Boku IN. 
8. Analysis of recurring issues and trends, and rectification thereof.

Boku IN shall ensure disclosure of comprehensive information regarding its merchant policy, customer grievance policy, privacy policy and other terms and conditions on its website and/ or its mobile application. 

5.  Scope and applicability: 

This Policy is applicable to all offices of Boku IN and is to be read in conjunction with related operational guidelines, issued from time to time.

6.  Nodal Officer:

Nishant Rohilla shall act as the Nodal Officer of Boku IN. The Nodal Officer shall be responsible for overall regulatory and customer grievance handling functions. 

The details of the Nodal Officer, such as his name and contact information, shall be prominently displayed on the Boku IN website.

7.  Turn around time:

In compliance with the RBI Notification on Harmonisation of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems, dated 20 September 2019, the principle behind TAT is based on the following: 

1. If the transaction is a 'credit-push' funds transfer and the beneficiary account is not credited while the debit to originator has been effected, then credit is to be effected within the prescribed time period failing which the penalty has to be paid to the beneficiary; 
2. If there is delay in initiation of a transaction at the originator bank’s end beyond the TAT, then penalty has to be paid to the originator.

The TAT and customer compensation for failed transactions via Boku IN will be as follows:

Sl. no.	Description of the incident	Framework for auto-reversal and compensation
		Timeline for auto-reversal	Compensation payable
I	II	III	IV
1	Card Transaction
a	Card to card transfer  Card account debited but the beneficiary card account not credited.	Transaction to be reversed (R) latest within T + 1 day, if credit is not effected to the beneficiary account.	₹ 100/- per day of delay beyond T + 1 day.
b	Point of Sale (PoS) (Card Present) including Cash at PoS  Account debited but confirmation not received at merchant location i.e., charge-slip not generated.	Auto-reversal within T + 5 days.	₹ 100/- per day of delay beyond T + 5 days.
c	Card Not Present (CNP) (e-commerce)  Account debited but confirmation not received at merchant’s system.
2	Immediate Payment System (IMPS)
a	Account debited but the beneficiary account is not credited.	If unable to credit to beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
3	Unified Payments Interface (UPI)
a	Account debited but the beneficiary account is not credited (transfer of funds).	If unable to credit the beneficiary account, auto reversal (R) by the Beneficiary bank latest on T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
b	Account debited but transaction confirmation not received at merchant location (payment to merchant).	Auto-reversal within T + 5 days.	₹100/- per day if delay is beyond T + 5 days.
4	Aadhaar Enabled Payment System (including Aadhaar Pay)
a	Account debited but transaction confirmation not received at merchant location.	Acquirer to initiate "Credit Adjustment" within T + 5 days.	₹100/- per day if delay is beyond T + 5 days.
b	Account debited but beneficiary account not credited.
5	Aadhaar Payment Bridge System (APBS)
a	Delay in crediting beneficiary’s account.	Beneficiary bank to reverse the transaction within T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
6	National Automated Clearing House (NACH)
a	Delay in crediting beneficiary’s account or reversal of amount.	Beneficiary bank to reverse the uncredited transaction within T + 1 day.	₹100/- per day if delay is beyond T + 1 day.
b	Account debited despite revocation of debit mandate with the bank by the customer.	Customer’s bank will be responsible for such debit. Resolution to be completed within T + 1 day.
7	Prepaid Payment Instruments (PPIs) – Cards / Wallets
a	Off-Us transaction  The transaction will ride on UPI, card network, IMPS, etc., as the case may be. The TAT and compensation rule of respective system shall apply.
b	On-Us transaction  Beneficiary’s PPI not credited.  PPI debited but transaction confirmation not received at merchant location.	Reversal effected in Remitter’s account within T + 1 day.	₹100/- per day if delay is beyond T + 1 day.

It may be noted that: 

1. the prescribed TAT is the outer limit for resolution of failed transactions; and 
2. Boku IN shall endeavour towards quicker resolution of such failed transactions. 

Wherever financial compensation is involved, the same shall be effected to the customer’s account, without waiting for a complaint or claim from the customer.

The aforementioned turn around time shall be complied by Boku IN to the extent applicable and may get affected due to dependencies on external factors or third parties, which are beyond the control of Boku IN.

8.  Types of disputes:

The types of disputes/ issues with customers may inter alia include: 

1. Facing issues while onboarding on Boku IN’s platform;
2. Technical issues while accessing Boku IN’s platform;
3. Disputes relating to rejection/ suspension of payments to customers, refunds and/ or any other dispute relating to transactions;
4. Identifying or being subject to fraudulent activity.

9.  Filing of Complaint:

Customers may get in touch with Customer Support Team of Boku IN to raise their complaints via any of the following modes:

1. Via web portal: Customer may write to Boku IN on the following webpage: https://boku.zendesk.com/
2. Via e-mail: Customer may write to Boku IN using the following e-mail ID: [e-mail].
3. Via call: Customer may call Boku IN at the following phone number: [phone].
4. Via post/ courier: Customer may write to Boku IN at the following address:

To

Boku Network Services IN Private Limited

501B, 5th Floor, Opposite City Mall

New Link Road, Veera Desai Road

Andheri (West), Mumbai - 400053

 

10.  Escalation matrix

Boku IN has a four-tier escalation matrix for handling customer complaints:

Level 1: Registration of complaint with customer support of Boku IN

Customers may file their complaints via any of the modes enumerated in Clause 9 of this Policy. Customers are encouraged to provide complete details of their grievance, along with relevant documents (if any), in their complaint. However, in case of any trouble faced by the customer in lodging an appropriate complaint, Boku IN shall endeavour to provide guidance to the customer in this regard. 

Upon raising a complaint in the manner provided above, the customer shall receive an acknowledgement and a Customer Reference Number, within 24 hours of receipt of the complaint, which will enable the customer to track the status of their complaint. 

Boku IN shall send its first response/ acknowledgement towards resolution of the complaint within 2 working days of the receipt of complaint. The response may either contain the resolution or an intimation that Boku IN requires more time to examine the complaint. The maximum time to resolve the complaint would be 10 business days from the date of receipt of the complaint. In case the complaint is not resolved, or the customer is not satisfied with the resolution, the customer may escalate the complaint as under.

Level 2: Customer Care Head/ Grievance Officer

In case timely resolution is not provided in Level 1, or in case the customer is not satisfied with the resolution provided, he/ she can reach out to the Customer Care Head/ Grievance Officer as below:

Risto Suurpere, Head of Global Customer Relations

The Customer Care Head/ Grievance Officer shall refer to the complaint history and take adequate steps for resolution of the complaint. The Customer Care Head/ Grievance Officer shall send the final response to the customer within 20 business days of receipt of the complaint. Such responses may either contain the resolution or an intimation that Boku IN requires more time to examine the complaint, along with reasons for seeking such extension. In case the complaint is not resolved, or the customer is not satisfied with the resolution, the customer may escalate the complaint as under.

Level 3: Nodal Officer

In case timely resolution is not provided in Level 2, or in case the customer is not satisfied with the resolution provided, he/ she can reach out to the Nodal Officer:

Nishant Rohilla, Manager & Nodal Officer, [e-mail]

The Nodal Officer shall send the final response to the customer within 30 business days of receipt of the complaint. Such a response may either contain the resolution or an intimation that Boku IN requires more time to examine the complaint, along with the reason for seeking such extension. 

The maximum time to resolve the complaint is 30 business days from the date of receipt of the complaint.

The contact details of the Nodal Officer shall be displayed and updated on the website of Boku IN.

Level 4: Ombudsman

In case the customer is not satisfied with the response from Boku IN within 30 days of receipt of the complaint, the customer can register a complaint with the RBI Integrated Ombudsman Scheme, 2021 (“Scheme”), as amended from time to time. The salient features of the Scheme along with the copy of the Scheme shall be displayed and updated on the website of Boku IN.

Any customer aggrieved by an act or omission of Boku IN resulting in deficiency of service may file a complaint under the Scheme personally or through an authorised representative. The complaints under the Scheme can be filed online at: https://cms.rbi.org.in. The format of complaint to be lodged with the Ombudsman is available at the Annex to the Scheme: https://cms.rbi.org.in/cms/assets/Documents/Ombudsman_Scheme_English.pdf. 

The complaint may also be submitted through electronic or physical mode to the Centralised Receipt and Processing Centre as notified by the RBI. The complaint, if submitted in physical form, shall be duly signed by the complainant or by the authorised representative. The complaint shall be submitted in electronic or physical mode in such format and containing such information as may be specified by RBI.

A complaint under the Scheme shall not lie unless the complainant had, before making a complaint under the Scheme, made a written complaint to Boku IN and the complaint was rejected wholly or partly by Boku IN, or the complainant is not satisfied with the reply, or the complainant did not receive any reply within 30 days after Boku IN received the complaint. Complaints which are in the nature of offering suggestions or seeking guidance or explanation shall not be treated as valid complaints under the Scheme and shall be closed accordingly with a suitable communication to the complainant.

The Ombudsman may reject a complaint at any stage if: 

1. in their opinion there is no deficiency in service; or 
2. the compensation sought for the consequential loss is beyond the power of the Ombudsman to award the compensation; or 
3. the complaint is not pursued by the complainant with reasonable diligence; or 
4. the complaint is without any sufficient cause; or 
5. the complaint requires consideration of elaborate documentary and oral evidence and the proceedings before the Ombudsman are not appropriate for adjudication of such complaint; or 
6. in the opinion of the Ombudsman there is no financial loss or damage, or inconvenience caused to the complainant.

The Ombudsman/ Deputy Ombudsman under the Scheme shall endeavour to promote settlement of a complaint by agreement between the complainant and Boku IN through facilitation or conciliation or mediation.

The complaint would be deemed to be resolved when: 

1. it has been settled by Boku IN with the complainant upon the intervention of the Ombudsman; or 
2. the complainant has agreed in writing or otherwise (which may be recorded) that the manner and the extent of resolution of the grievance is satisfactory; or 
3. the complainant has withdrawn the complaint voluntarily.

In case the complaint is not resolved, the Ombudsman shall pass an Award. The Ombudsman shall take into account the principles of banking law and practice, directions, instructions and guidelines issued by the RBI from time to time and such other factors as may be relevant, before passing a reasoned Award. The Award shall contain, inter alia, the direction, if any, to Boku IN for specific performance of its obligations and in addition to or otherwise, the amount, if any, to be paid by Boku IN to the complainant by way of compensation for any loss suffered by the complainant.

11.  Obligations of customers:

To ensure a timely and effective grievance redressal process, customers are expected to furnish relevant documentation and information for the verification of the complaint and investigation purposes. In certain cases, Boku IN may require customers to furnish additional information. Customers are requested to comply with such requests to ensure a smooth and efficient grievance redressal process. In addition, customers are expected to ensure that such documentation and information is accurate, bona fide, not misleading, and up to date. Boku IN disclaims all responsibility and liability for non-redressal of grievances due to false, inaccurate, mala fide, or outdated information/ documents that are submitted by customers.

12.  Governing law

The Agreements between Boku IN and merchants shall be governed by and construed in accordance with the laws of Republic of India.

13.  Maintenance of records:

Boku IN will preserve all records pertaining to grievance/ complaint received, current status, resolution provided and closure of the grievance, as required under the applicable laws.

14.  Training of employees:

Boku IN shall have an ongoing employee training programme so that members of the staff are adequately trained in this Policy and fully understand the rationale behind this Policy and implement them consistently.

15.  Customer education:

Boku IN recognizes the need to spread awareness on customer grievance redressal measures. Therefore, Boku IN shall endeavor to educate its customers on the objectives of this Policy. 

16.  Approval/ review

This Policy shall be reviewed by the Board periodically, or as and when there are any changes introduced by any statutory/ regulatory authority, or as and when it is found necessary to change the Policy owing to business needs.