Dispute Resolution

VestraPay Nigeria Limited is a CBN-licensed financial technology and payments company. We recognise that disputes, complaints, and service issues may arise in the ordinary course of providing financial services, and we are committed to addressing them promptly, fairly, and transparently.

This Dispute Resolution Policy sets out: the categories of disputes covered; the structured multi-tiered process from internal complaint handling through to external escalation and arbitration; the timelines at each stage; the rights of Complainants throughout; and VestraPay obligations under the CBN Consumer Protection Framework, the Arbitration and Mediation Act 2023, and other applicable Nigerian law.

VestraPay operates a three-tier dispute resolution framework:

Tier 1: Internal Complaint Resolution

The first step in all disputes is submission to our customer support team. Complainants may submit complaints through:

Please include your full name and account number, a description of the issue, the date(s) it occurred, any transaction reference numbers, supporting documents or screenshots, and your preferred contact method.

VestraPay will acknowledge receipt within 24 hours on Business Days, assign a unique complaint reference number, and provide a substantive response within 5 Business Days. Where additional time is required, we will notify you before that deadline expires.

Tier 2: Internal Escalation

If you are not satisfied with the Tier 1 response, or your complaint has not been resolved within 5 Business Days, you may escalate to VestraPay Compliance and Senior Management team:

• Email: compliance@vestrapay.com
• Subject line: COMPLAINT ESCALATION: [complaint reference number]

VestraPay will conduct an independent internal review, acknowledge escalation within 24 hours, and provide a final internal decision within 15 Business Days. The Tier 2 decision constitutes VestraPay final internal position and will be communicated in writing.

Tier 3: External Escalation

If your complaint remains unresolved after Tier 2, or you are not satisfied with the final internal decision, you may pursue resolution through the following external channels:

A. CBN Consumer Protection Department

• Email: consumerprotection@cbn.gov.ng
• Online: CBN Consumer Complaints Management System (CCMS) at https://ccms.cbn.gov.ng
• Post: Director, Consumer Protection Department, Central Bank of Nigeria, Abuja

B. Federal Competition and Consumer Protection Commission (FCCPC)

• Website: www.fccpc.gov.ng
• Email: info@fccpc.gov.ng

C. Mediation

The parties may elect to resolve the dispute through mediation before a mutually agreed mediator or a recognised Nigerian mediation centre. Mediation is voluntary, confidential, and without prejudice. VestraPay will cooperate in good faith with any agreed mediation process.

D. Arbitration (Arbitration and Mediation Act 2023)

Where a dispute remains unresolved after Tiers 1 and 2 and mediation has not succeeded, either party may refer the matter to binding arbitration under the Arbitration and Mediation Act 2023. The terms are:

• Seat: Lagos, Nigeria
• Language: English
• Appointing authority: Lagos Court of Arbitration (LCA) or such body as agreed
• Tribunal: Sole arbitrator (unless complexity warrants a panel of three)
• Governing law: Laws of the Federal Republic of Nigeria

The arbitral award shall be final and binding and may be enforced in any court of competent jurisdiction. Each party shall bear its own costs unless the tribunal determines otherwise.

E. Courts of Law

Nothing in this Policy prevents either party from seeking urgent interim relief from a Nigerian court of competent jurisdiction pending arbitration or other proceedings.

Throughout the dispute resolution process, you have the right to:

• Submit your complaint and receive a written acknowledgement and unique reference number;
• Be treated with dignity, courtesy, and without discrimination at all stages;
• Request copies of documents relevant to your complaint, subject to data protection and legal privilege limitations;
• Seek independent legal advice or representation at any stage;
• Escalate to the CBN or another external body without completing the internal process, if you choose;
• Receive a final written decision setting out VestraPay position and its basis; and
• Be informed of your rights to external escalation if your complaint is not resolved to your satisfaction.

VestraPay maintains a comprehensive Complaints Register recording all complaints received, channels, investigation, and outcomes. This register is reviewed monthly by the Chief Compliance Officer, reported quarterly to the Board Risk and Compliance Committee, and made available to the CBN upon request. VestraPay submits complaint data to the CBN in accordance with Consumer Protection Framework reporting obligations.

This Policy will be reviewed at least annually or following any material change in applicable law, CBN regulations, or VestraPay operations. Revisions will be communicated through the platform and website, with the updated version bearing a new effective date.