Dispute Resolution and Chargeback Policy and Procedure - current.docx

Dispute Resolution and Chargeback Policy


Document information and change log

Document Information

Header

Information

Next review

Sep 20, 2025

Status

Update

Regional scope & language

Territory of USA in English

Applies to entities

GiveCorporation Inc.

Overall responsibility

Loraine Stewart, CCO

Approved by

Joshua Rowley, CEO; Aaron Miller, CRTO;  Michael Brinker, CBFO

Change log

Date

Version

Reason for version

Sep 1, 2017

1.0

Initial Release

Sep 1, 2018

2.0

Annual Review

Sep 1, 2019

3.0

Annual Review

Sep 1, 2020

4.0

Annual Review

Sep 1, 2021

5.0

Annual Review & Updates Anti-Money Laundering Act of 2020

Sep 1, 2022

6.0

Annual Review

Aug 19, 2023

7.0

Annual Review & Updates PCI Level 1 4.0 & DSS 4

Sep 20, 2024

8.0

Annual Review

Feb 14, 2025

8.1

Updates on the Chargebacks and Disputes Process.  Policy Updated. The policy and procedure have been merged into a single document."

May 29, 2025

8.2

Contact Customer if suspected Fraudulent chargeback before marking as fraud

June 2nd, 2025

8.3

Updated dispute procedure and process steps, clarified evidence submission timelines, standardized the evidence package format and naming, added fraud/friendly classification criteria, and included merchant and customer follow-up actions.

June  20, 2025

8.4

Added “Procedure Override,”  “Why Arbitration,” “Arbitration Thresholds,” “Visa’s Threshold for Chargebacks,” “Visa Dispute/Chargeback Ratio

Visa Fraud Monitoring Program (“VFMP”),” “Visa Fraud Ratio,” “Mastercard Chargeback Thresholds,” sections, and “ Visa Dispute Monitoring Program,” “Visa Fraud Monitoring Program (“VFMP”),” “Mastercard Chargeback Thresholds Program,” “Mastercard Excessive Fraud Merchant (“EFM”) Program”

tables.

December, 2025

9.0

Annual Review

Gender And Entity Neutrality

The masculine form is used solely for the sake of better readability. It always refers to persons of any gender identity (m/f/diverse). This document uses the abbreviation “Give” for all legal entities and subsidiaries.


Table of Contents

Introduction        5

Definitions        5

Procedure Override        5

General Dispute Guidelines        5

Eligible Disputes        5

Informal Resolution        6

Formal Resolution        6

Notification        6

Acknowledgment        6

Investigation        6

Resolution        6

Mediation        6

Legal Proceedings        7

Fees and Expenses        7

Communication        7

Amendments        7

Governing Law, Court and Jury Trial        7

Chargebacks        8

Overview        8

Definitions        8

Chargeback        8

Chargeback Dispute        8

Chargeback Process        8

10.1 Why Arbitration        9

10.2 Arbitration Thresholds        9

Dispute Case Process        10

Evidence Gathering        11

Dispute Process Guidelines        12

Visa’s Threshold for Chargebacks        13

Visa Dispute/Chargeback Ratio        14

Visa Fraud Monitoring Program (“VFMP”) Visa Fraud Ratio        14

Contesting Disputes in the Visa Fraud Monitoring Program        15

Customer Notification        15

Mastercard Chargeback Thresholds        15

Visa Compelling Evidence        16

Responsibilities of the Merchant        16

Preventing Chargebacks        16

Chargeback Fees        17

Rights of Give        17

Assistance        17

Policy Changes        17

Appendix A: Chargeback and Dispute Resolution Checklist (Second Chargeback)        17


Introduction

This Dispute Resolution Policy ("Policy") sets out the procedures and guidelines to address and resolve disputes arising from merchant processing services provided by Give. All merchants, stakeholders, and customers ("Parties") are expected to understand and abide by this Policy.

Definitions

  • "Dispute" refers to any disagreement, controversy, or claim arising out of or in connection with the provision of our merchant processing services.
  • "Merchant" refers to any business or individual that uses Give’s services for processing payments.

Procedure Override

Instances will arise when procedures may not be followed to protect the organization and our stakeholders. Fraud, chargebacks and disputes instances may occur that Give will not follow the documented process to protect the organization’s chargeback/fraud ratios.

General Dispute Guidelines

All disputes will be automatically recorded on the platform and the Give disputes team will be notified to take action. All parties must maintain confidentiality throughout the resolution process.

Eligible Disputes

The following charges are eligible for dispute:

  • Unauthorized or fraudulent transactions
  • Incorrect billing amounts
  • Duplicate charges
  • Non-receipt of goods or services
  • Goods or services that were not as described or defective
  • Canceled transactions that were still charged

Informal Resolution

Before invoking the formal resolution process, Parties should attempt to resolve the dispute informally, including direct discussions between involved Parties. This will reduce the merchant’s number of disputes. Informal dispute resolutions are resolved instead of  the Bank or Give’s platform.

Formal Resolution

If the dispute cannot be resolved informally, the formal resolution process should begin immediately. At the same time, the merchant should contact the customer to attempt to have the dispute reversed. These actions should happen in parallel:

Notification

Give’s dispute team will receive an email and push notification to take action on each newly created dispute. All disputes will be initiated by the Bank and include details about the dispute case. The team will also receive notifications for every change in the dispute status and its final decision.

Acknowledgment

Give will acknowledge receipt of the dispute within 3 business days. The acknowledgment will include a reference number that should be used in all future correspondence related to the dispute.

Investigation

Give will conduct a thorough investigation. This may include seeking further information from the disputing Party, reviewing transaction records, and consulting any relevant third parties.

Resolution

Give team will dispute the chargeback if it is identified as a friendly chargeback. The team will provide supporting evidence and can engage in back-and-forth communication with the Bank through the platform. The Bank will review the case and issue a decision This decision will be final and binding unless the disputing Party escalates it to mediation or legal proceedings.

Mediation

If either Party is unsatisfied with the outcome of the formal resolution process, they may propose mediation. The following conditions apply:

  • Both Parties must agree on a neutral third-party mediator.
  • The costs of mediation will be shared equally unless otherwise agreed.

If mediation does not result in a resolution, Parties may seek legal remedies.        

Legal Proceedings

If the dispute remains unresolved after mediation, either Party may initiate legal proceedings. Legal proceedings shall be conducted in Maricopa County, Arizona, and Parties will be subject to laws of Arizona.

Fees and Expenses

Unless otherwise decided by Give or by the mediator/court, each Party will bear its own expenses arising from the dispute resolution process.

Communication

All communications related to this Policy should be directed to:

Give Corporation

Dispute Resolution Department

3200 E Camelback Rd., STE 275,

Phoenix, AZ 85018

Amendments

Give reserves the right to amend this Policy at any time. Any changes will be communicated to our merchants and will be effective from the date of announcement.

Governing Law, Court and Jury Trial

This Policy shall be governed by and construed in accordance with Arizona law. For any disputes, Parties agree to exclusively bring any action, litigation or proceeding related to this Agreement to Arizona courts in Maricopa County, waiving their right to a jury trial.

Chargebacks

Overview

This policy document outlines the procedures, rights, and obligations related to chargebacks for all merchants who process payments through Give. By processing payments with Give, merchants agree to abide by this chargeback policy.

Definitions

Chargeback

A reversal of a credit card transaction, typically initiated by the cardholder's issuing bank, due to a dispute raised by the cardholder.

Chargeback Dispute

The process where a merchant disputes a chargeback.

Chargeback Process

The chargeback dispute process involves the following steps and parties, including the cardholder, the merchant, the acquiring bank (Give Corporation in this case), and the issuing bank (cardholder's bank).

1. A cardholder makes a purchase from a merchant using a credit or debit card.

2. The cardholder disputes the charge after noticing an issue with the transaction (e.g., unauthorized charge, product not received, service dissatisfaction) and contacts their issuing bank.

3. Chargeback Issued: Once the issuing bank deems the cardholder's dispute is valid, the issuing bank initiates a chargeback and temporarily credits the amount back to the cardholder's account.

4. The acquiring bank receives notice of the chargeback. The merchant is debited for the transaction amount plus any applicable chargeback fees.4a. Before or immediately upon chargeback notification, the transaction is evaluated through chargeback prevention program Visa Rapid Dispute Resolution – RDR:

If eligible, a pre-chargeback refund is automatically issued to the cardholder to prevent the chargeback from proceeding.

If a refund is not applied or prevention is not available and the chargeback is received in our system, chargeback evidence is automatically generated in PDF format and submitted to the acquiring bank in accordance with card-network timelines.

5. The issuing bank review process may involve several rounds of back-and-forth communication between the banks, each requiring strict adherence to deadlines and procedures.

6. If the issuing bank agrees with the merchant, the chargeback is overturned, and the transaction amount is returned to the merchant. The cardholder's temporary credit is reversed.

If the issuing bank agrees with the cardholder, the chargeback stands, and the cardholder retains the credit. The merchant absorbs the loss of the transaction and any associated fees.

7. Second Chargeback or Pre-Arbitration (Optional)

Depending on the card network's rules and the case, there is an option for either party to dispute the resolution, leading to a second chargeback (also known as pre-arbitration). This step involves further review and possibly more detailed submission of evidence.

8. Arbitration: If the dispute cannot be resolved through the chargeback process, it may escalate to arbitration by the card network (e.g., Visa, Mastercard). Arbitration is a final review and a binding decision by the card network on all parties. Arbitration carries significant financial risk. The losing party may incur fees. Disputes should only escalate to arbitration if the internal risk team evaluates the evidence to have strong merit.

10.1        Why Arbitration

Companies go to arbitration when they believe they have strong evidence to support their claim(s). It is more cost effective than a lawsuit. The losing party often pays the cost. Which is the reason the organization will pursue arbitration when they have strong evidence to support their claim(s)

10.2        Arbitration Thresholds

Thresholds for arbitration are amounts that are significant to the organization. Organizations need to determine what is considered significant.

11. Card Brand-Specific Flows and Network Limitations

Give acknowledges that dispute processing may differ by card network. The procedures and escalation paths are adapted as follows:

  • Visa (Rapid Dispute Resolution - RDR):
    Visa provides a proactive dispute prevention mechanism known as Rapid Dispute Resolution (RDR). Give utilizes automated RDR processing for eligible Visa transactions.

RDR-eligible transactions are automatically evaluated and resolved through the platform without manual intervention.

Refund is automatically issued to the cardholder, preventing formal chargeback creation.

RDR-resolved transactions are automatically logged in the platform and marked as “RDR Refund” for tracking and audit purposes.

The applicable RDR fee is applied and credited to the Acquirer.

All RDR activity is recorded at transaction and dispute level and remains accessible for audit and reporting purposes.

  • Mastercard (Mastercom Collaboration Phase):
    Give’s processor does not support Mastercard’s pre-dispute collaboration phase via Mastercom. As a result, all Mastercard disputes are received directly as chargebacks. Manual refunds may be processed internally to address these disputes, but no upstream notification or resolution is available prior to the chargeback being issued.
  • American Express and Discover (Retrieval Requests):
     Retrieval requests from Amex and Discover are treated internally as pre-chargeback events. Upon receiving such a request, Give automatically issues a refund to prevent escalation. A non-refundable chargeback fee is applied upon receipt of the retrieval request. If no refund occurs or the request times out, the transaction is escalated to a chargeback and processed under standard rules.

All card-brand-specific dispute events are documented in the platform, and all manual actions (refunds, RDR refund, chargeback disputes) must be accurately reflected in the merchant ledger, audit trail, and timeline.

Dispute Case Process

  1. Chargeback Classification
  • When a chargeback is received, our team reviews the case and gathers all available evidence to confirm it as either fraudulent or friendly.
  • Fraudulent: A chargeback is considered fraudulent if the transaction shows signs of unauthorized activity. Our team will carefully review all supporting documents and transaction details to confirm if the chargeback is fraudulent. If confirmed as fraudulent, we will accept the chargeback and close the dispute case immediately.

Fraudulent chargeback examples: Invalid or disposable email, mismatched IP, device, or shipping location, clear signs of stolen card use, etc.

  • Friendly: A chargeback is considered friendly when it is initiated due to customer dissatisfaction, misunderstandings, or disputes over a product or service. Our team will investigate the evidence and circumstances that led to the chargeback. We will assess whether the merchant has a strong case by reviewing documentation. If our disputes team confirms that the chargeback is friendly, we  will proceed to dispute the chargeback on behalf of the merchant.

Friendly chargeback examples: Valid and matching customer info, prior legitimate transactions, signs of customer abuse or misunderstanding, etc.

  1. Evidence Submission
  • Evidence Submission: Ensure evidence is submitted on behalf of the merchant to counter the chargeback. As a first response to any dispute, regardless of classification, available evidence is automatically collected from the platform, compiled into a PDF, and submitted to the acquiring bank on behalf of the merchant. The Disputes Team follows the Dispute Responses guideline to review, supplement (if required), and manage responses for each dispute case.
  1. Outcome Confirmation
  • Confirm whether the merchant won or lost the dispute case:
  • If Merchant Lost:
  • Confirm the chargeback is applied to the merchant's account.
  • Reflect the chargeback in their balance and apply chargeback fees.
  • If negative balance occurs: Notify the merchant about the negative balance.
  • If unable to reconcile the negative balance: Add it to the TTM Credit/Fraud Loss.
  • If Merchant Won:
  • Confirm the chargeback is reversed (this can take a few weeks for the reversal to display).
  • Monitor the merchant's account to confirm the reversal of funds and reversal of associated fees.

Evidence Gathering

  1. Automated PDF Evidence Generation:
  • Customer Info:
  • A screenshot of the “View Customer” modal must be captured. The customer’s address must be clearly visible. This is necessary to verify that a shipping address has been provided by the user and, if applicable, that it corresponds to the location specified in the Risk Profile.
  • Transaction Summary:
  • Screenshot of the "Transaction Side Panel Summary".
  • Purchases:
  • Screenshot of the "Transaction Side Panel Purchases".
  • Email Receipt:
  • Screenshot of the "Resend Receipt" modal showing the email of the purchaser that received the receipt.
  • Screenshot of the actual email receipt.
  • Risk Profile:
  • Screenshot of the "Risk Profile" showing the location, IP address, and geolocation map.
  • Indicator if the same IP/email/cardholder was used on multiple transactions
  • Flagging if transaction occurred during odd hours or from high-risk geolocation
  • Reference to merchant communications (if applicable)
  • Additional Details:
  • Screenshot of any additional relevant details related to the dispute.
  1. Evidence Storage:
  • All dispute evidence is stored within the platform and is accessible through the dispute case record.
  • Evidence is automatically collected, compiled, sent and stored as a single system-generated PDF per dispute case.

PDF Naming Convention: dispute_<external_case_id>_merchant_evidence.pdf

Dispute Process Guidelines

  1. When to Dispute:
  • All disputed transactions are first evaluated through (RDR)and a refund is automatically issued and the dispute is resolved prior to chargeback.
  • If the transaction is not resolved through RDR and a chargeback is issued, evidence is automatically generated and submitted immediately.
  1. Dispute Response Timeline:
  • Initial Response:
  1. Automatically refunds all disputes eligible for automated refunds immediately upon identification.
  2. For disputes that escalate beyond pre-refund mechanisms, Give applies a secondary dispute management process whereby dispute evidence is automatically generated and submitted to the applicable card brands.
  • Full Resolution: Depending on the complexity of the dispute.

5. Actions if No Chargeback:

If a chargeback is prevented through RDR:

  • The transaction is refunded automatically.
  • The resolution is logged in the platform.

Visa’s Threshold for Chargebacks

Visa’s standard chargeback is transaction ratio of 0.9% and 100 chargeback in a month (Chargebacks911).  Visa also uses the chargeback ratios to determine compliance, fees, more obstacles to overcome, future business being affected, Visa may impose fines on high dispute/chargeback ratios and even lose the privilege of accepting of credit cards,

Both the chargeback ratio and number of chargebacks has to breach the standard limit for Visa to consider it a breach.  Once the dispute/chargeback ratio breaches the early warning category, the business enters the Visa Dispute Monitoring Program (“ VDMP”). A business exits the VDMP after reducing the dispute/chargeback ratio for three (3) consecutive months. If another dispute/chargeback ratio breaches one of the categories again then the clock starts again towards the 3 months.

Visa Dispute Monitoring Program

Visa’s Chargeback Categories

Monthly Threshold

Consequences for Exceeding Threshold

Early Warning

0.65% chargeback ratio and 75 chargebacks

Standard

0.9% chargeback ratio and 100 chargebacks

Enters VDMP

4 months grace period

Excessive

1.8% chargeback ratio and 1,000 chargebacks

No grace period.

 Copied from (Chargebacks911)

Visa Dispute/Chargeback Ratio

The organization’s dispute/chargeback ratio is calculated by dividing the total number of transactions by the total dispute/chargeback transactions during a specific period. Note: Even if chargeback is reversed it counts towards the dispute/chargeback ratio and count. Visa takes the chargeback from the acquirer's account. The acquirer then debits the payment processor’s account. The payment process then debits the merchant's account. Acquirers often establish more conservation thresholds than Visa.  

Visa Fraud Monitoring Program (“VFMP”) Visa Fraud Ratio

The organization’s fraud ratio is calculated by dividing the sum of the total number of transactions by the sum of the total fraudulent transactions during a specific period. Fraud type code 3 - fraud application is excluded from the fraud ratio calculation. High fraud ratios means higher processing fees if not managed. Visa only counts the first (1st) 10 fraudulent transactions from one cardholder in a month when calculating the fraud ratio and count. A business can exit the VFMP after reducing the fraud ratio for three (3) consecutive months. If another fraud ratio breaches one of the categories again then the clock starts again towards the 3 months.

Visa Fraud Monitoring Program (“VFMP”)

Visa’s Fraud Categories

Monthly Threshold

Consequences for Exceeding Threshold

Early Warning

0.65% of sales value and $50,000 in gross sales

Standard

0.9% of sales value and $75,000 in gross sales

  1. Enters VFMP or VFMP-3DS
  2. Requires a mitigation plan.
  3. 4 months grace period

Excessive

1.8% of sales value and $250,000 in gross sales.

  1. Automatic for high risk MCC e.g. 5962, 5966, 5967, 7995, 5912, 5122, and 5993.

  1. Only transactions in the US, Australia, Canada, Germany,  UK and Brazil are included.

Copied from (Chargebacks911)

 

Contesting Disputes in the Visa Fraud Monitoring Program

While in the VFMP, only evidence for reason code 10.5 can be  provided for disputes, they include:

We processed a refund before the dispute

A dispute for the transaction was accepted prior

The states in writing they will continue with the dispute

Visa considers fraud and disputes/chargebacks as indicators how the organization is managing potential chargebacks.

Customer Notification

The first month the merchant  enters either the VDMP or VFMP, the acquirer is required to notify the merchant that they exceeded their chargeback threshold.   The acquirer and merchant are required to coordinate on a remediation plan, The remediation plan should be implemented  in months 2-4. In months 5-12 acquirers make adjustments to reduce the merchant’s fraud levels to the appropriate level.

Mastercard Chargeback Thresholds

Mastercard calculates chargeback ratios by dividing the prior month’s number of processed transactions by the number of processed transactions for the current month.

Mastercard Chargeback Thresholds Program

Mastercard’s Chargeback Categories

Monthly Threshold

Excessive Chargeback Merchant Program

100 to 299 and 1.5% to 2.99%

High Excessive Chargeback Merchant Program

300 or more and 3% or more

Copied from (Chargebacks911)

Mastercard Excessive Fraud Merchant (“EFM”) Program

Number of Commerce Transactions

Fraud

Chargeback

Amount

Number of Fraud Chargeback

3DS Utilization

(Including Data Only Transactions)

1,000 or more

EUR/USD 50,000 or more

50 or more

 Less than 50%

(Regulated Countries)

Copied from (Chargebacks911)

Visa Compelling Evidence

Visa Compelling Evidence 3.0 (CE3.0) allows merchants to use a cardholder’s purchase history to prove that the disputed transaction is legitimate. Merchants can submit this compelling evidence at the post-dispute stage. The rules allow merchants to share two previous transactions that provide proof of a purchasing history between them and the cardholder, defined as a “historical footprint”.

These two historical transactions must meet the following criteria:

  • They must be between 120 and 365 days older than the date of the disputed transaction (the 120-day limit does not apply if the other undisputed transactions were original credit transactions).
  • They must both be undisputed and not have been reported as fraudulent.
  • At least two data elements (User ID, IP address, shipping address, device ID/fingerprint) must match across all three transactions, and one of these two must be the IP address or device ID/fingerprint.
  • Transactions must be from the same merchant.

CE3.0 applies only to disputes that use Visa reason code 10.4: Other Fraud: Card-Absent Environment. This reason code could indicate that the cardholder did not authorize or participate in a card-not-present (CNP) transaction or that a fraudulent CNP transaction was completed using an invalid account number or without authorization. The 10.4 reason code is often related to first-party or friendly fraud transactions.

Responsibilities of the Merchant

  • Accurate Information: Ensure that the payment form and receipt are customized with the proper transaction details, the business name, and descriptor are recognizable to cardholders to avoid unnecessary chargebacks.
  • Prompt Response: Merchants should reach out to customers who have initiated chargebacks within 48 hours to try informal resolution prior to engaging in the formal process.
  • Maintain Records: Maintain thorough records of all correspondence, and agreements with customers for at least 18 months.

Preventing Chargebacks

  • Clear Descriptors: Ensure that your billing descriptor is recognizable and accurately reflects your business.
  • Communication: Provide clear channels of communication for customers to resolve issues without initiating a chargeback.
  • Transparent Policies: Clearly state return, refund, and service policies at the point of purchase and on receipts.
  • Prompt Refunds: If a refund is necessary, process it promptly to prevent chargebacks.

Chargeback Fees

In the event of a chargeback, merchants may be subjected to a chargeback fee, irrespective of the chargeback's outcome. This fee covers administrative costs. Details of this fee are available in the merchant agreement.

Rights of Give

  • Reserve Right: In cases with an elevated risk of chargebacks, Give may hold a reserve on the merchant's account.
  • Termination: Excessive chargebacks can be grounds for termination of the merchant's account.
  • Adjustment: Give retains the right to adjust this Policy as necessary.

Assistance

Give provides tools and resources to help merchants reduce the risk of chargebacks. Consult our Merchant Resource Center or contact our Merchant Support team for guidance.

Policy Changes

Give may revise this Policy from time to time. Merchants will be notified of any significant changes in advance.

Appendix A: Chargeback and Dispute Resolution Checklist (Second Chargeback)

Chargeback Notification & Initial Review

  • Receive Notification: Confirm receipt of the second chargeback.
  • Review Merchant Details: Check transaction ID, merchant details, chargeback reason and disputed amount.
  • Review Case: Review the evidence to classify the chargeback as fraudulent or friendly dispute.
  • Check status timing: If dispute is marked as “Pending,” confirm if funds have moved. Submit evidence regardless.

Fraudulent Chargeback Process (If Confirmed Fraudulent)

  • Verify Unauthorized Activity: Confirm if the chargeback is due to unauthorized/fraudulent activity.
  • Contact Customer (If applicable): If the customer has a valid email, request more information about the chargeback. A none or suspicious response should further confirm a fraudulent chargeback.
  • Accept and Close Chargeback: If confirmed fraudulent, accept the chargeback and close the case.

Friendly Dispute Process (If Confirmed Friendly)

  • Identify Friendly Dispute: Confirm if the chargeback is due to customer dissatisfaction, misunderstandings, or service/product disputes.
  • Contact Merchant: Request order/shipping status or customer resolution attempts.
  • Initiate Dispute Process: Proceed immediately with evidence collection.

Evidence Collection & Submission

  • Gather Evidence: Collect transaction records, communication logs,any supporting documents from the platform, screenshots.
  • Compile evidence into a single PDF file.
  • File Naming Convention: dispute_<external_case_id>_merchant_evidence.pdf
  • Submit Evidence: Upload the PDF in the dedicated platform section.
  • Set dispute status to Pending Merchant Action.

Review Bank Decision

  • Monitor Decision: Track the bank’s resolution of the chargeback case.
  • Verify Outcome: Confirm if the merchant won or lost the dispute and check if the decision was applied correctly.
  • If Merchant Won:
  • Confirm reversal of funds and any fees.
  • If Merchant Lost:
  • Apply chargeback to merchant’s balance.
  • Notify merchant of negative balance.
    If unrecovered: Add to TTM Credit/Fraud Loss.

Pre-Arbitration & Arbitration Check

  • Ensure that the merchant accepts the decision and does not pursue pre-arbitration.
  • If escalation occurs:
  • Review strength of evidence before proceeding.
  • Note: Arbitration fees apply to the losing party.
  • Confirm Case Closure: Ensure that the case is fully resolved and documented as closed.

The information contained herein is intended to provide a general overview of the Company’s policies and procedures relating to compliance with this Policy and does not constitute legal advice or a complete description of the laws and regulations relating to this Policy. The Company has made every effort to ensure the accuracy and completeness of this Policy.  This document is intended to provide guidance to employees of Company on how to comply with applicable laws and regulations related to this Policy. Employees should consult with the Legal or Compliance Department if they have any questions about the Policy or how to comply with it. Company reserves the right to modify or update this Policy at any time without notice. Employees are responsible for reviewing the Policy on a regular basis to ensure that they are aware of any changes. This Policy applies to all employees of Company, regardless of their position or location unless stated otherwise in the Policy. Employees are responsible for complying with the Policy and for reporting any suspected violations to their respective supervisor, the Legal Department, AMLCO or respective recipient of such violation as outlined in this Policy.

Copyright © GiveCorporation Inc. All Rights Reserved