Document information and change log

Document Information

Change log

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

Definitions for terms and acronyms        4

Purpose        4

Scope        4

Policy        4

Understanding UDAAP        4

Unfair Practices        4

Deceptive Practices        4

Abusive Practices        5

Regulatory Implications and Compliance        5

Transparency        5

Complaint Resolution Procedures        5

Consumer Education        5

Compliance Programs        5

Training        6

Conclusion        6

Exhibit A: Compliance Contact        7

Definitions for terms and acronyms 

Purpose

Unfair, Deceptive, or Abusive Acts or Practices (“UDAAP”) is part of consumer protection. Understanding each component of UDAAP is essential for compliance and maintaining consumer trust.

Scope

Applies to all employees, vendors, systems and processes that interact with customers and maintain policies and processes for customers.

Policy

Understanding UDAAP

Unfair Practices

An unfair practice causes or is likely to cause substantial injury to consumers that is not reasonably avoidable and does not outweigh the offsetting benefits. Substantial injury may include monetary harm, unwarranted health and safety risks.

Deceptive Practices

A deceptive practice is a representation, omission, or practice that misleads or is likely to mislead a consumer or a consumer's reasonable interpretation or a consumer's product and or service decision-making process. Deceptive Practices include false advertising, misleading pricing, or failure to disclose critical information to a consumer..

Abusive Practices

An abusive practice is complex or confusing and materially takes advantage of a consumer’s inability to protect their interests because of the lack of understanding of a product’s and or service’s risks and costs. Therefore, the consumer has to rely  on a covered person to act in their interests.

Regulatory Implications and Compliance

To comply with regulations and avoid engaging in UDAAP has been doing the following:

Transparency

Give will ensure all terms, conditions, and costs of financial products and services are transparent and clearly communicated on the merchant agreement, marketing materials and on Give’s website. If necessary, the legal team will review materials for UDAAP compliance.

Complaint Resolution Procedures

Give has a customer complaint policy in place that includes a complaint log to document and manage customer complaints. Complaints will be sourced through the Merchant Complaints telephone number, customer disputes, communication during onboarding, with marketing and to the Client Services team. The Compliance team will review and analyze the customer complaints  to determine UDAAP. If necessary, the Chief Compliance Officer will seek guidance from legal council.

Consumer Education

Provide consumers with the information and tools they need to understand financial products and services. Give provides Merchant Training to educate sub-merchants on expectations, how to resolve disputes and chargebacks.

Compliance Programs

Give’s Compliance Programs includes a Compliance Schedule that will regularly review products, services, and marketing materials for potential UDAAP risks.

Training

The Compliance team will be providing periodic UDAAP employee training. The training will include UDAAP standards and understand how to avoid unfair, deceptive, or abusive practices.

Conclusion

Give’s UDAAP Policy and Procedures include a Complaint Log, Merchant Complaint telephone number, employee training and is part of the Compliance Schedule. Merchant Training provides sub-merchants with expectations.

Exhibit A: Compliance Contact

Chief Compliance Officer: Loraine Stewart         loraine@givecorporation.com 1(800) 913-0163 X5

Compliance Manager: Kateryna Ihnatovych         kateryna@givecorporation.com 1 (800) 913-0163 X5        

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.