PAYMENT SERVICES POLICY

Last updated: 13 August 2026

Finance Act Limited, trading as ESCALO («ESCALO», «we», «us», or «our»), operates within an international financial and payment environment involving payment processing, currency exchange, settlement, payment infrastructure and relationships with financial institutions and other service providers.

This Payment Services Policy describes the general principles and procedures applicable to payment-related activities carried out through or in connection with ESCALO.

The scope of any particular payment service depends on the relevant contractual arrangement, service structure, jurisdiction and applicable law.

Nothing in this Policy should be interpreted as confirming that Finance Act Limited is authorised or regulated to provide a particular regulated payment service unless such status is expressly stated in the applicable regulatory documentation.

1. Company Information

Finance Act Limited
Trading as ESCALO
Company number: 16839569

Registered office:

58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

2. Purpose of This Policy

The purpose of this Policy is to explain the general framework used by ESCALO in relation to payment-related activities.

This includes principles concerning:

• payment initiation and processing;
• receipt and transmission of funds;
• currency conversion;
• settlement;
• payment routing;
• transaction verification;
• customer identification;
• payment monitoring;
• fraud prevention;
• sanctions screening;
• transaction reconciliation;
• third-party payment providers;
• operational security;
• transaction records;
• handling of payment-related issues.

The specific procedures applicable to a transaction may depend on the service being used and the relevant contractual arrangements.

3. Scope of Payment Activities

Depending on the applicable service structure, ESCALO’s payment-related activities may involve:

• domestic payments;
• international payments;
• currency conversion;
• payment routing;
• settlement between counterparties;
• transfers through third-party financial institutions;
• P2P payment environments;
• payment accounts or infrastructure provided by third parties;
• reconciliation of incoming and outgoing transactions.

The availability of a particular payment route may vary by jurisdiction, currency, counterparty and provider.

4. Payment Service Providers

ESCALO may work with third-party financial institutions and payment infrastructure providers.

These may include:

• banks;
• payment institutions;
• electronic money institutions;
• payment processors;
• financial technology providers;
• exchanges;
• settlement providers;
• liquidity providers;
• other financial infrastructure providers.

Third-party providers may perform certain payment, settlement, verification or compliance functions.

Their own terms, policies, regulatory obligations and operational requirements may apply to the relevant part of a transaction.

5. Payment Instructions

Payment instructions must be accurate, complete and authorised.

Depending on the service, payment instructions may include:

• sender information;
• recipient information;
• account details;
• payment amount;
• currency;
• reference information;
• transaction purpose;
• other information required for processing.

ESCALO may reject or delay an instruction where required information is incomplete, inconsistent or cannot be verified.

6. Verification of Payment Instructions

ESCALO may apply verification procedures before processing certain payment instructions.

These procedures may include:

• identity verification;
• account verification;
• beneficiary verification;
• transaction confirmation;
• authentication;
• fraud screening;
• sanctions screening;
• AML/KYC checks;
• verification of authorised representatives.

Additional verification may be required where a transaction presents an elevated risk.

7. Authorisation

Payment transactions must be appropriately authorised by the relevant customer or authorised representative.

ESCALO may use authentication and verification mechanisms appropriate to the nature of the service.

Where a transaction appears inconsistent with previous activity or presents a security concern, ESCALO may require additional confirmation before proceeding.

8. Strong Customer Authentication

Where applicable to a particular regulated payment service, ESCALO or the relevant payment service provider may apply Strong Customer Authentication («SCA») or another legally required authentication mechanism.

SCA may involve two or more independent elements relating to:

• knowledge;
• possession;
• inherence.

The precise authentication process depends on the relevant payment provider, service and transaction.

Where applicable, exemptions may be available under the relevant regulatory framework.

9. Payment Processing

Once a valid payment instruction has been received and all required checks have been completed, the transaction may be submitted for processing.

Processing may involve multiple parties and systems.

The time required may depend on:

• payment method;
• currency;
• jurisdiction;
• receiving institution;
• intermediary institutions;
• compliance screening;
• fraud checks;
• transaction volume;
• weekends and public holidays;
• technical availability.

ESCALO cannot guarantee that every payment will be completed within a particular timeframe unless a specific timeframe has been contractually agreed.

10. International Payments

International payments may pass through multiple financial institutions or payment networks.

This may result in:

• additional processing time;
• intermediary charges;
• additional verification;
• additional compliance checks;
• currency conversion;
• payment restrictions;
• changes in the availability of a payment route.

The laws and regulations of more than one jurisdiction may apply to an international payment.

11. Currency Conversion

Where payment processing involves currency conversion, the applicable exchange rate may depend on:

• market conditions;
• liquidity;
• the selected payment route;
• the relevant provider;
• transaction timing;
• applicable fees.

Exchange rates may change between the time a payment instruction is submitted and the time conversion is completed.

Where a specific exchange rate has been contractually agreed, the relevant agreement will govern.

12. Fees and Charges

Payment transactions may involve fees charged by ESCALO or third-party providers.

Potential charges may include:

• payment processing fees;
• currency conversion fees;
• intermediary bank charges;
• receiving bank charges;
• network fees;
• settlement charges;
• other transaction-related costs.

Where applicable, fees will be disclosed through the relevant pricing or contractual documentation.

Third-party charges may be outside ESCALO’s direct control.

13. Intermediary Banks and Financial Institutions

International payments may be processed through intermediary financial institutions.

An intermediary institution may:

• apply a fee;
• delay a payment;
• request additional information;
• reject a payment;
• return a payment;
• apply its own compliance procedures.

ESCALO cannot guarantee the decisions or processing times of independent financial institutions.

14. Payment Delays

A payment may be delayed for operational, technical, compliance or regulatory reasons.

Possible causes include:

• sanctions screening;
• AML/KYC review;
• fraud investigation;
• incorrect payment information;
• banking restrictions;
• insufficient information;
• intermediary processing;
• technical disruption;
• payment network issues;
• regulatory requirements.

Where a payment is delayed, ESCALO may request additional information before processing can continue.

15. Rejected or Returned Payments

A payment may be rejected or returned by ESCALO or a third-party provider.

Reasons may include:

• incorrect beneficiary information;
• insufficient information;
• compliance restrictions;
• sanctions concerns;
• fraud indicators;
• technical failure;
• payment-provider restrictions;
• regulatory requirements;
• unavailable payment routes.

Where funds are returned, the applicable refund or return process will depend on the circumstances of the transaction.

16. Payment Reversals

Certain transactions may be capable of being reversed, recalled or returned.

The possibility of reversal depends on:

• payment method;
• transaction status;
• applicable banking rules;
• provider capabilities;
• contractual terms;
• applicable law.

Once a payment has been fully settled, reversal may not always be possible.

Customers should therefore review payment instructions carefully before authorisation.

17. Unauthorised Transactions

If you believe that a payment was made without your authorisation, you should contact ESCALO immediately:

support@escalo.uk

We may request information necessary to investigate the transaction.

Where applicable payment-services legislation provides statutory rights concerning unauthorised payments, those rights will apply.

This Policy does not limit mandatory statutory protections.

18. Incorrectly Executed Payments

Where a payment is believed to have been executed incorrectly, ESCALO may investigate:

• payment instructions;
• transaction records;
• beneficiary details;
• processing timestamps;
• payment provider records;
• settlement information;
• relevant communications.

Where applicable law imposes specific obligations concerning incorrectly executed payments, those obligations will apply.

19. AML and KYC Controls

Payment activity may be subject to ESCALO’s AML/KYC framework.

Depending on the transaction and risk profile, ESCALO may request:

• identification information;
• beneficial ownership information;
• source-of-funds information;
• source-of-wealth information;
• information concerning the purpose of a transaction;
• information about counterparties;
• additional supporting documents.

A payment may be delayed or rejected where required information cannot be obtained or verified.

Our AML/KYC Policy provides additional information about these controls.

20. Sanctions Screening

Payment transactions may be screened for sanctions risks.

Screening may include relevant:

• customers;
• beneficiaries;
• counterparties;
• jurisdictions;
• financial institutions;
• payment routes.

A potential sanctions match may result in additional review.

Where applicable law requires a transaction to be blocked, rejected or otherwise restricted, ESCALO will take the appropriate action.

21. Fraud Prevention

ESCALO maintains controls designed to reduce the risk of payment fraud.

These may include:

• identity verification;
• transaction monitoring;
• behavioural analysis;
• payment verification;
• anomaly detection;
• account controls;
• fraud screening;
• manual investigation.

No fraud-prevention system can eliminate financial crime risk completely.

22. Transaction Monitoring

ESCALO may monitor payment activity for unusual or potentially suspicious behaviour.

Monitoring may consider:

• transaction value;
• transaction frequency;
• transaction patterns;
• counterparties;
• jurisdictions;
• payment routes;
• changes in customer behaviour;
• unusual transaction characteristics.

Monitoring may be automated, manual or a combination of both.

An alert does not necessarily indicate that unlawful activity has occurred.

23. Transaction Limits

Certain payment routes may be subject to limits.

Limits may be imposed by:

• ESCALO;
• banks;
• payment institutions;
• electronic money institutions;
• exchanges;
• payment networks;
• applicable law.

Limits may relate to:

• individual transactions;
• daily activity;
• monthly activity;
• currencies;
• jurisdictions;
• counterparties.

Limits may change without prior notice where required for security, compliance, operational or regulatory reasons.

24. Payment Account Information

Where applicable to a particular service, information concerning payment activity may include:

• transaction date;
• transaction amount;
• currency;
• payer;
• beneficiary;
• payment reference;
• transaction status;
• fees;
• settlement information.

Customers should review transaction information and notify ESCALO promptly if they identify an apparent error.

25. Payment Reconciliation

ESCALO may maintain reconciliation procedures designed to identify discrepancies between:

• customer records;
• transaction records;
• payment provider records;
• bank records;
• settlement records.

Reconciliation may be performed periodically or through automated systems, depending on the relevant service.

Identified discrepancies may be investigated and corrected where appropriate.

26. Safeguarding of Funds

Where ESCALO or a relevant service provider is legally required to safeguard customer funds, applicable safeguarding requirements will apply.

UK payment and e-money institutions subject to safeguarding requirements must protect relevant customer funds in accordance with the applicable regulatory framework. The FCA’s current 2026 framework includes updated safeguarding rules under CASS for firms within scope.

However, this Policy does not represent that all funds handled in connection with ESCALO are safeguarded funds.

The treatment of funds depends on:

• the service;
• the legal entity holding the funds;
• the relevant payment provider;
• the contractual structure;
• applicable law.

Customers should refer to the applicable service documentation for information about how their funds are held.

27. No Automatic Deposit Protection

Customers should not assume that funds associated with an ESCALO service are equivalent to deposits held with a bank.

The availability of any statutory compensation or protection depends on the nature of the service and the legal entity providing it.

Unless expressly stated in the applicable documentation, ESCALO does not represent that funds are protected by the Financial Services Compensation Scheme or another compensation arrangement.

28. Third-Party Payment Infrastructure

ESCALO may depend on third-party infrastructure to process payments.

Third-party failures may result in:

• delays;
• failed transactions;
• temporary unavailability;
• incorrect status information;
• additional processing;
• increased costs.

ESCALO will take reasonable operational measures to manage these dependencies but cannot guarantee uninterrupted third-party availability.

29. Payment Security

ESCALO seeks to maintain appropriate security measures for payment-related systems.

These may include:

• access controls;
• authentication;
• transaction monitoring;
• encryption where appropriate;
• system logging;
• security monitoring;
• fraud controls;
• incident management;
• operational controls.

Security measures may be updated as threats and technology evolve.

30. Customer Security Responsibilities

Customers are responsible for protecting their own:

• login credentials;
• passwords;
• authentication information;
• devices;
• authorised payment instructions.

Customers should promptly notify ESCALO if they suspect:

• unauthorised access;
• compromised credentials;
• fraudulent activity;
• suspicious payment instructions;
• account takeover.

31. Operational Resilience

Payment processing may be affected by operational incidents.

Potential incidents include:

• system outages;
• connectivity failures;
• cyber incidents;
• software errors;
• telecommunications failures;
• power disruptions;
• third-party failures;
• human error.

ESCALO maintains operational processes intended to support continuity and recovery.

However, uninterrupted payment availability cannot be guaranteed in every circumstance.

32. Payment Data

Payment transactions may require the processing of personal and financial information.

Such information may include:

• names;
• account details;
• transaction information;
• payment references;
• identification information;
• beneficiary information;
• compliance information.

ESCALO processes personal data in accordance with applicable data protection law and its Privacy Policy.

33. International Data Transfers

Payment processing may involve service providers located outside the United Kingdom.

Where personal data is transferred internationally, ESCALO will apply appropriate safeguards where required by applicable data protection law.

Further information is provided in the Privacy Policy.

34. Payment Records

ESCALO may retain records concerning payment activity for purposes including:

• transaction management;
• reconciliation;
• customer support;
• fraud prevention;
• AML/KYC compliance;
• regulatory compliance;
• dispute resolution;
• accounting;
• legal obligations.

Records will be retained in accordance with applicable legal and internal retention requirements.

35. Payment Instructions and Customer Responsibility

Customers are responsible for providing accurate payment information.

Before confirming a payment, customers should verify:

• beneficiary details;
• amount;
• currency;
• payment purpose;
• reference information.

Where a payment is sent using incorrect information supplied by the customer, recovery may not always be possible.

36. Payment Availability

The availability of a payment service may depend on:

• jurisdiction;
• currency;
• customer eligibility;
• payment provider availability;
• transaction size;
• compliance requirements;
• regulatory restrictions;
• operational conditions.

ESCALO may restrict certain payment routes where necessary.

37. Restricted Payment Routes

ESCALO may restrict or discontinue a payment route where:

• the provider terminates the service;
• the route presents unacceptable risk;
• sanctions requirements change;
• regulatory requirements change;
• fraud levels become unacceptable;
• technical infrastructure becomes unavailable;
• the route no longer meets operational requirements.

Where appropriate, alternative payment routes may be considered.

38. Payment Service Discontinuation

ESCALO may discontinue a particular payment route or service where necessary.

Reasons may include:

• regulatory changes;
• provider changes;
• operational requirements;
• risk management;
• commercial considerations;
• changes in market infrastructure.

Where required by law or contract, customers will be given appropriate notice.

39. Payment Errors

If an error is identified, ESCALO may investigate and take appropriate corrective action.

This may include:

• correcting transaction records;
• correcting payment information;
• returning funds;
• requesting additional information;
• contacting a payment provider;
• initiating a recovery process.

The outcome will depend on the nature of the error and the applicable legal and contractual framework.

40. Payment Disputes

Payment-related disputes may be handled through ESCALO’s Complaints Handling Policy.

Customers should first contact:

support@escalo.uk

Where a particular regulated payment service is involved, additional statutory or regulatory dispute-resolution rights may apply.

41. Refunds and Payment Returns

Where a payment is eligible for a refund or return, the relevant process will be governed by the Refund Policy and applicable contractual terms.

A completed payment is not automatically reversible simply because the customer later changes their mind.

Where statutory refund rights apply, those rights will take precedence.

42. Fees and Currency Differences on Returns

Where a payment is returned following currency conversion, the amount received may differ from the original amount due to:

• exchange-rate movements;
• conversion fees;
• intermediary charges;
• payment provider fees.

The applicable contractual terms will determine how such amounts are handled.

43. Payment Processing and Compliance Holds

ESCALO may temporarily restrict or hold payment activity where additional checks are required.

This may occur due to:

• AML/KYC review;
• sanctions screening;
• fraud investigation;
• regulatory requirements;
• incomplete information;
• suspicious transaction indicators.

A compliance-related restriction does not necessarily mean that wrongdoing has occurred.

44. Counterparty Risk

Payment transactions may involve counterparties whose ability to complete a transaction may change.

A counterparty may:

• fail to settle;
• reject a transaction;
• become unavailable;
• experience financial difficulties;
• become subject to regulatory restrictions;
• change its operating conditions.

Such events may affect payment completion.

45. Regulatory Compliance

Where a payment service falls within a regulated payment-services framework, ESCALO or the relevant provider will comply with the requirements applicable to that service.

The UK payment-services framework includes the Payment Services Regulations 2017, which cover activities such as execution of payment transactions, money remittance, payment account services and certain other payment services.

The FCA’s May 2026 Payment Services and Electronic Money Approach Document covers areas including conduct of business, safeguarding, complaints, operational and security risks and financial crime.

46. Regulatory Status

This Policy does not itself constitute a statement that Finance Act Limited is:

• an authorised payment institution;
• a small payment institution;
• an electronic money institution;
• a registered account information service provider;
• an authorised payment initiation service provider;
• or otherwise authorised by the FCA for a particular regulated activity.

Any regulatory status will be stated separately where applicable.

Customers should not infer regulatory authorisation solely from the existence of this Policy.

47. Payment Services Provided by Third Parties

Where the actual regulated payment service is provided by a third-party institution, that institution may be responsible for the regulated payment activity.

Its:

• regulatory status;
• terms;
• safeguarding arrangements;
• complaints procedure;
• payment execution obligations;
• customer protections

may therefore apply to the relevant part of the transaction.

ESCALO will provide appropriate information where necessary to clarify the role of a third-party provider.

48. Consumer Protection

Where ESCALO provides services to consumers, applicable consumer protection requirements will apply.

Nothing in this Policy is intended to:

• exclude mandatory consumer rights;
• restrict statutory protections;
• exclude liability that cannot legally be excluded;
• prevent access to a mandatory dispute-resolution mechanism.

49. Payment Services Risk

Payment services involve operational, financial and regulatory risks.

These may include:

• payment delays;
• rejected transactions;
• currency fluctuations;
• counterparty failure;
• fraud;
• cyber incidents;
• compliance restrictions;
• third-party failures;
• incorrect payment information;
• regulatory changes.

Additional information is provided in ESCALO’s Risk Disclosure.

50. Changes to Payment Services

ESCALO may change payment routes, providers, procedures or available currencies from time to time.

Changes may be required because of:

• regulatory developments;
• provider decisions;
• market conditions;
• security requirements;
• operational considerations;
• changes in customer demand.

Where a change materially affects an existing contractual relationship, ESCALO will provide any notice required by the applicable agreement or law.

51. Complaints

Payment-related complaints may be submitted to:

support@escalo.uk

Complaints will be handled in accordance with ESCALO’s Complaints Handling Policy.

Where a regulated payment service is involved, any applicable statutory or regulatory complaint-handling requirements will take precedence.

52. Contact Us

For questions concerning payment services:

Finance Act Limited trading as ESCALO

Company number: 16839569

Registered office:
58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

53. Relationship With Other Policies

This Payment Services Policy should be read together with:

• Terms & Conditions / Terms of Use;
• Privacy Policy;
• Cookie Policy;
• AML / KYC Policy;
• Risk Disclosure;
• Refund Policy;
• Complaints Handling Policy;
• applicable service agreements;
• applicable regulatory disclosures.

Where a specific agreement or mandatory legal requirement contains more specific provisions, those provisions will apply to the relevant service.

54. Updates to This Policy

ESCALO may update this Policy periodically.

Updates may reflect:

• changes to payment services;
• changes in payment providers;
• changes in applicable law;
• regulatory developments;
• changes in technology;
• changes in operational procedures;
• improvements to security and risk management.

The «Last updated» date indicates when this Policy was most recently revised.

55. Final Statement

ESCALO aims to maintain payment processes that are secure, transparent, operationally resilient and appropriately controlled.

Payment activity may involve multiple financial institutions, payment providers, counterparties, currencies and jurisdictions. As a result, the availability, timing and outcome of a payment may depend on factors outside ESCALO’s direct control.

ESCALO applies appropriate operational, compliance and security controls to manage these risks, but no payment system can guarantee uninterrupted processing or eliminate all financial, operational or regulatory risks.

Finance Act Limited trading as ESCALO
Company number: 16839569
58 Oswald Terrace, Sunderland, England, SR2 9RP

support@escalo.uk

Last updated: 13 August 2026