COMPLAINTS HANDLING POLICY

Last updated: 13 August 2026

Finance Act Limited, trading as ESCALO («ESCALO», «we», «us», or «our»), is committed to handling complaints fairly, consistently, transparently and in a timely manner.

We recognise that customers, partners, counterparties and other stakeholders may occasionally be dissatisfied with our services, communications, processes or the way a particular matter has been handled.

This Complaints Handling Policy explains how complaints can be submitted to ESCALO, how we assess and investigate complaints, how we communicate with complainants and how we seek to resolve issues appropriately.

This Policy should be read together with our Terms & Conditions / Terms of Use, Privacy Policy, Refund Policy, AML / KYC Policy and any applicable service-specific agreements.

1. Company Information

The company responsible for ESCALO is:

Finance Act Limited
Trading as ESCALO
Company number: 16839569

Registered office:

58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

2. Our Approach to Complaints

ESCALO aims to ensure that complaints are:

• acknowledged promptly;
• handled fairly;
• investigated objectively;
• assessed consistently;
• treated confidentially;
• handled by appropriately authorised personnel;
• resolved wherever reasonably possible;
• used to identify opportunities for improvement.

We do not expect a complainant to use specific legal terminology or follow a particular format when raising a complaint.

A complaint may be submitted in writing or through another appropriate communication channel made available by ESCALO.

3. What Is a Complaint?

For the purposes of this Policy, a complaint generally means an expression of dissatisfaction concerning:

• our services;
• our failure to provide a service;
• a transaction or payment;
• a delay;
• a communication;
• customer support;
• an operational process;
• fees or charges;
• account administration;
• the handling of personal data;
• another aspect of our business relationship.

A complaint may be made whether or not the complainant ultimately turns out to be correct.

Where applicable regulatory rules apply to the relevant service, the regulatory definition of a complaint may also apply.

The FCA defines a complaint, for the relevant DISP framework, broadly as an oral or written expression of dissatisfaction alleging financial loss, material distress or material inconvenience in connection with relevant financial services activities.

4. Who Can Make a Complaint?

A complaint may be made by:

• an existing customer;
• a prospective customer;
• an authorised representative;
• a business customer;
• a partner;
• a counterparty;
• another person directly affected by our services or activities.

Where a person submits a complaint on behalf of another individual or organisation, ESCALO may request evidence that the complainant is authorised to act on that person’s behalf.

5. How to Submit a Complaint

Complaints should preferably be submitted by email to:

support@escalo.uk

You may also write to:

Finance Act Limited
58 Oswald Terrace
Sunderland
England
SR2 9RP

Where appropriate, complaints may also be submitted through another communication channel made available by ESCALO.

6. Information to Include

To help us investigate your complaint efficiently, we recommend providing:

• your full name;
• company name, where applicable;
• contact details;
• customer or account reference, where applicable;
• transaction reference, where applicable;
• relevant dates;
• description of the issue;
• details of the outcome you are seeking;
• supporting documents or correspondence;
• any other information that may assist our investigation.

You do not need to provide every item listed above for a complaint to be considered.

If additional information is necessary, we may contact you.

7. Complaint Acknowledgement

We aim to acknowledge complaints promptly.

Our acknowledgement may confirm:

• that the complaint has been received;
• the date of receipt;
• the person or team responsible for handling it;
• any additional information required;
• the expected next steps;
• applicable response timeframes.

Where a complaint is incomplete or unclear, we may request additional information.

We will not use a request for additional information unnecessarily to delay the handling of a complaint.

8. Complaint Registration

Where appropriate, complaints will be recorded in our internal complaints records.

Records may include:

• date received;
• complainant details;
• nature of the complaint;
• relevant service or transaction;
• responsible team;
• investigation steps;
• evidence considered;
• outcome;
• remedial action;
• communication with the complainant;
• date of closure.

Complaints records will be handled securely and retained in accordance with applicable legal, regulatory and internal requirements.

9. Investigation Process

ESCALO will investigate complaints in a competent, diligent and impartial manner.

Depending on the nature of the complaint, the investigation may include reviewing:

• transaction records;
• account information;
• communications;
• payment records;
• operational logs;
• relevant contractual terms;
• internal procedures;
• compliance records;
• system information;
• information supplied by third parties;
• other relevant evidence.

The scope of the investigation will depend on the circumstances.

Where appropriate, we may request additional information from the complainant or relevant third parties.

FCA complaint-handling rules similarly require applicable firms to investigate complaints competently, diligently and impartially and to assess them fairly, consistently and promptly.

10. Impartiality

Complaints should be handled by individuals who are appropriately positioned to assess the matter objectively.

Where reasonably possible, a complaint should not be investigated solely by an individual who was directly responsible for the decision or action being challenged.

Where a potential conflict of interest exists, ESCALO may allocate the complaint to another appropriate person.

11. Confidentiality

Complaints will be handled confidentially and information will be shared only where reasonably necessary for:

• investigating the complaint;
• resolving the matter;
• protecting ESCALO or another person;
• complying with legal obligations;
• complying with regulatory requirements;
• obtaining professional advice;
• preventing fraud or financial crime.

Complaint information may contain personal data and will be processed in accordance with our Privacy Policy and applicable data protection law.

12. Complaint Investigation and Third Parties

Some complaints may concern services involving third parties, such as:

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

Where a third party is involved, ESCALO may need to obtain relevant information from that third party.

The involvement of a third party may affect the time required to investigate a complaint.

Where appropriate, we will explain the role of the third party to the complainant.

13. Complaints About Transactions

Where a complaint concerns a transaction, we may review:

• transaction instructions;
• execution details;
• transaction timestamps;
• exchange or conversion information;
• payment records;
• settlement information;
• applicable fees;
• relevant communications;
• compliance checks;
• third-party processing records.

Where appropriate, we may also review whether the transaction was processed in accordance with the applicable agreement.

14. Complaints About Payments

Where a complaint concerns a payment, we may investigate:

• payment initiation;
• payment processing;
• payment status;
• beneficiary information;
• settlement;
• rejection or return;
• delays;
• third-party processing;
• relevant compliance checks.

Where mandatory payment-services rules apply to the relevant activity, those rules will take precedence over this general Policy.

15. Complaints About Fees

If a complaint concerns a fee or charge, we may review:

• the applicable agreement;
• pricing information;
• transaction records;
• disclosures provided before the transaction;
• third-party charges;
• applicable conversion costs;
• relevant communications.

Where a fee has been incorrectly charged, ESCALO will consider appropriate corrective action.

16. Complaints About Customer Service

Complaints may concern:

• delays in communication;
• lack of information;
• inappropriate communication;
• failure to respond;
• service quality;
• administrative issues.

We will consider the circumstances and take reasonable steps to address service failures where identified.

17. Complaints About AML / KYC Decisions

Customers may submit complaints concerning:

• onboarding delays;
• verification requirements;
• requests for additional information;
• account restrictions;
• transaction restrictions;
• compliance-related delays.

However, ESCALO may be legally or operationally unable to disclose certain information concerning AML/KYC, sanctions screening, fraud monitoring or suspicious activity investigations.

Nothing in this Policy requires ESCALO to disclose information where doing so would:

• breach applicable law;
• compromise an investigation;
• constitute unlawful tipping off;
• disclose confidential information;
• create a security risk.

18. Complaints About Refunds

If you disagree with a refund decision, you may submit a complaint to:

support@escalo.uk

The complaint will be considered separately from the original refund request where appropriate.

We may review:

• transaction status;
• contractual terms;
• payment records;
• reason for the refund request;
• applicable fees;
• legal requirements;
• previous communications.

The Refund Policy should be read together with this Complaints Handling Policy.

19. Response Time

We aim to resolve complaints as quickly as reasonably possible.

The time required will depend on:

• complexity;
• availability of information;
• involvement of third parties;
• nature of the complaint;
• need for additional investigation;
• applicable legal or regulatory requirements.

Where a specific statutory or regulatory deadline applies, ESCALO will comply with that deadline.

Where applicable FCA DISP rules apply to a particular complaint, the relevant regulatory timeframes will take precedence over the general timeframes described in this Policy.

20. Keeping the Complainant Informed

Where a complaint cannot be resolved promptly, we will seek to keep the complainant reasonably informed of its progress.

Updates may include:

• confirmation that the investigation remains ongoing;
• requests for additional information;
• information concerning expected next steps;
• notification of material developments;
• the expected timing of a response.

We will avoid providing unnecessary internal information that could compromise confidentiality, security or legal obligations.

21. Final Response

Once the investigation is complete, ESCALO will provide a response appropriate to the nature of the complaint.

The response may:

• uphold the complaint;
• partially uphold the complaint;
• reject the complaint;
• offer corrective action;
• offer redress where appropriate;
• explain why no corrective action is appropriate.

Where appropriate, the final response will explain:

• the issue considered;
• the relevant findings;
• the basis for the decision;
• any remedial action;
• any further steps available to the complainant.

Where a regulatory regime imposes specific final-response requirements, those requirements will apply.

For firms subject to FCA DISP, the applicable rules specify the required content and timing of final responses, including information about referral to the Financial Ombudsman Service where applicable.

22. Remedial Action

Where a complaint is upheld, ESCALO may consider appropriate remedial action.

Depending on the circumstances, this may include:

• correcting an error;
• correcting account information;
• returning an incorrectly charged amount;
• reviewing a transaction;
• providing clarification;
• improving a process;
• correcting a communication;
• other appropriate action.

The appropriate remedy will depend on the circumstances and applicable legal and contractual obligations.

23. Compensation and Redress

Where appropriate, ESCALO may consider compensation or other forms of redress.

Any redress will be assessed based on:

• the circumstances;
• applicable contractual terms;
• applicable law;
• actual loss where established;
• regulatory requirements;
• the nature of the error or service failure.

Nothing in this Policy creates an automatic entitlement to compensation.

24. Complaints That Cannot Be Fully Disclosed

There may be circumstances where ESCALO cannot provide a full explanation of a decision.

This may occur where disclosure would:

• breach AML requirements;
• constitute tipping off;
• reveal sanctions-screening controls;
• disclose confidential third-party information;
• compromise fraud prevention;
• interfere with law enforcement;
• breach another legal obligation;
• create a security risk.

In such circumstances, ESCALO will provide as much information as it can lawfully provide.

25. Escalation

If a complainant remains dissatisfied after receiving our response, they may request that the matter be reviewed internally where an internal escalation mechanism is available.

An escalation may involve:

• review by a more senior member of management;
• reassessment of relevant evidence;
• review of the original decision;
• consideration of new information.

The availability of an internal escalation does not affect any statutory or regulatory rights that may apply.

26. Financial Ombudsman Service

Where ESCALO is subject to the jurisdiction of the Financial Ombudsman Service («FOS») for the relevant activity and the complainant is an eligible complainant, the complainant may have the right to refer the complaint to FOS.

The availability of FOS depends on factors including:

• the legal entity providing the service;
• the nature of the activity;
• the complainant’s status;
• applicable FCA rules;
• applicable jurisdiction.

Where FOS applies, ESCALO will provide the information required by the applicable rules, including the relevant referral timeframe and FOS information.

The standard FCA DISP framework currently requires applicable firms, in relevant cases, to inform complainants of their right to refer an eligible complaint to the Financial Ombudsman Service.

27. Financial Ombudsman Service Information

Where applicable, information about the Financial Ombudsman Service is available from:

Financial Ombudsman Service

Website: https://www.financial-ombudsman.org.uk/

We will provide the appropriate FOS information and documentation where required by the regulatory framework applicable to the relevant complaint.

Nothing in this Policy should be interpreted as confirming that every ESCALO customer, service or complaint falls within the jurisdiction of FOS.

28. Complaints Outside Regulatory Jurisdiction

Not every complaint submitted to ESCALO will necessarily fall within a regulated complaints framework.

For example, complaints concerning:

• general website content;
• non-regulated commercial services;
• general business communications;
• matters outside the scope of a regulated activity;

may be handled under ESCALO’s internal complaints process rather than a specific regulatory complaints regime.

Where applicable, we will explain the relevant process.

29. Complaints From Businesses

Business customers and corporate counterparties may submit complaints through the same general process.

However, certain regulatory protections, including eligibility for external dispute resolution, may depend on the customer’s legal status and the nature of the service.

The applicable contractual agreement may also contain specific dispute-resolution procedures.

30. Complaints From Representatives

If a representative submits a complaint on behalf of another person or organisation, ESCALO may require evidence of authority.

This may include:

• written authorisation;
• power of attorney;
• corporate authority;
• confirmation from the account holder.

We may communicate directly with the underlying customer where appropriate.

31. Anonymous Complaints

ESCALO may accept anonymous complaints where sufficient information is provided to investigate the matter.

However, anonymous complaints may be more difficult to investigate or resolve.

Where possible, complainants are encouraged to provide appropriate contact information.

32. Malicious or Abusive Complaints

ESCALO will consider complaints fairly even where they are difficult or strongly worded.

However, we may take proportionate measures where communications involve:

• threats;
• harassment;
• abusive conduct;
• deliberately false information;
• repeated unreasonable demands;
• attempts to interfere with an investigation.

Such measures will not prevent a person from exercising a legitimate legal or regulatory right to complain.

33. Repeated Complaints

If a complaint has already been investigated and no materially new information is provided, ESCALO may refer to the previous response rather than repeating the same investigation indefinitely.

Where appropriate, we may explain why no further review is being undertaken.

This will not prevent consideration of genuinely new information or a complaint arising from a new event.

34. Data Protection

Personal data provided in connection with a complaint will be processed in accordance with applicable data protection law.

Information may be used to:

• investigate the complaint;
• communicate with the complainant;
• verify identity;
• review transactions;
• prevent fraud;
• comply with legal obligations;
• comply with regulatory requirements;
• maintain complaint records;
• improve our services.

Further information is available in our Privacy Policy.

35. Complaint Records

ESCALO will maintain appropriate records of complaints and their outcomes.

Records may include:

• complaint date;
• complainant;
• subject matter;
• relevant service;
• investigation;
• evidence;
• decision;
• remedy;
• correspondence;
• closure date.

Where applicable regulatory requirements apply, ESCALO will retain complaint records for the required period.

The FCA’s DISP framework contains specific complaint record and reporting requirements for firms within its scope.

36. Management Oversight

Senior management will maintain appropriate oversight of the complaints process.

This may include reviewing:

• complaint volumes;
• complaint categories;
• recurring issues;
• response times;
• root causes;
• remedial actions;
• customer impact;
• operational weaknesses.

Complaints may be used as a source of information for improving products, services, processes and controls.

37. Root Cause Analysis

Where appropriate, ESCALO may perform root cause analysis to identify why a complaint occurred.

This may involve reviewing:

• internal processes;
• technology;
• communications;
• staff actions;
• third-party dependencies;
• documentation;
• training;
• system controls.

Where a recurring or systemic issue is identified, ESCALO may implement corrective or preventative measures.

38. Staff Responsibilities

Relevant employees and personnel are expected to:

• treat complaints seriously;
• remain professional;
• avoid defensive or misleading communication;
• escalate complaints appropriately;
• preserve relevant records;
• cooperate with investigations;
• protect confidential information;
• comply with applicable legal and internal requirements.

Employees should not attempt to resolve matters outside their authority where doing so could create legal, financial or regulatory risk.

39. Conflicts of Interest

ESCALO seeks to identify and manage conflicts of interest that could affect the fair handling of a complaint.

Where appropriate, an alternative reviewer may be appointed.

A person should not ordinarily be solely responsible for determining the outcome of a complaint where they have a material personal interest in the matter.

40. Third-Party Complaints

Where a complaint concerns a third party, ESCALO may:

• investigate matters within its control;
• contact the relevant third party;
• provide information about the third party’s complaints process;
• explain which organisation is responsible for the relevant activity.

ESCALO cannot determine or control the outcome of a complaint that falls solely within another organisation’s responsibility.

41. Regulatory Reporting

Where ESCALO is subject to applicable regulatory complaints reporting requirements, it will maintain appropriate processes for reporting complaints to the relevant regulator.

For firms within the FCA DISP reporting framework, complaints reporting requirements may apply periodically.

42. Accessibility

ESCALO seeks to make its complaints process accessible.

If you require reasonable assistance in making a complaint because of a disability, communication difficulty or another relevant circumstance, please contact:

support@escalo.uk

We will consider reasonable ways of assisting you.

43. Language

Complaints may generally be submitted in English.

Where appropriate and reasonably possible, ESCALO may consider communications in another language.

Where a regulatory or contractual requirement applies to the language of communications, the applicable requirement will take precedence.

44. No Retaliation

ESCALO will not penalise or disadvantage a customer merely because they have made a genuine complaint.

Making a complaint will not, by itself, affect a person’s ability to exercise legitimate contractual or legal rights.

This does not prevent ESCALO from taking lawful action where there are independent reasons to do so, including fraud, financial crime, security or contractual breaches.

45. Changes to This Policy

ESCALO may update this Complaints Handling Policy from time to time.

Updates may be made to reflect:

• changes in our services;
• changes in applicable law;
• regulatory developments;
• changes to dispute-resolution arrangements;
• improvements to our complaints process;
• operational changes.

The «Last updated» date at the beginning of this Policy indicates when it was most recently revised.

46. Contact Us

Complaints and questions concerning this Policy should be directed to:

Finance Act Limited trading as ESCALO

Company number: 16839569

Registered office:
58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

47. Important Regulatory Notice

This Policy describes ESCALO’s general approach to handling complaints.

It does not by itself establish that Finance Act Limited is authorised or regulated by the Financial Conduct Authority for any particular activity, nor does it establish that a particular customer or complaint is eligible for referral to the Financial Ombudsman Service.

Where a particular service is subject to a regulatory complaints regime, the applicable statutory and regulatory requirements will take precedence over this general Policy.

Where no specific regulatory complaints regime applies, complaints will be handled in accordance with this Policy, the applicable contractual terms and applicable law.

48. Final Statement

ESCALO considers complaints an important part of maintaining high standards of service, operational control and customer relationships.

We aim to:

Listen carefully.
Investigate fairly.
Communicate clearly.
Resolve appropriately.
Learn from recurring issues.

Our objective is not simply to close complaints, but to identify genuine problems and improve the processes and services that caused them.

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

support@escalo.uk

Last updated: 13 August 2026