REFUND POLICY

Last updated: 13 August 2026

This Refund Policy explains how Finance Act Limited, trading as ESCALO («ESCALO», «we», «us», or «our»), handles refunds, reversals, failed transactions and other requests relating to the return of funds.

This Policy applies to the extent that a refund is available for the relevant service.

Specific services may be subject to separate contractual terms, transaction terms or applicable legal and regulatory requirements. Where those terms provide specific refund rights or procedures, they will apply to the relevant service.

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. General Refund Principles

ESCALO aims to handle refund requests fairly, transparently and in accordance with applicable law and the contractual terms governing the relevant service.

Whether a refund is available depends on:

• the nature of the transaction;
• whether the transaction has already been executed;
• whether funds have been settled;
• the applicable service agreement;
• the reason for the refund request;
• applicable fees and third-party costs;
• applicable legal and regulatory requirements.

A request for a refund does not automatically mean that a refund is available.

Where a refund is legally required, ESCALO will process it in accordance with the applicable legal requirements.

3. Transactions That Have Not Been Executed

Where a transaction has not yet been executed or settled, ESCALO may, where operationally possible, attempt to cancel or return the relevant funds.

The ability to cancel a transaction may depend on:

• whether processing has already begun;
• whether funds have been transferred to a third party;
• whether the transaction has been executed;
• whether the relevant payment route remains available;
• whether compliance checks are in progress;
• whether the transaction can technically be reversed.

A cancellation request should be submitted as soon as possible.

Once a transaction has been executed or settled, cancellation may no longer be possible.

4. Completed Transactions

Once a transaction has been completed and funds have been delivered, converted, settled or otherwise processed, it may not be possible to reverse the transaction simply because a customer has changed their mind.

This is particularly relevant to transactions involving:

• currency exchange;
• P2P transactions;
• market execution;
• third-party payment providers;
• external counterparties;
• completed settlements.

The availability of a refund or reversal will depend on the specific circumstances and applicable contractual and legal requirements.

5. Unauthorised Transactions

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

support@escalo.uk

You should provide sufficient information to allow us to identify and investigate the transaction.

Where applicable law requires a payment service provider to refund an unauthorised transaction, the relevant statutory rights will apply.

For regulated payment services, UK rules may provide specific protections concerning unauthorised payment transactions and the circumstances in which a refund must be made.

This Policy does not limit any mandatory statutory rights.

6. Incorrect or Defective Transactions

If you believe that a transaction was:

• processed incorrectly;
• processed for the wrong amount;
• sent to incorrect beneficiary details due to an error;
• duplicated;
• otherwise incorrectly executed,

you should notify ESCALO as soon as reasonably possible.

We may investigate the transaction and determine whether a correction, reversal or refund is appropriate.

Where applicable law imposes obligations on a payment service provider in relation to defective or non-executed payment transactions, those obligations will apply.

7. Failed Transactions

A transaction may fail because of:

• insufficient liquidity;
• technical issues;
• incorrect payment information;
• third-party provider restrictions;
• compliance checks;
• sanctions screening;
• fraud controls;
• banking restrictions;
• payment network failures;
• counterparty failure;
• other circumstances affecting execution.

Where funds have been received by ESCALO but the transaction cannot be completed, we will determine the appropriate next step based on the circumstances.

This may include:

• returning the relevant funds;
• attempting an alternative settlement route;
• holding the funds temporarily while required checks are completed;
• applying applicable fees or third-party charges where permitted;
• taking another appropriate action under the relevant agreement.

8. Compliance and AML/KYC Restrictions

Funds may sometimes be delayed, restricted or returned because additional compliance checks are required.

This may occur where:

• customer information requires verification;
• beneficial ownership information is incomplete;
• source-of-funds information is required;
• a sanctions screening alert is generated;
• fraud concerns arise;
• transaction activity appears inconsistent with the customer’s profile;
• applicable law requires additional review.

In such circumstances, ESCALO may be unable to complete or return a transaction immediately.

Where disclosure is restricted by law, ESCALO may not be able to provide detailed information concerning the reason for a compliance-related decision.

9. Refunds Following Cancellation

Where a transaction or service is validly cancelled before completion and a refund is available, ESCALO will generally return the eligible amount using the original or an appropriate payment route.

The amount returned may be affected by:

• transaction status;
• third-party charges;
• fees already incurred;
• currency conversion;
• applicable contractual terms;
• applicable law.

ESCALO will not impose a cancellation or refund charge that is prohibited by applicable law.

Any applicable charge must be reasonable and proportionate to the circumstances.

UK consumer guidance states that businesses should not rely on excessive cancellation charges or automatically retain advance payments where this would be unfair.

10. Third-Party Fees

A transaction may involve third-party fees charged by:

• banks;
• payment providers;
• exchanges;
• electronic money institutions;
• intermediary financial institutions;
• other service providers.

Where a transaction is cancelled or returned, third-party charges may not always be recoverable.

Where permitted by the applicable agreement and law, amounts already incurred in connection with processing may be deducted from the amount returned.

We will seek to provide appropriate information concerning applicable charges where required.

11. Currency Conversion and Refund Amounts

Where a transaction involves currency conversion, the amount returned may differ from the original amount due to exchange-rate movements.

For example, if funds were converted before a transaction was cancelled or reversed, returning the funds to the original currency may require a new conversion.

The applicable exchange rate at the time of the refund may therefore differ from the rate applicable to the original transaction.

Where the applicable service agreement specifies how currency conversion is handled during a refund, that agreement will apply.

12. Refund Processing Time

Refunds will be processed within a reasonable period after ESCALO determines that a refund is due and the relevant processing information is available.

The actual time required may depend on:

• the payment method;
• banking systems;
• third-party providers;
• currency;
• compliance checks;
• transaction status;
• weekends and public holidays;
• international payment routes.

ESCALO does not control the processing time of independent banks or third-party payment providers.

Where a specific statutory timeframe applies, that timeframe will take precedence.

13. How to Request a Refund

Refund requests should be submitted to:

support@escalo.uk

Please include:

• your full name;
• company name, where applicable;
• transaction or reference number;
• date of the transaction;
• amount and currency;
• reason for the refund request;
• relevant supporting information.

We may request additional information to verify the request and protect against fraudulent refund claims.

14. Verification of Refund Requests

ESCALO may verify the identity and authority of the person requesting a refund.

This may include confirming:

• account ownership;
• transaction details;
• authorised representative status;
• payment information;
• identity documentation where appropriate.

We will not normally process a refund to an unrelated third party unless permitted by the applicable service terms and appropriate verification has been completed.

This is intended to reduce the risk of fraudulent refund requests.

15. Refunds to Third Parties

Where possible and legally appropriate, refunds will be made through the original payment route or to the account from which the funds originated.

ESCALO may refuse to send a refund to an unrelated third party where doing so would create:

• fraud risk;
• AML risk;
• sanctions risk;
• regulatory risk;
• uncertainty concerning ownership of the funds.

Alternative refund arrangements may be considered where legally and operationally appropriate.

16. Duplicate Payments

If you believe that you have made a duplicate payment, please contact:

support@escalo.uk

We will review the relevant transaction records.

Where a genuine duplicate payment has been identified and no other legal or contractual restriction applies, the excess amount may be returned.

17. Overpayments

If an amount has been paid to ESCALO in excess of the amount properly due, we may investigate the payment and determine the appropriate method of returning the excess.

Where an overpayment has resulted from an error, ESCALO may take reasonable steps to correct the position.

18. Fraudulent Refund Claims

ESCALO may investigate refund requests where there are reasonable grounds to believe that:

• a transaction was authorised;
• the refund request contains false information;
• supporting documents have been manipulated;
• the requester is not authorised;
• the transaction has already been refunded;
• the claim is otherwise fraudulent.

Where fraud is suspected, ESCALO may suspend the refund investigation, restrict the relevant account or take other appropriate action.

Deliberately submitting a false refund claim may constitute fraud and may be reported to the appropriate authorities where required or permitted by law.

19. Refunds and Financial Crime Controls

A refund will not automatically be processed where doing so would conflict with:

• AML requirements;
• sanctions requirements;
• fraud prevention controls;
• court orders;
• law enforcement requests;
• regulatory requirements;
• other applicable legal obligations.

In such circumstances, ESCALO may delay or restrict the refund while determining the appropriate lawful course of action.

20. Refunds and Contractual Terms

Where you have entered into a separate agreement with ESCALO, that agreement may contain specific provisions concerning:

• cancellation;
• refunds;
• transaction reversals;
• fees;
• settlement;
• liability;
• termination.

Those provisions will apply to the relevant service.

If there is a conflict between this Refund Policy and a specific contractual agreement, the specific agreement will govern to the extent permitted by law.

21. Consumer Rights

Where ESCALO provides services to consumers, mandatory consumer protection laws may apply.

Nothing in this Policy is intended to exclude or restrict any statutory right that cannot lawfully be excluded or restricted.

Depending on the nature of the service and how the contract is formed, consumers may have specific rights concerning cancellation, refunds, defective services or other matters.

The existence and scope of those rights may depend on the particular service and applicable legislation.

22. Payment Services

Where ESCALO or a relevant service provider provides a regulated payment service, additional statutory rights may apply to:

• unauthorised transactions;
• incorrectly executed transactions;
• non-executed transactions;
• transaction information;
• refunds;
• complaints.

These rights will apply where relevant and will not be excluded by this Policy.

For example, the FCA states that payment service providers generally have obligations concerning unauthorised payments and certain incorrectly executed or non-executed transactions.

23. No Automatic Refund for Market Losses

A change in market conditions does not automatically create a right to a refund.

In particular, a refund will not normally be available solely because:

• an exchange rate changed;
• a market price moved;
• a spread decreased;
• a transaction became less profitable;
• an expected opportunity disappeared;
• market liquidity changed.

Where a transaction has been properly executed in accordance with the applicable agreement, subsequent market movements do not by themselves constitute grounds for reversal.

24. Transaction Execution and Market Conditions

Where a transaction has been executed based on the applicable instructions and agreed terms, the fact that market conditions subsequently changed will not necessarily create a right to cancellation or refund.

This is particularly relevant to:

• currency exchange;
• P2P transactions;
• market execution;
• liquidity-based transactions.

The relevant service agreement may contain additional provisions concerning execution and settlement.

25. Refunds and Fees

Where a refund is approved, ESCALO will determine which amounts are eligible for return under the applicable agreement and law.

Fees that have already been properly incurred may not always be refundable.

However, ESCALO will not retain or deduct amounts where doing so would conflict with applicable law or contractual obligations.

26. Refused Refund Requests

Where ESCALO determines that a refund is not available, we will, where appropriate and legally permitted, explain the basis for the decision.

A refund may be refused where:

• the transaction was validly completed;
• the request is outside the applicable contractual or statutory framework;
• the transaction was properly authorised;
• the request is fraudulent;
• the funds cannot lawfully be returned;
• applicable compliance restrictions prevent the return;
• the requested refund would create an unlawful or inappropriate outcome.

Nothing in this section limits mandatory statutory rights.

27. Complaints About Refund Decisions

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

support@escalo.uk

Please provide:

• your name;
• transaction reference;
• relevant dates;
• details of the refund request;
• reasons for your disagreement;
• any supporting documents.

We will review the complaint in accordance with our applicable complaints procedure.

Where a regulated service is involved, additional regulatory complaint procedures may apply.

28. Data Protection

Information provided in connection with a refund request may include personal and financial information.

ESCALO will process this information in accordance with applicable data protection law and our Privacy Policy.

Information may be used to:

• verify the request;
• investigate the transaction;
• prevent fraud;
• comply with AML/KYC obligations;
• process the refund;
• maintain records;
• resolve disputes;
• comply with legal obligations.

29. Changes to This Refund Policy

ESCALO may update this Refund Policy from time to time.

Changes may be made to reflect:

• changes to our services;
• changes in payment arrangements;
• changes in applicable law;
• regulatory developments;
• operational improvements;
• changes to third-party providers.

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

30. Contact Us

For refund requests and related questions:

Finance Act Limited trading as ESCALO

Company number: 16839569

Registered office:
58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

31. Final Statement

ESCALO seeks to handle refunds and transaction corrections fairly, consistently and in accordance with applicable law and contractual obligations.

Because ESCALO operates across financial markets, payment infrastructure, currency exchange and P2P environments, the availability and method of a refund may depend on the status of a transaction and the third parties involved.

Where a transaction has already been executed or settled, it may not be possible to reverse it simply because circumstances have changed.

Where a refund is legally required, ESCALO will comply with the applicable legal requirements.

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

support@escalo.uk

Last updated: 13 August 2026