Consumer Policy

Introduction:

In an era where consumer rights and protection have gained paramount significance, NETG5 Global Ltd recognizes the pivotal role it plays in safeguarding the interests and well-being of our valued customers. It is with this commitment to excellence and consumer-centric practices that we introduce our Consumer Duty Policy.

The Consumer Duty Policy will serve as a cornerstone of our dedication to providing the highest standards of service and protection to our customers. It outlines our core principles and obligations towards consumers, setting the stage for transparent, fair, and responsible business practices. With this policy, we aim to reinforce trust, enhance consumer confidence, and ensure that the rights of our customers are upheld in every facet of our operations

The Consumer Duty was set to take effect on July 31, 2023, constituting a new and comprehensive framework of regulations established by the Financial Conduct Authority (FCA).

These regulations are designed to enforce a fundamental shift in the financial industry’s approach to consumer welfare. The primary objective of the Consumer Duty is to compel companies to prioritize the interests and well-being of their customers, setting forth exacting and stringent standards of consumer protection across the spectrum of financial products and services offered to retail clients.

As a result, when engaging with retail consumers, NETG5 Global Ltd is unequivocally bound to adhere to these elevated and rigorous care standards.

The information presented in this document serves the purpose of providing guidance to NETG5 Global Ltd’s employees and representatives, enabling them to navigate the intricacies of the Consumer Duty effectively.

This duty comprises four distinct consumer duty outcomes, each consisting of a combination of explicit rules and advisory recommendations that delineate precise requisites:

• Products & Services: In accordance with the Consumer Duty, our products and services must be not only suitable but meticulously tailored to the needs of a precisely defined target market. Furthermore, it is imperative to conduct periodic assessments to ascertain that these products and services consistently align with the requirements of the target market.
• Price & Value: The financial services we offer must be reasonably priced, and the benefits we confer must be both relevant and commensurate with the associated costs. The Consumer Duty mandates an equilibrium between the cost of services and the value derived from them, ensuring equity and transparency.
• Consumer Understanding: NETG5 Global Ltd is obligated to ensure that all customer communications, including pivotal product information, are presented in a manner that is lucid, comprehensible, and factually accurate. This transparency is integral to empowering consumers to make informed and judicious decisions promptly.
• Consumer Support: An essential facet of the Consumer Duty entails providing consumers with access to the appropriate level of support whenever they require it. The onus is on us to facilitate uncomplicated and expedient access to the support mechanisms, ensuring that our clients encounter no obstacles when seeking assistance.

The official and comprehensive guidance on the Consumer Duty is available within the FCA document labeled FG22/5. For a more detailed exploration of the obligations and expectations encapsulated within the Consumer Duty, this document can be accessed on the official FCA website at the following URL: [FCA Consumer Duty Guidance](https://www.fca.org.uk/publication/finalised- guidance/fg22-5.pdf).

By diligently adhering to the principles and provisions of the Consumer Duty, NETG5 Global Ltd commits itself to upholding the highest standards of care and integrity in its dealings with retail consumers, thereby contributing to the broader objectives of consumer welfare and protection mandated by the FCA.

Products & Services:

At NETG5 Global Ltd, our primary focus is serving the UK immigrant community, specifically those individuals seeking to send money to Afghanistan. These transactions are often driven by personal financial responsibilities, including but not limited to family support, savings, as well as financing loans or real estate acquisitions.

Our target audience encompasses individuals of all ages (above 18), income brackets, and backgrounds who seek a swift, straightforward, and reliable channel to send money, primarily to family members residing in Afghanistan. The majority of our clientele employs our service to cover essential living expenses for their overseas relatives. These expenditures may include child support, medical bills, groceries, educational costs, and more. It is worth highlighting that a substantial portion of these transactions falls under the category of urgent family support, particularly in situations such as medical emergencies, where swift, secure, and hassle-free money transfers are imperative.

In the immigrant population, money transfers hold a pivotal and fundamental role, a perspective recognized by the UK government. Our service distinguishes itself through its ease of use, transparent cost structures, competitive currency rates, and swift transaction processing times. Importantly, our commitment ensures that the beneficiary always receives their funds in a timely manner. A significant portion of our customers will direct their remittances to Afghanistan.

However, we acknowledge that our service may not align with the needs or circumstances of every individual. Therefore, we refrain from offering our services to individuals falling within the following categories:

• Individuals below the legal age as stipulated by the law.
• Individuals who are unable to undergo our consumer identification and verification processes, a vital component of our regulatory compliance.
• Individuals acting on behalf of third parties.

At NETG5 Global Ltd, our overarching goal is to provide a straightforward, efficient, and secure means for our valued customers to meet their personal remittance needs, especially when it involves supporting their loved ones across international borders. We take pride in our commitment to clarity, compliance, and customer satisfaction.

Price & Value:

At NETG5 Global Ltd, our commitment to providing reasonable, fair, and competitive pricing for our clients is unwavering. We will continuously evaluate our pricing strategy and structure, considering an array of factors, including data analysis, consumer feedback, processing and distribution costs, and the prevailing market conditions. This diligent assessment is pivotal in ensuring that our pricing remains aligned with the interests of our valued clients.

Pricing Determinants

Our pricing structure will be underpinned by a comprehensive examination of our competitors’ pricing, acquired through meticulous research and transaction analysis. It is through this meticulous process that we derive our pricing strategy, considering multiple factors:

• In-House Costs: We will scrutinize our own operational costs, ensuring that our pricing structure takes into consideration the expenses incurred within our organisation.
• Profit Margins: To sustain our operations and continue delivering exceptional services, we factor in a targeted profit margin that helps us cover our various expenses while maintaining competitive pricing.
• Competitor Benchmarking: The prices set by our competitors are closely monitored and form an integral part of our pricing deliberations. This ensures that our pricing is not only competitive but also reflective of the prevailing market dynamics.

Transparency and Informed Decisions

At NETG5 Global Ltd, we prioritize transparency in our pricing strategy. We are unwavering in our commitment to providing clients with all relevant information regarding fees and charges. This practice ensures that our clients have the opportunity to make informed decisions about our services before finalizing any transactions. We firmly believe that transparency is the cornerstone of trust in our client relationships.

Continous Improvement

We understand that pricing is a dynamic aspect of our business. To ensure that our pricing strategy will remain congruent with our commitment to fairness and competitiveness, NETG5 Global Ltd is embarking on a robust action plan. This plan will target the following key areas to address any gaps in our pricing strategy:

• An in-depth examination of our current fee structures for each service, encompassing regular charges, contingent fees, and all associated charges and fees.
• A thorough analysis of the specific cost components incurred by our firm in delivering services. This examination will encompass operational costs, regulatory compliance expenses, technology infrastructure costs, and other relevant expenditures.
• We will invest in the development or adoption of a proprietary pricing service or mechanism. This innovative tool will accurately calculate fair value and proportionate fees based on the identified cost components, market dynamics, competitive analysis, and our firm’s unique cost structure.
• The establishment of a structured process for the continuous monitoring and review of our pricing structures. This periodic review will consider changes in our business costs and the evolving market conditions.
• Based on the findings of our evaluation and review, we will make necessary adjustments to our pricing structure. These adjustments will ensure that fees and charges are commensurate with the actual costs incurred by our firm. Such revisions may entail changes to pricing tiers, introduction of new pricing models, or other modifications to maintain the fairness and equity that our clients deserve.

At NETG5 Global Ltd, our unwavering commitment to client-centric pricing is at the heart of our operations. We remain dedicated to delivering services that are reasonably priced, transparent, and fair, fostering trust and confidence among our valued clients.

Consumer Understanding:

At NETG5 Global Ltd, we hold our commitment to customer-centric service and clear, understandable communication in the highest regard. It is our goal to provide comprehensive support for all our customers, including those with unique needs, while maintaining a commitment to transparency and compliance with the highest standards. We employ several key strategies to ensure these principles are upheld.

Communication review & Approval

Every communication with our valued customers will undergo internal review and approval process before it is issued. This meticulous process ensures that all customer communications are clear, transparent, and reflect the diversity of our customer base, including those with potentially vulnerable characteristics. By doing so, we can be confident that our communications are not only accurate but also invaluable in helping our customers make informed decisions about our services, both before and after their use.

Customer-Centric Approach

When interacting with consumers, we hold an unwavering expectation that our staff prioritize the unique needs of each individual customer. In situations where necessary, our staff is encouraged to consult with NETG5 Global Ltd’s Money Laundering Reporting Officer (MLRO) to ensure that any customer requirements are met promptly and effectively.

Continuous Assessment under the Customer Duty

NETG5 Global Ltd maintains an ongoing commitment to monitor and assess customer outcomes under the four fundamental pillars of the Customer Duty. To ensure that we consistently adhere to these standards, we conduct periodic evaluations using a variety of management data, including:

• Analyzing new customers’ interactions and their initial experiences with our services.
• Monitoring customer interactions throughout their ongoing relationship with the company.
• Performing root cause analysis to understand the origins of customer concerns and addressing them proactively.
• Tracking patterns of service usage, frontline surveys, and customer feedback to identify challenges within the customer journey that could lead to adverse outcomes, as well as identifying and preventing potential instances of consumer fraud.

These periodic assessments are intended to occur at least semi-annually, with ongoing reviews of customer outcomes. In case any unfavorable customer outcomes are detected, we are committed to reviewing and, if necessary, modifying our services to rectify any discrepancies and align our offerings with customer expectations. Our particular attention will be dedicated to safeguarding the interests of vulnerable customers, ensuring that any negative consequences are minimized

Adaptive Product Line and Commitment to Transparency

NETG5 Global Ltd acknowledges that customer needs may evolve over time. As a response to these changing needs, we aim to expand our product line while steadfastly adhering to our promise of providing dependable, easily comprehensible services that offer value for money. We are resolute in our commitment to providing comprehensive information about all charges, devoid of any hidden fees, so our customers can make informed decisions.

Support for Vulnerable Customers

Our commitment extends to providing appropriate consideration for customers who may exhibit signs of vulnerability, which may include:

• Customers with limited English proficiency, for whom we intend to offer multilingual support.
• Ensuring that customers can only send money when they have the available funds to do so, mitigating financial resilience concerns.
• Recognizing customers under duress and offering additional support as needed.
• Accommodating customers with diminished mobility, hearing, or other sensory faculties.

We have clear expectations for all our employees to:

• Identify and offer extra support to customers who may be at risk.
• Listen attentively to each customer’s unique needs, taking the time to fully understand them and not assuming awareness of their requirements.
• Be alert to any signs of misunderstanding or indications of ignorance regarding previously covered information.
• Display patience and understanding, without rushing or showing signs of impatience.
• Allow customers time to process the information presented and make their own decisions.
• Ensure that vulnerable customers have the opportunity to consult with others before making decisions.
• Provide all necessary transactional details before proceeding with any transaction, including cost, exchange rate, payment amounts, payment availability, and beneficiary requirements.
• Politely reject any attempts at fraud or coercion, immediately reporting such incidents to our MLRO for appropriate action.

At NETG5 Global Ltd, our unwavering commitment to our customers is underscored by a dedication to clarity, fairness, and service excellence. We continually strive to ensure that all individuals, regardless of their unique circumstances, have access to the financial services they need while being treated with respect, empathy, and professionalism.

Consumer Support

At NETG5 Global Ltd, we believe that the support we will extend to our valued clientele throughout the entire lifecycle of our products and services is of paramount importance. We will diligently craft and administer a robust customer support protocol that, at its core, will consider the unique vulnerabilities and challenges our customers may encounter, striving to eliminate any obstructions that could hinder their ability to effectively utilize and benefit from our services.

Our commitment to continuous improvement is enshrined within our organisational culture. We will establish rigorous monitoring and assurance programs through which we can continually evaluate and refine our customer support delivery standards. This steadfast dedication to refinement allows us to proactively identify areas that necessitate enhancement, rectify issues, and make incremental adjustments to prevent foreseeable harm. By engaging in this ongoing process of refinement, we further reinforce our ability to offer valuable assistance to our clients as they pursue their financial objectives.

The Complaints Handling procedure at NETG5 Global Ltd reflects our commitment to addressing customer concerns efficiently and fairly. Nevertheless, we believe in the continuous pursuit of excellence, and as part of our commitment to further improve the customer experience, we are developing plans to render our complaint handling services even more accessible and customer-centric. To achieve this, we are poised to introduce a specialized customer support service, where dedicated team members will not only guide customers through the process of formally lodging complaints, whether through traditional postal methods or electronic communication, but will also provide real-time updates on the status of existing complaints.

In cases where customers remain dissatisfied with the resolution of their complaints, the team will also clarify the process for escalating their concerns to the Financial Ombudsman Service (FOS), should such a course of action be deemed necessary.

At NETG5 Global Ltd, our dedication to customer support is unwavering. We are committed to not only meeting but exceeding the expectations of our clients. Through these initiatives, we aspire to enhance the accessibility, transparency, and efficiency of our customer support services, underscoring our commitment to safeguarding the interests and satisfaction of our customers.

Our Expectations Towards Employees:

At NETG5 Global Ltd, we uphold a proactive approach to the betterment of our products and services, wherein we actively engage our staff in the pivotal task of gathering valuable feedback from both our esteemed customers and team members who directly interact with our clientele. These assessments represent an indispensable facet of our broader commitment to fulfill our duty, fostering service enhancements that resonate with the unique needs of our customers.

In alignment with this commitment, we place a crucial responsibility on our dedicated staff members to engage in candid dialogues with our customers. Through these exchanges, our staff not only inquire about their experiences but also encourage them to share feedback. This comprehensive approach allows us to pinpoint, address, and refine areas within our products and services that require attention.

To ensure a systematic and constructive feedback loop, our staff facilitates the submission of feedback through various channels, often electronically via email. The areas we prioritize for feedback are as follows:

• Our customers’ feedback in cases where the product or service proved unsuitable, instances of perceived unfair pricing, unclear communications concerning fees and charges, or unforeseen support measures are invaluable for making necessary improvements.
• We will actively seek and review feedback obtained directly from customers through surveys, feedback forms, or interactions with our customer support. This valuable information assists us in identifying evolving trends in customer satisfaction, enabling us to proactively address concerns or identify opportunities for improvement.
• As part of our comprehensive feedback process, we endeavor to identify any new or emerging customer vulnerabilities. We closely examine how our staff handles and supports these vulnerable customers, ensuring that their unique needs are met and addressed with sensitivity.
• Feedback involving customer complaints or escalations is vital to us. Our staff will be responsible for documenting and reporting these cases, providing insight into how issues were addressed, resolved, and lessons learned for future improvements.
• Monitoring customer wait times, response times, and resolution times for inquiries, complaints, or support requests forms an integral aspect of our service quality assessment. By understanding and addressing these metrics, we enhance the efficiency and timeliness of our customer support.
• Our commitment extends to ensuring that language or cultural barriers do not hinder effective communication with our customers. Feedback pertaining to such barriers allows us to adopt strategies for more inclusive and comprehensive communication.
• Comments or complaints, whether direct or received through various channels, provide valuable insights into our service performance and areas that necessitate refinement.
• We actively encourage our staff to report any ad hoc comments regarding system issues, service outages, delayed payments, and similar concerns. This helps us identify, address, and rectify emerging issues promptly.

Through this planned and staff-led feedback initiative, we are committed to upholding our pledge for continuous improvement. At NETG5 Global Ltd, we believe that listening to our customers and empowering our staff to act upon their insights are fundamental steps toward enhancing the quality and accessibility of our services.