Complaints Procedure

1. What counts as a complaint

A complaint is any expression of dissatisfaction about Kingscross, an employee, an approved agent, a transaction, a service, a delay, a fee, an exchange rate, customer treatment, data handling, fraud response or another matter where the customer expects a response or remedy.

A customer does not need to use the word “complaint”. If the concern reasonably indicates dissatisfaction and requires investigation or corrective action, Kingscross should treat it as a complaint.

2. Who may make a complaint

A complaint may be made by:

• an individual customer;
• a business customer;
• a beneficiary or intended beneficiary;
• an authorised representative;
• a director, employee or authorised signatory of a business customer;
• a guardian, executor, administrator or legal representative where properly authorised.

Kingscross may request evidence of authority before disclosing confidential information or accepting instructions from a representative.

3. How to make a complaint

A complaint may be submitted through any approved Kingscross channel, including:

• email;
• the website or customer portal;
• a branch;
• an approved agent;
• postal correspondence;
• telephone or another recorded customer-support channel when available.

Customers should not be required to use a specific format where the complaint can otherwise be understood and investigated.

4. Information that helps us investigate

Customers should provide, where available:

• full name and contact details;
• customer or business name;
• transaction, quote or complaint reference;
• date, amount, currency and beneficiary details;
• a clear description of what happened;
• the outcome sought;
• receipts, screenshots, emails, messages or other supporting evidence.

Kingscross should not reject a genuine complaint merely because every item is not available.

5. Accessibility and assistance

Kingscross should make reasonable efforts to assist customers who may have difficulty submitting a complaint because of disability, language, literacy, age, vulnerability or lack of digital access.

Where appropriate, Kingscross may accept an authorised representative or help the customer record the complaint in writing.

6. Acknowledgement of the complaint

Kingscross should acknowledge the complaint promptly and provide:

• a complaint reference number;
• the date received;
• a summary of the issue where useful;
• the contact point handling the complaint;
• an indication of the next steps;
• the expected response period, subject to final approved timelines.

The final acknowledgement deadline must be confirmed before launch and reflected consistently in policy, training and customer communications.

7. Urgent complaints

The following should receive urgent attention:

• suspected fraud or scam;
• unauthorised account access;
• payment to the wrong beneficiary;
• duplicate payment;
• security compromise;
• personal data breach;
• customer funds that cannot be located;
• serious misconduct by an employee or agent.

Urgent handling does not guarantee recovery of funds, but Kingscross should take reasonable steps to investigate, trace, hold, recall or escalate the matter where possible.

8. Investigation process

The investigation may include:

1. reviewing the complaint and identifying the issues;
2. checking customer, transaction and communication records;
3. reviewing quotes, fees, funding, settlement and payout information;
4. examining authentication, OTP, login and audit records;
5. contacting relevant staff, agents, banks or payment partners;
6. requesting further information from the customer;
7. reviewing applicable policies, terms, laws and partner rules;
8. determining the root cause and appropriate outcome.

9. Independence, fairness and conflicts

A complaint should be reviewed by a person with appropriate authority and, where reasonably possible, someone who was not directly responsible for the disputed decision or conduct.

Any actual or potential conflict of interest should be identified and managed. The complaint handler should consider both evidence supporting Kingscross and evidence supporting the customer.

10. Progress updates

If the complaint cannot be resolved within the initial expected period, Kingscross should provide a progress update explaining:

• why more time is needed;
• what investigation remains outstanding;
• whether information is required from the customer;
• when the next update or final response is expected.

11. Final response

The final response should be clear, balanced and understandable. It should normally include:

• the complaint reference;
• the issues investigated;
• the material facts and evidence considered;
• whether the complaint is upheld, partly upheld or not upheld;
• the reasons for the decision;
• any remedy or corrective action;
• the available internal or external escalation route.

Where legal or regulatory restrictions prevent full disclosure, Kingscross should provide as much information as it is lawfully permitted to provide.

12. Possible remedies

Depending on the circumstances, a remedy may include:

• an explanation or clarification;
• an apology;
• correction of records;
• transaction tracing or recall;
• refund or partial refund;
• fee or exchange-rate adjustment;
• reprocessing of a transaction;
• restoration of account access;
• staff or agent training;
• process, system or policy improvement;
• disciplinary or contractual action where appropriate.

Any financial remedy should be authorised, documented and paid through an approved Kingscross channel.

13. Where a complaint is not upheld

If Kingscross does not uphold a complaint, the response should still explain the reasons and identify the evidence or contractual basis relied upon.

The customer should be informed of any further review or escalation option.

14. Internal escalation

A dissatisfied customer may request review by a more senior or independent person where appropriate.

Internal escalation may be considered where:

• new evidence becomes available;
• the customer identifies a material factual error;
• the original investigation may have been incomplete;
• the complaint concerns serious misconduct, fraud, data protection or customer funds.

15. External escalation

Depending on the subject matter, a customer may have the right to raise the matter with a competent authority, including:

• the Central Bank of Kenya for a matter relating to regulated money-remittance activity;
• the Office of the Data Protection Commissioner for a personal-data complaint;
• a court or tribunal with jurisdiction;
• law-enforcement authorities where fraud or criminal conduct is suspected;
• another competent authority relevant to the complaint.

Final regulator contact details and any mandatory escalation wording should be confirmed before launch.

16. Fraud, scam and security complaints

Fraud or security complaints should be prioritised. Kingscross may:

• restrict account access;
• invalidate credentials or OTP sessions;
• attempt to hold or recall funds;
• contact banks, mobile operators or payment partners;
• preserve relevant records and evidence;
• make a lawful report to a competent authority.

Kingscross may be legally restricted from disclosing the existence or content of certain investigations or reports.

17. Privacy and data-protection complaints

A complaint about personal data may concern access, correction, deletion, disclosure, security, marketing, international transfer, automated processing or another privacy issue.

Privacy complaints should be coordinated with the designated privacy contact and handled in accordance with the Privacy Notice and applicable Kenyan data-protection law.

18. Complaints involving agents or branches

Kingscross remains responsible for receiving and assessing complaints concerning an approved agent or branch where the complaint relates to Kingscross services.

The agent should forward the complaint promptly and must not discourage the customer from contacting Kingscross directly.

Kingscross may review agent records, CCTV where lawfully available, receipts, staff conduct, cash handling, pricing and customer communications.

19. Confidentiality and personal data

Complaint information should be accessed only by persons who need it for investigation, decision-making, legal advice, audit or regulatory reporting.

Personal data should be handled in accordance with the Privacy Notice and applicable law.

20. Complaint records

Kingscross should maintain records of:

• the complaint and date received;
• customer and transaction references;
• communications and evidence;
• investigation steps;
• decision and reasons;
• remedy and payment details;
• internal and external escalation;
• root cause and corrective action.

Records should be retained in accordance with the approved retention schedule and applicable law.

21. Root-cause analysis and corrective action

Kingscross should analyse complaints to identify recurring or systemic issues, including:

• unclear fees or rates;
• delays and failed payments;
• agent conduct;
• technology failures;
• poor customer communication;
• KYC or compliance delays;
• fraud trends;
• privacy or security weaknesses.

Corrective actions may include policy changes, system improvements, additional controls, staff training, partner escalation or customer communication changes.

22. Management and Board reporting

Management should receive regular complaint information including:

• number and type of complaints;
• open and overdue cases;
• response times;
• upheld and rejected outcomes;
• refunds or compensation;
• agent-related complaints;
• fraud and privacy complaints;
• root causes and corrective actions.

Material trends, control weaknesses and serious complaints should be escalated to the Board or relevant committee.

23. Service standards to be approved before launch

24. Complaint contact details

The final dedicated complaints email, website form, postal address and any telephone channel should be confirmed before launch.