Consumer Protection Policy

1         INTRODUCTION

The Financial Consumer Protection Regulatory Framework, recently implemented by the Central Bank of the UAE, outlines high-level objectives aimed at safeguarding consumers' interests in their interactions with Licensed Financial Institutions. It encompasses diverse standards that articulate specific regulatory requirements, ensuring a uniform understanding and application of these standards. The regulations provide a comprehensive guide to the expected conduct from both the Licensed Financial Institution and its staff.

2         PURPOSE

The central aim of the Consumer Protection Regulation and its accompanying standards is to ensure the well-being of consumers by safeguarding their rights and interests, thereby contributing to the overall economic stability. These regulations, along with their associated standards, foster an ethical culture within the Licensed Financial entity, emphasizing the importance of respecting and prioritizing the consumer's best interests. The responsibilities of the Licensed Financial entity in protecting consumers' rights and interests include:

• Establishing or fortifying the governance structure within the organization.
• Exercising vigilant oversight over the design, promotion, and sale of financial products/services.
• Responsibly promoting financial products/services to safeguard consumers' interests.
• Providing adequate disclosure of information related to financial products/services, enabling consumers to make informed decisions.
• Investigating and addressing unreasonable barriers that restrict consumers' choices and options.
• Offering knowledge and awareness to consumers, empowering them to assess financial products/services.
• Ensuring inclusivity by eliminating unjust barriers and practices that hinder consumers' access to financial products/services across all segments of society.

3         SCOPE

The Consumer Protection Regulation and its associated Standards are relevant to every Licensed Financial Institution overseen by the Central Bank UAE. These regulations and standards aim to elevate the safeguarding of consumers' interests and empower them with the necessary knowledge and education to make informed decisions about the financial products/services provided by the Licensed Financial entity. The exchange house is obligated to furnish all records and documents in alignment with these regulations.

4         GENERAL CONSUMER PROTECTION PRINCIPLES

5         DISCLOSURE and TRANSPARENCY

• Our exchange house adheres to transparent disclosure practices by proactively furnishing essential information to consumers, aiding them in making well-informed decisions regarding our financial products/services. In alignment with the Consumer Protection Regulation and its accompanying standards, our practices include:
• Providing Terms and Conditions to consumers in both English and Arabic languages, ensuring information is presented in a clear and straightforward manner for easy understanding.
• Allowing consumers sufficient time to comprehend the disclosed information, and assisting them in understanding the characteristics, advantages, and disadvantages of our financial products/services.
• Analyzing complaints and conducting consumer satisfaction surveys to assess the effectiveness of our disclosure practices and implementing improvements accordingly.
• Ensuring accessibility of information for individuals with different abilities.

5.1       Terms and Conditions

• The Terms and Conditions are presented to consumers in both English and Arabic languages.
• The provided information is transparent and easily comprehensible.
• The Terms and Conditions are devoid of any misleading content.
• Our exchange house practices the proactive notification of consumers about any changes or updates in the terms and conditions.
• Cautionary statements in the Terms and Conditions highlight the repercussions to consumers if they use financial products and services in violation of the specified terms.
• To ensure integrity within our organization, our exchange house enforces stringent policies against:
• Providing consumers with partial or biased information for enticing purposes.
• Exploiting consumers' ignorance and apathy.
• Offering deceptive, misleading, fraudulent, or unclear information to consumers.
• Engaging in any deceptive, misleading, fraudulent, or unfair representations, omissions, or activities related to advertising and marketing.
• Avoiding exaggeration in conveying information about the advantages of our products/services.

5.2   Advertising and Marketing

Our exchange house uses various channels to provide information regarding our products and services to our targeted customers. The advertising and marketing methods we follow are in line with the standards of the regulations.  The following factors must be taken into consideration which performing any advertisement or marketing practices:

1. Our exchange House takes great care in ensuring that the information provided to the customers is not misleading or amplifies the benefits of the financial products/services to boost sales. 
2. The information provided to the consumers should be basic, straightforward, and easy to understand.
3. The advertisement should contain all the information relating to the product, e.g., additional charges, expiry date of the promotion, etc.
4. All abbreviations used in the advertisement and marketing campaign must be narrated.
5. The consumers are having an option to "Opt IN' and 'Opt OUT' of the SMS and Email marketing emails they receive.

Furthermore, as a part of enhancing the governance practices, we have developed an authority and responsibility matrix for ensuring good transparency and disclosure practices. In addition to this, we are conducting complaint analysis surveys as a part of continuous monitoring to improve the disclosure and transparency practices.

6         INSTITUTIONAL OVERSIGHT

Our exchange house aligns with consumer protection regulations by instituting a well defined governance structure, incorporating an organized organizational framework, qualified personnel, effective monitoring controls, and fostering a positive corporate culture.

In compliance with consumer protection regulations and associated standards, our exchange house maintains a robust management system overseeing various aspects of our operations, including the design, development, promotion, sale, and distribution of products/services, as well as compliance, risk management, and audit controls. We consistently update policies, procedures, and training materials to ensure our staff is adequately qualified.

We actively monitor and identify potential market risks to uphold fair treatment of consumers without any discrimination. Stringent controls are in place to monitor staff activities and transactions. Additionally, we ensure that all authorized agents comply with applicable regulations and associated standards.

6.1       Trainings Provided:

1. A short training is given to our consumers to ensure that the consumers are well educated, informed, and aware of their rights and responsibilities to make a well-informed decision.
2. Senior management provides training to the employees to ensure that the employees inform and educate them about the ethical practices that must follow, code of conduct, etc.

7         BUSINESS CONDUCT

Our exchange house has established an adequate code of conduct that instills a culture of integrity and ethics in our financial products and services. We ensure that we follow good ethical practices in all aspects of the products and services, including product design, distribution, development, sales, promotion, etc.

To maintain sound business conduct, our exchange house follows the following practices:

• We are providing adequate training to the staff to raise awareness about the ethical behavior of the team towards the consumers.
• Ensuring the staffs are qualified and have sufficient knowledge about the financial products and services.
• Ensuring that the staff is professionally qualified to provide advice to the consumers and carry out the transactions.
• We are conducting staff appraisals periodically.

7.1       Prohibited Practices:

• Mis-selling
• Unreasonable Risk Taking
• Abusive or excessive contractual terms
• Misleading and aggressive sales practices
• The exploitation of the consumers
• Discrimination against the consumers
• We are restricting the customers from selecting the products and services.
• Bundling of products and services.
• We are taking unfair benefits from the errors of the consumers.
• Undue and coercive pressure on the consumers.

7.2       Charges and Commission

• The exchange house provides the charges and commissions relating to the consumer's opted financial products/services.
• The exchange house will inform consumers of any changes in the charges or commissions that happened in the past 30 days.
• The details regarding the calculation of the charges and commission and the following profits will be disclosed to the consumers.

7.3       Employee Requirements

• The employees must fulfill their duties with utmost professionalism and efficiency.
• The employees must follow the ethical code of conduct at all times.
• The employees must have full knowledge of our exchange house's financial products and services to assist and guide the consumers to make a well-informed decision.
• The employees must have a professional certificate and must provide periodic training to them.

8         MARKET CONDUCT

Our exchange house engages in responsible market conduct by providing products and services approved by the market. To maintain this commitment, we consistently monitor and adhere to the high ethical standards prevalent in the market

Prohibited Practices

a)     Sales and marketing practices that are abusive and unfair.

b)     Establishing unjust barriers that unfairly restrict consumers' access to necessary financial products/services.

c)     Imposing obstacles that hinder consumers from changing their policy.

d)     Engaging in price fixing.

e)     Utilizing misleading or incomplete information

8.1     Fair Treatment

To protect the interests and financial well-being of our customers:

We commit to embed fair dealing into our institution’s corporate culture and core values

• We will set minimum standards on fair business practices in all dealings with our users. This includes preserving the confidentiality of our customers’ information; and
• We will take customers’ feedback seriously and provide immediate constructive feedback to our staff.

We commit to ensure that our customers are provided with fair terms

• We will ensure that the terms in our contracts or agreements are fair, transparent, and well communicated to users. 
• We will ensure that the terms and conditions set out the respective rights, liabilities and obligations clearly and as far as possible in plain language.
• We commit to provide at least thirty (30) days’ notice before any changes to the terms and conditions/Terms of Service take effect.

9         PROTECTION OF CONSUMER DATA AND ASSETS

Our exchange house ensures that our consumer's data and assets are safeguarded against any form of fraudulent activities happening. We have appointed a dedicated data management officer to prevent the consumer's data and information misuse. To ensure the safety of the consumer's data, our exchange house has implemented various measures:

• Conducting VAPT on our IT environment to understand and thereby rectify the cybersecurity vulnerabilities.
• We provide well-written terms and conditions to the consumers to provide them with the information regarding obtaining the consumer's confidential data.
• Obtaining the consent of the consumer regarding using their confidential data and sharing it with third parties.
• We are providing training to the staff on the topics of data protection and fraud awareness.

Furthermore, we have implemented various internal controls to protect consumers' data and assets against various internal frauds. We ensure that we apply adequate resources to detect both internal and external frauds and for ensuring that the detected frauds are fully addressed with sufficient measures taken to prevent any such incidents does not happen in the future.  Our Fraud/Risk Officer ensures the same.

9.1     Data Confidentiality and Data Sharing

A data protection policy is an internal document created for the purpose of establishing data protection policies within the organization. It is made available to company employees, as well as third party vendors and agents, responsible for handling or processing sensitive data. Protecting the confidentiality and integrity of personal data is a critical responsibility that we take seriously at all times. This policy is therefore intended to apply to the personal data that we process.

The Company will ensure any processing of personal data has a documented legal basis. All parties who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice/policy or a fair processing notice.

To ensure fair, lawful and transparent processing, Privacy Notices shall be issued to data subjects to make them aware of how the company intends to use and protect their data. As a part of the same, the following information will be provided to the customer:

• The purposes of processing data.
• The information that is to be held
• The legal basis for processing data
• The length of time that the data will be retained for
• The measures taken to protect all data held
• The third parties that can access this data

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and legal action.

9.2       Topics included for training:

1. Sharing of passwords and unauthorized access.
2. Threats of Phishing, Ransomware, and other Malware.
3. Threats arising due to usage of external devices.
4. Connecting to unknown networks.

We have a practice of verifying security and monitoring measures to detect IT and other human unauthorized access to consumer's data. If any harmful data breaches are observed/identified during the verification, the same will be immediately reported to the Central Bank for their review.

9.3       Record Retention

Our exchange house has the policy of retaining the records for a minimum period of 5 years to make them available to the Central Bank examiners and for any investigation. The primary purpose of doing this is to ensure that the financial institution can obtain the past year's records as per the requirements of the competent authorities. The documents are safely kept and stored in a well-secured location where there is no data breach and where the records can be obtained upon request.

The consumer's documents are retained regardless of the status of the transactions and the verification of the IDs provided. The supporting documents include customer IDs, trade licenses, invoice details, Central Bank forms, account opening documents, customer profiles, Passport copy, trade license, turnover of account, the origin of funds, (Source of funds), beneficial owners, purpose, the type of instructions and authority regarding operating of account should also be kept and made available to Central Banks examiners and for investigation for a minimum of 5 years.

10   COMPLAINT MANAGEMENT AND COMPLAINT RESOLUTION

Our financial institution is having a practice of ensuring that all the consumers of our financial products and services are allowed to provide us with feedback and complaints regarding the products and services they have availed from us. To ensure this, we have developed a complaint management function that oversees all the complaint management activities and ensures that all procedures are performed with minimum turnaround time. As a part of effective complaint management, we have made various enhancements in our system:

• Established a dedicated email and telephonic assistance platform which only deals with customer support and conveying the complaint information.
• Providing information to the customers about the process of our complaint management and the recourse of the complaints.
• Providing information to the consumers to ensure that they are fully aware of their rights and responsibilities.
• Providing training to our staff, agents and counterparties to identify and handle complaints.
• Using the previous complaint data to analyze the key trends and understand the risks involved to develop new controls.

10.1   Complaint Filing

We also ensure that the complaints against our authorized agents and counterparties are accepted and handled adequately:

• EDD will be performed on all agents and counterparties.
• The Ultimate Beneficial Owner will be identified.
• All the agents and counterparties and the Ultimate Beneficial Owners will undergo a sanction screening process.
• Ensuring that the agent/counterparty has sound, credible and unbiased complaint management.

10.2   Delays/Cancellations from the side of the counterparties:

1. If cancellation occurs due to the customer's fault, the customer will be refunded after deducting the cost incurred by the exchange house.
2. If cancellation occurred due to the fault of the agent/counterparty, the consumer would be refunded with appropriate compensation.
3. In case of any known delays, the consumers will be immediately informed of the delay and will be given the option of whether to continue or cancel the transaction.
4. In case of any unknown delays, the consumers will be informed when the delay is identified and the consumer will be given the option to continue the transaction or cancel.

11   CONSUMER EDUCATION AND AWARENESS

Our Exchange house has established a consumer education and awareness program to ensure that the consumers are well educated and aware of their rights and responsibilities to make a well-informed decision.

11.1   Methods of Providing Information to the Consumers:

• Distributing information to customers through pamphlets, brochures, etc.
• Providing face-to-face assistance to consumers.
• Creating diverse initiatives to enhance consumer awareness

Consumers' Responsibilities

• The consumer must always give complete and accurate information while filing any documents. Providing false information or intentionally omitting information may lead to further competition.
• The consumer must carefully review and evaluate the terms and conditions provided to them by the exchange house to understand their obligations.
• Enquire about any unclear or unsure information to the staff of the exchange house to make well-informed decisions.
• In case of any difficulties faced, escalate the issue to the senior management in the form of a well-written and detailed complaint.
• Purchase the products and services only after carefully understanding the risks involved.
• Purchase the products and services that are suitable for the needs and financial situations of the consumer.
• The consumer must not disclose the exchange house's sensitive information to any other party.
• The consumer must update their information with the exchange house as and when required to avoid any miscommunication.
• The consumer must review and verify all the information before signing any forms.

11.2  Customer Feedback and Customer Satisfaction Surveys

We will strive to continually improve the services we provide. Compliments, complaints and suggestions for improvement are the most immediate and effective forms of feedback that will assist efforts to improve our service.

In the management of compliments, complaints and feedback, Redha Alansari Exchange will be in line with the following:

• Accessibility – We will provide easy ways to submit complaints, compliments and feedback through flexible and convenient methods
• Responsiveness – We will acknowledge all compliments, complaints and feedback and maintain good communication with complainants throughout the process about expected timeframes, outcomes and of relevant avenues of further review.
• Confidentiality – We are committed to customer privacy in accordance with our Privacy Policy
• Customer centricity – We will respond to all customer and stakeholder contact in an equitable, objective, consistent and unbiased manner. A customer-focused approach will be adopted supported by promoting an open, responsive and non-confrontational process.

12  Conflict of Interest

A conflict of interest arises when personal interests may interfere with the obligations one has to another person or entity, such as an employer. This situation can lead one party to question the intentions of another.

Our organization has well-defined policies to prevent conflicts of interest with customers:

• Acceptance of gifts by employees from customers is prohibited to avoid any potential conflict of interest. Employees are not allowed to accept gifts, entertainment, or other benefits unless it directly enhances the quality of our firm's products and services without detriment.

• Employees are prohibited from sharing confidential information of the organization with customers, preventing any potential harm to the organization.

• Employees are not allowed to provide tips or guidance to customers on evading or bypassing regulations.

• Employees are instructed to report all suspicious transaction reports (STRs) on customers, even if the customer is well-known to the employee.

• Special rates are prohibited for known relatives or associates of employees, and employees are directed to provide uniform treatment to all customers

FINANCIAL INCLUSION

Our exchange house follows the concept of financial inclusion. We ensure that all the necessary regulations and mechanisms are deployed to ensure that all our consumers have access to all parts of the financial products/services suited to their needs.  To ensure this, we have the practice of following the below points:

• We have a practice of providing appropriate training to the staff to identify and assist the vulnerable groups and people with determination.
• Ensuring that the employees of the exchange house follow the code of conduct established for anti-discrimination.
• We provide training to the employees of the exchange house after considering the unique requirements of the vulnerable groups and people with determination.

However, our exchange house refrains ourselves from the following practices:

• Discriminating the consumers based on gender, family status, ethnicity, etc.
• Providing special rates for financial products and services.

13    GENERAL DEFINITIONS