A.1 Les Amis Private Limited (“LAPL”) is engaged in the business of providing technological support and infrastructure for cross-border payments and related compliance requirements and runs a cross border payments platform by the brand name ‘EximPe’.
A.2 The Reserve Bank of India (“RBI”) vide notification dated October 31, 2023 “Regulation of Payment Aggregator – Cross Border” (“PA-CB Guidelines”) issued vide CO.DPSS.POLC.No.S-786/02-14-008/2023-24 read with the “Guidelines on Regulation of Payment Aggregators and Payment Gateways, 2020” issued vide DPSS.CO.PD.No.1810/02.14.008/2019-20, 17 March 2020, (the "PA Guidelines”) has laid out regulations for all Payment Aggregators – Cross Border (“PACB”) to ensure that a suitable mechanism is in place for receiving and addressing complaints from its customers with specific emphasis on resolving such complaints fairly and expeditiously regardless of source of the complaints.
A.3 This Grievance Redressal Policy has been formulated in light of the above-mentioned laws read with ‘Harmonization of Turnaround Time and customer compensation for failed transactions using authorized Payment Systems dated September 20, 2019’ and ‘ODR System for Digital Payments dated August 6, 2020’ and Integrated Ombudsman Scheme, 2021 to provide Customers adequate facilities to lodge and escalate their grievances, concerns and queries with EximPe and to provide a speedy and effective redressal mechanism for the same.
In this Grievance Redressal Policy, the following words and expressions shall have the following meanings, unless the context otherwise requires:
The Grievance Redressal Policy outlines a structured grievance redressal mechanism for the resolution of the grievances of the Customers on EximPe and informs the Customers of this mechanism of grievance redressal. This policy outlines the grievance redressal procedures for disputes that may arise during the course of the business conducted by EximPe. The 3 (three) levels of grievance redressal are:
The policy is relevant to all EximPe Customers and covers all products and services offered by EximPe in the realm of cross-border payment aggregation. This ensures a uniform approach to grievance handling across various EximPe company levels and customer interactions, maintaining consistency and efficiency in our service standards
EximPe is committed to exceptional grievance handling through comprehensive team training. Our training modules focus on empathy, effective communication, problem-solving, and in-depth understanding of company policies. We conduct these sessions regularly to keep our team updated with the latest in customer service excellence.
We also integrate customer feedback into our training programs, enabling continuous improvement. The performance of our team in addressing grievances is closely monitored, and insights gained are used to refine training strategies
This training regimen is aimed at achieving first-time resolution of customer issues, thereby building trust and enhancing overall customer satisfaction. The impact of this training is evident in both our operational efficiency and the quality of our customer interactions.
The Grievance Redressal Committee at EximPe plays a pivotal role in maintaining high standards of customer service. Comprised of members from key areas of EximPe, the committee convenes monthly to meticulously review customer complaints and suggestions.
Their tasks incllude
At EximPe, the role of the Nodal Officer is assigned to the Key Account Manager. This position entails:
EximPe enables its Customers to register a complaint using any of the following mechanism:
| Channel | Official | Process |
|---|---|---|
| Online Grievance Form | Yes | Primary channel via website form |
| Walk-in Support | Yes | Handled by Customer Service / Service Assurance / Nodal Officer / senior PA team and entered into grievance system |
| Written Correspondence | Yes | Letters to Nodal Officer forwarded to service team; additional details sought via phone or email if required; response via email with Nodal Officer in copy (letters only in exceptional cases) |
| Social Media | No | Not an official channel; EximPe responds via official handle requesting customers to file through website |
| RBI Ombudsman | Yes | Highest priority treatment |
Customers will be required to necessarily provide the following details while communicating with EximPe:
Each complaint is assigned a unique reference number and shared with the Customer for future reference and monitoring.
Appropriate steps will be taken via coordination with technology, risk, acquiring bank, and merchant partners as applicable.
For Customer grievances that cannot be addressed by EximPe, the Customer shall be redirected to the relevant Bank/Payment Gateway for appropriate action. These complaints could be related to product liability, delivery, fraud claims (i.e., matters beyond the scope of EximPe)
Complaints are tracked through various statuses including Open, Investigation, Pending Customer, Resolved, and Escalated to ensure transparency and accountability
If a customer does not respond to requests for additional information within the specified timeframe, the complaint may be deemed closed. Customers retain the right to reopen such complaints by providing the required information.
EximPe shall have a three-tier escalation mechanism for handling Customer grievances.
| Escalation Level | Designation | Contact | Max TAT for Acknowledgement | Max TAT since Complaint Registration for Resolution |
|---|---|---|---|---|
| Level 1 | Customer Service Team | Customer Support Form | 24 hours from receipt of complaint at Level I | 3 days |
| Level 2 | Operations Head | Escalation Form | 24 hours from receipt of complaint at Level II | 10 days |
| Level 3 | Nodal Officer | nodalofficer@eximpe.com | 24 hours from receipt of complaint at Level III | 10 days |
| Level 4 | RBI Integrated Ombudsman | https://cms.rbi.org.in | As per RBI guidelines | As per RBI guidelines |
Note: Complaints are automatically escalated to the next level if the turnaround time is exceeded. The Customer can approach the Ombudsman if appropriate resolution is not received within 30 days in line with RBI Integrated Ombudsman Scheme, 2021.
EximPe has a Customer Service Team responsible for handling Customer complaints. Customers can contact the team on any channels in Section H. The helpline is available 10AM–6PM on business days.
Unresolved or unsatisfactory complaints can be escalated to the Operations Head (primary mode: escalation form).
Name: Syed Arief Ulla
Designation: Nodal Officer
Address: 1st Floor, 592, Nomads Centre, 1st Cross Rd, Santhosapuram, Koramangala 3 Block, Koramangala, Bengaluru, Karnataka 560034
Email: nodalofficer@eximpe.com
Contact: Phone (10AM–6PM), Email, Written Correspondence, Walk-in Support
The Nodal Officer can be contacted via phone (during business hours: 10AM-6PM), email, written correspondence, or walk-in support. All communications are logged in the grievance tracking system.
Note: Since this is a Level III escalation, giving a first call resolution on the phone might not be possible. Customer will be required to approach Level III with a previous ticket Request Number. The complaint history will be accessible by the team using such ticket Request Number.
The customer may appeal to the RBI Ombudsman under the RBI Integrated Ombudsman Scheme, 2021 if resolution is not achieved within 30 days or the customer remains unsatisfied. EximPe will acknowledge Ombudsman complaints within stipulated timeframes, provide comprehensive written responses within 15 days, and ensure full compliance with Ombudsman awards within 30 days.
For additional details and FAQs, please click: RBI Integrated Ombudsman Scheme, 2021
Further, a complaint can be registered on: https://cms.rbi.org.in/cms/indexpage.html#eng.
I.1 EximPe has put in place a process to address all customer grievances in relation to failed transactions due to failure in communication links, time-out of sessions etc. (transactions charged to Customer / Buyer but not returned to the EximPe and, in turn, to Customer, hence no services are rendered). However, if failure can be attributed to the Customer, then the same shall not qualify as a failed transaction. The Customer should ensure that the credentials are kept secure and confidential. Grievances related to failed transactions can be lodged through email or website. In the event of a consumer encountering a failed transaction, the Customer is advised to try again after some time provided money has not been debited from the account balance.
In instances of failed transactions where an account has been debited, Customers are advised to promptly report the issue to EximPe. EximPe will adhere with and where EximPe utilizes a payment gateway provider for executing domestic transfers, it is the responsibility of this provider to adhere to the RBI's guidelines on 'Harmonization of Turnaround Time (TAT) and Customer Compensation for Failed Transactions' as outlined in the RBI circular DPSS.CO.PD No. 629/02.01.014/2019-20 dated September 20, 2019. As per the RBI guidelines, the payment gateway provider shall initiate auto-reversal of failed transactions within T+5 days (where T is the transaction date) for all payment methods including Card, UPI, and Net Banking. In case of delay beyond T+5 days, compensation of ₹100/- per day shall be automatically credited to the customer's account
Customers should use the established complaint registration channels and escalation matrix as detailed in Sections H and I of this document. EximPe collaborates closely with the payment gateway provider to ensure timely resolution of these issues, in compliance with the specified RBI timelines. Customers are advised to wait for T+5 days for auto-reversal before lodging a complaint. If auto-reversal and applicable compensation are not received within the prescribed timeline, customers should immediately escalate through the channels mentioned in Section H
Use complaint channels and escalation matrix in Sections H and I. EximPe collaborates with gateway providers to ensure timely resolution within RBI timelines.
J.1 A chargeback is a charge for goods or services not received by the buyer and his bank debited to his UPI/Credit/Debit Account. The buyer has the option to file a chargeback for the same with his card issuing bank.
J.2 Chargebacks are high priority issues and are handled as detailed hereinafter. Broadly, where a customer has reached out to the Issuing Bank/other institution and has disputed the transaction made by them using his/her payment mode/mechanism on the merchant site, the following process is followed:
| Possibility | Outcome |
|---|---|
| Acceptance | When the Customer’s chargeback is valid, the merchant may choose to accept the chargeback. An acceptance will result in a credit to the Customer’s account as per the network timelines and a permanent debit to the merchant’s account |
| Contestation / Representation | When services / goods are rendered against the said payment, the merchant can upload the relevant documents such as proof of delivery, service utilization proofs etc. The documents hence submitted are further represented to the acquiring banks and subsequently to the issuers and networks. |
| Deemed Accepted | In the event a chargeback is not represented / accepted by the merchant within the given timeline, the chargeback is deemed as accepted and the decision is not reversible. As in the case of acceptance this too shall have a permanent debit to the merchant’s account. |
Dispute reason codes and categories: see Annexure 1.
Customers may request a refund from the merchant due to reasons such as the non-delivery of goods or poor service quality. Merchants can initiate refunds against transactions with EximPe, which are posted to the original method of payment unless otherwise agreed by the end Customer. Credits for such refunds or reversals shall be routed back through partner PA’s Escrow account or EximPe’s escrow account (as applicable).
| Payment Mode | Minimum TAT from initiation | Maximum TAT |
|---|---|---|
| Credit/Debit Card | 5 days | 10 days |
| UPI | Instant | 7 days |
| Net Banking | 2 days | 10 days |
When a merchant requests a refund for a transaction, the following process is followed:
All the above go through the chargeback and refund resolution process in Sections J and K.
Following reports shall be submitted to the Board on an annual basis:
In line with Master Direction – Know Your Customer (KYC) Direction, 2016, EximPe shall preserve records of Customer complaints and the resolution offered shall be maintained for a minimum period of five years from the date of resolution. EximPe shall evolve a system for proper maintenance and preservation of complaint records in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.
The policy is reviewed on an annual basis and updated to incorporate changes as per RBI Guidelines. All updates/changes to the Policy will be communicated to the relevant staff/relevant stakeholders on a periodic basis. All such changes /modifications will be reported to the Board for approval.
In the event of any conflict between the provisions of this policy and applicable RBI guidelines or any other statutory enactments, rules, the provisions of the applicable RBI guidelines or statutory enactments, rules shall prevail over and automatically be applicable to this policy and should be read in tandem with the provisions of the policy. The relevant provisions of the policy would be amended/modified in due course to make it consistent with the applicable law. Any deviations from the procedures specified in this policy shall be permitted only with the approval of Nodal Officer, the details of the deviation shall in the immediately following Board meeting be placed before the Board for scrutiny. However, no approvals shall be granted where such a deviation results in breach of any circular, direction, order or guidelines issued by any regulatory authority including the RBI.
| Reason Code | Description | External Category |
|---|---|---|
| 10.1 | EMV Liability Shift Counterfeit Fraud | Fraud |
| 10.2 | EMV Liability Shift Non-Counterfeit Fraud | Fraud |
| 10.3 | Other Fraud: Card-Present Environment | Fraud |
| 10.4 | Other Fraud: Card-Absent Environment | Fraud |
| 10.5 | Visa Fraud Monitoring Program | Fraud |
| 11.1 | Card Recovery Bulletin | Authorisation |
| 11.2 | Declined Authorisation | Authorisation |
| 11.3 | No Authorisation | Authorisation |
| 12.1 | Late Presentment | Processing Errors |
| 12.2 | Incorrect Transaction Code | Processing Errors |
| 12.3 | Incorrect Currency | Processing Errors |
| 12.4 | Incorrect Account Number | Processing Errors |
| 12.5 | Incorrect Amount | Processing Errors |
| 12.6 | Duplicate Processing / Paid by Other Means | Processing Errors |
| 12.7 | Invalid Data | Processing Errors |
| 13.1 | Merchandise / Services Not Received | Consumer Disputes |
| 13.2 | Cancelled Recurring Transaction | Consumer Disputes |
| 13.3 | Not as Described or Defective Merchandise / Services | Consumer Disputes |
| 13.4 | Counterfeit Merchandise | Consumer Disputes |
| 13.5 | Misrepresentation | Consumer Disputes |
| 13.6 | Credit Not Processed | Consumer Disputes |
| 13.7 | Canceled Merchandise / Services | Consumer Disputes |
| 13.8 | Original Credit Transaction Not Accepted | Consumer Disputes |
| 13.9 | Non-Receipt of Cash or Load Transaction Value | Consumer Disputes |
| Reason Code | Description | External Category |
|---|---|---|
| 4808 | Authorization Related Chargeback | Authorisation |
| 4834 | Point of Interaction Error | Point of Interaction Error |
| 4837 | No Cardholder Authorization | No Cardholder Authorisation / Fraud |
| 4840 | Fraudulent Processing of Transactions | No Cardholder Authorisation / Fraud |
| 4849 | Questionable Merchant Activity | No Cardholder Authorisation / Fraud |
| 4850 | Installment Billing Dispute | Installment Billing Dispute |
| 4853 | Cardholder Disputes | Cardholder Disputes |
| 4854 | Cardholder Dispute Not Classified Elsewhere (US) | Cardholder Dispute Not Classified Elsewhere |
| 4855 | Goods or Services Not Provided | Cardholder Disputes |
| 4860 | Credit not processed | Cardholder Disputes |
| 4870 | Chip Liability Shift | No Cardholder Authorisation / Fraud |
| 4871 | Chip / PIN Liability Shift – Lost / Stolen / NRI Fraud | No Cardholder Authorisation / Fraud |
| Reason Code | Description | External Category |
|---|---|---|
| 4507 | Incorrect Charge Amount / Currency Discrepancy | Processing Errors |
| 4512 | Duplicate Charge | Processing Errors |
| 4513 | Credit not processed / No Show | Cardmember Dispute |
| 4516 | No Reply | Inquiry / Miscellaneous R03 |
| 4521 | Charge Amount Exceeds Authorisation Amount / No valid Authorisation | Insufficient Reply |
| 4523 | Unassigned Card Number | Authorisation |
| 4533 | Goods / Services Not as Described / Damaged / Defective | Processing Errors |
| 4534 | Missing Signature | Cardmember Dispute |
| 4536 | Late Submission | Fraud |
| 4540 | Card Not Present | Processing Errors |
| 4544 | Cancelled Recurring Billing | Fraud |
| 4554 | Goods / Services Not Received or Partially Received / Paid by Other Means | Cardmember Dispute |
| 4750 | Vehicle Rental - Capital Damages | Cardmember Dispute |
| 4752 | Credit Processed as Charge | Processing Errors |
| 4755 | No Cardmember Authorisation | Fraud |
| 4763 | Fraud Full Recourse Program | Fraud |
| 4798 | EMV Counterfeit | Fraud |
| 4799 | EMV Lost / Stolen / Non-Received | Fraud |
| Reason Code | Description | External Category |
|---|---|---|
| A02 | Authorization Processing Errors | Processing Errors |
| A06 | Unissued Account Number | Authorization |
| B24 | Late Presentation | Processing Errors |
| B25 | Duplicate Charge | Processing Errors |
| B26 | Alternate Settlement Currency Incorrect Exchange Rates | Processing Errors |
| B27 | Incorrect Currency | Processing Errors |
| C41 | Fraud - Card Present Transaction | Fraud |
| C42 | Fraud - Card Not Present Transaction | Fraud |
| C46 | Multiple Charges at Service Establishment Fraudulent Transaction | Fraud |
| C53 | Fraud – Chip Card Counterfeit Transaction | Fraud |
| C54 | Fraud – Lost or Stolen Chip and PIN Card Transaction | Fraud |
| D61 | Altered Amount | Processing Errors |
| D62 | Non-Receipt of Goods or Services | Consumer Disputes |
| D66 | Credit not Processed | Consumer Disputes |
| D67 | Cardmember Paid by Other Means | Processing Errors |
| D69 | Cancelled Recurring Transactions | Consumer Disputes |
| D70 | Cardmember Does Not Recognize | Consumer Disputes |
| Reason Code | Description | External Category |
|---|---|---|
| 4534 | Duplicate Processing | Processing Error |
| 4541 | Recurring Payment | Consumer Disputes |
| 4542 | Late Presentation | Processing Error |
| 4550 | Credit / Debit Posted Incorrectly | Processing Error |
| 4553 | Cardholder Disputes Quality of Goods or Services | Consumer Disputes |
| 4586 | Altered Amount | Processing Error |
| 4865 | Paid by Other Means | Processing Error |
| 4752 | Does not Recognize | Consumer Disputes |
| 4753 | Invalid Cardholder Number | Authorization |
| 4755 | Non-Receipt of Goods or Services | Fraud |
| 4866 | Fraud Chip Card Counterfeit Transaction | Fraud |
| 4867 | Fraud Chip Card and PIN Transaction | Fraud |
| 7010 | Fraud Card Present Transaction | Fraud |
| 7030 | Fraud Card Not Present Transaction | Fraud |
| 8002 | Credit Not Processed | Consumer Disputes |
| Reason Code | Description | External Category |
|---|---|---|
| 108 | Remitter a/c debited but beneficiary a/c not credited | Chargeback Raise |
| 109 | Remitter still disputes beneficiary not credited | Pre-arbitration Raise |
| 121 | TCC raised but beneficiary still not credited | Deferred Chargeback Raise |
| 128 | Chargeback on Fraudulent Transaction | Fraud Chargeback Raise |
| 1061 | Credit not processed for cancelled/returned goods/services | Chargeback Raise |
| 1062 | Goods/Services not as described/defective | Chargeback Raise |
| 1063 | Paid by alternate means | Chargeback Raise |
| 1064 | Goods or Services Not Provided / Not Received | Chargeback Raise |
| 1065 | A/c debited but confirmation not received at merchant | Chargeback Raise |
| 1081 | Transaction not settled within timeframes | Chargeback Raise |
| 1084 | Duplicate / Multiple Transaction | Chargeback Raise |
| 1085 | Charged more than transaction amount | Chargeback Raise |
| 1097 | Services still not delivered (customer claim) | Pre-arbitration Raise |
| Reason Code | Description | External Category |
|---|---|---|
| 1061 | Credit not processed for cancelled or returned goods and services | Chargeback Raise |
| 1062 | Goods and Services not as described / defective | Chargeback Raise |
| 1063 | Paid by alternate means | Chargeback Raise |
| 1064 | Goods or Services Not Provided / Not Received | Chargeback Raise |
| 1065 | Account debited but transaction confirmation not received at merchant | Chargeback Raise |
| 1081 | Transaction not settled within specified timeframes | Chargeback Raise |
| 1084 | Duplicate / Multiple Transaction | Chargeback Raise |
| 1085 | Cardholder was charged more than the transaction amount | Chargeback Raise |
| 1097 | Customer still claims services not delivered | Pre-arbitration Raise |
General documents required for the representation of disputes
| Document Name | Description |
|---|---|
| Delivery/Service Proof | Proof that the customer received goods/services (e.g., signed delivery confirmation). |
| Shipping Proof | Evidence goods were shipped to the validated address. |
| Statement of Service | Wallet/account statement where funds were loaded by the customer. |
| Proof of Service Used | Customer acknowledgement of services used (e.g., recurring transactions). |
| Cancellation of Service Proof | Evidence customer cancelled before delivery date. |
| Refund Proof | Refund details if processed via other mode. |
| Business Model Explanation | Letter explaining your business flow post-payment. |
| Extra Charges Declaration | T&Cs stating applicability of extra charges. |
| Terms & Conditions | Refund/cancellation policies. |
| Customer Withdrawal Letter | Proof that the customer no longer disputes / issue resolved. |
| Certificate of Authenticity | Manufacturer proof products sold are genuine. |
| Reseller Agreement | Legal authorization to sell manufacturer products. |
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