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RN Wellness COMPLAINTS HANDLING AND BUSINESS CONDUCT POLICY DATED JULY 2021

This Policy relates to RN Wellness complaints handling and business conduct policies and procedures (“Business Conduct Policy”). This Policy is solely for the purpose of providing general information and is not in any way legally binding either on RN Wellness and/or any other person(s) (natural or otherwise). This Business Conduct Policy is drafted on the 21st day of July of 2021 and may not take into account any legal and/or further regulatory change(s) relating to Payment Service Provider Licence licensees after the 21st day of July 2021.

We are guided by MAS Notice No. PSN07 and MAS Notice No. PSN08.

Part I: Business Conduct

A. Record of transactions

We shall keep a record in the English language containing all the information set out in Annex A of MAS Notice No. PSN07 – in respect of any transaction for DPT service, we shall record:

  1. the date of transaction;
  2. the type of transaction (DPTs bought or sold);
  3. the total amount of money or DPTs received by us and where we did not receive Singapore dollars, the equivalent amount in Singapore dollars, and the exchange rate applied to determine the Singapore dollar equivalent, with a breakdown of the following:
    1. the amount of money or DPT received by the payee, in the currency or DPT received by the payee, the exchange rate applied to convert the currency or DPT received by us to the currency or DPT transferred to the payee;
    2. the amount of commission and other service charges in Singapore dollars, if any;
  4. the date of receipt of money or DPT by payee.

B. Issuance of receipts

We will, within 90 days, issue a receipt containing the information set out in Annex B of MAS Notice No. PSN07 for every transaction that we accept, process or execute to a customer –

  1. where the customer is an individual or sole-proprietor; and
  2. in all other cases, whether the customer requests a receipt.

The aforesaid receipt shall include:

  1. our business name;
  2. our contact details such as our address, telephone number and electronic mail address;
  3. the date of receipt of money or DPT from customer
  4. the total amount of money or DPTs received by us, the amount of money or DPT received by the payee in the currency or DPT received by the payee, the exchange rate applied to convert the currency or DPT received by us to the currency or DPT transferred to the payee;
  5. the amount of commission and other service charges, if any;
  6. transaction reference number, or whether no transaction reference number is available, all of the following information –
    1. the name of the customer and contact details of the customer such as address, telephone number and electronic mail address; and
    2. the name of the payee and contact details of the payee such as address, telephone number and electronic mail address.

C. Display of exchange rate and fees

We will display prominently the following information such that a customer or potential customer would have notice of such information before using our service:

  1. the exchange rate which we are offering in respect of any purchase or sale of a DPT; and
  2. any separate fee that we will charge for the provision of the payment service.

Where we do not offer an exchange rate, we will disclose in writing to the customer that the exchange rate will be determined by a third party. In furtherance of this disclosure, we shall:

  1. publish such disclosure once in a publicly available material issued by us;
  2. provide such disclosure to a potential customer prior to the potential customer using the payment services provided by us;
  3. provide such disclosure at least once in writing to any customer where such customer was not provided the statement set out directly above at paragraph
  4. not obstruct or obscure such disclosure, or embedded it within other unrelated writing; and
  5. have the content of such disclosure be of reasonable size and typeface.

D. Notification of normal business hours

We will notify all our customers and potential customer of our normal business days and hours and any changes to our business days and hours by:

  1. publishing the notification in publicly available material; and
  2. displaying prominently the notification such that a customer or potential customer would have notice of such information prior to using our services.

E. Informing the Authority of change(s) in Form 1

We will inform the Monetary Authority of Singapore of any change(s) in any of the information provided by us in Form 1 for the purposes of section 15(1)(f) of the Payment Services Act (No. 2 of 2019).


F. Operating hours

We shall operate at our permanent place of business on usual business days, from 9.00am to 5.00pm (excluding days where our premises are closed to comply with designated circuit-breaker measures). We will inform our customers in writing of any changes related to the aforesaid.

Part II: Corporate Disclosures and Communications

A. Mandatory disclosure prescribed by MAS Notice No. PSN08***

RN Wellness will:

  1. in its website; and
  2. in all official correspondence(s) with our customers and potential customer(s),

provide the following statement:

“RN Wellness is licensed by the Monetary Authority of Singapore to provide digital payment token service. Please note that this does not mean you will be able to recover all the money you paid to RN Wellness if GBEX’s business fails.”


B. Risk warning statement

We will, in accordance with MAS Notice No. PSN08, provide all our customers and potential customers with the risk warning statement set out in Annex A1 of MAS Notice No. PSN08 (as of 14 May 2020 and as provided for in Annexure A of this Policy) in the following manner:

  1. the aforesaid risk warning statement will be published on our website;
  2. the aforesaid risk warning statement will be provided to a potential customer prior to them signing up and/or being on-boarded for our service;
  3. the aforesaid risk warning statement will be of reasonable size and typeface.

C. Accurate representation of scope of licence

When RN Wellnessmakes a representation in respect of the scope of its regulation by the Monetary Authority of Singapore in any publicly available material, we will at all times ensure that the representation is accurate and not false or misleading.

We will not misrepresent the scope of the activities that we are licensed to carry out.

We will state clearly that it is RN Wellnessand not any other entity related to GBEX) that holds the licence under the Singapore Payment Services Act 2019 (No. 2019)


D. Fulfilment of correction request*

Where the Monetary Authority of Singapore has informed us that a third party has made a false or misleading statement in respect of our scope of regulation, we will request the third party to correct the statement.

Annexure A

DIGITAL PAYMENT TOKEN SERVICE RISK DISCLOSURE

Annex 1A

RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES

The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a digital payment token (DPT) service provider.

Before you pay your DPT service provider any money or DPT, you should be aware of the following.

  1. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider if your DPT service provider’s business fails.
  2. You should not transact in the DPT if you are not familiar with this DPT. Transacting in DPTs may not be suitable for you if you are not familiar with the technology that DPT services are provided.
  3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.