Complaint Handling Procedure

Purpose

This document describes how WithLess receives, manages, investigates, and resolves customer complaints, in line with applicable Italian regulatory requirements.

The objective is to ensure complaints are handled fairly, transparently, and within regulatory deadlines, while maintaining a proportionate and efficient operational approach.

Definition of a Complaint

A complaint is any expression of dissatisfaction, whether justified or not, addressed to WithLess in relation to its services, even in the absence of a contractual relationship, in line with the definition provided by the Arbitro Bancario Finanziario (ABF).

Complaints may relate to, among others:

• WithLess services or products
• Account, card, or transaction handling
• Delays or failures in processing transactions or requests
• Customer support or communication

Any request containing implicit or explicit dissatisfaction is treated as a complaint.

Complaints may be submitted by:

• End users (consumers and micro-businesses with fewer than 10 employees and annual turnover ≤ €2M)
• Third parties (where applicable)

Complaints Department – Contact Details

Complaints must be addressed to the WithLess Complaints Department through the following dedicated channels:

• Email: info@withless.com
• Postal address: Via Amilcare Ponchielli 51, 24125 Bergamo (BG), Italy

These contact details are communicated to customers on the WithLess website, app, and in relevant contractual documentation.

Complaint Handling Process

Intake and Logging

• Complaints are received via official WithLess support channels (e.g. email, Freshdesk, or other designated channels).
• All complaints are logged in Freshdesk and tracked until final resolution.
• Each complaint is classified upon receipt based on: origin of the request, product/service involved, and type of grievance raised.
• A dedicated complaints register is maintained in accordance with ABF requirements, recording for each complaint: date of receipt, identity of the complainant, nature and subject, outcome and resolution date, and any escalation to the ABF or other competent authority.

Acknowledgement

• An acknowledgement of receipt is sent to the complainant without undue delay upon receipt of their complaint.

The acknowledgement includes:

• Confirmation of receipt and the complaint reference number
• Maximum response timeframes (no later than 15 business days, or up to 35 business days in exceptional PSD2 cases)
• Contact details of the department handling the complaint
• Information on escalation rights and procedures (including ABF recourse, where applicable)
• A link to the WithLess website page detailing the complaint handling framework

• Ownership of the complaint remains with Customer Success throughout the process.

Investigation

• The complaint is reviewed and investigated based on its nature and scope.
• The processing scope is identified: complaints relating to Treezor's T&Cs are forwarded to Treezor; those relating to WithLess's T&Cs are handled internally. Overlapping complaints are split accordingly.
• Relevant internal teams (e.g. Compliance, Technical, Operations) and, where necessary, banking partners are involved.
• Investigation steps and findings are documented in Freshdesk.

Resolution and Response

A clear, factual, and reasoned response is provided to the complainant within the following regulatory deadlines (calculated in business days):

• 15 business days for PSD2-related complaints (wire transfers, bank cards, direct debits, electronic payments)
• Up to 35 business days in exceptional PSD2 cases — an interim communication explaining the delay must be sent before the initial 15-day deadline
• 60 business days for non-PSD2 complaints (e.g. KYC, account switching, general banking transparency)

• In case of exceptional delay, an interim explanatory communication is sent before the initial deadline expires, specifying the final response date.
• Corrective or preventive actions are implemented where appropriate.
• All responses are logged in Freshdesk.

Escalation and Oversight

Complaints are escalated when:

• They cannot be resolved by Customer Success
• Compliance or regulatory risks are identified

Where the complainant is eligible, information on escalation to the ABF is provided. Eligibility covers:

• Natural persons (consumers)
• Micro-businesses with fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million

To refer a case to the ABF, the complainant must first exhaust WithLess's internal channels, then:

• Submit their case online via the ABF portal: https://www.arbitrobancariofinanziario.it
• Or submit a written application to the competent ABF secretariat

The ABF Practical Guide (Guida Pratica all'ABF) is available on the ABF website and will be provided by WithLess to any eligible complainant upon request.

Any response that fully or partially rejects the complainant's request must include information on ABF recourse and the possibility of civil action.

All escalations and outcomes are documented.

Record Keeping and Review

• All complaints, responses, and supporting documentation are retained in Freshdesk for a minimum of 10 years, in accordance with applicable Italian regulatory requirements.
• Complaint data is periodically reviewed to identify recurring issues and areas for service improvement.

Annual Reporting

To comply with Banca d'Italia transparency rules, WithLess prepares an annual complaints report and submits it to the banking partner and competent authorities upon request. The report covers:

• Total number of complaints received, by product and cause
• Outcomes (accepted / rejected / partial)
• Average response times, with adherence to the 15-business-day rule
• Total compensation awarded
• Systemic issues identified and corrective actions taken

Key Principles

Complaint handling at WithLess is based on:

• Transparency
• Accountability
• Timely and compliant resolution (deadlines calculated in business days)
• Clear documentation and traceability
• Continuous improvement through data-driven review