Effective Date: July 2025  Issued by: Quadropay Ltd, Registered Office: 8 Stanley Street, Bourne PE10 9BL, United Kingdom

1. Purpose and Scope

This Risk Policy outlines Quadropay Ltd’s approach to identifying, assessing, and mitigating risks associated with its role as a non-bank intermediary—specifically, a broker of banking and payment services. The policy applies to all client engagements, third-party partnerships, and internal operations that support the sourcing and facilitation of payment solutions.

2. Business Model and Risk Exposure

Quadropay operates as a broker, not a direct provider, of financial services. We connect merchants with acquiring banks, payment gateways, and financial institutions across multiple jurisdictions. This model inherently involves third-party risk, regulatory exposure, and reputational considerations, particularly in high-risk verticals such as gaming, recurring billing, and cross-border e-commerce.

3. Risk Categories and Controls

3.1 Regulatory and Compliance Risk

•      We conduct due diligence on all acquiring and banking partners to ensure alignment with applicable AML, KYC, and data protection regulations.

•      Quadropay does not onboard merchants directly; instead, we facilitate introductions and support documentation for compliance vetting by licensed financial institutions.

3.2 Operational Risk

•      Our internal processes are designed to align with our providers and ensure secure and efficient transmission of merchant data to acquiring partners.

3.3 Reputational Risk

•      We avoid engagement with merchants or sectors that may compromise the integrity of our partner network.

•      All marketing and client communications are reviewed to ensure transparency regarding our role as a broker, not a licensed financial institution.

3.4 Credit and Fraud Risk

•      As Quadropay does not hold or process funds, we do not assume credit or chargeback liability.

•      We advise merchants on fraud prevention tools and risk mitigation strategies offered by acquiring partners.

4. Partner Due Diligence

We maintain a curated network of acquiring banks and payment service providers. Each partner undergoes a structured onboarding process, including:

•      Jurisdictional risk assessment

•      Licensing and regulatory status verification

•      Sectoral expertise and risk appetite alignment

5. Merchant Risk Profiling

Quadropay supports acquiring partners by conducting preliminary merchant profiling, including:

•      Business model analysis

•      Transaction volume forecasting

•      Sector classification (low, medium, high risk)

6. Governance and Review

This policy is reviewed annually or upon material change in regulatory landscape or business operations. The Risk and Compliance Lead is responsible for ensuring adherence and recommending updates.