Chargeback & Dispute Resolution Policy

CHARGEBACK AND DISPUTE RESOLUTION POLICY - GOATCOM

1. Introduction and Objective

1.1. This Chargeback and Dispute Resolution Policy ("Policy") establishes the guidelines, procedures, and responsibilities of Goatcom, as a sub-acquirer (sub-creditor), regarding the contesting of payment transactions carried out through its platform.

1.2. Although Goatcom is not a Payment Institution directly approved by the Central Bank of Brazil (BACEN), this policy was prepared in strict compliance with BACEN's rules governing payment arrangements, especially BCB Resolution No. 150/2021 and its subsequent updates, such as BCB Resolution No. 522/2025, which establish the regulatory framework for all participants in the payment chain.

1.3. The fundamental objective of this Policy is to establish a robust normative and operational framework that ensures transparency, legal certainty, and efficiency in handling disputes, equitably protecting the interests of all participants in the payment arrangement, including paying users, receiving users (merchants), issuers, and Goatcom itself.

1.4. As a sub-acquirer, Goatcom plays a critical role in the payment chain, acting as the connecting link that enables merchants to accept various payment instruments, managing not only the financial flow but also the mitigation of operational risks and compliance with payment arrangement rules and anti-money laundering and combating the financing of terrorism (AML/CFT) regulations.

2. Fundamental Definitions

2.1. For the purposes of this Policy, the following definitions are adopted, in accordance with the current regulatory framework:

• Chargeback: It is the reversal or cancellation of a payment transaction at the request of the paying user or the issuer of the payment instrument. It may result from fraud, scam, processing failure, authorization failure, or commercial disagreement.
• Dispute: Administrative process initiated when there is a transaction dispute, in which the involved parties present evidence to prove the legitimacy or irregularity of the operation.
• Sub-acquirer (Sub-creditor): Entity that enables receiving users (merchants) to accept payment instruments, acting as an intermediary between the establishment and the acquirer. Operates under the indirect supervision of BACEN.
• Commercial Disagreement: Situation in which the paying user alleges that the product or service was not delivered, was delivered defective, or does not correspond to what was advertised.

3. Dispute Process Flow

3.1. The dispute resolution process at Goatcom is governed by a rigorous and structured administrative procedure, designed to ensure the exercise of contradictory and ample defense, while guaranteeing strict compliance with the deadlines established by payment arrangement institutors.

3.2. The flow begins with the Contestation Notification, at which point Goatcom, upon being informed by the acquirer about the intention of reversal, proceeds to immediately signal the merchant through secure digital channels.

3.3. Subsequent to the notification, the Evidentiary Instruction phase opens, in which the establishment has a predefined period to collect and submit all documentary evidence of the transaction. The absence of timely manifestation results in the automatic loss of the right to dispute.

3.4. After receipt, Goatcom performs a Technical Compliance Analysis, verifying whether the evidence (access logs, delivery receipts, invoices) has probative force. Once validated, the defense is transmitted to the acquirer for presentation to the card issuer, who holds the final decision-making prerogative.

4. Merchant Responsibilities

4.1. The receiving user (merchant) assumes the leading role in mitigating operational risks and preventing fraud. It is imperative that the establishment adopts rigorous practices of documentary governance and customer service.

4.2. The establishment's responsibility extends throughout the entire transaction lifecycle, requiring the maintenance of an organized archive of all transactional records, including electronic invoices, transaction logs, signed delivery receipts (AR), and communication histories.

4.3. The establishment must ensure that its cancellation, exchange, and refund policies are presented clearly and conspicuously to the final consumer before the conclusion of any transaction, in compliance with the Consumer Defense Code (CDC).

4.4. Timely Response to Goatcom's requests is an undeniable contractual obligation; silence or inertia within the stipulated deadlines will be interpreted as tacit acceptance of the irregularity, authorizing the immediate debit of the contested amounts.

5. Risk Management and Financial Retentions

5.1. In compliance with Article 24 of BCB Resolution No. 150/2021, Goatcom implements a robust system for monitoring and controlling chargebacks to identify patterns of fraud or operational failures.

5.2. Index Monitoring evaluates the transactional volume versus the volume of contests. If it exceeds the tolerance thresholds (commonly 1%), Goatcom will initiate a Risk Mitigation Plan, which may include audits or contract termination.

5.3. Goatcom reserves the prerogative to institute a Financial Reserve (Rolling Reserve), which consists of the temporary retention of a portion of receivables as a guarantee fund to cover eventual future contests.

5.4. Regarding Chargeback Debit, Goatcom will proceed with the automatic financial compensation of any contested amount directly from the establishment's credit balance. In case of insufficient funds, the establishment remains indebted, authorizing discounts in future settlements or credit recovery measures.

6. Regulatory Deadlines and Limits of Liability

6.1. According to BCB Resolution No. 522/2025, the financial responsibility of participants for chargeback observes specific criteria for risk allocation.

6.2. The 180-Day Period constitutes the temporal limit for the direct financial responsibility of participants. Any chargeback request initiated within this interval will be processed under the responsibility of the recipient, if the dispute is lost.

6.3. For contests that occur After 180 Days, financial responsibility is transferred to the arrangement institutor (card brand), respecting the specific regulations of each arrangement.

6.4. There is a Prohibition in Cases of Bankruptcy, a systemic protection that prohibits the incidence of chargeback when the dispute arises from commercial disagreements originating from the declaration of bankruptcy or civil insolvency of the receiving user.

7. Final Provisions

7.1. This policy is an integral part of Goatcom's Acquiring Agreement. Goatcom reserves the right to change this Policy at any time to adapt to new Central Bank regulations or changes in card brand rules.

7.2. Goatcom reaffirms its commitment to the security of the Brazilian payment ecosystem, acting diligently in combating fraud and fairly resolving commercial conflicts.

7.3. GOAT COMMERCE LTDA - CNPJ: 60.126.754/0001-14