FREENOW Fraud Policy

1 Purpose
This regulation is defined for the purpose of communicating FREENOW’s stance and processes in respect to fraud.

FREENOW has put in place a fraud prevention system which takes appropriate measures to deter fraud, maintain necessary procedures to detect fraud, investigate all instances of suspected fraud and report all suspected fraud to the appropriate authorities, when required (the “Fraud Policy”, or “this Policy”).

2 Scope
The Fraud Policy applies to:

• Independent Taxi or PHV Drivers registered in the FREENOW platform; and
• Independent Taxi or PHV Drivers in the onboarding phase (i.e., in the process of being registered in the FREENOW platform).

Both categories hereinafter referred to as the “Drivers”, each a “Driver”, and/or “you”.

3 Fraudulent Activities
The Fraud Policy covers the following fraudulent activities and gives a general overview of the situations and/or acts that FREENOW may consider as deceitful.
FREENOW reserves the right to amend the list of fraudulent activities listed below, in which case FREENOW will notify you in respect of such change. Fraudulent activities may include, but are not limited to, the following activities.

• Priority/Turbo Fraud: whereby the Driver creates fake tours during peak time to enhance their performance (e.g. where the Driver uses passenger details that belongs or relates to the Driver).
• Quest Fraud: whereby the Driver cooperates with a passenger to create a fake tour from the original tour, which involves the splitting the original tour into two or more tours for the purposes of the Driver attempting to reach the minimum threshold for additional bonuses.
• Voucher Fraud: whereby the Driver creates fake bookings and uses vouchers as a payment method to achieve a higher pay out.
• Overcharges: whereby the Driver charges an amount to the passenger which is not matching to the average time distance fare. All overcharges have a higher distance or minute rate.
• Repeated Cooperation with a Fraudster: whereby the Driver repeatedly cooperates with a passenger to fulfil rides that are arranged via phone before the dispatch happens. This involves a situation where there is no random allocated booking and the Driver and the passenger agree on the pickup point in advance. Therefore, the tour is not considered to have followed the corresponding process within the FREENOW App. FREENOW only considers repeated behaviours as fraudulent.
• Commission Fraud / Cash Under Reporting: includes, but is not limited to, instances whereby the Driver receives a cash tour from a genuine passenger and provides a lower cash value to avoid commission or closes a tour earlier in order to provide a lower value.
• Cancellation Fraud: whereby the Driver cancels tours to achieve a scrub (cancellation compensation) or to disrupt the service and/or other drivers.
• Rating Fraud: whereby the Driver creates tours from fake or personal accounts and rates his/her service.
• Device and App Manipulation: whereby the Driver uses third party app software and hacks FREENOW’s app or services in order to simulate different locations, or the Driver uses software to automate in app function.
• Money Laundering: whereby the Driver or a company uses the FREENOW app to launder money from other sources. Instances of Money Laundering might involve the creation of a fake service, or passenger, to conceal the actual money source.
• Duplication of Accounts: whereby dummy or duplicate accounts are created for fraudulent purposes.

4 Managing Violations
The process below explains what actions, among others, FREENOW may take if it considers that the Driver has attempted, or has committed, a fraudulent activity as described in this Policy. FREENOW reserves the right to change the actions below in which case we will
notify you:

• FREENOW reserves the right to restrict or suspend the provision of its services to the Driver where multiple instances of fraudulent activities have been identified;
• FREENOW will provide the driver with a statement of reasons if FREENOW restricts or suspends the provision of its services to the Driver in response to identified instances of fraudulent activities;
• Where FREENOW has restricted or suspended the Driver after having provided a statement of reasons in relation to same, FREENOW shall provide the Driver an opportunity to clarify the facts surrounding the decision by FREENOW to take action against the Driver via FREENOW’s internal complaint-handling process and, following such a process, if FREENOW’s decision to restrict or suspend the Driver is revoked, the Driver’s access to such restricted or suspended services will be reinstated without undue delay;
• FREENOW reserves the right to terminate the provision of its services to the Driver where it has been identified that the Driver has carried out fraudulent activities;
• Where FREENOW decides to terminate the provision of its services to Drivers, it shall provide at least 30 days’ notice to Drivers that includes a statement of reasons for that decision, with the only exception to this being if, for example, Free Now is subject to a legal or regulatory obligation not to provide the specific facts or circumstances or the reference to the applicable ground or grounds, or if it can be demonstrated that the business user being terminated has repeatedly infringed the applicable terms and conditions, resulting in termination of the provision of the whole of the online intermediation services in question;
• Where FREENOW has terminated the Driver, FREENOW shall provide the Driver an opportunity to clarify the facts surrounding the decision by FREENOW to take action against the Driver via FREENOW’s internal complaint-handling process, and, following such a process, if FREENOW’s decision to terminate the Driver is revoked, the Driver’s termination will be reversed without undue delay.

The standard notice period of 30 days shall not apply where FREENOW has, in accordance with the process set out in this Policy, determined that the Driver has repeatedly breached this Policy, and/or has repeatedly engaged in fraudulent activities, and FREE NOW proceeds to the termination of the provision of its services.

In accordance with the procedure set out in this Policy, FREENOW reserves the right, in its sole discretion, to withhold any payment to the Driver that is deemed to arise out of, or in connection with, any fraudulent activity of the Driver. FREE NOW will provide the Driver an opportunity to clarify facts and appeal such a decision by FREENOW via FREENOW’s internal complaint-handling process.

FREENOW may, in its sole discretion, put a hold on the Driver’s account or switch the status of the Driver’s account to ‘inactive’ until FREENOW completes a review for the purposes of assessing whether the Driver has committed a fraudulent activity. FREENOW will provide the Driver with a statement of reasons for that decision, an opportunity to clarify facts and appeal such a decision by FREENOW via FREENOW’s internal complaint-handling
process.

5 Roles & Responsibilities
You as the Driver must comply with the relevant regulations and policies that FREENOW may implement from time to time.
If you do not do so, FREENOW may restrict, suspend or terminate the provision of its services to you and withhold any payment to you that is deemed to arise out of, or inconnection with, any fraudulent activity as a Driver.

6 Fraud Policy
This document and this Policy therein, applies to Drivers, and sets out the policy and procedures of FREENOW against fraud and other forms of dishonesty. However, anybody associated with the Driver who commits fraud, theft or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action.

Valid from 27 March 2023