COMPLAINTS AND DISPUTES
JFK IMPORT-EXPORT LLC — CONFIRMA

*** Draft for review. These documents were prepared as a starting point and have not been reviewed by a lawyer. Do not execute or publish any of them without review by qualified counsel in each relevant jurisdiction — the United States for the entity, the Democratic Republic of the Congo for the counterparties, and any jurisdiction whose law a counterparty insists upon. ***


## Raising a complaint

Write to legal@[DOMAIN] with your company name, what happened, and what you want done. Include the request identifier if you have one — every response from the platform carries one, and it lets us reconstruct exactly what occurred.

## What we do

We acknowledge within 2 business days, investigate, and give a reasoned answer within 20 business days. If we need longer we tell you why and when to expect an answer.

## Having a refused invoice reviewed

If we declined to purchase an invoice, you may ask a person to review the decision. Say so in your complaint. The review is carried out by someone who was not involved in the original decision.

We will tell you the outcome. Where the refusal relates to fraud prevention, sanctions screening or anti-money-laundering obligations, we may be limited in what we can explain, and we will say so plainly rather than inventing a different reason.

A refusal to purchase is a commercial decision. It does not affect any right you hold against the operator that owes the invoice, and that debt remains yours to collect.

## Reporting suspected fraud

If you believe an invoice, a document or a person is being used fraudulently — including by someone inside your own organisation — write to legal@[DOMAIN] with the subject line beginning INTEGRITY. These are read first.

Where we find an irregularity inside an operator's payables, we report it to that operator's internal audit at no charge.

## If we cannot agree

Disputes that cannot be resolved are referred to arbitration seated in Wilmington, Delaware, United States under the International Centre for Dispute Resolution (ICDR), in English, before a single arbitrator, under State of Delaware, United States. Either party may still apply to the Court of Chancery of the State of Delaware, or where it lacks jurisdiction, the state and federal courts sitting in Delaware or any other competent court for urgent interim relief.

We will not treat a counterparty less favourably for having complained.

Effective 19 August 2026.