KEY REGULATIONS AND POLICIES

The following description is a summary of certain key regulations and policies prescribed by the Government
which are applicable to our Company and the Subsidiaries in India. The information detailed in this section has
been obtained from publications available in the public domain. The regulations set out below may not be
exhaustive, and are only intended to provide general information to the investors and are neither designed nor
intended to substitute for professional legal advice. The information in this section is based on the current
provisions of applicable law that are subject to change or modification by subsequent legislative, regulatory,
administrative or judicial decisions in India. For details regarding the registrations and approvals obtained by
our Company and our Material Subsidiary under applicable laws and regulations, see “Government and Other
Approvals” on page 384.

Payment and Settlement Systems Act, 2007 (the “PSS Act”)

The PSS Act and the rules made thereunder regulate and supervise the payment and settlement systems in India.
Under the PSS Act, a “payment system” means a system that enables payment to be effected between a payer
and a beneficiary, involving clearing, payment or settlement services or all of them and includes systems which
enable credit or debit or smart card operations, money transfer operations or similar operations and a “system
provider” means a person who operates an authorized payment system. The PSS Act is not applicable to stock
exchanges or the clearing corporations of the stock exchanges.

Any person who wishes to operate a payment system is required to apply for an authorization from the RBI
under the PSS Act. If a system provider fails to comply with the provisions of the PSS Act, the terms of the
authorization and orders or directions issued by the RBI, then the RBI may revoke the authorization given to
such system provider. The RBI may also impose fines and initiate criminal prosecution in case of any such non-
compliance.

Further, pursuant to notifications dated April 6, 2018, the RBI has (i) prescribed certain minimum standards for
the service providers and sub-contractors engaged by the banks for cash management logistics; (ii) prohibited all
entities regulated by it from dealing in virtual currencies or providing services for facilitating any person or
entity in dealing with or settling virtual currencies; and (iii) directed all system providers to ensure that the data
relating to payment systems operated by them are stored in a system only in India. However, such data may also
be stored in the foreign country, if required, for the foreign leg of the transaction, if any.

Through a notification dated January 31, 2019, RBI introduced the “Ombudsman Scheme for Digital
Transactions”, which establishes a mechanism of ombudsman for redressal of complaints against deficiencies in
services related to digital transactions. On May 15, 2019, the RBI published ‘Payment and Settlement Systems
in India: Vision 2019-2021” (the “Vision-2021”) with the theme of ‘Empowering Exceptional (E) payment
Experience’. Vision-2021 concentrates on a two-pronged approach of exceptional customer experience and
enabling an eco-system which will result in such customer experience.

Issuance and Operation of Pre-Paid Payment Instruments

Issuance and operation of pre-paid payment instruments (“PPI”) is currently regulated by the Master Direction
on Prepaid Payment Instruments (PPIs) issued by the RBI on August 27, 2021, as amended (the “PPI Master
Direction”).

The PPI Master Direction defines PPIs to mean instruments that facilitate the purchase of goods and services,
including financial services and remittance facilities against the value stored on such instruments. PPIs that
require prior RBI approval/ authorization prior to issuance are classified under two categories:

@ Small PPIs: Issued by banks and non-banks after obtaining minimum details of the PPI holder, and can
be used only for purchase of goods and services at a group of clearly identified merchant locations/
establishments which have a specified contract with the PPI issuer (or contract through a payment
aggregator/ payment gateway) to accept the PPIs as payment instruments);

(ii) Full-KYC PPIs: Issued by banks and non-banks after completing KYC of the PPI holder, and can be used
for purchase of goods and services, funds transfer or cash withdrawal.

The issuance of closed system PPIs is not classified as a payment system that requires authorization from the
RBI. Closed System PPIs cannot be used for payment or settlement for third party services.

177
