FREENOW Fraud Policy

1. Purpose

This regulation is defined for the purpose of communicating FREE NOW’s stance and
processes in respect to fraud.

FREE NOW 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 FREE NOW platform; and
● Independent Taxi or PHV Drivers in the onboarding phase (i.e., in the process
of being registered in the FREE NOW 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 FREE NOW may consider as deceitful.
FREE NOW reserves the right to amend the list of fraudulent activities listed below, in which
case FREE NOW 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 FREE NOW
App. FREE NOW 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 FREE NOW’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 FREE NOW 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, FREE NOW may take if it considers
that the Driver has attempted, or has committed, a fraudulent activity as described in this
Policy. FREE NOW reserves the right to change the actions below in which case we will
notify you:
● FREE NOW reserves the right to restrict or suspend the provision of its services to the
Driver where multiple instances of fraudulent activities have been identified;
● FREE NOW will provide the driver with a statement of reasons if FREE NOW
restricts or suspends the provision of its services to the Driver in response to identified
instances of fraudulent activities;
● Where FREE NOW has restricted or suspended the Driver after having provided a
statement of reasons in relation to same, FREE NOW shall provide the Driver an
opportunity to clarify the facts surrounding the decision by FREE NOW to take action
against the Driver via FREE NOW’s internal complaint-handling process and,
following such a process, if FREE NOW’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;
● FREE NOW 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 FREE NOW 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 FREE NOW has terminated the Driver, FREE NOW shall provide the Driver
an opportunity to clarify the facts surrounding the decision by FREE NOW to take
action against the Driver via FREE NOW’s internal complaint-handling process, and,

following such a process, if FREE NOW’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 FREE NOW 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, FREE NOW 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 FREE NOW via FREE NOW’s
internal complaint-handling process.

FREE NOW 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 FREE NOW completes a review for the purposes of
assessing whether the Driver has committed a fraudulent activity. FREE NOW will provide
the Driver with a statement of reasons for that decision, an opportunity to clarify facts and
appeal such a decision by FREE NOW via FREE NOW’s internal complaint-handling
process.

5. Roles & Responsibilities

You as the Driver must comply with the relevant regulations and policies that FREE NOW
may implement from time to time.

If you do not do so, FREE NOW 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 in
connection 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
FREE NOW 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 21 December 2022