Vintage Cash Cow

(trading name of Vintage Trading Solutions Limited)

Anti-Money Laundering Policy Document (United Kingdom)

PURPOSE

VintageCash Cow (“The Company”) is the trading name of Vintage Trading Solutions Ltd of 20-22 Bridge End, Leeds, West Yorkshire LS1 4DJ (Company number: 03862799), and which trades from its premises in Gildersome, Leeds, West Yorkshire.

The Company operates a service to private customers (as against businesses) who send to The Company vintage items which they wish to have appraised, with the purpose of agreeing with The Company a price for their sale to The Company. Following appraisal by The Company, the contents of the box are either purchased by The Company or returned to the Customer.

Among the items which The Company purchases on a regular basis are items of jewellery, including gold and silver, as well as other higher value items. The Company purchases the full contents of a box, rather than individual items.

This Policy is designed to ensure that The Company is not being used as a conduit for Money laundering, Terrorist activity, Sanction evasion, Handling stolen property and/or any other criminal activity.

The Company is cognisant of the possible risk that a criminal may attempt to use The Company as a means (for example) of selling stolen property to The Company and it is determined to ensure that any such risk is minimised by the preventative and pro-active actions it takes.

This policy defines what checks and balances The Company regularly adopts in order to comply with its legal obligations when purchasing items from the Customer (including second-hand goods, precious metals, gold, jewellery and watches) and thereafter making payment to the Customer for the items it has agreed to buy.

RISK

The Business assesses, on an ongoing basis, the risk of Money laundering and other financial crime. It is vigilant in its approach, without being unduly and deliberately intrusive. It is a delicate balance which the Company applies fairly and justly but with the consistent emphasis on crime prevention and strict legal compliance.

The Company adopts a risk-based approach which involves a proportionate response to any perceived risk. That risk can manifest itself in (by way of example only) the manner or approach of the Customer; the nature and/or value of the item(s); the source of the items and payment details.

The Company remains alert at all times to all such risks. In assessing risk, the Company will take into account the following indicative signs (though this, once again, is not intended as an exhaustive list):

• An unwillingness on the part of the Customer to provide ID or other relevant documents or information to The Company.
• A Customer providing any details of any nature which alert The Company to inconsistency or unreliability.
• A Customer hesitating to answer relevant questions and/or becoming aggressive in manner.
• A Customer who is, or is suspected of being, a PEP or sanctioned person.
• Evidence of repeated selling.
• The nature of the items and, in particular, their intrinsic value and portability.
• No clear explanation for their source, though new or almost new.
• Items that have serial numbers removed.
• Any items associated with theft or organised crime.
• Repeat selling by the same customer.
• A reluctance or inability to verify the KYC information requested by The Company.

ENHANCED DUE DILIGENCE

This policy distinguishes between simple due diligence and enhanced due diligence. The line drawn for this purpose between those two levels of due diligence is when the value of any box purchased is £2,500 (two thousand five hundred pounds) or more as a single transaction or, in the case of more than one transaction by the same customer in a period of twelve months, the aggregated sum paid (i.e. the total sum of all sales in that period) exceeds the sum of £2,500 (two thousand five hundred pounds).

Accordingly:

• Simple Due Diligence: Price agreed for one Box (or a number of boxes in a twelve-month period) no more than £2,500.
• Enhanced Due Diligence: Price agreed for one Box (or a number of boxes in a twelve-month period) in excess of £2,500.

Simple Due Diligence is applicable in any case, whatever the value. The name and address are obtained as a matter of course but, if the Company becomes aware of any aspect of the Customer or the intended transaction that raises any genuine suspicion, it may seek further clarification and/or not continue with any transaction and terminate any contact with the Customer. It also reserves its right to report any suspicious activity to the appropriate authorities at any time.

Enhanced Due Diligence will be automatically carried out by the Company when a ‘deal’ between the Company and the customer is reached and The Company agrees to purchase the Customer’s Box with a value in excess of £2,500 (or the aggregated sums in the course of the last twelve months payable to the same Customer amount to a sum in excess of £2,500 in total).

There are no exceptions to this process, regardless of whether the Customer had been subject previously to the same process. Enhanced due diligence follows a prescribed and documented process in order to avoid any criminal activity of the nature referred to above and is always undertaken prior to any payment being made by The Company to the Customer.

In the case of Enhanced Due Diligence, the Customer will be asked for the following (and the responses documented):

• The fullest details regarding the source of the item(s), including any documentary evidence in support.
• Verifiable ID, being their own current Passport/Photographic Driving Licence.
• In addition, in anticipation of making the agreed payment to the customer’s bank, the Company requests the Customer’s bank details, being the name of the account (which must tally with the customer’s name) and the bank account and sort code.
• Any other or further information it deems appropriate in any particular case in order to verify the identity of the customer.

If the documents fail to identify the Customer and/or raise any genuine suspicion regarding the bona fides of the Customer, the Company will undertake further enquiries and due diligence and take all reasonable measures to verify the Customer and the transaction. If still dissatisfied with the responses/documentation, The Company will under no circumstances proceed with the transaction and will take steps, if appropriate, to notify the authorities and take whatever action in relation to the Box it deems appropriate in all the circumstances, which may involve holding the Box pending further action.

Each transaction and every Customer are considered in the context of all the relevant circumstances and deliberate caution is exercised by the Company in identifying and responding to suspicious circumstances.

In the event that a suspicion of Money laundering is raised, The Company is under a legal obligation not to disclose details to the Customer of any referral it may make to the authorities.

LEGAL COMPLIANCE

The Company will at all times fully comply with all legislation and guidance in relation to anti-Money laundering, Counter-terrorism, Fraud, Stolen goods, Sanction compliance and Data protection. Moreover, this Policy shall be read as incorporating all applicable statutory requirements in full.

GOVERNANCE

The senior management of The Company acknowledge their responsibility for approving this Policy and ensuring full compliance by having adequate systems and resources allocated for these purposes.

Vintage Cash Cow

[trading name of Vintage Trading Solutions Ltd]

OUR PRIVACY POLICY

INTRODUCTION

The Vintage Cash Cow Privacy Policy is designed to fully comply with UK and EU statutory obligations, which are contained in UK GDPR and EU GDPR, including KYC (‘Know Your Customer’) and AML checks, which are further particularised in the AML Policy, also forming part of the Vintage Cash Cow Terms and Conditions. This Privacy Policy explains how Vintage Cash Cow collects, uses, stores and shares personal information when you: [i] use our website; [ii] request an appraisal; [iii] send items to us for appraisal; [iv] sell items to us; [v] communicate with us; or [vi] use any of our services otherwise than stated above.

THE DATA CONTROLLER

The Data Controller is Vintage Trading Solutions Ltd ( Company number: 03862799), whose registered office is located at 20-22 Bridge End, Leeds West Yorkshire LS1 4DJ, trading as Vintage Cash Cow.

Contact details are: Email: Telephone:

You have the right to contact the Information Commissioner’s Office in Wilmslow, Cheshire.

YOUR PERSONAL DATA WHICH WE COLLECT

We may collect and use several types of information personal to you. This may include (by way of example only) the following:

• Your name, email address, telephone number and customer account information relating to you.
• Information in relation to business transacted between yourself and the Company, including items you have sent to us, valuations, offers made to you, offers accepted or rejected, purchase history, payments, details of delivery and collection, as well as all other communications between you and the Company, including details of disputes and complaints (if any).
• As referred to in our AML/KYC Policy document, we are required to collect information to verify your identity in order to protect against fraud, money laundering, the handling of stolen goods and other criminal activity. For this purpose we will ask to see a valid identity document. We record a reference of the verification, being the type and number of the document, who verified it and when; we do not retain copies or images of your identity document once verification is complete. We may retain documented records of the checks that we undertake, which may include fraud risk indicators.
• In addition, we will frequently collect bank account details obtained in order to transfer agreed payment to you. For obvious reasons, we treat these details with the utmost discretion and confidentiality, as we do any personal data that we receive from you or any other source.
• We may collect your IP address, device information and other technical information when you use our website.
• We may retain, and not necessarily delete, our communications with you. This may include file and call notes, chat messages, any complaints and similar records that detail your contact with us.

HOW WE COLLECT YOUR INFORMATION

• We may collect personal information directly from you when you are on our website, request a brochure and postal label, send items to us for appraisal, or accept or reject an offer we may make.
• We may collect similar personal information from the Box you send to us and/or any correspondence between us.
• Information of a personal nature may be collected by us via the courier and postal services that we offer.
• We request ID as we are legally obliged to do in certain circumstances, as outlined in the AML Policy document.
• We can obtain certain information from publicly available sources, including social media and cookies.

WHY WE USE YOUR PERSONAL DATA LAWFULLY

We use your personal information for a number of essential purposes, including the following:

• To provide a service in accordance with our business model and practice, whereby we take delivery and either purchase your items or generally (other than in the exceptional circumstances outlined in our Terms and Conditions) return them to you. This enables us to enter into a contract with you (or to manage the position where an offer is not made, or an offer we do make is declined by you).
• We verify your identity and carry out appropriate ‘Know Your Customer’ checks when a value in excess of £2,500 (two thousand five hundred pounds) is reached, in order to comply with AML obligations and, more particularly, in order to prevent fraud, money laundering, the handling of stolen property and other criminal activity.
• We obtain payment details in order that we may pay you whatever the agreed sum is for the items we purchase.
• In addition, we are also obliged to retain all or any such records in order to meet our legal requirements vis-à-vis the tax authorities, consumer laws, AML and law enforcement more generally. In other words, should we not retain certain records that bear your personal data, we would be failing to comply with our legal and regulatory obligations.
• We may need to retain a record of communications between ourselves and you in the event that you raise any subsequent complaint or query regarding any aspect of our service, whether it resulted in an agreed purchase or not.
• We may, if lawfully permitted to do so, send you marketing material on our company’s behalf, in respect of which you will be given an opportunity in advance to opt out. Your right to opt out remains available to you at any subsequent time.

LEGITIMATE INTERESTS

We rely upon ‘legitimate interests’, which can include: [a] operating our business in an acceptable and commercial manner; [b] preventing criminal activities and/or abuse of our services; [c] maintaining accurate records; [d] being in a position to address any complaints regarding our service; [e] protecting all aspects of our Company and, in particular, all our staff and customers, as well as the relationship that we have with our customers; and [f] lawfully marketing our services.

In seeking to rely upon our ‘legitimate interests’, we always bear in mind fairness, transparency and proportionality. We treat the question of privacy with considerable caution and regard your privacy and personal interests as being of paramount importance. We fully understand and respect that your data cannot be held without a true lawful purpose and that its retention must be under constant review. Not only does the question arise as to whether we can justify retaining it, but also for what period of time. Whilst we respect your rights, these must be balanced against other legitimate interests.

WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We may legitimately share your personal information with:

• Courier, postal and logistics personnel;
• Banks and other financial institutions;
• AML and similar screening companies or entities;
• Professional advisors;
• IT hosting and software analytics companies;
• Public authorities;
• Group companies;
• Prospective purchaser(s) of our Company, if any.

In all cases, we insist upon any other parties treating your information as confidential to them only.

OUR RETENTION OF YOUR PERSONAL INFORMATION

We only retain such information for the minimum time it is required, whilst still taking into account our ongoing need to retain it for the reasons referred to above. We never take the act of retaining such information lightly, and it is under regular review.

Our general retention periods, which may vary bearing in mind the particular circumstances, are as follows:

• Customer account and transaction records: 6 years after the end of the customer relationship
• Tax records: 6 years
• KYC/AML records: 6 years;
• Marketing records: until cancelled at your instigation;
• CCTV: 4 weeks, unless footage is required in connection with a specific incident;
• Website analytics: 14 months.

YOUR RIGHTS IN RELATION TO DATA

• Depending upon your location and circumstances, you may have the right of access to your personal information.
• Moreover, you are entitled to ask us to correct any inaccuracies.
• You may ask us to erase your personal information.
• You can request that we restrict its use.
• You can legitimately withdraw consent, e.g. in respect of marketing.
• You may complain to the Data Protection Authority.

COMPLAINTS

In the event that you have any complaint regarding our actions in relation to your personal information, we ask that you contact us in the first instance in order that we may try to resolve the issue. In any event, you have the right to raise a complaint with The Company initially but if not satisfied with that outcome, you may contact the I.C.O.( The Information Commissioner’s Office)

AMENDMENTS TO THIS POLICY

We may from time to time update this Privacy Policy, and you should consult our website to locate the current version.

Vintage Cash Cow

(the trading name of Vintage Trading Solutions Ltd)

POLICY: Our Purchase of Digital Devices

DEFINITION

For the purposes of this Policy, "Digital Devices" means any electronic device capable of processing, storing, transmitting or displaying digital information.

The Company purchases certain Digital Devices, including smartphones, iPads and selected tablets. The Company does not purchase all Digital Devices, and acceptance of any device is subject to the Company's eligibility criteria and sole discretion.

Before sending any Digital Device to the Company, the Customer must ensure that the relevant make and model is one that the Company currently accepts for appraisal and purchase by checking the Company's website. The Company shall have no obligation to appraise or purchase any Digital Device that is not listed as an accepted item on the Company's website at the time it is sent.

TERMS OF SALE

• We must be satisfied that the title to the phone will pass to us free from all encumbrances/finance.
• The Customer must provide accurate information regarding the battery condition; faults, if any; legal ownership; and all matters relating to the phone, its condition, age and identity.
• The Customer must remove all or any activation locks and all remaining personal data of any nature prior to sending it to us, for which we cannot be held responsible at the time or at any time thereafter, should this not be done.
• In so far as any such Device is, at any time whilst in transit or in our possession, found by public search or any other means to be lost or stolen, it will be retained by us and the circumstances of its retention reported to the relevant authorities as required by law, and we will give our full cooperation to the authorities, which will inevitably include providing the Customer’s details, including their address.
• We may undertake IMEI and serial number checks against industry databases, and the Customer gives their consent to this and to the disclosure of any further information of any relevant nature required for this purpose.

Prior to the Customer sending the Device to us, the Customer must do the following:

• Back up their data;
• Remove all SIM and memory cards;
• Sign out of all user accounts;
• Disable any ‘Find My Phone’ service;
• Remove passwords, PINs and biometric security;
• Take all other steps that are necessary to wipe the Device clear of any data or anything else which identifies the Customer and/or reveals any information relating to the Customer, be it of a private nature or not.

We will not knowingly purchase any device that:

• Has been reported lost or stolen;
• Is blacklisted;
• Has altered or missing IMEI numbers;
• Appears to be and/or might be counterfeit;
• Has any possible connection with criminal activity;
• Has been modified in any manner whatsoever.

Save for these special conditions, the Customer shall be subject to, and have agreed to be bound by, and therefore consented to, the Terms and Conditions to which this Policy is annexed.

Should we discover, after the purchase has been agreed but before payment, that the Customer has been in breach of any of these conditions, we shall be entitled to cancel the agreement forthwith, without any consent from the Customer. In the event that payment has by that time been made to the Customer, we will be further within our rights to claim a full reimbursement from the Customer of the price paid.

THE VINTAGE CASH COW CUSTOMER BOX PROTECTION SCHEME

1. PURPOSE OF THIS POLICY

This Scheme forms part of the Agreement between ‘Vintage Cash Cow’ and ‘The Customer’.

It defines the terms whereby Boxes may be eligible for compensation under this scheme: [i] whilst in transit to Vintage Cash Cow; [ii] whilst in the possession of Vintage Cash Cow and [iii] during return transit to The Customer where applicable.

This is a compensation-based scheme and is not insurance-based, and therefore not regulated. It does not guarantee reimbursement of retail value, purchase price, sentimental value, or The Customer’s own assessment of value.

All or any compensation is strictly limited to the terms set out in Scheme

2. DEFINITIONS

For the purposes of this policy:“Box” means any package sent to Vintage Cash Cow containing customer items.

“Item” means any individual object contained within a Box.

“Claim” means any request for compensation under this Scheme.

“Maximum Level” means the maximum compensation limit applicable at each stage of the Box’s journey.

“Market Value” means the estimated price that an item would reasonably achieve in the UK or EU secondary resale market at the time of assessment, taking into all relevant factors including an item’s condition, age, rarity, demand, and resale potential.

“Approved Delivery Service” means a tracked courier service authorised by Vintage Cash Cow.

“Reasonable Assessment” means the fair determination made by Vintage Cash Cow based on all available evidence in addition to internal expertise and relevant market data. Vintage Cash Cow reserves the right to assess and determine the weight given to each source of evidence.

“Vintage Cash Cow Assessment” means the internal valuation and claims determination process carried out by trained assessors using market data, experience, and the evidence at its disposal.

3. PROOF OF CONTENTS DEFINITION

“Proof of Contents” means any information or documentation that Vintage Cash Cow reasonably requires in order to verify the contents, ownership and value of items in a Box. This may reasonably include, but is not limited to, photographs, videos, receipts, purchase records, valuations, certificates of authenticity, written descriptions, and/or any other supporting evidence.

Customers are strongly encouraged to retain photographic evidence of their Box and its contents prior to dispatch. While the absence of such evidence will not automatically result in a claim being rejected, it may limit Vintage Cash Cow’s ability to verify the contents and value of the items and such absence may be taken into account when assessing the claim and its outcome. Vintage Cash Cow is fully entitled to determine the level of compensation payable based on the totality of the available evidence.

Vintage Cash Cow reserves the right to reject a claim or reduce the level of any compensation where sufficient evidence is not provided to enable it to reasonably verify contents and/or value.

4. VALUATION PROCESS

Where a claim is accepted, Vintage Cash Cow will determine a fair and reasonable settlement value based on the available evidence and in accordance with this Scheme. The maximum compensation payable will not exceed the applicable cover limit for the Box, regardless of the assessed value of the items.

Settlement values are based on market value rather than the original purchase price, retail price, and/or any assessment of replacement cost. Receipts, invoices, or any original purchase documentation do not determine or guarantee the settlement value, as these documents may reflect retail pricing, branding, or other commercial mark-ups that do not represent resale value.

In assessing a claim, Vintage Cash Cow will consider all reasonably available evidence, which may include (but is not limited to) photographs, videos, receipts, valuations, certificates of authenticity, written descriptions, comparable market data, and internal expert appraisal. Where there is conflicting evidence, greater weight may be given to independent market data and expert assessment.

Where sufficient evidence is not available to precisely verify an item’s value, Vintage Cash Cow will determine a fair and reasonable settlement based on the totality of the available information and its fair and reasonable judgment.

The presence of a Maximum limit does not guarantee payment at that level. Compensation will reflect the proven and/or reasonably assessed value of the items in the Box. in accordance with this Scheme.

The valuation determined by Vintage Cash Cow shall be final for the purposes of this Scheme, subject to internal review procedures where applicable.

5. JOURNEY-BASED COVER STRUCTURE

5.1 Sending a Box to us

When a customer uses a Vintage Cash Cow pre-paid or approved tracked delivery service, their Box is eligible for compensation for loss or damage up to a maximum of maximum value of £300.

Customers who believe their Box exceeds this value may request an increased Cover Level prior to dispatch. Any increased Cover Level must be approved by Vintage Cash Cow in writing before the Box is sent.

Cover under this section applies only during transit to Vintage Cash Cow and is subject to the terms of this Scheme including, in particular, evidence of contents, ownership and value.

5.2 Received at our Business Premises

Once a Box has been received and scanned into Vintage Cash Cow’s operational system, it is eligible for compensation for loss or damage up to a maximum cover of up to £1,000, subject to verification of contents and value under this Scheme.

Any compensation payable will be based on the assessed market value of the items, in accordance with the Scheme.

5.3 Returning a Box to a Customer

When Vintage Cash Cow makes an offer for a Box and the customer chooses to decline that offer, the Box and/or items will be returned to the customer using a tracked delivery service.

During return transit to The Customer, it is eligible for compensation for loss or damage up to a maximum value of £300, subject to the terms of this policy.

Compensation for items lost or damaged during return transit will be assessed on a case-by-case basis and will reflect the reasonable cost of repair, restoration, or replacement value with reference to current market value, where appropriate and supported by evidence.

The original purchase price, retail value, or any amount previously paid for the items will not determine or guarantee any settlement value.

Where items are damaged in transit but remain repairable or partially recoverable, Vintage Cash Cow may, at its sole discretion, offer compensation based on repair cost or reduction in market value rather than full replacement.

Higher Compensation Request

As per our Terms and Conditions 3.9 it clearly states - The maximum level can be increased upon request made by The Customer to The Company prior to sending a Box to The Company, and subject to the written agreement by The Company, up to a maximum of £10,000 (ten thousand pounds). The Customer must read the Scheme to make themselves fully conversant with the precise terms and process relating to this increase. Any increase of any kind must be made prior to the dispatch of the Box. The Scheme is equally binding on both parties.

The Customer may request an increase to the standard Box compensation limit before sending their Box to the Company. Any request for an increased compensation limit must be submitted in writing and approved by the Company before the Box is dispatched.

The Customer must not send a Box containing items for which an increased compensation limit has been requested unless the Company has provided written confirmation of the approved increased compensation limit. In the absence of such written confirmation, the standard Box compensation limit shall apply.

To enable the Company to assess any request for increased compensation, the Customer must provide photographic evidence of all items intended to be included within the Box. This evidence should include, where applicable, clear images showing the condition of the items, hallmarks, signatures, certificates, valuations and any other relevant identifying features.

Where the Customer intends to send precious metals or jewellery, the Customer is advised to provide photographic evidence of the item's weight, including an image showing the item being weighed and the recorded weight in grams. This information may assist the Company in carrying out a preliminary assessment.

Photographic evidence must be submitted to hello@vintagecashcow.co.uk. The Company will endeavour to respond to requests within two working days; however, the Customer acknowledges that additional time may be required depending on the number, type and complexity of the items being assessed. The Company will notify the Customer if additional time is required.

The Company may provide an increased Box compensation limit of up to £10,000 (ten thousand pounds) at its sole discretion. Any reference to an increased compensation limit of up to £10,000 does not constitute a guarantee that the maximum amount will be offered or approved.

The amount of any increased compensation limit offered by the Company shall be determined based on the information available at the time of assessment, including the photographic evidence provided, the Company's appraisal of the items, their condition, market value, authenticity and other relevant factors.

The Company is under no obligation to increase the standard Box compensation limit where, in its assessment, the evidence provided does not justify an increased limit. Where an increased compensation limit is approved, the Company is under no obligation to approve the maximum available amount and may approve a lower limit based on its assessment of the items.c.

6. PROHIBITED ITEMS

Certain items are not suitable for transport, handling, or processing by Vintage Cash Cow due to safety, legal, or operational reasons.

The following items are strictly prohibited and must not be included in any Box sent to Vintage Cash Cow:

• Fragile or breakable items that are unsuitable for standard parcel handling, including but not limited to glass, ceramics, china, porcelain, pottery, figurines, and similar delicate materials; Firearms, ammunition, explosives, or any related components or replica items that may reasonably be mistaken for real weapons.
• Knives, blades, or edged weapons of any kind, with the exception of standard domestic cutlery knives intended for household use.
• Ivory, or any items containing ivory or derived from endangered or protected animal species, including items restricted under applicable wildlife trade regulations.

These items are excluded due to health and safety risks, legal restrictions, and the potential for injury during handling, inspection, or unpacking of Boxes.

If prohibited items are included in a Box, Vintage Cash Cow reserves the right to:

• Exclude such items from any assessment, valuation, or compensation under this policy.
• Adjust or decline a claim where the presence of such items has contributed to loss, damage, or increased handling risk
• Take appropriate action, where required, to comply with legal or regulatory obligations

Inclusion of prohibited items may affect the handling and assessment of the entire Box, particularly where it creates safety risks or prevents normal processing. However, any decision to limit or decline compensation will be made reasonably and justly and based on the specific circumstances of the case.

Inclusion of prohibited items in a Box may result in the entire claim being voided where such items compromise safety, handling, or investigation integrity.

7. CLAIMS TIME LIMITS

All claims relating to the Customer Box Compensation Scheme must be submitted to the Company within 30 days of the customer receiving their box from The Company. This timeframe is in place to ensure claims can be reviewed fairly, accurately, and within a reasonable period, and is clearly communicated to all customers.

The Company will not normally accept claims submitted after this 30-day period. However, in exceptional circumstances, and where appropriate, the Company may, at its discretion, consider a late submission where there is a reasonable explanation for the delay and it is fair and proportionate to do so.

In such cases, the Customer may be asked to provide such evidence as the Company may reasonably require to support the reasons for the late submission. Any decision by the Company to accept or consider a late claim shall be entirely at the Company's sole discretion.

Where a claim has been accepted, Vintage Cash Cow will request the necessary payment details from the customer in order to process payment.

Customers are responsible for providing accurate and complete payment information to enable settlement to be made.

If requested information is not provided within a reasonable timeframe, Vintage Cash Cow may place the settlement on hold until the required details are received.

Vintage Cash Cow will make reasonable efforts to contact the customer and remind them to provide the required information before any settlement is delayed or closed.

Where a settlement remains unclaimed for a period of 90 days from the date it is first made available to The Customer, Vintage Cash Cow may close the claim.

After this time, Vintage Cash Cow will have no ongoing obligation to hold funds or maintain the settlement allocation.

However, where a customer contacts Vintage Cash Cow after this period and can demonstrate a reasonable explanation for the delay (for example, circumstances entirely outside their control), Vintage Cash Cow may, at its sole discretion, review the case and determine whether the settlement can be reinstated in whole or in part.

Any reinstatement will be considered on a case-by-case basis and will depend on the circumstances and availability of supporting information.

After 90 days from submission of the Claim, Vintage Cash Cow shall have no obligation to retain or administer the claim unless otherwise required under applicable law.

8. PACKAGING LIABILITY

Customers are responsible for ensuring that all items are securely and appropriately packaged in accordance with all guidance provided by Vintage Cash Cow and/or its approved delivery partners.

Vintage Cash Cow may refuse or limit compensation where damage is likely to have been caused directly as a result of inadequate or unsuitable packaging provided by The Customer.

Packaging guidance is made available to customers prior to dispatch and should be followed carefully to minimise the risk of damage in transit.

Where damage occurs, Vintage Cash Cow will fairly assess the circumstances of the particular case, including the condition of packaging, handling process, and all available evidence, in order to determine whether compensation is payable under this Scheme.

This does not affect Vintage Cash Cow’s responsibility for loss or damage that occurs while the Box is in its care, where such loss or damage is not caused by inadequate customer packaging.

Any assessment of packaging-related damage will consider whether the damage was directly and solely caused by inadequate packaging.

9. CLAIM CLASSIFICATION

Definition of Loss and Damage

For the purposes of this policy, claims will be assessed based on the nature and extent of the loss or damage as set out below:

9.1 Total Loss

A total loss occurs where a Box is confirmed as lost in transit or cannot be located after reasonable investigation. In such cases, compensation will be assessed on the basis of proven or reasonably estimated total value of the Box, subject to the applicable Cover Level.

9.2 Partial Loss

A partial loss occurs where one or more items contained within a Box are confirmed as missing, but other items are received and are not missing. Compensation will be limited to the assessed value of the missing items only and will not extend to unaffected items within the Box.

9.3 Damage

Damage occurs where items are received but are in a condition that has been materially affected during transit or handling, as a result of which their market value or usability is materially reduced. Compensation will be based on the reduction in market value or reasonable cost of repair where applicable.

9.4 Partial Damage

Partial damage occurs where only part of an item is affected, including but not limited to missing components, broken elements, or cosmetic deterioration. Compensation will be based on the reduction in overall market value of the item rather than the value of the entire item.

9.5 General Assessment Principle

All claims will be assessed based on the specific nature of the loss or damage, supported by available evidence and in accordance with the valuation process set out in this scheme. Compensation will be limited to the proven or reasonably assessed value of the affected items and will not automatically reflect the full Maximum Level of the Box.

The classification of claims is determined solely by Vintage Cash Cow based on evidence and the outcome of inspection:

10. GENERAL EXCLUSIONS

This scheme does not extend to the following:

10.1 Pre-existing condition

Any loss, damage, or defect that existed prior to the Box being received by Vintage Cash Cow, including damage not due to transit or handling under this Scheme.

10.2 Valuation expectations

Any difference between a customer’s expectation of value and the assessed market value determined under this Scheme. This includes (but is not limited to) expectations based on:

• original purchase price
• retail pricing
• sentimental value
• insurance valuation for other purposes
• third-party or online listing prices

10.3 Insufficient or inconsistent disclosure

Items that are not reasonably identifiable, described, or evidenced in a way that enables verification of ownership, authenticity, or existence to be made.

10.4 Non-compliant packaging contribution

Any loss or damage where packaging materially contributed to the issue and the packaging did not meet reasonable handling standards as set out in guidance provided by Vintage Cash Cow and/or its delivery partners.

10.5 External delay-related losses

Any indirect loss arising from delay in transit, processing, or investigation, including inconvenience, loss of opportunity, or consequential financial impact of any nature.

10.6 Items outside reasonable parcel scope

Items which, due to their nature, fragility, or handling risk, are unsuitable for standard parcel-based transport and were not explicitly agreed in advance for acceptance under enhanced cover terms.

Multiple exclusions may apply concurrently to the same claim, and the application of one exclusion does not limit the applicability of others.

11. FRAUD, MISREPRESENTATION AND ABUSE

Vintage Cash Cow reserves the right to investigate, suspend, adjust, or reject any claim where there is reasonable suspicion of fraud, misrepresentation, or abuse of this Scheme.

This includes (but is not limited to):

• intentional misstatement of contents, ownership, or value
• submission of altered, misleading, or fraudulent documentation
• omission of relevant items from declared contents
• attempted double claiming or duplicated recovery
• deliberate inflation of item value beyond reasonable market assessment

Where fraud or misrepresentation is identified or reasonably suspected, Vintage Cash Cow may:

• reject the claim in full or part
• recover any payments already made
• offset amounts against any future payments due to The Customer
• retain items for investigation purposes
• share relevant information with third parties where legally required to do so

All decisions will be made fairly and reasonably, and based on all relevant and available evidence and internal investigation outcomes. Vintage Cash Cow may withhold payment pending completion of any investigation.

12. LIMITATION OF LIABILITY

Vintage Cash Cow’s total liability under this policy is strictly limited to the applicable Maximum Level assigned under this Scheme at the time of the relevant Box event.

To the maximum extent permitted by law, Vintage Cash Cow shall not be liable for:

• sentimental value or emotional loss
• indirect or consequential loss of any kind
• loss of profit, opportunity, or anticipated value
• any amount exceeding the applicable Cover Level
• delays caused by third-party courier networks or external operational disruption

Nothing in this policy excludes liability where it would be unlawful to do so under applicable consumer protection law. The Cover Level represents the maximum aggregate liability of Vintage Cash Cow under this Scheme for any single Box event.

13. FORCE MAJEURE

Vintage Cash Cow shall not be held liable for any delay, failure, or disruption in performance of this policy obligations where such delay or failure is caused by events outside its reasonable control.

Such events include, but are not limited to:

• natural disasters (fire, flood, storm, earthquake)
• industrial action or labour disputes
• failure or disruption of courier or logistics networks
• governmental restrictions or legal interventions
• system outages, cyber incidents, or infrastructure failure
• public health emergencies or widespread operational disruption

Where a force majeure event occurs, Vintage Cash Cow will take reasonable steps to mitigate impact and resume normal service as soon as reasonably practicable.

14. CHANGES TO THE SCHEME

Vintage Cash Cow reserves the right to amend, update, or replace this Scheme at any time.

Any updated version will apply to Boxes dispatched after the effective date of the amendment.

No amendment shall operate retrospectively to reduce the cover applicable to Boxes already dispatched under a prior version of this policy.

VINTAGE CASH COW

[trading name of Vintage Trading Solutions Limited]

MODERN SLAVERY STATEMENT

Vintage Cash Cow is a company committed to preventing Modern Slavery and Human Trafficking in all aspects of our business, including, in particular, our supply chains. We take a zero-tolerance approach to any instance, or any reasonable suspicion, of forced labour, servitude and/or human trafficking, and we are committed to acting ethically and with integrity in every area of our company’s activities.

We work with a range of third-party suppliers and service providers, in respect of whom we take a risk-based approach to managing Modern Slavery. We seek to proactively ensure that each one of our suppliers shares our unconditional commitment to legal and responsible working practices, and we keep our supply chain under review to ensure that no Modern Slavery practices are present, ignored or overlooked.

Moreover, we encourage all our employees and suppliers to report to us directly in the event that they have any concerns or suspicions of any nature relating to unethical conduct and/or potential Modern Slavery. Any concerns raised will always be treated with the utmost seriousness and will always be promptly and thoroughly reviewed and addressed in a proportionate and dynamic manner.

Vintage Cash Cow defines Modern Slavery as including all of the following:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental and/or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as if merely property;
• Being physically constrained or having a restriction placed upon freedom of movement.

Vintage Cash Cow is fully aware of, and embraces, its responsibilities in relation to tackling Modern Slavery and is entirely committed to complying with the provisions of the Modern Slavery Act 2015.

We appreciate that this requires a regular and ongoing review not only of our own internal practices vis-à-vis our own employees and consultants, but also in relation to our supply chains. We fully appreciate that processes must be in place in order to protect other human beings, who are often in vulnerable situations.

It is distinctly not the practice of Vintage Cash Cow to have business relations with any other organisation, company, business or individual, wherever they are located, who knowingly supports, or is reckless as to the same, or is discovered involving itself in any respect that amounts to, any form of slavery, servitude and/or forced labour.

We at all times take every reasonable step to ensure that workers, or any other party who in any manner assists Vintage Cash Cow to provide its services, are never in any respect party to, or connected with, any aspect of slavery or human trafficking. We strictly adhere to the minimum standards required in relation to all such responsibilities under relevant employment legislation and, wherever reasonably possible, will take active steps to rise above the minimum obligations imposed upon us by law.

Our business model is one of purchasing second-hand items from private individuals and thereafter selling, through various legitimate channels, the items that we have purchased. We do not own companies or factories that produce goods, and we ourselves do not manufacture. Our suppliers support our business activities as providers of services; they do not supply the goods that we sell.

We carefully oversee the process by which we select the suppliers with whom we work, in terms of what they provide and how they provide it. We believe that it is of vital importance to engage with suppliers who are reputable and whom we believe, on proper enquiry and appropriate scrutiny, to be ethical.

Our business is committed to ensuring that there are no Modern Slavery or human trafficking activities in its operations, and to ensuring that its supply chains are strictly free from slavery and human trafficking.

In the EU, we are aware of the developing corporate sustainability due diligence framework, including the Corporate Sustainability Due Diligence Directive. While its obligations apply to companies far larger than ours, we monitor these developments and support their underlying aims of identifying, preventing and mitigating adverse human rights and environmental impacts, including forced labour, child labour, unsafe working conditions and environmental and climate harms, in businesses and their supply chains. We are similarly aware of the EU Forced Labour Regulation, which prohibits products made with forced labour from being placed on the EU market, and we take this into account in our dealings with suppliers.

The potential risk lies in relation to our suppliers and our own employees. In respect of the latter, as part of the recruitment process, we take all active measures to ensure that none of the individuals we employ have been, or are, to the best of our knowledge, exposed to the risk of slavery and human trafficking.

We consider the risk of exposure to slavery and/or human trafficking in a business like ours to be relatively limited, but we nevertheless remain aware of risk at all times and would never take risks once any suspicion is drawn to our attention. Our policies and our business ethos ensure that the risk is maintained at a minimum level, whilst our checks and balances are applied rigidly and unflinchingly.

We ensure that all our employees are made fully aware of our whistleblowing procedure and policy, so that risks such as Modern Slavery in our business dealings can be reported to us with an unconditional assurance of absolute confidentiality.

Accordingly:

• All staff receive relevant training.
• Our suppliers must provide their policy and statements pertaining to modern slavery.
• Our recruitment process ensures we verify identity and the right to work.
• Our suppliers are under ongoing review.
• We regard all these obligations as being for the common good, and they are under permanent and periodic review.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

This statement was approved by the Board of Directors.

Signed:

______________________________

Name and position:

Tobias Hinteregger - Chief Executive Officer

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