Platform Policy & Compliance Framework

Platform Policy & Compliance — XB2BX.COM
Master Policy Document

Platform Policy &
Compliance Framework

Governing all financial transactions, cancellations, returns, refunds, dispute resolution, fraud prevention, user conduct, modern slavery obligations, and regulatory compliance across the XB2BX.COM global B2B marketplace — 180+ countries.

Effective: 26 May 2026
Version 4.0
180+ Countries
9 Policy Chapters
Jurisdiction: England & Wales
PCI DSS · GDPR · ISO 27001
Chapter A

Payments & Transactions

This chapter governs all financial instruments, transaction flows, escrow mechanisms, currency handling, and platform fee structures applicable to every monetary exchange on XB2BX.COM. By completing any payment on the Platform, all Users irrevocably agree to these terms in their entirety.

01

Scope, Applicability & Definitions

Who this applies to and key terminology

This Master Policy ("Policy") constitutes a legally binding agreement between XB2BX.COM Ltd ("Platform", "we", "us") and every individual, company, or entity ("User", "you") that registers on, accesses, or transacts through the Platform. It applies to all payment activities, including purchase orders, subscription fees, service charges, promotional transactions, and any monetary exchange facilitated by or through XB2BX.COM.

1.1 Key Definitions

  • Buyer — any User initiating a purchase of goods or services on the Platform.
  • Seller / Supplier — any registered business or individual offering goods or services for sale.
  • Transaction — any confirmed financial exchange, payment instruction, or order processed via the Platform.
  • Escrow Account — a ring-fenced holding account managed by XB2BX.COM or an authorised processor pending order fulfilment milestones.
  • Payment Processor — any third-party financial institution or gateway engaged by XB2BX.COM to process payments.
  • Chargeback — a transaction reversal initiated by a cardholder's issuing bank.
  • Order Reference Number (ORN) — the unique identifier issued upon confirmed payment authorisation.
  • GMV — Gross Merchandise Value; total value of all transactions processed through the Platform.
  • Material Change — any amendment to this Policy that significantly affects User rights, fees, or obligations.
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Governing Principle Where local laws impose stricter obligations on any provision of this Policy, those local requirements shall prevail to the extent of the inconsistency. Users in the European Economic Area benefit from additional protections under EU Directive 2015/2366 (PSD2) and the EU Consumer Rights Directive.
02

Accepted Payment Methods

Supported instruments and regional availability
MethodAvailabilitySettlementCurrencies
Visa / MastercardGlobal (180+ countries)1–3 business daysMulti-currency
American ExpressSelected regions1–3 business daysMulti-currency
SWIFT / Wire TransferGlobal2–5 business daysAll major currencies
PayPal / StripeGlobal (where permitted)Instant – 2 daysMulti-currency
Letters of Credit (LC)Enterprise B2B accountsPer LC termsMulti-currency
Alipay / WeChat PayAsia-Pacific1 business dayCNY, USD, HKD
SEPA Direct DebitEEA only1–2 business daysEUR
Cryptocurrency (USDT/USDC)Selected accounts — enhanced KYC requiredSame-day on-chainStablecoins only
⚠️
Method Availability XB2BX.COM reserves the right to suspend or remove any payment method at any time. Permanent removals will be communicated with a minimum of 30 days' advance notice. Crypto payments are subject to enhanced KYC/AML verification and may be declined at our sole discretion.
03

Transaction Processing

Authorisation, confirmation, and supplier settlement

3.1 Authorisation & Confirmation

All payments require explicit Buyer authorisation. An order is confirmed only upon receipt of a successful payment authorisation code and issuance of an ORN. Email confirmation is dispatched within 15 minutes. Pending or failed transactions do not constitute confirmed orders and carry no contractual effect.

3.2 Supplier Settlement Schedule

  • Standard B2B Orders: 3–7 business days after confirmed delivery or milestone acceptance.
  • Enterprise Contract Orders: per negotiated payment milestones in the Purchase Agreement.
  • Subscription / SaaS Fees: on the scheduled billing date, subject to successful collection.
  • Disputed Orders: settlement withheld pending resolution per Chapter D of this Policy.
  • Refunded Orders: net settlement adjusted; any already-disbursed amounts subject to clawback per Section 9.

3.3 Payment Failures

Where a payment fails after order placement, XB2BX.COM will attempt re-authorisation up to two times within 24 hours. If unsuccessful, the order is automatically cancelled and the Buyer notified. No goods will be dispatched and no contract formed where payment has not been successfully confirmed.

04

Pricing, Currencies & Foreign Exchange

Multi-currency handling, FX conversion, and risk disclosure

All prices are displayed in the Seller's nominated currency. Buyers may view indicative converted amounts for informational purposes only. The transaction settles in the Seller's nominated currency unless a dual-currency agreement exists in writing.

Where currency conversion is applied, XB2BX.COM uses the mid-market exchange rate at the time of transaction plus a conversion margin of up to 1.5%. Buyers should verify applicable rates with their bank or card issuer, as additional charges may apply at the issuing end.

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Currency Risk Disclosure Cross-border transactions carry inherent currency risk. Exchange rates can fluctuate significantly between order placement and settlement. XB2BX.COM bears no liability for currency losses from rate movements. Buyers and Sellers are strongly encouraged to fix transaction currencies in their commercial contracts.
05

Platform Fees & Charges

Commission, processing fees, and billing terms
Fee TypeRateCharged ToNotes
Transaction Commission2.5% – 5.0%SellerTiered by monthly GMV
Payment Processing1.4% + $0.30BuyerCard payments; varies by method
Escrow Management0.5% per transactionBuyerIncluded in checkout total
Wire Transfer Handling$15 flat feeBuyerSWIFT/international wires
Chargeback Administration$35 per incidentResponsible partyCharged if claim upheld against Seller
Currency ConversionUp to 1.5%Initiating partyAbove mid-market rate
Late Payment Interest1.5% per monthDebtorOverdue enterprise invoices
Dispute Administration$25 per escalated disputeLosing partyApplied where claim is unfounded
Premium SubscriptionPer plan pricingSubscriberMonthly or annual billing

All fees are exclusive of applicable VAT, GST, or withholding taxes. Tax obligations are borne by the relevant User in accordance with local law. Fee changes will be communicated with a minimum of 30 days' written notice.

06

Escrow & Buyer Protection

Fund holding, release conditions, and guarantees

XB2BX.COM operates a mandatory Escrow Protection Program for qualifying transactions. Buyer funds are held in a segregated escrow account and released only upon verified fulfilment of agreed conditions.

6.1 Escrow Release Conditions

  • Buyer confirms receipt and acceptance of goods or services via the platform dashboard.
  • Automatic release is triggered 7 business days after confirmed delivery if no dispute is raised.
  • Milestone-based contracts: each milestone payment released upon written Buyer acceptance.
  • Early release may be authorised by the Buyer at any time via the platform.
  • Where a dispute is raised, funds remain frozen until the dispute is resolved per Chapter D.

6.2 Buyer Protection Guarantee

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You Are Protected When: Goods are not delivered within 30 days of the confirmed dispatch date; goods received are materially different from the product description; goods are damaged, defective, or non-conforming on inspection; or the Seller is found to have engaged in fraudulent misrepresentation. Full refund applies in all qualifying cases.
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Eligibility Note Buyer Protection applies only to transactions processed through the XB2BX.COM payment system. Transactions settled off-platform or via direct bank transfer arranged outside the Platform do not qualify. Custom enterprise contracts may specify alternative protection terms.

Chapter B

Cancellations & Returns

This chapter sets out the rights and procedures governing order cancellations and the return of goods purchased through XB2BX.COM. These provisions protect both Buyers and Sellers while maintaining the commercial integrity of the marketplace.

07

Cancellation Policy

Pre-dispatch, post-dispatch, and non-cancellable categories

7.1 Buyer Cancellations

TimingEligibilityRefundConditions
Within 24 hours of order placement & before dispatchβœ“ EligibleFull refundNo Seller consent required
24–72 hours before dispatch confirmedConditionalFull refund minus processing feeSeller must confirm non-dispatch
After dispatch confirmationLimitedPartial — subject to return policyReturn must be initiated; see §8
Custom / bespoke / manufactured goodsRestrictedNon-refundable once production startedUnless Seller consent given in writing
Digital goods & software licencesNon-cancellableNon-refundable once delivered/activatedUnless defective at delivery
Perishable goodsNon-cancellableNon-refundable after dispatchDefect claims accepted within 24 hrs

7.2 Seller-Initiated Cancellations

Sellers may cancel confirmed orders only in the following circumstances: (a) goods are confirmed out of stock and no substitute is available; (b) the Buyer's payment has not cleared within the authorised window; (c) an export licence or regulatory approval has been refused; (d) the order contains a material error (e.g., pricing error acknowledged by both parties).

Where a Seller cancels a confirmed order without a valid reason, the Seller will be subject to a cancellation penalty of up to 5% of the order value, automatic negative platform rating, and potential suspension of the Seller account. The Buyer receives a full refund including all processing fees.

7.3 Subscription Cancellations

  • Subscription services may be cancelled at any time via the platform dashboard.
  • Cancellation takes effect at the end of the current billing cycle; no pro-rata refund is issued for the remaining period.
  • Annual subscriptions cancelled within 14 days of initial purchase are entitled to a full refund, provided no premium features have been used.
  • Downgrading from a higher plan tier is effective from the next billing cycle.
08

Return Policy

Return windows, eligibility, conditions, and Seller obligations

8.1 Standard Return Eligibility

Buyers may request a return of physical goods within the following windows, provided the goods meet the stated conditions. The return window begins from the date of confirmed delivery as recorded by the Platform's logistics system.

Return WindowEligible CategoriesCondition Required
7 calendar daysAll eligible physical goodsUnused, original packaging, all tags/labels intact
30 calendar daysGoods that are defective, damaged, or not-as-describedDocumented defect; photographic/video evidence required
90 calendar daysGoods with latent manufacturing defectsDefect must not be due to misuse; requires inspection report

8.2 Non-Returnable Items

  • Custom-manufactured, personalised, or bespoke goods made to Buyer's specifications.
  • Perishable goods, hazardous materials, and goods with expired shelf life.
  • Unsealed software, licences, or digital goods once delivered or activated.
  • Goods that have been used, modified, or damaged by the Buyer after delivery.
  • Goods expressly marked "final sale" or "non-returnable" on the product listing, provided this designation complied with applicable consumer law.

8.3 Return Process

1
Submit Return RequestWithin eligible window

Buyer submits a return request via the platform dashboard, selecting the reason and uploading evidence (photos/video where applicable).

2
Seller ReviewWithin 3 business days

Seller reviews the request and either approves (issues Return Merchandise Authorisation — RMA) or contests it. Silence beyond 3 days constitutes automatic approval.

3
Return ShipmentWithin 7 business days of RMA

Buyer ships goods to the designated return address. Tracking must be provided. Return shipping cost allocation is per the product listing or Seller agreement.

4
Goods InspectionWithin 5 business days of receipt

Seller inspects returned goods and confirms condition. For defect returns, inspection must be completed by a qualified individual and report uploaded to the platform.

5
Refund or Replacement IssuedWithin 5–10 business days

Upon confirmed acceptance of return, refund or replacement is processed per Chapter C. Escrow funds are adjusted accordingly.

8.4 Return Shipping Costs

  • Defective / Damaged / Not-as-Described: Seller bears full return shipping cost.
  • Buyer Change of Mind (within 7 days): Buyer bears return shipping cost unless Seller's listing explicitly offered free returns.
  • Seller Error (wrong item sent): Seller bears all return and re-dispatch costs.
  • International Returns: Customs duties on returned goods are Buyer's responsibility unless the return is due to Seller error or defect.

Chapter C

Refunds & Replacements

This chapter governs the refund and replacement framework, including eligibility criteria, processing timelines, partial refunds, and replacement obligations. These provisions apply to all qualifying transactions across all categories on XB2BX.COM.

09

Refund Framework

Types, timelines, methods, and conditions

9.1 Refund Categories

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Full Refund

Total order value including taxes and shipping, returned to original payment method.

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Partial Refund

A proportionate refund reflecting accepted goods, minus applicable deductions such as restocking fees.

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Credit Refund

Platform credits equivalent to refund amount, usable for future orders. Issued by mutual agreement.

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Price Adjustment

Refund of the price difference where goods delivered were of lesser value or specification than ordered.

9.2 Refund Eligibility Conditions

ScenarioRefund TypeWho Pays Return Shipping
Order cancelled before dispatch (within 24 hrs)Full refundN/A
Goods not delivered within 30 days of dispatchFull refundN/A
Goods not as described / wrong itemFull refund + return shippingSeller
Goods arrived damagedFull or partial at Buyer's choiceSeller
Goods defective within 30 daysFull refund or replacementSeller
Goods defective 31–90 days (latent defect)Partial or replacementNegotiated
Buyer change of mind (within 7 days)Full refund less return shippingBuyer
Subscription — within 14-day cooling-offFull refund (annual plans only)N/A
Seller cancels confirmed orderFull refund incl. processing feesN/A

9.3 Refund Processing Timelines

  • Credit/Debit Cards: 5–10 business days to appear on statement (subject to issuing bank processing time).
  • PayPal / Stripe / Digital Wallets: 1–3 business days.
  • Bank Wire / SWIFT: 3–7 business days.
  • Platform Credits: Instant upon approval.
  • Cryptocurrency: 1–3 business days on-chain, subject to network conditions.
ℹ️
Timeline Notice XB2BX.COM initiates refunds promptly upon approval. The timeline for funds to appear in your account is dependent on your payment provider or bank and is outside our control. If a refund has not appeared after the maximum stated period, contact payments@xb2bx.com.

9.4 Non-Refundable Items & Deductions

The following are non-refundable in all circumstances: (a) platform subscription fees for current billing cycle; (b) currency conversion margins already applied; (c) wire transfer handling fees; (d) custom manufacturing costs where production has commenced; (e) digital goods once delivered and activated; (f) goods damaged through Buyer misuse or negligence post-delivery.

XB2BX.COM reserves the right to apply a restocking fee of up to 15% of the order value for change-of-mind returns where Sellers have explicitly stated such a fee in their product listing. Any such fee must be clearly disclosed prior to purchase.

10

Replacements

Conditions, timelines, and Seller obligations for replacement goods

Where a Buyer elects to receive a replacement rather than a refund, the following framework governs the replacement process. Replacement is subject to product availability. If the item is no longer available, a full refund is provided automatically.

10.1 Replacement Eligibility

  • Goods arrived damaged or with visible defects confirmed by photographic evidence.
  • Goods are non-conforming with the agreed product specification or sample.
  • Wrong item delivered by the Seller.
  • Goods develop a manufacturing defect within 30 days of delivery.
  • Latent manufacturing defects identified within 90 days, subject to inspection report.

10.2 Replacement Process & Timelines

  • Buyer must formally request replacement via the platform within the applicable return window.
  • Seller must confirm acceptance and dispatch the replacement within 10 business days of receiving the returned defective goods.
  • If the Seller fails to dispatch within the stated timeline, a full refund is automatically issued.
  • Replacement goods carry the same warranty and return entitlements as the original order.
  • Sellers who repeatedly fail to meet replacement obligations may have their account reviewed and listings delisted.
⚠️
Seller Obligation Sellers are solely responsible for ensuring replacement goods meet the full original specification. XB2BX.COM reserves the right to fund a refund from escrowed funds and seek recovery from the Seller where the Seller fails to fulfil a valid replacement obligation.

Chapter D

Disputes & Resolution

This chapter governs the formal dispute resolution process, escalation pathways, chargeback procedures, and binding determination mechanisms available to all Users of XB2BX.COM. The Platform is committed to fair, transparent, and expeditious resolution of all commercial disputes.

11

Dispute Resolution Process

Stages, timelines, evidence requirements, and outcomes

11.1 Grounds for Dispute

Any Buyer may formally open a dispute on any of the following grounds: (a) non-delivery; (b) significant not-as-described; (c) damaged or defective goods; (d) quality substantially below agreed specification; (e) Seller misrepresentation; (f) duplicate charge or billing error; (g) unauthorised transaction.

11.2 Resolution Stages

1
Stage 1 — Dispute OpenedDay 0

Buyer opens dispute via platform dashboard, selects grounds, and submits supporting evidence (photos, tracking, communications). Escrow funds are immediately frozen. Seller is notified within 1 hour.

2
Stage 2 — Seller ResponseWithin 5 business days

Seller submits formal response with counter-evidence (proof of dispatch, delivery confirmation, specification documents, photos). Failure to respond within 5 days results in automatic finding in Buyer's favour.

3
Stage 3 — MediationDays 6–12

XB2BX.COM Dispute Resolution Team reviews all evidence and may request additional documentation or photographs. Team may facilitate direct communication between parties to seek an agreed resolution.

4
Stage 4 — DeterminationDays 13–18

A binding determination is issued. Escrow funds are released in accordance with the outcome. The finding is communicated to both parties with written reasons. Partial outcomes may be issued where evidence supports a mixed finding.

5
Stage 5 — Escalation / ArbitrationAfter Day 18

Either party may escalate an unresolved or unsatisfactory determination to formal arbitration per the rules of the London Court of International Arbitration (LCIA). Arbitration costs are borne initially by the claimant; the unsuccessful party bears costs in the final award.

11.3 Evidence Standards

  • All evidence must be submitted in unedited form; manipulated images or documents will result in immediate determination against the submitting party.
  • Timestamped photographs and videos carry the highest evidentiary weight.
  • Third-party inspection reports from qualified professionals are accepted and weighted accordingly.
  • Platform chat and communication logs are automatically preserved and available to the Dispute Resolution Team.
12

Chargebacks & Bank Reversals

Policy, consequences, and abuse prevention

A chargeback initiated by a Buyer with their card issuer or bank, while a platform dispute is simultaneously open or has been resolved, constitutes misuse of the financial system and a material breach of this Policy.

12.1 Chargeback Consequences

  • Immediate suspension of the User account pending investigation.
  • A chargeback administration fee of $35 per incident will be applied to the responsible party.
  • Where a chargeback is upheld by the bank in a case already resolved in the Seller's favour on the Platform, the Buyer's account will be debited for the recovered amount plus fees.
  • Repeated or abusive chargeback behaviour results in permanent account termination and referral to relevant financial crime units.
  • Sellers: if a chargeback is upheld against you, the full chargeback amount plus any bank penalty is recovered from your escrowed or future earnings.
🚨
Chargeback Fraud Policy Deliberate initiation of fraudulent chargebacks — commonly known as "friendly fraud" — is a criminal offence in many jurisdictions. XB2BX.COM actively monitors for and prosecutes such behaviour. Users found to have submitted fraudulent chargebacks face permanent bans, civil recovery proceedings, and criminal referrals.

Chapter E

Anti-Fraud & Platform Security

XB2BX.COM employs enterprise-grade fraud detection and prevention systems to protect all Users and maintain the integrity of the marketplace. This chapter outlines our security infrastructure, User obligations, and incident response procedures.

13

Fraud Prevention & Detection

Systems, monitoring, and Platform obligations

The Platform deploys the following fraud prevention infrastructure across all transactions in real time:

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ML Transaction Monitoring

Machine learning models analyse every transaction in real time, flagging anomalous patterns for human review.

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3D Secure 2.0 (3DS2)

Strong Customer Authentication enforced on all eligible card transactions per PSD2 requirements.

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Risk Scoring

Dynamic risk scores applied to each transaction based on device, behaviour, velocity, and counterparty signals.

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IP & Device Fingerprinting

Advanced device intelligence to detect account takeovers, synthetic identities, and coordinated fraud rings.

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KYC/AML Screening

All Users screened against global sanctions, PEP, and adverse media databases at onboarding and ongoing.

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Dark Web Monitoring

Continuous monitoring for compromised platform credentials appearing in data breach repositories.

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Zero Tolerance — Fraud & Financial Crime Any attempt to conduct fraudulent transactions, money laundering, terrorist financing, or manipulation of Platform payment systems results in immediate account termination, forfeiture of all held funds, and mandatory referral to the relevant law enforcement and financial intelligence authorities including the National Crime Agency (UK), FinCEN (US), TRACFIN (FR), and/or AUSTRAC (AU) as applicable.
14

Account & Payment Security

User obligations, 2FA, breach reporting, and liability

14.1 User Security Obligations

  • All payment-enabled accounts must have two-factor authentication (2FA) enabled. Accounts without 2FA may have payment functionality restricted.
  • Users must use strong, unique passwords and must not reuse passwords from other platforms.
  • Sharing account credentials with any third party is strictly prohibited and voids all fraud liability protections.
  • Users must ensure all payment instruments used on the Platform are legitimately owned or authorised by them.
  • Any suspected unauthorised access or suspicious account activity must be reported to security@xb2bx.com within 24 hours of discovery.
  • Users are liable for any transactions initiated during any period of unauthorised access caused by the User's failure to maintain account security.

14.2 Data Security Standards

XB2BX.COM is certified to PCI DSS Level 1. We do not store full card numbers, CVV codes, or sensitive authentication data. All payment data is tokenised and processed via certified gateway partners. Bank account details provided for wire transfers are encrypted at rest using AES-256. All data in transit uses TLS 1.3 minimum.


Chapter F

Code of Conduct

All Users of XB2BX.COM — Buyers, Sellers, and any person or entity accessing the Platform — are required to uphold the standards set out in this Code of Conduct. These standards protect the integrity of the marketplace and the rights of all participants.

15

Code of Conduct — General Standards

Behavioural standards, honesty, and fair dealing
Users Must
  • Transact honestly and in good faith at all times.
  • Provide accurate and complete information in all listings, profiles, and communications.
  • Honour all confirmed orders and contractual commitments.
  • Respond to Platform communications in a timely and professional manner.
  • Respect the privacy, intellectual property, and commercial rights of other Users.
  • Comply with all applicable laws and regulations in their jurisdiction.
  • Report suspected fraud, abuse, or policy violations via the Platform's reporting tools.
Users Must Not
  • Engage in misleading, deceptive, or fraudulent conduct.
  • Manipulate feedback, reviews, or Platform ratings artificially.
  • Use the Platform to circumvent taxes, customs duties, or export controls.
  • Engage in price-fixing, bid-rigging, or other anticompetitive behaviour.
  • Harass, threaten, or discriminate against other Users or Platform staff.
  • Attempt to transact or communicate with other Users off-platform to evade fees or protections.
  • Create multiple accounts to circumvent bans, limits, or KYC requirements.

15.1 Seller-Specific Standards

  • Sellers must ensure all product listings are accurate, complete, and not misleading as to specification, origin, quality, or price.
  • Sellers must hold all required business registrations, licences, and permits relevant to the goods offered for sale.
  • Sellers must not knowingly sell counterfeit, stolen, or infringing goods. Discovery of any such listing results in immediate removal, account suspension, and potential criminal referral.
  • Sellers must fulfil confirmed orders promptly and within the stated dispatch timeline, or notify Buyers and the Platform immediately of any delay.
  • Sellers must process valid refund and return requests in accordance with this Policy without undue delay or obstruction.

15.2 Buyer-Specific Standards

  • Buyers must use payment instruments that are legitimately owned or authorised.
  • Buyers must not submit false or exaggerated defect or dispute claims.
  • Buyers must not abuse the Platform's Buyer Protection Guarantee or chargeback mechanisms.
  • Buyers must inspect goods promptly upon delivery and raise any issues within the applicable timeframes.
16

Prohibited Activities & Listings

Absolute prohibitions, restricted categories, and enforcement

16.1 Absolutely Prohibited

🚫
Zero Tolerance — Immediate Termination The following activities result in immediate account termination, forfeiture of funds, and referral to law enforcement authorities: trafficking in human beings or labour exploitation; child sexual abuse material or goods enabling child exploitation; weapons of mass destruction or components thereof; narcotics, controlled substances, and drug paraphernalia; counterfeit currency; goods produced by forced, trafficked, or child labour; money laundering, terrorist financing, or financing of sanctioned parties.

16.2 Restricted Categories

The following categories require prior approval, enhanced documentation, or are subject to specific terms. Sellers wishing to list in restricted categories must contact compliance@xb2bx.com prior to listing:

  • Pharmaceuticals, medical devices, and healthcare products — require applicable regulatory approval documentation.
  • Food and beverage products — require relevant food safety certifications and labelling compliance.
  • Chemicals, industrial gases, and hazardous materials — require MSDS sheets, UN transport classifications, and any applicable export licence.
  • Dual-use technologies and controlled goods — subject to export control verification per applicable national law.
  • Financial instruments, securities, or investment products — require applicable financial regulatory authorisation.
  • Tobacco, vaping products, and alcohol — require age verification protocols and applicable excise compliance.

16.3 Enforcement

Violations of the Code of Conduct may result in: (a) listing removal; (b) account suspension (temporary or permanent); (c) forfeiture of escrowed or outstanding settlement funds; (d) recovery of costs incurred by XB2BX.COM; (e) civil proceedings; and/or (f) criminal referral. The severity of enforcement action is determined by the nature, frequency, and impact of the violation.


Chapter G

Anti-Slavery, Anti-Bribery & Ethical Trading

XB2BX.COM Ltd is committed to acting ethically in all business dealings. We take a zero-tolerance approach to modern slavery, human trafficking, forced labour, and corruption in any form, and we require all Platform Users to uphold equivalent standards.

17

Modern Slavery & Human Trafficking Policy

UK Modern Slavery Act 2015 compliance, supply chain obligations

This section is issued in compliance with Section 54 of the UK Modern Slavery Act 2015. XB2BX.COM Ltd publishes an annual Modern Slavery Transparency Statement available at xb2bx.com/legal/modern-slavery. This Policy supplements that statement.

17.1 Our Commitments

  • We prohibit the use of forced, compulsory, bonded, trafficked, or child labour anywhere in our operations or supply chain.
  • We conduct due diligence on high-risk Suppliers through our KYB onboarding process, including beneficial ownership verification and supply chain questionnaires.
  • We provide training to relevant Platform staff on identifying indicators of modern slavery in trade transactions.
  • We operate a confidential reporting mechanism (ethics@xb2bx.com) for the reporting of suspected modern slavery.
  • We cooperate fully with law enforcement and the Gangmasters and Labour Abuse Authority (GLAA) in any investigation of modern slavery linked to Platform transactions.

17.2 Seller Obligations

  • All Sellers warrant that goods offered for sale have not been produced, in whole or in part, through forced, trafficked, bonded, or child labour.
  • Sellers of goods in high-risk industries (garment manufacturing, electronics, agriculture, construction, mining) must provide supply chain transparency documentation upon request.
  • Sellers must maintain their own appropriate due diligence policies in relation to modern slavery and human trafficking within their supply chains.
  • Any Seller found to have knowingly or recklessly traded in goods produced through exploitation will be permanently banned and reported to the National Referral Mechanism and relevant law enforcement.

17.3 Reporting Suspected Exploitation

Any User who suspects that goods listed or sold on the Platform have been produced through modern slavery or labour exploitation must report this immediately to ethics@xb2bx.com. Reports are treated with strict confidentiality. XB2BX.COM will investigate all credible reports and take appropriate action, including listing removal, account suspension, and law enforcement referral.

18

Anti-Bribery & Corruption Policy

UK Bribery Act 2010, FCPA compliance, and facilitation payments

XB2BX.COM operates in strict compliance with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and all applicable anti-corruption legislation in the jurisdictions in which we operate.

18.1 Prohibited Conduct

  • Offering, promising, giving, requesting, agreeing to receive, or receiving any financial or other advantage intended to improperly influence a business decision or public official.
  • Facilitation payments — payments made to public officials to expedite routine actions — are strictly prohibited, regardless of local custom or market practice.
  • Providing or accepting gifts, hospitality, or entertainment of excessive value in connection with Platform business where this could be perceived as an attempt to influence.
  • Entering into arrangements with third parties (agents, intermediaries, distributors) where any part of any payment is known or suspected to be a bribe.

18.2 User Obligations

All Sellers operating on XB2BX.COM warrant that they maintain, implement, and enforce their own adequate procedures to prevent bribery as required by applicable law. Sellers must immediately disclose to XB2BX.COM any request for, or payment of, a bribe in connection with any transaction on the Platform at compliance@xb2bx.com. Failure to disclose constitutes a material breach of these terms.


Chapter H

Compliance, Data Protection & Regulatory Framework

This chapter governs our data privacy obligations, sanctions compliance, cross-border regulatory requirements, and the limitations of Platform liability. XB2BX.COM maintains the highest standards of regulatory compliance across all operating jurisdictions.

19

Data Protection & Privacy

GDPR, CCPA, data collection, retention, and User rights

XB2BX.COM processes personal and financial data in compliance with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA), and analogous legislation globally. Our full Privacy Policy is available at xb2bx.com/legal/privacy.

19.1 Payment Data We Collect

  • Transaction metadata: amount, currency, timestamp, order ID, payment method type.
  • Billing address and identity information for fraud prevention and KYC/KYB compliance.
  • Bank account details (IBANs/account numbers) for wire transfers — encrypted at rest using AES-256.
  • Device fingerprints and IP addresses for fraud scoring and security purposes.
  • Communications and dispute submissions retained for evidence and compliance purposes.

19.2 Data Retention

Transaction data is retained for a minimum of 7 years from the date of the transaction in compliance with tax, AML, and financial reporting obligations. After the retention period, data is securely deleted or anonymised. Users requesting erasure of data that falls within mandatory retention periods will be informed accordingly.

19.3 User Rights

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Access

Request a copy of all personal and payment data held about you.

✏️
Rectification

Correct inaccurate or incomplete data in your payment profile.

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Erasure

Request deletion subject to legal retention obligations.

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Object

Object to processing for profiling or direct marketing.

πŸ“¦
Portability

Receive data in a structured, machine-readable format.

⏸️
Restriction

Request restriction of processing while a complaint is resolved.

Submit data rights requests to privacy@xb2bx.com with proof of identity. Response within 30 calendar days (GDPR/UK GDPR) or 45 days (CCPA). California residents additionally have the right to opt out of any "sale" of personal information — XB2BX.COM does not sell personal data.

20

Sanctions, AML & Counter-Terrorist Financing

OFAC, UN, EU, UK sanctions; KYC/KYB; AML obligations

XB2BX.COM maintains strict compliance with all applicable international sanctions regimes, anti-money laundering (AML) regulations, and counter-terrorist financing (CTF) requirements.

20.1 Prohibited Parties & Transactions

  • Users appearing on OFAC (US), UN, EU, or UK Consolidated Sanctions Lists are prohibited from accessing or transacting on the Platform.
  • Transactions with parties in comprehensively sanctioned countries are strictly prohibited.
  • Shell companies, nominees, or structures designed to obscure beneficial ownership are prohibited from onboarding.
  • Transactions involving prohibited goods (weapons, narcotics, CSAM) are automatically blocked and reported to authorities.

20.2 KYC / KYB Requirements

All Sellers and high-value Buyers are subject to mandatory Know Your Customer (KYC) / Know Your Business (KYB) verification before payment capabilities are activated. This includes: government-issued identity verification; business registration documents; beneficial ownership declarations; and source of funds declarations for transactions above applicable thresholds. Enhanced Due Diligence (EDD) applies to accounts with monthly transaction volumes exceeding USD $50,000 and to Politically Exposed Persons (PEPs).

20.3 Suspicious Activity Reporting

XB2BX.COM is required by law to file Suspicious Activity Reports (SARs) with relevant Financial Intelligence Units where we have reasonable grounds to suspect money laundering, terrorist financing, or sanctions evasion. We are prohibited by law from disclosing ("tipping off") any User that a SAR has been filed in connection with their account.

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Cross-Border Compliance

Tax obligations, export controls, and import duties

21.1 Tax Obligations

  • XB2BX.COM collects and remits VAT/GST where required by law as a deemed marketplace supplier (EU VAT OSS, UK VAT, Australian GST, and equivalent regimes).
  • Buyers are responsible for import duties, customs clearance fees, and local consumption taxes not collected at point of sale.
  • Sellers are solely responsible for income tax, corporate tax, withholding tax, and any other tax obligations on their earnings from the Platform.
  • Annual transaction summaries are available to all Users for tax filing purposes via the platform dashboard.

21.2 Export Controls

Certain goods traded on the Platform may be subject to export control regulations, including the US Export Administration Regulations (EAR), EU Dual-Use Regulation, UK Export Control Order, and equivalent national controls. Sellers of controlled items must maintain all required export licences and remain solely liable for all export compliance violations. XB2BX.COM reserves the right to block transactions involving controlled goods pending licence verification.

22

Liability, Indemnification & Governing Law

Platform limitations, User indemnity, and jurisdiction

22.1 Platform Liability Limitations

To the maximum extent permitted by applicable law, XB2BX.COM's total aggregate liability arising from any payment transaction shall not exceed the greater of: (a) the transaction value in dispute; or (b) USD $5,000. XB2BX.COM is not liable for indirect, consequential, punitive, or incidental damages, including loss of profit, loss of business, or loss of data arising from Platform use. Nothing in this Policy limits liability for death or personal injury caused by negligence, fraud, or fraudulent misrepresentation.

22.2 User Indemnification

Users agree to indemnify, defend, and hold harmless XB2BX.COM Ltd, its officers, directors, employees, and agents from any claims, damages, losses, or expenses (including reasonable legal fees) arising from: (i) breach of this Policy; (ii) fraudulent or unauthorised transactions; (iii) violation of applicable law; (iv) disputes with other Users; or (v) infringement of any third-party intellectual property or other rights.

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Governing Law & Jurisdiction This Policy is governed by the laws of England and Wales. For EU consumers, the mandatory consumer protection provisions of their country of residence additionally apply. Disputes not resolved through the Platform's dispute resolution process shall be submitted to the exclusive jurisdiction of the courts of England and Wales, unless arbitration under LCIA Rules is elected by either party.

Chapter I

Policy Enforcement, Amendments & Contact

This final chapter covers the mechanisms by which this Policy is maintained, updated, and enforced, along with the full contact directory for all Policy-related enquiries, reports, and regulatory communications.

23

Amendments, Versioning & User Notification

Change management, effective dates, and acceptance mechanism

XB2BX.COM reserves the right to update, modify, or replace this Policy at any time. Material changes are communicated as follows:

  • Email notification to all registered Users at least 30 days prior to material amendments taking effect.
  • Platform banner notification visible upon login for at least 14 days following updated policy publication.
  • Version history is maintained and accessible at xb2bx.com/legal/policy-history.
  • Minor amendments (typographical corrections, clarifications that do not affect User rights) may take effect immediately and are noted in the version changelog.
  • Continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you do not agree to any amendments, you must cease use of the Platform and contact support@xb2bx.com to arrange account closure and settlement of any outstanding amounts.

24

Contact Directory, Enforcement & Reporting

All key contacts for policy, legal, security, and regulatory matters

For any questions, complaints, reports, or concerns relating to this Policy, please contact the relevant team. Standard response: 2 business days. Urgent security matters: 24 hours.

Payment Support
payments@xb2bx.com

Transaction queries, refunds, billing disputes, escrow.

Data Privacy & GDPR
privacy@xb2bx.com

DSAR requests, DPO enquiries, consent, CCPA opt-outs.

Security & Fraud
security@xb2bx.com

Suspicious activity, fraud reports, vulnerability disclosure.

Legal & Compliance
legal@xb2bx.com

Regulatory enquiries, law enforcement requests, sanctions screening.

Ethics & Anti-Slavery
ethics@xb2bx.com

Modern slavery reports, bribery disclosures, ethical trade concerns.

Enterprise Accounts
enterprise@xb2bx.com

Custom payment terms, LC arrangements, KYB onboarding.

Dispute Escalation
disputes@xb2bx.com

Formal dispute submissions, arbitration referrals, Stage 3 escalations.

AML / Compliance
aml@xb2bx.com

KYC/KYB queries, SAR liaison, enhanced due diligence requests.

Registered Address

XB2BX.COM Ltd
Global Operations Centre
London, United Kingdom

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Regulatory Supervisory Authorities UK Users may contact the Financial Conduct Authority (FCA) at fca.org.uk regarding financial services complaints. EU Users may contact their national financial supervisory authority. Data protection complaints may be referred to the ICO (UK) at ico.org.uk, or to the relevant national Data Protection Authority in EU member states. These rights exist independently of XB2BX.COM's internal complaint procedures.
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