Verification Integrity and Fraud Prevention Framework

Pion operates a global identity verification and closed consumer group (“CCG”) access platform that enables brands to deliver targeted offers securely to eligible users. Our core responsibility is to ensure that access to protected offers is granted exclusively to verified, legitimate users, and that offer codes and associated benefits cannot be misused, leaked, or exploited. Our fraud prevention and verification integrity model is built on four foundational pillars:

1. Verification integrity and eligibility assurance
2. Code leakage detection and prevention
3. Continuous monitoring, adaptive controls, and enforcement
4. Human oversight, specialist review, and partner collaboration

These controls operate across all geographies and platform touchpoints, and are proportionate to the scale, sensitivity, and commercial impact of protected offers.

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Platform Scale, Volume, and Global Footprint

Our platform supports:

• Global verification coverage across multiple closed consumer groups, including student, graduate, professional, and other eligibility-based segments.
• High-volume verification requests across web, mobile, and API-integrated environments.
• Real-time verification decisions and code issuance at scale.
• Cross-border code distribution and redemption, with jurisdiction-appropriate safeguards.

Our infrastructure is designed to operate reliably at scale while maintaining strong controls against fraudulent access, account misuse, or code exploitation.

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Verification Integrity Model

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Layered Eligibility Verification

Access to protected offers is only granted following successful eligibility verification through one or more of the following mechanisms:

• Direct integration with authoritative eligibility data sources.
• Secure verification workflows involving institutional or organisational validation.
• Multi-signal behavioural and technical validation, including device, network, and usage pattern analysis.
• Risk-based verification workflows where higher-risk signals trigger enhanced validation.
• Manual verification review where automated verification confidence thresholds are not met.

Verification decisions are made dynamically, in real time, based on multiple eligibility signals and platform integrity controls.

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Dedicated Verification Integrity Team and Manual Review

In addition to automated controls, Pion operates a dedicated verification integrity team responsible for manual review of verification submissions and ongoing fraud prevention activities. This team consists of trained verification specialists (yes, real people!) who:

• Manually review verification documents where required, particularly in higher-risk or ambiguous cases
• Assess documents for authenticity, consistency, and integrity
• Identify indicators of manipulation, fabrication, or synthetic document creation
• Apply contextual judgement that complements automated verification systems

Verification specialists undergo continuous training to ensure they remain equipped to identify emerging fraud techniques, including documents that may have been fraudulently created or manipulated using AI-enabled tools. This human oversight layer provides an essential safeguard, ensuring that eligibility decisions are not solely reliant on automated systems and that complex or evolving fraud patterns can be identified and addressed effectively.

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Real-Time Access Control and Enforcement

Where eligibility cannot be verified or risk signals exceed defined thresholds, access is automatically restricted or denied. Controls include:

• Automated blocking of high-risk verification attempts
• Rate limiting to prevent automated abuse or scripted access attempts
• Detection and blocking of suspicious account creation patterns
• Dynamic restriction of verification retries where abuse signals are detected

These controls ensure that access to protected offers is granted only where eligibility confidence is high.

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Code Leakage and Misuse Prevention Framework

Because promotional codes represent a direct financial exposure to brands, Pion applies specific controls to prevent unauthorised code access, sharing, or exploitation.

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Controlled Code Issuance

Offer codes are:

• Issued only after successful eligibility verification
• Delivered in a controlled and authenticated session environment
• Associated with specific user accounts and eligibility events

This ensures that codes cannot be accessed anonymously or without successful verification.

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Leakage Detection and Containment

Pion operates active monitoring systems designed to detect patterns consistent with code leakage or abuse, including:

• Abnormal redemption patterns
• Excessive access attempts to specific offers
• Behaviour indicative of automated scraping or bulk harvesting
• Geographic or behavioural anomalies inconsistent with expected user behaviour

In addition, Pion conducts proactive monitoring of external environments where leaked codes commonly appear, including:

• Voucher aggregation websites
• Online forums and discussion platforms
• Social media platforms
• Code-sharing communities and channels

This enables early identification of leaked codes and rapid containment measures. Where leakage is detected or suspected, controls may include:

• Immediate suspension of affected offers
• Revocation or rotation of exposed codes
• Restriction or suspension of suspicious accounts
• Strengthening of verification requirements for affected offer categories

These responses are implemented in real time or near real time to minimise financial exposure.

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Risk-Based Control Framework

Our fraud prevention approach is risk-based and proportionate to the sensitivity of each offer and brand partner. Controls may include:

• Enhanced verification requirements for high-value or high-risk offers
• Stricter access limits or issuance controls where required
• Increased monitoring for offers with elevated misuse risk
• Manual verification review for elevated risk scenarios
• Immediate intervention where integrity risk thresholds are exceeded

This ensures appropriate protection without negatively impacting legitimate user access.

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Operational Response and Incident Management

Where suspected fraud, misuse, or code leakage is identified, Pion follows defined response procedures, which may include:

• Investigation of suspicious activity by fraud and verification specialists
• Immediate containment measures to prevent further misuse
• Restriction or suspension of affected accounts
• Revocation or replacement of affected codes
• Strengthening of platform controls to prevent recurrence
• Collaboration with brand partners where appropriate

These procedures ensure prompt containment and remediation of any fraud-related risk.

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Partner Collaboration and Shared Fraud Prevention Responsibility

Fraud prevention is most effective when approached as a collaborative effort between Pion and its brand partners. While Pion maintains comprehensive controls across the verification and code issuance lifecycle, brand partners possess additional transaction-level visibility that can provide important fraud signals. Partners can support fraud prevention efforts by:

• Monitoring redemption and transaction patterns for suspicious activity
• Identifying anomalous redemption volumes, geographic irregularities, or unusual purchasing behaviour
• Notifying Pion of suspected code leakage or misuse
• Sharing relevant fraud intelligence, where appropriate and compliant with applicable law

Pion and its partners operate as complementary layers of protection. This collaborative model enables rapid identification, investigation, and containment of fraud risks, while maintaining appropriate data protection boundaries and regulatory compliance.

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Continuous Monitoring and Improvement

Fraud prevention is an ongoing and actively managed process. Pion continuously refines its verification methodologies, detection capabilities, and enforcement mechanisms through:

• Ongoing training of verification and fraud specialists
• Continuous monitoring of fraud trends and attack patterns
• Evaluation and deployment of enhanced verification technologies
• Refinement of risk-based controls based on real-world platform insights
• Collaboration with partners and industry stakeholders

This ensures that Pion’s verification and offer protection systems remain robust, scalable, and aligned with evolving fraud risks and industry best practices.