Refund Policy

1. SCOPE AND STATUS OF THIS POLICY
1.1 This Refund Policy (the "Policy") applies to the strategic advisory and consulting services provided by Ekofylia EOOD, a Bulgarian company with registered office at 70, William Gladstone Street, 8000 Bourgas City, Bulgaria (UIC/EIK 206220941; LEI 9845008H9DAC92E9EC55; "Ekofylia"), to company directors, managers and other senior executives and ordered or paid for through www.ekofylia.com (the "Services"). It governs cancellation, rescheduling, withdrawal, complaints about the Services and refunds of fees paid. 1.2 This Policy forms an integral part of the Terms of Service published on the Website (the "Terms"), whose definitions apply here, including "PSP" and "Merchant of Record". In the event of conflict, a specific written provision of the applicable Engagement Letter prevails over this Policy, and this Policy prevails over the Terms in respect of cancellations and refunds. Nothing in this Policy affects rights that cannot be waived under mandatory law. 1.3 By ordering Services, the Client confirms that it has read this Policy before the conclusion of the contract and accepts it. Ekofylia sends a copy of this Policy with each order confirmation.

2. NATURE OF THE SERVICES
2.1 The Services are intangible, personalised advisory services, performed through the time, expertise and preparatory work of Ekofylia's consultants. Once a session has taken place, or once preparatory work or a deliverable has been carried out or supplied, the resources committed cannot be restored or reused, and the value of the Services is received by the Client at the time of performance. 2.2 The Services are an obligation of means and not of result. A refund is therefore not due because the Client's business results, decisions, negotiations, funding, regulatory outcomes or expectations differ from those anticipated, nor because the Client later changes its mind or its strategy.

3. PROFESSIONAL CLIENTS AND CONSUMERS
3.1 The Services are intended for persons acting for purposes related to their business, trade or profession. Professional Clients have no statutory right of withdrawal; their cancellation and refund rights are those set out in this Policy and in the Engagement Letter. 3.2 A Client who qualifies as a consumer under the Bulgarian Consumer Protection Act and Directive 2011/83/EU and who concludes a contract at a distance may withdraw from it without giving any reason within fourteen (14) days from the day of conclusion of the contract, by an unequivocal statement sent to info@ekofylia.com (a model withdrawal form is available on request, and its use is optional). 3.3 If the consumer expressly requests that the Services begin before the end of the withdrawal period, the consumer must pay Ekofylia an amount proportionate to the Services already provided at the time of notification of the withdrawal, calculated on the basis of the agreed price. The consumer loses the right of withdrawal once the Services have been fully performed, provided that performance began with the consumer's prior express consent and acknowledgement that the right of withdrawal would be lost upon full performance. Ekofylia will request this consent and acknowledgement at the time of the order. 3.4 For consumers, the cancellation tiers of Article 4 apply only to the extent that they are more favourable than the statutory rights, and Ekofylia does not deduct payment processing costs from any refund due to a consumer.

4. CANCELLATION AND RESCHEDULING BY THE CLIENT
4.1 For one-off Services consisting of a scheduled session or meeting (a "Session"), the Client may cancel or reschedule by written notice to info@ekofylia.com. If notice is received more than seven (7) calendar days before the scheduled start of the Session, the Client is entitled to a refund of one hundred percent (100%) of the fee paid or, at its option, to one free rescheduling to a date offered within ninety (90) days. If notice is received between seven (7) calendar days and forty-eight (48) hours before the scheduled start, the Client is entitled to a refund of fifty percent (50%) of the fee paid or to one rescheduling subject to the availability of Ekofylia. If notice is received less than forty-eight (48) hours before the scheduled start, or if the Client does not attend, no refund is due and the Session is deemed performed, unless Ekofylia agrees to reschedule in its discretion. 4.2 For a Session already begun, the fee is due in full irrespective of the Client's early departure or the shortening of the Session at the Client's request. 4.3 A cancellation takes effect on the date on which Ekofylia receives written notice, as evidenced by the e-mail record. Rescheduling is limited to one occasion per Session unless Ekofylia agrees otherwise.

5. RETAINERS AND PROJECT MANDATES
5.1 For advisory programmes or retainers invoiced periodically (monthly or per quarter) in advance, the Client may terminate for convenience by giving thirty (30) days' written notice, ending at the end of a billing period. Fees for the billing period in progress are not refundable, and fees paid in advance for any period beginning after the effective date of termination are refunded in full. Unused hours or sessions included in a period expire at its end and are not refundable or creditable, unless the Engagement Letter provides otherwise. 5.2 For project mandates priced as a fixed fee or by milestones, the Client may terminate before completion by written notice. Ekofylia will then invoice, and may retain from the fees paid, the portion of the fee corresponding to the work performed and the deliverables supplied up to the date of termination, calculated by reference to the milestones achieved or, failing a milestone schedule, to the time spent at the rate stated in the Engagement Letter, together with any non-recoverable third-party costs properly incurred and authorised by the Client. The balance of any amount paid in excess of that portion is refunded. 5.3 A deposit or initial instalment paid on a project mandate secures the reservation of the consultants' time and is retained, up to the amount of the work performed and the reserved capacity lost, if the Client cancels after the Engagement Letter has been accepted and Ekofylia has started the preparatory work or declined other engagements for the reserved period; otherwise it is refunded under Article 4.

6. CANCELLATION BY EKOFYLIA
6.1 If Ekofylia cancels or is unable to perform a Session or any part of the Services for reasons other than the Client's default, it will notify the Client without delay and offer, at the Client's choice, rescheduling to a mutually convenient date or a full refund of the fee corresponding to the Services not performed. 6.2 If Ekofylia declines or terminates the Services because of a conflict of interest, because it cannot complete its client due diligence, or because the Services would breach applicable law, it will refund the fees corresponding to the Services not performed. Where the termination results from the Client's failure to provide required information or from a breach of Article 10 of the Terms, Ekofylia may retain the fees for the Services performed.

7. NON-REFUNDABLE ITEMS
7.1 Subject to mandatory law, no refund is due for: (a) Services fully performed and Sessions held; (b) preparatory work, analyses and deliverables already supplied; (c) time reserved and lost because the Client failed to attend or to provide information, documents or access within the agreed time; (d) third-party costs, disbursements, fees or taxes already incurred or paid on the Client's behalf with its approval; (e) bank and PSP charges borne by the Client; (f) dissatisfaction with the outcome of the advice or with business results, as stated in Article 2; and (g) amounts paid under an Engagement Letter for Services which the Client has terminated without complying with the notice required by Article 5.

8. SERVICE QUALITY CLAIMS AND REMEDIES
8.1 If the Client considers that a Session or deliverable has not been performed in accordance with the Engagement Letter or with the care and skill reasonably expected, it must notify Ekofylia in writing at info@ekofylia.com within fourteen (14) days of the Session or of the delivery, describing the alleged defect with reasonable precision. This period does not apply to consumers, who retain their statutory remedies. 8.2 Ekofylia will acknowledge the claim within three (3) Business Days and, where the claim is justified, will first remedy the defect at no additional cost by re-performing the Services or correcting the deliverable within fifteen (15) Business Days of acknowledgement, or such longer period as the parties agree. 8.3 If Ekofylia does not remedy the defect within that period, or the remedy is not possible, the Client is entitled to a reduction of the fee or, where the defective Services are of no substantial use to it, to a refund of the fee for the defective part, in proportion to the defect established. The Client's remedies under this Article are in addition to any non-excludable remedy under mandatory law.

9. REFUND PROCEDURE
9.1 A refund request must be sent by e-mail to info@ekofylia.com, quoting the name of the Client, the order or invoice reference, the date and amount of payment, the Services concerned and the grounds of the request, and enclosing any supporting document. 9.2 Ekofylia acknowledges the request within three (3) Business Days and informs the Client of its decision within ten (10) Business Days of receipt of a complete request. Where Ekofylia may need further information or identity or payment verification, it will state what is required, and the period runs again from receipt. 9.3 Where a refund is due, Ekofylia initiates it as soon as possible and in any event within fourteen (14) calendar days from the date of the decision or, for a consumer who withdraws, from the day on which Ekofylia is informed of the decision to withdraw. Ekofylia may suspend the refund of a consumer until it has received evidence that the Services returned or not yet performed are not in dispute, to the extent permitted by Directive 2011/83/EU. 9.4 Refund eligibility periods. A refund request must be submitted within thirty (30) calendar days of the event giving rise to it (the Session, the delivery of the deliverable, the cancellation by Ekofylia or the payment error) and, in any event, within ninety (90) calendar days of the date of payment. A request submitted after these periods is not eligible for a refund, except in the case of a duplicate, erroneous or unauthorised payment, of a refund due to a cancellation by Ekofylia, or of a statutory right of a consumer that cannot be limited by contract.

10. METHOD, CURRENCY, TIMING AND TAXES
10.1 Refunds are made through the same payment method and to the same payer account used for the original payment, via the PSP or Merchant of Record that processed it, which executes the refund on behalf of Ekofylia (Ekofylia not itself initiating refunds with card acquirers or card schemes), Ekofylia remaining financially responsible for refunds due under this Policy, unless the Client expressly agrees otherwise and the change is accepted by Ekofylia and the PSP in compliance with anti-fraud and anti-money-laundering requirements. Refunds are made in euro (EUR), in the amount actually received by Ekofylia, and Ekofylia is not responsible for exchange-rate differences or charges applied by the Client's bank or card issuer. 10.2 Following initiation, the time needed for a refund to appear on the Client's account depends on the PSP and the Client's bank or card issuer, and is generally between five (5) and ten (10) Business Days. Ekofylia is not responsible for delays attributable to those third parties. 10.3 Where fees are refunded in whole or in part, the corresponding credit note is issued by the Merchant of Record where it issued the invoice for the transaction and otherwise by Ekofylia, with the adjustment of value added tax, where applicable, in accordance with the Bulgarian Value Added Tax Act. Where the Client is a professional, Ekofylia may deduct from the refund the non-recoverable transaction costs charged by the PSP for the original payment and the refund, to the extent these are documented; no such deduction applies to a consumer.

11. DUPLICATE, ERRONEOUS AND UNAUTHORISED PAYMENTS
11.1 If a Client is charged twice for the same order, or is charged an amount different from the amount invoiced, Ekofylia refunds the excess in full, without deduction, once the error is verified, normally within ten (10) Business Days. A Client who identifies a payment made without its authorisation must immediately notify both its payment service provider and Ekofylia, which will cooperate with the investigation and will not provide Services against a payment found to be unauthorised.

12. CHARGEBACKS AND PAYMENT DISPUTES
12.1 Before initiating a chargeback or payment dispute with its bank, card issuer or PSP, the Client undertakes to contact Ekofylia and to allow the periods stated in this Policy to run, so that the matter can be resolved directly. Ekofylia may contest any chargeback, within the time limits set by the PSP or Merchant of Record (generally seven (7) calendar days from notification), by providing the PSP and the issuer with the Engagement Letter, invoices, session records, deliverables and correspondence evidencing the performance of the Services. 12.2 A chargeback initiated in respect of Services that were performed in accordance with the contract, or in breach of the procedures of this Policy, constitutes a breach of the contract. Ekofylia may recover the amount chargedback and all PSP and card-scheme fees, penalties and reasonable recovery costs resulting from it, and may suspend any further Services to the Client until payment, without prejudice to the consumer's rights.

13. COMPLIANCE HOLDS
13.1 Ekofylia and its PSP may delay, condition or refuse a refund, and may require additional identification or documents, where this is required by anti-money-laundering, counter-terrorist-financing, sanctions or fraud-prevention legislation, by an order of a competent authority or by the rules of the payment schemes. Ekofylia will inform the Client of the reasons for any delay to the extent permitted by law.

14. FORCE MAJEURE
14.1 If the performance of the Services is prevented or delayed by an event of force majeure as defined in Article 20 of the Terms, the parties will reschedule the Services. If performance remains impossible for more than sixty (60) days, either party may terminate the affected Services, and Ekofylia refunds the fees paid for the Services not performed, in accordance with Article 6.

15. CHANGES TO THIS POLICY
15.1 Ekofylia may amend this Policy to reflect changes in law, in the Services or in its payment processes. The amended Policy is published on the Website with a new revision date and applies to orders placed after publication; orders placed earlier remain governed by the version in force at the time of the order, unless the amendment is required by law or is more favourable to the Client.

16. GOVERNING LAW, DISPUTE RESOLUTION AND JURISDICTION
16.1 This Policy, and any dispute or claim (including non-contractual disputes) arising out of or in connection with it or with any refund, is governed by the law of the European Union applicable in the Republic of Bulgaria and by the law of the Republic of Bulgaria. The parties shall first seek to resolve any dispute amicably by written notice and good-faith negotiation for thirty (30) days. 16.2 Any dispute not resolved amicably is subject to the exclusive jurisdiction of the competent courts of Bourgas, Republic of Bulgaria, in accordance with Article 25 of Regulation (EU) No 1215/2012. Where the Client is a consumer, this paragraph applies without prejudice to the mandatory provisions of the law of the consumer's country of habitual residence under Article 6 of Regulation (EC) No 593/2008 and to the consumer's right to sue and be sued before the courts of its Member State of domicile under Articles 17 to 19 of Regulation (EU) No 1215/2012. Consumers may also have recourse to alternative dispute resolution bodies and to the Bulgarian Commission for Consumer Protection (www.kzp.bg). 1

7. CONTACT
17.1 Refund requests, withdrawal notices and questions about this Policy are to be sent by e-mail to info@ekofylia.com.



 version 1.0, dated 17 October 2026

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