1. Purpose and Scope

This Refund Policy (the “Policy”) sets out how Ohana Real Estate Development & Construction LLC SPC (the “Company”, the “Developer”, “we”, “us” or “our”) processes customer refund requests at each stage of the sales cycle — Expression of Interest (“EOI”), Offer to Purchase (“OTP”) and Sale and Purchase Agreement (“SPA”) — and for any related online payments, service charges, registration fees and administrative fees.

It provides clarity on customer eligibility for refunds, the conditions under which refunds may be approved or restricted, and the operational, legal and compliance controls that apply. It is binding on all Ohana staff and applies to every payment initiated through our website, mobile application, customer portal, payment links and any third-party payment gateways we authorize.

By submitting a payment, the payer (the “Purchaser”, “you” or “your”) confirms acceptance of this Policy together with the related Online Sales Terms, the SPA and the EOI terms, where applicable. If there is any inconsistency, the SPA shall prevail in respect of the transaction it governs.

2. Governing Law and Regulators

This Policy is issued in compliance with, and shall be interpreted in accordance with, the laws of the United Arab Emirates and the Emirate in which the relevant property is located, including in particular:

• Law No. (7) of 2006 Concerning Real Property Registration in the Emirate of Dubai;
• Law No. (8) of 2007 Concerning Escrow Accounts for Real Property Development in the Emirate of Dubai;
• Law No. (13) of 2008 Regulating the Interim Real Property Register in the Emirate of Dubai, as amended by Law No. (19) of 2017 and Law No. (19) of 2020 (and in particular Article 11 on developer-led termination and refund tiers);
• Federal Decree-Law No. (15) of 2020 on Consumer Protection and its Executive Regulations issued under Cabinet Resolution No. (66) of 2023;
• Federal Decree-Law No. (14) of 2023 on Trading by Modern Technological Means (e-commerce);
• Central Bank of the UAE Consumer Protection Regulation and Standards on retail payment services and card transactions;
• Abu Dhabi: Law No. (3) of 2015 (as amended by Law 2 of 2025) Concerning the Regulation of the Real Estate Sector in the Emirate of Abu Dhabi and the regulations of the Department of Municipalities and Transport (DMT).

The Dubai Land Department (“DLD”) and the Real Estate Regulatory Agency (“RERA”), and, where applicable, the DMT in Abu Dhabi, are the competent regulators.

3. Definitions

EOI (Expression of Interest): A pre-launch, non-binding payment made by the Purchaser to be considered for unit allocation. The EOI does not constitute a reservation or a binding sale.

OTP (Offer to Purchase): The Purchaser’s binding offer to acquire a specific unit, supported by a booking/reservation payment and the terms attached to that offer. The OTP secures the unit for a defined period pending execution of the SPA (typically 5–14 calendar days).

SPA (Sale and Purchase Agreement): The legally binding contract between Ohana and the Purchaser setting out the purchase price, payment plan, handover and post-handover obligations.

Down Payment: The first instalment payable on or shortly after signature of the SPA, expressed as a percentage of the purchase price.

Instalment: Any scheduled payment due under the SPA payment plan, including construction-linked or time-linked milestones.

Service Charges: Recurring community, master-community and building service fees calculated and approved in accordance with applicable regulations.

Registration & Administrative Fees: Statutory fees payable to the DLD/DMT (including the Oqood registration fee) and Developer administrative fees (Oqood handling, NOC, name change, assignment, etc.).

Online Payment: Any payment initiated by electronic means through a card scheme (Visa, Mastercard, American Express), local debit network, online bank transfer, payment link, Apple Pay/Google Pay or any other regulated channel we make available.

3A. Material Changes

For the purposes of this Policy, a Material Change means a significant change initiated by the Company that substantially alters the key physical or contractual terms of the Property or the Purchaser’s rights under the Sale and Purchase Agreement (SPA) and would reasonably be expected to influence the Purchaser’s decision to proceed with the purchase. Material Changes include, but are not limited to, the following:

Property

• A reduction in the net saleable area of the Property exceeding 5% of the area specified in the Sale and Purchase Agreement (SPA).
• A material change to the unit type, configuration, or intended use.
• Allocation of an alternative unit that is materially different in size, location, value, or characteristics from the originally purchased Property.

Development Scope

• Cancellation of the Project.
• Permanent removal of significant facilities, amenities, or features that formed part of the Company’s sales offering and materially affect the value, intended use, or overall appeal of the Property.

Delivery

• The Company’s inability to deliver the Property in accordance with the Sale and Purchase Agreement (SPA) or applicable law.

Changes that generally do not constitute a Material Change

• Minor amendments to architectural drawings, layouts, construction plans, or technical specifications that do not materially affect the value, functionality, or intended use of the Property.
• Changes required by applicable laws, governmental authorities, or regulatory bodies.
• Replacement, substitution, or modification of finishes, fixtures, fittings, equipment, materials, brands, or specifications with items of equivalent or superior quality, functionality, and overall standard.
• Where a facility, amenity, feature, or specification originally proposed by the Company is replaced with an equivalent or superior alternative that does not materially diminish the overall quality, functionality, or value of the Project or Property.
• Minor variations in dimensions or specifications that fall within the permitted contractual or regulatory tolerances.
• Administrative corrections, clerical amendments, or documentation updates.
• Changes resulting solely from a Force Majeure Event, where such events are addressed in accordance with the Sale and Purchase Agreement (SPA) or applicable law (see Section 9.2).

Determination of Material Change

Whether a change constitutes a Material Change shall be determined by the Company, in accordance with the Sale and Purchase Agreement (SPA), applicable laws and regulations, and the specific facts and circumstances of each case. The Company’s determination under this Section 3A shall be final.

4. Accepted Online Payment Methods

We accept the following methods, subject to the limits and authentication standards published from time to time on our website:

• Credit and debit cards under the Visa, Mastercard and American Express schemes, processed through a PCI-DSS-compliant payment service provider with 3D Secure (3DS2) authentication;
• Local UAE debit network transactions where supported;
• Online bank transfers (push payments) into the relevant project escrow account opened under Law No. (8) of 2007;
• Apple Pay and Google Pay on supported devices;
• Such other regulated payment channels as we may designate from time to time.

Cash, cheques and crypto-assets are not accepted as online payment methods. All payments must originate from a bank account or card held in the name of the Purchaser. Payments made by third parties may be returned; any refund will be made to the originating account once source-of-funds verification is satisfied.

5. Refunds at the EOI Stage

EOI amounts are non-binding and are fully refundable until a unit is formally allocated, an SPA is offered for signature, or the Purchaser converts the EOI into an OTP. The EOI does not confer any priority right unless expressly stated in the EOI terms.

5.1. Refund Triggers

• Withdrawal by the Purchaser at any time prior to unit allocation (no reason required);
• Non-allocation by the Developer because the requested unit type, floor or view is no longer available;
• Withdrawal of the project from the market, change of launch date, or material change to the unit specification or price guidance;
• Failure of the Purchaser to satisfy KYC, source-of-funds or AML checks (refund subject to compliance clearance under Section 14).

5.2. Refund Treatment

• Refunds are made back to the original payment instrument used for the EOI, in AED;
• No interest, indemnity or other compensation shall be payable on refunded EOI amounts.

Operational Workflow

• Submission: the Purchaser sends the refund request, with supporting documents, to the Client Services – Operations team (refunds@ohana.ae or via the Customer Portal).
• Review: Operations review the case within twenty-five (25) UAE business days and issues a cancellation letter for signature, confirming the refund amount and any deductions applicable to the EOI stage.
• Payment: once the signed cancellation letter is received, the refund is processed within seven (7) UAE business days to the original payment instrument, in line with Section 11.
• Charges: any bank transfer charges, scheme fees or correspondent bank charges shall be borne by the Purchaser and may be deducted from the refunded amount.

6. Refunds at the OTP Stage

Once a Purchaser confirms a specific unit by executing an OTP and paying the related booking/reservation amount, the OTP secures the unit for the period stated in the booking confirmation. Within that hold period, the SPA must be signed and the balance of the Down Payment paid.

6.1. When the OTP Payment is Non-Refundable

• Failure by the Purchaser to execute the SPA within the hold period;
• Failure by the Purchaser to pay the balance of the Down Payment within the hold period;
• Withdrawal by the Purchaser without cause after unit allocation; or
• Provision by the Purchaser of materially incorrect KYC information.

6.2. When the OTP Payment is Refundable

• The Developer is unable to deliver the reserved unit for any reason within its control;
• Material changes are made by the Developer to the unit, payment plan, handover date or master plan before the SPA is executed (as defined in Section 3A);
• The Purchaser is rejected on legitimate compliance, sanctions or AML grounds despite acting in good faith;
• The Developer terminates the OTP prior to SPA execution for reasons not attributable to the Purchaser.
• Deductions at this stage are based on the terms and conditions set out in the OTP.

Operational Workflow

• Submission: the Purchaser sends the refund request, with supporting documents, to the Client Services – Operations team ( refunds@ohana.ae or via the Customer Portal).
• Review: Operations reviews the case within twenty-five (25) UAE business days and issues a cancellation letter for signature, confirming the refund amount and any deductions applicable to the OTP stage.
• Payment: once the signed cancellation letter is received, the refund is processed within seven (7) UAE business days to the original payment instrument, in line with Section 11.
• Charges: any bank transfer charges, scheme fees or correspondent bank charges shall be borne by the Purchaser and may be deducted from the refunded amount.

7. Refunds at the SPA Stage (Down Payments and Instalments)

The SPA is a legally binding agreement between Ohana and the Purchaser. The Purchaser is obligated to adhere to the payment terms set out in the SPA, and the Down Payment and all subsequent instalments are governed by the SPA and the applicable escrow account arrangements.

• Any cancellation request at this stage is subject to legal review and processed in accordance with the SPA and Section 8 (Statutory Cancellation Tiers);
• The Down Payment and any paid instalments are not refundable in the ordinary course on a Purchaser-initiated cancellation;
• Refunds, where due under Section 8, Section 9 (Developer Default and Force Majeure) or by mutual written agreement, are paid into the originating bank account net of (a) any amounts the Developer is entitled to retain by law and (b) reasonable costs and applicable taxes;
• Refunds in respect of amounts that have been swept from escrow into construction draws are made within the statutory timelines set out in Section 8;
• Where the SPA is assigned to a substitute purchaser with the Developer’s prior written consent, no refund is due to the original Purchaser other than as separately agreed in the assignment documents.

Operational Workflow

• Submission: the Purchaser sends the refund request, with supporting documents, to the Client Services – Operations team ( refunds@ohana.ae or via the Customer Portal).
• Review: Operations review the case within twenty-five (25) UAE business days and issue a cancellation letter for signature, confirming the refund amount and any deductions applicable to the SPA stage.
• Payment: once the signed cancellation letter is received, the refund is processed within seven (7) UAE business days to the original payment instrument, in line with Section 11.
• Charges: any bank transfer charges, scheme fees or correspondent bank charges shall be borne by the Purchaser and may be deducted from the refunded amount.

8. Statutory Cancellation Tiers

8.1. Dubai Projects (Article 11, Law No. 13 of 2008, as amended)

Where the Developer exercises its right to terminate the SPA in respect of an off-plan unit for a Purchaser default, the refund (if any) is calculated in accordance with the tiered framework set out in Article 11 of Law No. (13) of 2008 Regulating the Interim Real Property Register, as amended by Law No. (19) of 2017 and Law No. (19) of 2020:

The Developer will register the termination with RERA, obtain the official completion-percentage certificate, and process the refund through escrow against the Purchaser’s release of all claims over the unit. DLD/Oqood fees already paid to the regulator are non-refundable by the Developer (recovery, if any, must be sought directly from the regulator).

8.2. Abu Dhabi Projects (Law No. 3 of 2015, as amended by Law No. 2 of 2025)

Where the Developer exercises its right to terminate the Sale and Purchase Agreement (SPA) in respect of an off-plan unit in an Abu Dhabi project for a Purchaser default, the Developer’s maximum retention is calculated by reference to the Project’s construction completion percentage at the date of cancellation, in accordance with the Default and Termination provisions of the applicable Sale and Purchase Agreement (SPA) issued under Law No. (3) of 2015 Concerning the Regulation of the Real Estate Sector in the Emirate of Abu Dhabi, as amended by Law No. (2) of 2025:

The Developer will register the termination with the Department of Municipalities and Transport (DMT) or ADREC as applicable, obtain confirmation of the Project’s construction completion percentage, and

process the refund through the escrow account against the Purchaser’s release of all claims over the unit. Registration fees already paid to the regulator are non-refundable by the Developer (recovery, if any, must be sought directly from the regulator).

9. Developer Default and Force Majeure

9.1 Developer Default

If the Developer terminates the SPA for reasons attributable to the Developer, or if the project is cancelled in circumstances giving rise to a full refund right under applicable law, 100% of the amounts paid by the Purchaser (excluding non-refundable government fees) will be refunded to the originating account within sixty (60) calendar days of the effective date of termination, without interest unless ordered by a competent court or regulator.

9.2. Force Majeure

A Force Majeure Event includes acts of God, war, civil unrest, pandemics, government action, sanctions, embargoes, denial-of-access events and other circumstances beyond the reasonable control of the affected party. Performance obligations and payment deadlines are suspended for the duration of the event. If the event continues for more than twelve (12) consecutive months and renders the SPA incapable of performance, either party may terminate and the Purchaser will be refunded all amounts paid, less amounts the Developer is permitted to retain under Section 8 in respect of works actually executed and subject to any other applicable law.

10. Service Charges, Registration Fees and Administrative Fees

10.1. Service Charges

• Service charges are calculated and billed annually in accordance with the budget approved by the relevant Owners’ Association or regulator;
• Pre-paid service charges are refundable on a pro-rata daily basis where the Purchaser is no longer the registered owner of the unit during the period in question, less any arrears, late-payment interest and reasonable administrative recovery costs;
• Service charges paid for periods after handover are not refundable merely because the unit is vacant or unused.

10.2. Government Registration Fees

• DLD transfer fees, Oqood registration fees, mortgage registration fees and Title Deed issuance fees collected from the Purchaser are paid through to the relevant authority and are not refundable by the Developer;
• Where a transaction is reversed before registration is effected, the Developer will use reasonable efforts to assist the Purchaser in recovering such fees directly from the regulator, subject to that regulator’s rules.

10.3. Administrative Fees

NOC issuance, name-change, assignment, document-reissue, late-payment processing and similar administrative fees are earned once the corresponding service is delivered and are non-refundable;

If the requested service is not performed or is withdrawn before delivery, the administrative fee is refunded in full to the originating account within fourteen (14) UAE business days.

11. How to Request a Refund

A refund request must be submitted in writing through Ohana’s official channels (the Customer Portal, refunds@ohana.ae, or in person at an Ohana Sales Centre) and must include:

• The Purchaser’s full legal name and Emirates ID / passport number (matching the original booking);
• The project, building, unit number and SPA reference (if applicable);
• A copy of the original payment receipt(s) and the bank statement evidencing the debit;
• A signed refund authorization form and source-of-funds declaration; and
• Where applicable, a power of attorney duly notarised and (if executed abroad) attested by a UAE Embassy and the UAE Ministry of Foreign Affairs.

Following the standard operations workflow set out in Sections 5–7 (25 UAE business days for review and issuance of the cancellation letter, then 7 UAE business days from signed confirmation to payout conditional on “complete documents, compliance clearance, finance approval, escrow bank approval, and regulator requirements.”), the following indicative timelines apply by payment method:

*Indicative only. Timelines may be extended for compliance, AML, sanctions, source-of-funds or judicial reasons. Cross-border refunds are subject to the receiving bank’s and correspondent network’s timelines.

11.1. Refund Channel

All refunds are issued to the same instrument used for the original payment. If that instrument has been closed or is otherwise unavailable, the Developer will require additional KYC documents and may, in its discretion, refund to an alternative account held in the Purchaser’s own name.

11.2. Currency, Bank Charges and Foreign Exchange

• Refunds are issued in AED. Where the original payment was made in a foreign currency, the AED amount actually received by the Developer is the amount that will be refunded; foreign exchange gains or losses are for the Purchaser’s account; Ohana has the express right to deduct unpaid instalments, penalties, admin costs, chargeback fees, bank charges, taxes, broker commissions if contractually recoverable, and any amounts Ohana may retain under the SPA or applicable law as applicable.
• Correspondent bank charges, intermediary bank charges and acquirer fees are borne by the Purchaser and may be deducted from the refunded amount;
• VAT applied to the original transaction (where applicable) will be refunded to the Purchaser in line with the Federal Tax Authority’s rules and the Developer’s tax position.

11A. Refund Approval Matrix

All refund requests shall undergo the appropriate review and approval process before any refund is processed. The approval process is designed to ensure that refund requests are commercially justified, contractually compliant, accurately calculated, and processed in accordance with the Company’s governance framework. The reviews described in this Section 11A form part of, and must be completed within, the twenty-five (25) UAE business day review period referred to in Sections 5, 6 and 7; they do not extend that period. The refund approval process shall comprise the following stages:

Business Review

The Business Review shall assess the commercial justification for the refund request and verify that the refund is eligible under the Sale and Purchase Agreement (SPA), this Policy, and any applicable commercial arrangements. Management shall determine whether the refund should be approved or rejected based on the commercial merits of the request. For refund requests that are expected to have a material impact on the Project’s cash flow, liquidity, or financial commitments, the Chief Financial Officer (CFO) shall also participate in the Business Review and approval process.

Legal Review

The Legal Review shall assess the refund request for compliance with the Sale and Purchase Agreement (SPA), applicable laws and regulations, and any contractual or legal implications. Where applicable, Legal shall confirm that the refund complies with contractual obligations and recommend any necessary legal actions or conditions.

Accounting Review

• Verify the refund amount and supporting calculations.
• Confirm the validity of any deductions permitted under the Sale and Purchase Agreement (SPA), this Policy, or applicable law.
• Review supporting documentation to ensure completeness and accuracy.
• Assess the accounting, tax, escrow, and financial reporting implications of the refund.
• Process the refund in the accounting system and coordinate payment upon receipt of all required approvals.

Refund Approval Matrix

Governance

The approval authorities specified above represent the minimum approval requirements. Additional approvals may be required in accordance with the Company’s Delegation of Authority (DOA) or where deemed necessary by Management. Where Business, Legal and Accounting do not agree on the recommended outcome, the matter shall be escalated to the CFO and the Legal & Strategic Director for joint determination before any refund is processed. No refund shall be processed until all required reviews and approvals have been completed and documented.

12. Consumer Protection and Cooling-Off

Where required by Federal Decree-Law No. (15) of 2020 and its Executive Regulations, or where expressly offered by Ohana, the Purchaser may benefit from a cooling-off period during which the online purchase may be cancelled without penalty. The standard cooling-off window for online transactions is fourteen(14) calendar days from the date of payment, provided that:

• No SPA has been signed, and no unit has been registered in the Interim Real Property Register;
• The request is submitted in writing through the official channels in Section 11; and
• The transaction does not fall within an exception listed in the Executive Regulations (including off-plan units already registered in the Interim Real Property Register or amounts paid into a regulated escrow account against works in progress).
• During the cooling-off period the Developer is entitled to deduct only the reasonable, documented costs of card scheme fees and out-of-pocket disbursements actually incurred.

13. Chargebacks and Payment Disputes

If you believe payment was unauthorized, duplicated or processed in error, contact us immediately through the channels in Section 11 before initiating a chargeback with your card issuer. Unjustified chargebacks may be defended by the Developer and, if reversed, may result in (i) suspension of access to the Customer Portal, (ii) reapplication of any cancelled holds, and (iii) recovery of the associated bank and scheme fees from the Purchaser.

Where a chargeback is upheld, the corresponding amount is treated as refunded for the purposes of this Policy and the SPA, and the underlying contractual position is revisited in accordance with Sections 6 to 8.

14. KYC, AML and Sanctions

All refunds are subject to satisfactory completion of Know-Your-Customer, anti-money-laundering, counter-terrorism-financing and sanctions screening checks under UAE federal law and the Developer’s internal compliance policies. The Developer reserves the right to:

• Withhold a refund pending receipt of additional information or documents;
• Decline to process a refund where a sanctioned person, jurisdiction or instrument is involved, and to report the matter to the competent authority; and
• Refund only to a verified account held in the name of the Purchaser and located in a permitted jurisdiction.

15. Data Protection and Payment Security

Online payments are processed through PCI-DSS-compliant payment service providers. The Developer does not store full primary account numbers, CVV2/CVC2 values or one-time passwords on its systems. Personal data submitted in connection with refunds is processed in accordance with Federal Decree-Law No. (45) of 2021 on the Protection of Personal Data and the Ohana Privacy Notice.

15A. Audit Trail and Record Retention

The Company shall maintain a complete audit trail for all refund requests to ensure transparency, accountability, and compliance with applicable laws, regulations, and internal policies. The refund file shall, where applicable, include:

• Customer and Property details, including the relevant unit information and Sale and Purchase Agreement (SPA) reference.
• The refund request, cancellation details, reason for the refund, and all supporting documents submitted by the Purchaser.
• All relevant correspondence and records relating to the refund, including emails, meeting notes, call records, negotiations, and internal comments or recommendations, excluding privileged legal advice, which shall be retained separately by the Legal Department in accordance with the Company’s document retention protocols.
• Business, Legal, and Accounting reviews conducted under Section 11A, together with the respective approvals obtained in accordance with this Policy and the Company’s Delegation of Authority (DOA).
• Refund calculations, deductions (where applicable), accounting records, payment approvals, proof of payment, and any other documents supporting the processing of the refund.
• Any additional documentation considered necessary to demonstrate the basis of the refund decision and provide a complete audit trail.

All refund records shall be retained for a minimum period of seven (7) years from the date the refund is processed, or for such longer period as may be required under applicable laws, regulatory requirements, or the Company’s Record Retention Policy, and shall be handled in accordance with Section 15 and the Ohana Privacy Notice. The Client Services – Operations team shall act as custodian of the refund audit trail; the Legal Department shall separately retain records of its own legal review and advice.

16. Limitation of Liability

Save for liability that cannot be excluded under applicable law, the Developer’s aggregate liability arising out of or in connection with this Policy is limited to the amount of the relevant payment in respect of which a refund is being claimed. The Developer is not liable for indirect, consequential or punitive losses, lost profits, lost opportunities or currency movements.

17. Amendments

The Developer may amend this Policy from time to time to reflect changes in law, regulation or business practice. The updated Policy will be published on the Developer’s website with the new effective date. Online payments initiated after the effective date will be governed by the updated Policy; payments initiated before that date will continue to be governed by the version then in force.

18. Governing Law and Dispute Resolution

This Policy is governed by the federal laws of the United Arab Emirates and the laws of the Emirate in which the relevant project is located. Disputes are referred first to the Ohana Client Services team for amicable resolution within thirty (30) days. If unresolved, the dispute is referred to:

• For Dubai projects: the Rental Disputes Settlement Centre (where applicable) or the Dubai Courts, and the DLD/RERA complaints mechanism;
• For Abu Dhabi projects: the competent courts of the Emirate of Abu Dhabi and the DMT complaints mechanism;
• Consumer matters may additionally be referred to the Ministry of Economy Consumer Protection Department under Law 15/2020.

19. Contact Details

OHANA REAL ESTATE DEVELOPMENT & CONSTRUCTION LLC SPC

For more information, contact info@ohana.ae or use the below channels

Website: www.ohana.ae

Customer Care E-mail: customercare@ohana.ae

Refunds E-mail: refunds@ohana.ae

Telephone: (+971) 800 600 600, (+971) 02 307 3333 – Ex: 3

Office Hours: Mon–Sat, 09:00–18:00 (GST)

Registered Office: Landmark Tower 64th floor, Corniche Area, Abu Dhabi

Location Pin: Click Here