Lost and Found Policy

Chapter I — Preliminary and General Provisions

1. Name, Title and Commencement

1.1 This document shall be known as the Setura Mobility Private Limited – Lost and Found Policy (hereinafter referred to as the "Policy").

1.2 This Policy shall come into effect from the date of its approval by the Board of Directors of Setura Mobility Private Limited or such other authorised person or committee as may be competent to approve the same under the Company's internal governance framework.

1.3 This Policy shall remain effective until amended, replaced, suspended or withdrawn in accordance with the Company's applicable governance procedures.

1.4 The Policy shall apply prospectively to relevant Lost and Found enquiries and incidents, subject to applicable law and any mandatory obligations relating to earlier incidents.

2. Corporate Background and Business Model

2.1 Setura Mobility Private Limited (hereinafter referred to as "Setura", the "Company" or "Platform") is engaged in providing technology-enabled mobility solutions and facilitating access to passenger transportation services through its digital platforms, booking interfaces, communication infrastructure and associated technological services.

2.2 The Company operates on a business model under which independent third- party bus operators, fleet owners, transportation service providers and other authorised partners (collectively referred to as "Bus Operators") provide and operate the actual buses and physical transportation facilities.

2.3 Unless expressly agreed otherwise, the Bus Operators are independently responsible for the physical deployment, operation, maintenance and management of their respective vehicles, including their drivers, conductors, attendants, onboard personnel, luggage compartments, cleaning personnel and other operational resources.

2.4 Setura's role, in relation to transportation services facilitated through its platform, is primarily technology-oriented, administrative, communication-based and facilitative, subject to the actual contractual arrangements and the Company's obligations under applicable law.

2.5 The Company does not, merely by facilitating a booking or receiving a passenger complaint, automatically acquire physical possession, custody, control or safekeeping responsibility over any bus, luggage compartment, personal belonging or other article.

2.6 The Parties' actual conduct, applicable statutory provisions and contractual arrangements shall determine their respective legal responsibilities. Nothing in this Policy shall be interpreted as conclusively determining the legal character of a relationship where applicable law provides otherwise.

3. Purpose of the Policy

3.1 The purpose of this Policy is to establish a legally structured framework governing the reporting, identification, verification, recovery, safekeeping, handling, collection and administrative closure of Lost and Found incidents associated with transportation services facilitated through Setura.

3.2 This Policy seeks to:

1. Establish a standardised procedure for reporting lost or forgotten articles;
2. Define the Company's limited technology and facilitation role;
3. Establish the physical responsibilities of the relevant Bus Operator;
4. Reduce disputes concerning the ownership, identity, condition and recovery of articles;
5. Prevent fraudulent, misleading, duplicate or unauthorised claims;
6. Provide a documented mechanism for communication and escalation;
7. Establish appropriate safeguards for valuable, sensitive, hazardous and restricted articles;
8. Minimise legal, financial, regulatory, reputational and operational exposure to the Company;
9. Protect passenger information and confidential data;
10. Establish appropriate contractual and procedural accountability for participating Bus Operators; and
11. Promote consistency, transparency, reasonable assistance and regulatory compliance.

4. Guiding Principles

The interpretation and implementation of this Policy shall be guided by the following principles:

4.1 Technology-provider distinction: The Company's role as a technology service provider shall be distinguished from the physical operational responsibilities of the independent Bus Operator.

4.2 Actual custody principle: Physical safeguarding obligations shall ordinarily attach to the person or entity actually possessing or controlling the article, subject to applicable law.

4.3 Reasonable assistance: Setura may provide reasonable administrative and communication assistance without guaranteeing successful recovery.

4.4 Passenger fairness: Legitimate passenger complaints shall be handled objectively and without arbitrary denial.

4.5 Verification and authenticity: No article shall be released through the facilitated process without reasonable verification of the Claimant's entitlement.

4.6 Proportionality: Verification, documentation, retention and disclosure measures shall be proportionate to the nature, value and sensitivity of the article.

4.7 Legal compliance: No provision of this Policy shall override a mandatory statutory obligation or lawful direction of a competent authority.

4.8 Accountability: All relevant actions, communications, decisions and handovers should be documented to the extent reasonably practicable.

5. Scope and Application

5.1 This Policy shall apply to Lost and Found incidents arising in connection with journeys facilitated through Setura's Digital Platform, including incidents involving:

1. Articles allegedly forgotten inside a bus;
2. Articles allegedly misplaced during boarding or disembarking;
3. Articles allegedly left in seating areas, overhead compartments or luggage racks;
4. Articles found by drivers, conductors, attendants, cleaning personnel or other authorised persons;
5. Articles recovered during vehicle cleaning, maintenance or inspection;
6. Articles transferred to a Bus Operator's office, depot or designated storage facility; and
7. Articles reported as missing or recovered at a designated transportation facility under the relevant Bus Operator's control.

5.2 This Policy shall not automatically extend to incidents occurring at independent railway stations, airports, hotels, restaurants, shopping centres, public premises or other third-party facilities merely because a Passenger has used a transportation service facilitated by Setura.

5.3 Where an incident occurs outside the physical or contractual control of the relevant Bus Operator, Setura may, where practicable, provide contact or referral assistance without assuming responsibility for the independent facility or its personnel.

5.4 This Policy applies to domestic transportation services facilitated through Setura within the territorial scope of the Company's operations, subject to applicable law and any additional requirements relevant to a particular service.

6. Definitions

Unless the context otherwise requires, the following expressions shall have the meanings assigned below.

6.1 "Company" or "Setura" means Setura Mobility Private Limited, including its lawful successors and permitted assigns.

6.2 "Bus Operator" means an independent third-party entity, individual, fleet owner, contractor or transportation service provider responsible for providing and/or operating the relevant bus or physical transportation service.

6.3 "Passenger" means an individual who has booked, purchased, accessed or used transportation services facilitated through Setura.

6.4 "Lost Property" means any movable article, personal belonging, luggage, document, electronic device, valuable or other item alleged to have been forgotten, misplaced, lost or left behind in connection with a journey.

6.5 "Found Property" means an article discovered, recovered, located or reported by a Bus Operator or other person having physical access to the relevant vehicle or facility.

6.6 "Claimant" means a Passenger or any individual asserting lawful ownership, possession or authority to collect an article.

6.7 "Recovery Coordination" means the administrative, communication and technology-enabled assistance undertaken by Setura to facilitate communication between the Passenger and the relevant Bus Operator or other person.

6.8 "Physical Custodian" means the person or entity actually possessing or controlling a recovered article, including a Bus Operator, its authorised personnel or another person to whom the article has lawfully been entrusted.

6.9 "Custody Record" means a record identifying the article, the person having physical possession, the date and time of receipt, subsequent transfers and final disposition, where such information is available.

6.10 "Unclaimed Property" means Found Property which remains unclaimed after reasonable efforts to identify or notify its apparent owner, subject to applicable law.

6.11 "High-Value Property" means property having substantial monetary, financial, personal, commercial or other material value, including jewellery, cash, luxury accessories and electronic devices.

6.12 "Sensitive Property" means property containing confidential, personal, financial, biometric, medical, authentication or other protected information.

6.13 "Hazardous Property" means any article reasonably suspected of presenting a threat to health, safety, security, property or the environment.

6.14 "Business Day" means a day other than a Sunday or public holiday at the relevant place of business, unless otherwise stated.

6.15 "Digital Platform" means the Company's website, mobile application, booking interface, customer support infrastructure and other technology systems made available by Setura.

6.16 "Applicable Law" means all central and state laws, rules, regulations, statutory notifications, judicial orders and binding directions applicable to the relevant subject matter.

6.17 "Incident" means an event involving the alleged loss, discovery, recovery, damage, theft, disappearance, transfer or unauthorised handling of property.

6.18 "Authorised Representative" means a person expressly authorised by the Passenger or another lawful Claimant to submit a complaint, receive communications or collect an article, subject to verification.

6.19 References to singular expressions shall include plural expressions and vice versa, where the context permits.

6.20 References to legislation shall include amendments, re-enactments, modifications and applicable subordinate legislation.

Chapter II — Allocation of Responsibility and Operational Control

7. General Allocation of Responsibility

7.1 The Company and the Bus Operator shall discharge their respective responsibilities in accordance with their actual contractual arrangements, operational control, possession of relevant property and applicable legal obligations.

7.2 For administrative purposes, responsibilities shall ordinarily be allocated as follows:

7.3 The above allocation is an administrative and contractual framework. It shall not override any liability arising independently under applicable law.

8. Setura's Capacity as a Technology Service Provider

8.1 Setura shall ordinarily perform Lost and Found functions through its Digital Platform, customer support systems, internal administrative processes and communication channels.

8.2 The Company's responsibilities may include:

1. Receiving Lost Property complaints;
2. Recording relevant booking details;
3. Verifying available electronic journey records;
4. Identifying the relevant Bus Operator;
5. Forwarding complaints and recovery requests;
6. Obtaining status updates;
7. Communicating responses to Passengers;
8. Maintaining administrative records;
9. Escalating unresolved matters internally; and
10. Facilitating a mutually agreed recovery arrangement.

8.3 The Company shall not be deemed to have undertaken physical inspection, surveillance, storage, transportation or security services merely because it provides any of the above assistance.

8.4 The Company shall not represent that it has physically inspected a bus or verified an article unless the relevant verification has actually been undertaken by an authorised person and communicated to the Company.

8.5 The Company shall not make independent factual representations regarding the condition, authenticity, quantity, contents, ownership or physical availability of an article beyond information reasonably verified or received from the relevant source.

9. Physical Responsibilities of the Bus Operator

9.1 The Bus Operator shall remain responsible for physical transportation operations under its control, subject to applicable law.

9.2 Without limiting the generality of the foregoing, the Bus Operator shall establish appropriate internal procedures for:

1. Vehicle cleaning and inspection;
2. Identification of unattended articles;
3. Recovery and documentation of articles;
4. Safe storage of recovered articles;
5. Access control over recovered property;
6. Employee and driver reporting;
7. Passenger identification and handover;
8. Escalation of suspicious or dangerous articles; and
9. Maintaining relevant records.

9.3 The Bus Operator shall designate an appropriate individual or department to coordinate Lost and Found matters.

9.4 The Bus Operator shall ensure that its drivers, conductors, attendants, cleaning personnel and other relevant employees are informed of the applicable Lost and Found procedures.

9.5 The Bus Operator shall not knowingly permit its employees or representatives to use, consume, appropriate, sell, pledge, transfer, conceal, tamper with or otherwise unlawfully deal with any recovered article.

9.6 The Bus Operator shall be responsible for investigating allegations concerning its personnel and taking appropriate corrective or disciplinary measures in accordance with applicable law.

10. No Automatic Creation of Bailment or Custodial Relationship with Setura

10.1 A Passenger's submission of a complaint through Setura's website, application, email, telephone support or other communication channel shall not, by itself, constitute delivery of an article into the Company's physical possession.

10.2 Mere knowledge of an alleged loss, receipt of a complaint, forwarding of information or facilitation of communication shall not, without more, constitute an acceptance of physical custody by Setura.

10.3 Where Setura expressly agrees to receive or physically hold a particular article, or where the circumstances and applicable law establish actual custody or a bailment relationship, the Company shall discharge the corresponding legal obligations.

10.4 No employee, customer support representative or other unauthorised person shall independently undertake to:

1. Accept physical custody of recovered articles on behalf of Setura;
2. Promise compensation or replacement;
3. Guarantee recovery or delivery;
4. Confirm ownership of an article;
5. Undertake insurance or safekeeping obligations; or
6. Make any binding admission of liability.

10.5 Any exceptional physical receipt by Setura must be approved by an authorised management representative and documented through a written custody acknowledgement.

Chapter III — Reporting, Registration and Initial Assessment

11. Reporting of Lost Property

11.1 A Passenger who discovers that an article may have been lost during a journey facilitated through Setura may submit a Lost Property complaint through the Company's officially designated customer support channels.

11.2 The Passenger should report the incident as soon as reasonably practicable after discovering the loss.

11.3 The Company may provide a dedicated Lost and Found reporting facility through its Digital Platform, email, telephone or other designated channels.

11.4 A report should ordinarily contain:

1. Full name of the Passenger;
2. Booking ID, PNR or ticket reference;
3. Registered contact number;
4. Email address;
5. Journey date;
6. Boarding and destination locations;
7. Bus Operator details, where known;
8. Seat number, if available;
9. Description of the missing article;
10. Approximate time and place where the article was last seen;
11. Estimated monetary value, if relevant;
12. Photographs or identifying information, where available; and
13. Any additional information reasonably required for verification.

11.5 The Company may request further information where the original complaint is insufficient to identify the journey, relevant vehicle or alleged missing article.

12. Time of Reporting

12.1 Passengers are encouraged to submit complaints immediately upon discovering the loss.

12.2 For operational purposes, the Company may prioritise complaints received within 24 hours of completion of the journey, particularly where the vehicle may still be available for inspection.

12.3 Complaints received after 24 hours may also be considered and forwarded to the Bus Operator, subject to available information and practical feasibility.

12.4 No internal reporting period shall be interpreted as automatically extinguishing a Passenger's statutory right, legal cause of action or remedy.

12.5 Delay in reporting may materially affect the ability to identify and recover an article, particularly where the vehicle has undertaken subsequent journeys, undergone cleaning or maintenance, or been redeployed.

13. Acknowledgement and Complaint Registration

13.1 Upon receipt of a complaint through an official channel, Setura may generate a complaint reference number.

13.2 The Company may acknowledge the receipt of the complaint through email, SMS, telephone or an appropriate Digital Platform notification.

13.3 The acknowledgement should contain:

1. Complaint reference number;
2. Date of registration;
3. Relevant booking reference;
4. Brief description of the reported article;
5. Contact details for further communication; and
6. A statement clarifying that registration does not guarantee recovery.

13.4 The acknowledgement shall constitute evidence of complaint receipt only.

13.5 It shall not constitute:

1. Confirmation that the article has been located;
2. Admission that the article was present in the bus;
3. Confirmation that the Bus Operator has accepted custody;
4. Acceptance of ownership by the Claimant;
5. Acceptance of negligence or liability by Setura; or
6. An undertaking to reimburse or compensate the Passenger.

14. Initial Classification of Complaints

14.1 Every Lost Property complaint should, where practicable, be classified according to its nature and risk profile.

14.2 The following categories may be adopted:

14.3 Complaints involving suspected theft, high-value property, personal documents, financial instruments, hazardous materials or competing ownership claims should be escalated for enhanced verification.

14.4 Classification shall be undertaken for administrative purposes and shall not amount to a legal finding concerning ownership, negligence, criminality or liability.

15. Booking and Journey Verification

15.1 Setura may verify the Passenger's complaint against information available in its booking systems.

15.2 Such verification may include:

1. Booking confirmation;
2. Journey date and time;
3. Route and destination;
4. Bus Operator identification;
5. Seat allocation;
6. Passenger contact details; and
7. Relevant transaction or booking status.

15.3 Where booking information is unavailable, incomplete or inconsistent, Setura may request additional evidence from the Passenger.

15.4 Setura shall not be responsible for the accuracy of physical vehicle records independently maintained by a Bus Operator, except to the extent any inaccuracy is attributable to Setura's own conduct or obligations.

15.5 Verification of a booking shall not establish that the alleged article was present in the vehicle or that it was lost due to the act or omission of any particular person.

16. Forwarding of Complaint to Bus Operator

16.1 Where the relevant Bus Operator can reasonably be identified, Setura may forward the complaint to its designated Lost and Found representative.

16.2 The forwarded complaint may include only such Passenger information as is reasonably necessary for identification, physical search and recovery coordination.

16.3 Setura may request the Bus Operator to:

1. Acknowledge receipt;
2. Identify the relevant vehicle;
3. Conduct an appropriate physical search;
4. Consult relevant personnel;
5. Check available inspection and recovery records;
6. Confirm whether the article has been located;
7. Provide information regarding physical custody; and
8. Suggest an appropriate collection arrangement.

16.4 The Bus Operator shall provide a factual response based on its actual verification and shall not provide an unsupported assurance that an article has been recovered.

16.5 Setura may communicate the Bus Operator's response to the Passenger, making clear where the information is based on third-party confirmation.

Chapter IV — Search, Recovery and Evidentiary Procedures

17. Physical Search Procedure

17.1 The Bus Operator shall be responsible for arranging a reasonable physical search of the relevant vehicle or facility within its control.

17.2 Subject to the vehicle's availability and operational safety, the search may include:

1. The Passenger's assigned seat;
2. Under-seat compartments;
3. Seat pockets;
4. Overhead luggage compartments;
5. Luggage racks;
6. Passenger-accessible storage areas;
7. Curtains, side pockets and adjacent spaces;
8. Common passenger areas;
9. Boarding and disembarking areas under the operator's control; and
10. Other reasonably accessible areas.

17.3 The Bus Operator may consult the driver, conductor, attendant, cleaning staff, maintenance staff and other personnel who may have information concerning the article.

17.4 Searches should be undertaken in a manner that does not compromise passenger safety, vehicle security or the rights of other passengers.

17.5 No employee shall be required to undertake an unsafe, unlawful or technically impracticable search.

17.6 The Company may request confirmation that a search has been conducted, but shall not be responsible for physically conducting or supervising that search.

18. Vehicle Cleaning and Subsequent Journeys

18.1 Bus Operators are encouraged to conduct reasonable post-journey inspections and cleaning checks.

18.2 Such checks should include inspection of passenger seating areas and reasonably accessible storage spaces for unattended articles.

18.3 Where an article is discovered during cleaning, the employee discovering it should report the matter to the designated operator representative.

18.4 The Bus Operator should record the date, time, vehicle identification, location and identity of the person reporting the discovery, where reasonably practicable.

18.5 The Company does not guarantee that an article will be detected during cleaning, particularly where the article is concealed, inaccessible, removed by a third party or not reasonably identifiable.

18.6 The redeployment of a bus to another route may affect the timing and feasibility of a physical search.

18.7 The Bus Operator should nevertheless take reasonable measures to communicate the status of the search without unnecessarily delaying a legitimate Passenger enquiry.

19. Recovery and Initial Documentation

19.1 Upon discovery of an article, the Bus Operator or other person having physical custody should, where reasonably practicable, prepare an initial recovery record.

19.2 The record should contain:

1. Unique Lost and Found reference;
2. Description of the article;
3. Date and approximate time of discovery;
4. Vehicle registration number or relevant facility;
5. Location within the vehicle;
6. Name or identification of the person discovering the article;
7. Name of the person receiving physical custody;
8. Visible condition of the article;
9. Any visible damage or unusual feature; and
10. Subsequent storage or transfer details.

19.3 Photographs may be taken where appropriate and legally permissible.

19.4 Photographs should avoid unnecessary exposure of personal documents, sensitive information, private images or confidential contents.

19.5 The Bus Operator should not unnecessarily open sealed packages, access electronic devices, inspect confidential documents or examine personal contents merely to establish a general description of an article.

19.6 Where an article requires opening or examination for safety, identification or lawful handling, the action should be restricted to what is reasonably necessary and undertaken by an appropriately authorised person.

20. Custody Record and Chain of Handover

20.1 The Bus Operator should maintain a reasonable custody record for recovered articles that remain in its physical possession.

20.2 Every material transfer of custody should, where practicable, record:

1. Description of the article;
2. Date and time of transfer;
3. Identity of the transferring person;
4. Identity of the receiving person;
5. Reason for transfer;
6. Location of transfer; and
7. Acknowledgement of receipt.

20.3 Where an article is transferred from the bus to an operator office, depot, security office or other storage facility, the transfer should be documented.

20.4 Setura may request relevant custody information where reasonably required to address a Passenger complaint.

20.5 The Company shall not represent that a complete chain of custody exists unless the relevant documentation has actually been provided and reasonably verified.

20.6 Any suspected unexplained break in custody should be escalated to the Bus Operator's designated management representative.

21. Preservation of Evidence

21.1 Where an incident involves alleged theft, tampering, unauthorised removal, damage or other suspected misconduct, the relevant Bus Operator should take reasonable steps to preserve available evidence.

21.2 Such evidence may include:

1. CCTV footage;
2. GPS and journey records;
3. Vehicle inspection records;
4. Cleaning records;
5. Driver and conductor duty records;
6. Internal incident reports;
7. Relevant electronic communications; and
8. Available witness details.

21.3 Setura may forward a Passenger's reasonable preservation request to the Bus Operator.

21.4 The Bus Operator shall be responsible for preserving records under its control in accordance with applicable law, contractual obligations and its internal retention arrangements.

21.5 Setura shall preserve relevant records under its own control where required by law or where reasonably necessary in connection with a genuine complaint, dispute, investigation or legal proceeding.

21.6 Neither Setura nor the Bus Operator shall be required to create evidence that does not exist or reconstruct unavailable footage or records.

21.7 Evidence shall not be altered, concealed, intentionally destroyed or unlawfully disclosed.

Chapter V — Classification and Special Handling of Articles

22. General Handling Standards

22.1 Recovered articles should be handled with reasonable care, having regard to their nature, size, fragility, value and sensitivity.

22.2 The person having physical custody should avoid:

1. Unauthorised use;
2. Unnecessary opening;
3. Consumption or personal appropriation;
4. Unauthorised photography or circulation;
5. Unnecessary transfer;
6. Exposure to avoidable damage;
7. Mixing with unrelated articles; and
8. Unauthorised disposal.

22.3 The Bus Operator should provide reasonable access restrictions to any designated area used for storing recovered articles.

22.4 These standards are intended to guide reasonable handling and shall not be interpreted as an absolute guarantee against every form of loss or deterioration.

23. Luggage and Baggage

23.1 Luggage, backpacks, handbags, suitcases and other baggage may be reported under this Policy.

23.2 The Bus Operator should record externally visible identifying features, including colour, size, brand, markings and luggage tags.

23.3 The contents of luggage should not be opened merely to create an inventory unless reasonably necessary for safety, identification or compliance with a lawful direction.

23.4 A Claimant may be asked to identify distinctive features or contents without disclosing excessive personal information.

23.5 The release of luggage should be subject to reasonable verification of the Claimant's entitlement.

23.6 Any luggage containing hazardous, prohibited, perishable or suspicious contents shall be dealt with under the relevant special handling provisions.

24. Electronic Devices and Digital Property

24.1 Electronic devices shall include mobile phones, laptops, tablets, cameras, smartwatches, headphones, hard drives, memory cards and other electronic equipment.

24.2 The person having physical custody shall avoid unnecessary switching on, unlocking, browsing, copying, deleting, transferring or otherwise accessing information stored on the device.

24.3 The Claimant may be asked to establish ownership using a device model, colour, serial number, IMEI number, distinctive marking or other reasonable identifier.

24.4 Setura shall not require the Claimant to disclose passwords, OTPs, banking credentials, UPI PINs or other authentication secrets.

24.5 Where a device is locked, no person should attempt to bypass its security protections merely to establish ownership.

24.6 The Bus Operator should not charge, connect, reset or modify a device unless reasonably necessary for its safe preservation and legally permissible.

24.7 Any suspected data exposure, unauthorised access or device tampering should be escalated appropriately.

25. Cash, Jewellery and Financial Instruments

25.1 Cash, jewellery, precious metals, watches, securities, bank cards, cheques and other financially valuable articles shall be treated as high-value property.

25.2 Such articles should be recorded with additional care, including:

1. Date and time of recovery;
2. Description and visible identifying characteristics;
3. Identity of the discovering person;
4. Identity of the person receiving custody;
5. Relevant supporting photographs, where appropriate; and
6. Every subsequent physical transfer.

25.3 The amount of cash, number of ornaments or contents of a sealed financial packet should not be represented as verified unless actually verified by an authorised person.

25.4 Where the article is suspected to involve unlawful proceeds, theft or another criminal matter, it should be referred to the appropriate competent authority.

25.5 Setura shall not undertake valuation, authentication, encashment, replacement or financial reimbursement merely because such an article has been reported missing.

26. Personal, Government and Confidential Documents

26.1 This category includes identity cards, passports, driving licences, Aadhaar documents, PAN cards, educational certificates, employment records, bank documents, medical records, property papers and similar material.

26.2 Such documents should be protected against unnecessary viewing, copying, circulation or disclosure.

26.3 Where the relevant document is a government-issued identity document, the Claimant may be advised to contact the relevant issuing authority where replacement, blocking or loss reporting is necessary.

26.4 The Company shall not undertake to replace, authenticate, certify or restore official documents.

26.5 The handling of documents containing personal or sensitive information shall be consistent with applicable privacy and data protection requirements.

27. Medicines and Medical Articles

27.1 Medicines, medical devices, medical records and other health-related articles shall be treated as sensitive property.

27.2 The Bus Operator should not administer, consume, dispense or otherwise use recovered medicines.

27.3 Where medicines require refrigeration, temperature control or other special storage conditions, no preservation guarantee shall be made unless appropriate facilities are actually available.

27.4 Perishable, contaminated, expired or potentially unsafe medical articles may be isolated or dealt with in accordance with applicable law and reasonable safety requirements.

27.5 Any medical emergency shall be referred to appropriate medical or emergency services rather than being treated merely as an ordinary Lost and Found enquiry.

28. Perishable and Unsanitary Articles

28.1 Food, beverages, flowers, organic materials and other perishable articles may deteriorate with time.

28.2 The person having physical custody may take reasonable measures to isolate or lawfully dispose of articles presenting hygiene, contamination, leakage or spoilage risks.

28.3 The Company does not guarantee preservation, refrigeration, freshness or usability of any perishable article.

28.4 Where practicable, disposal should be recorded and communicated to Setura if a related Passenger complaint exists.

29. Prohibited, Restricted and Hazardous Articles

29.1 Any article reasonably suspected of being explosive, flammable, toxic, radioactive, illegal, prohibited or otherwise dangerous shall not be handled under the ordinary recovery procedure.

29.2 The person discovering such an article should avoid unnecessary contact or movement and follow appropriate safety procedures.

29.3 The relevant Bus Operator should immediately notify the appropriate police, emergency, security or competent authority where the circumstances reasonably require it.

29.4 No employee or representative of Setura shall be authorised to receive, store, transport or return a prohibited or dangerous article contrary to applicable law.

29.5 The Company may suspend ordinary complaint processing where the matter requires police or regulatory intervention.

29.6 Any disclosure or communication concerning such an article shall be restricted to persons who have a legitimate operational or legal need to know.

30. Perishable, Fragile and Temperature-Sensitive Property

30.1 Fragile items such as glassware, artwork, optical equipment, specialised instruments and delicate personal accessories should be handled with reasonable care by the person having physical custody.

30.2 The Company does not guarantee that specialist packaging, temperature control, shock protection or other specialised preservation facilities will be available.

30.3 Any delivery arrangement for such property shall be separately assessed and agreed, including applicable third-party service charges and risks.

Chapter VI — Ownership Verification and Release

31. Principle of Verification

31.1 No recovered article shall be released through the Company's facilitated process without reasonable verification of the Claimant's identity and entitlement.

31.2 The verification procedure shall be proportionate to the nature, value and sensitivity of the article.

31.3 Verification shall not be construed as a judicial or conclusive determination of ownership.

32. Acceptable Identification and Ownership Evidence

32.1 The Claimant may be required to provide one or more of the following:

1. Booking ID or PNR;
2. Government-issued identity proof, where reasonably necessary;
3. Photograph of the article;
4. Purchase invoice or receipt;
5. Warranty card;
6. Serial number or unique device identifier;
7. Distinctive physical characteristics;
8. A detailed description of the article;
9. Luggage tag or identifying mark;
10. Written authorisation from the Passenger; or
11. Other reasonably relevant evidence.

32.2 The Company should avoid collecting unnecessary copies of government identity documents.

32.3 Where an identity document is necessary, the Company should adopt an appropriate verification method and avoid retaining more information than reasonably required.

32.4 Any identity document collected shall be handled in accordance with applicable data protection and information security requirements.

33. Insufficient or Inconsistent Claims

33.1 The Company or Bus Operator may request additional information where the Claimant's evidence is insufficient or inconsistent.

33.2 Release may be temporarily withheld where:

1. Ownership cannot reasonably be established;
2. The Claimant's identity is uncertain;
3. The article has distinctive features inconsistent with the claim;
4. Multiple competing claims exist;
5. The Claimant is suspected of submitting fabricated information; or
6. A competent authority has directed that the article be retained.

33.3 Any refusal or suspension should be supported by a reasonable explanation, where legally permissible.

34. Authorised Representative Collection

34.1 A Passenger may nominate another person to collect an article on their behalf.

34.2 The Bus Operator or other Physical Custodian may require:

1. Written authorisation;
2. Passenger booking details;
3. Identity verification of the Passenger;
4. Identity verification of the authorised representative; and
5. Any additional reasonable evidence relevant to the particular article.

34.3 Setura shall not be required to facilitate release to an unauthorised individual merely on the basis of an oral assertion.

34.4 The person physically releasing the article should obtain a collection acknowledgement.

35. Minors, Deceased Persons and Legal Representatives

35.1 Where a Claimant is a minor, the article may be released to a parent or lawful guardian upon reasonable verification.

35.2 Where the Passenger is deceased or legally incapable of collecting the article, the relevant Bus Operator may require appropriate proof of authority from a lawful representative.

35.3 Depending upon the circumstances, such evidence may include a death certificate, legal heirship document, succession certificate, court order, guardianship documentation or other legally relevant authorisation.

35.4 Setura shall not adjudicate inheritance, succession or competing family claims.

35.5 Where ownership or entitlement remains disputed, the matter may be referred to the competent legal authority.

36. Disputed Ownership

36.1 Where multiple persons claim the same article, the Company may suspend its facilitation of release pending reasonable clarification.

36.2 Setura shall not decide competing proprietary rights or determine the legal title of an article.

36.3 The Physical Custodian may be requested to preserve the article, where practicable and legally permissible, pending a lawful resolution.

36.4 The parties may be advised to obtain a mutual written settlement or approach a competent court or authority.

36.5 No article should be released merely to resolve an administrative backlog where the ownership dispute remains material.

Chapter VII — Collection, Delivery and Physical Handover

37. Collection Arrangements

37.1 Upon confirmation that an article has been located, Setura may communicate the available collection arrangements to the Passenger.

37.2 The collection arrangement may be determined by reference to:

1. The location of the article;
2. The identity of the Physical Custodian;
3. The nature and size of the article;
4. The operational availability of the Bus Operator;
5. The Passenger's reasonable convenience;
6. The security and preservation requirements of the article; and
7. Applicable legal or regulatory restrictions.

37.3 Collection may ordinarily be facilitated through:  The Bus Operator's designated office.  The Bus Operator's depot or authorised facility.  Another mutually agreed location.  An authorised representative.  A third-party courier or logistics service, where available.

37.4 The Company shall not be required to arrange collection from a location that it does not own, occupy or control.

38. Physical Handover

38.1 The actual physical handover shall ordinarily be conducted by the Bus Operator or the person having physical possession of the recovered article.

38.2 Setura's communication of the collection location or arrangement shall not constitute physical delivery by Setura.

38.3 The Physical Custodian should verify the Claimant's identity before releasing the article.

38.4 The Physical Custodian should, where practicable, obtain a written or electronic acknowledgement recording:

1. The description of the article;
2. The date and time of collection;
3. The identity of the recipient;
4. The identification of the person effecting the handover;
5. The apparent condition of the article at handover; and
6. Any apparent discrepancy acknowledged by the parties.

38.5 The acknowledgement should confirm physical receipt without unnecessarily requiring the Passenger to waive any statutory right or claim that cannot lawfully be waived.

38.6 Setura may request a copy of the handover acknowledgement for its administrative records.

39. Courier and Third-Party Delivery

39.1 Where the Passenger requests delivery through a courier or logistics provider, the arrangement shall be subject to the availability and terms of the relevant service provider.

39.2 Before dispatch, the Passenger should be informed of:

1. Applicable delivery charges;
2. Packaging charges, if any;
3. Estimated delivery arrangements;
4. Any insurance option actually available;
5. Restrictions on transporting the article; and
6. Relevant third-party service conditions.

39.3 The Company shall not automatically become the courier, transporter, warehouse operator or insurer merely by forwarding a delivery request or assisting with coordination.

39.4 Where Setura independently contracts with a courier or accepts responsibility for a delivery service, its obligations shall be determined by that separate arrangement and applicable law.

39.5 High-value, fragile, prohibited, restricted or temperature-sensitive articles may be excluded from ordinary courier delivery.

39.6 No article shall be dispatched without reasonable verification of the recipient and confirmation of the delivery arrangement.

40. Condition of the Article At Collection

40.1 The Passenger is encouraged to inspect the article at the time of physical collection.

40.2 Any apparent damage, shortage, missing component or discrepancy should be reported immediately to the person effecting the handover.

40.3 Where practicable, the discrepancy should be recorded in the collection acknowledgement.

40.4 An acknowledgement of receipt shall not automatically establish that the article was in perfect condition, nor shall it extinguish any legally enforceable claim arising from prior damage, mishandling or other actionable conduct.

40.5 Setura shall not certify the authenticity, market value, internal contents or technical functionality of an article unless it has expressly undertaken such a service.

41. Failure to Collect

41.1 Where a Claimant fails to collect an article within the collection period communicated by the Bus Operator, the Physical Custodian may issue a reminder through available contact details.

41.2 The Company may facilitate such communication where it has received the relevant information.

41.3 If the article remains uncollected, it shall be handled under the Unclaimed Property provisions of this Policy and applicable law.

41.4 No arbitrary storage fee, handling fee or penalty shall be imposed by Setura unless there is a valid legal or contractual basis and the charge has been appropriately disclosed.

Chapter VIII — Unclaimed, Abandoned and Disputed Property

42. Retention of Unclaimed Property

42.1 The Bus Operator or other Physical Custodian shall ordinarily be responsible for the physical retention of recovered property in its possession.

42.2 The Bus Operator should adopt a documented retention procedure taking into consideration:

1. The nature of the article;
2. Its monetary and personal value;
3. Its condition and perishability;
4. Applicable safety requirements;
5. Reasonable efforts to identify the owner;
6. Legal requirements;
7. Directions of competent authorities; and
8. Practical storage limitations.

42.3 The Company may communicate an operator's published retention procedure to the Passenger where appropriate.

42.4 Setura shall not guarantee indefinite storage or preservation of property held by an independent Bus Operator.

43. Notification and Reminders

43.1 Where the owner can reasonably be identified, the Bus Operator or Setura may attempt to communicate the availability of the article.

43.2 Notifications may be issued through:

1. Registered email;
2. Registered mobile number;
3. SMS;
4. In-platform communication; or
5. Other officially designated channels.

43.3 Notifications should avoid disclosing sensitive details of the article to an unverified person.

43.4 The Company may retain reasonable records of notifications sent through its systems.

43.5 Failure to receive or respond to a notification shall not automatically transfer ownership of the article to Setura or the Bus Operator.

44. Disposal and Lawful Disposition

44.1 Unclaimed Property shall not be automatically treated as abandoned merely because a Passenger has not responded within a specified administrative period.

44.2 No article shall automatically vest in Setura by reason of its discovery, recovery, retention or failure to be collected.

44.3 Any sale, disposal, destruction, transfer, donation, appropriation or other disposition shall be undertaken only in accordance with applicable law and any lawful entitlement or direction.

44.4 The Bus Operator shall not dispose of articles containing identity documents, financial instruments, confidential information or other sensitive materials without considering applicable legal requirements.

44.5 Hazardous, perishable or unsafe articles may be dealt with promptly where necessary to protect persons, property or public health, subject to applicable law.

44.6 Where lawful disposal is undertaken, the relevant Physical Custodian should maintain a reasonable record of the decision and action.

44.7 Setura shall not derive any ownership, financial interest or beneficial entitlement in Unclaimed Property merely by administering the Lost and Found process.

45. Property Handed Over to Police or Competent Authorities

45.1 Where an article is required to be handed over to police or another competent authority, the Physical Custodian shall comply with applicable law and lawful directions.

45.2 The Company may request confirmation of such handover for the purpose of communicating the status of the Passenger's complaint.

45.3 Setura shall not interfere with any lawful seizure, investigation, preservation order or custody direction.

45.4 Where an article has been transferred to a competent authority, its subsequent release shall ordinarily be governed by the relevant authority's procedure.

45.5 Setura shall not guarantee retrieval of property that has been lawfully seized, retained or placed under the control of an investigating authority.

Chapter IX — Alleged Theft, Damage, Tampering and Misconduct

46. Allegation of Theft or Unauthorised Removal

46.1 Where a Passenger alleges that an article was stolen, unlawfully removed or misappropriated, the complaint shall be treated as a potentially serious incident.

46.2 Setura may:

1. Register the complaint;
2. Verify available booking details;
3. Identify the relevant Bus Operator;
4. Forward the complaint to the Bus Operator;
5. Request preservation of relevant records;
6. Facilitate communication with the appropriate authorities; and
7. Escalate the matter internally where necessary.

46.3 The Company shall not independently declare any person guilty of theft, fraud or misconduct.

46.4 The Passenger may be advised to lodge a complaint with the appropriate police authority where the facts reasonably indicate a criminal offence.

46.5 Setura may cooperate with lawful investigations and provide information within its possession or control in accordance with applicable law.

47. Allegation of Damage

47.1 Where an article is recovered in a damaged condition, the Passenger may report the alleged damage through the designated complaint channels.

47.2 The Passenger should, where reasonably possible, provide:

1. Photographs of the damaged article;
2. A description of the damage;
3. Evidence of its apparent condition before the journey;
4. Purchase invoice or other relevant valuation material;
5. Relevant journey and booking information; and
6. Any other reasonably relevant evidence.

47.3 The Company may forward the complaint to the relevant Bus Operator for its response.

47.4 The existence of damage shall not, by itself, establish the cause of damage or the liability of Setura or the Bus Operator.

47.5 Any liability shall be determined by reference to actual responsibility, contractual obligations, applicable law and available evidence.

48. Tampering or Unauthorised Access

48.1 Any suspected unauthorised opening, access, modification, removal of contents or tampering with recovered property should be documented.

48.2 The relevant Bus Operator should investigate conduct within its operational control.

48.3 Setura may seek a factual report and available supporting records.

48.4 Where electronic devices or confidential documents are involved, the incident should also be assessed from a data protection and information security perspective.

49. Misconduct by Bus Operator Personnel

49.1 Any complaint alleging misconduct by a driver, conductor, attendant, cleaner or other operator personnel should be forwarded to the relevant Bus Operator for investigation.

49.2 The Bus Operator shall remain responsible for its personnel and shall take appropriate action under applicable employment, contractual and statutory requirements.

49.3 Setura may, where permitted by the operator agreement:

1. Require a written explanation;
2. Seek an investigation report;
3. Require corrective action;
4. Require relevant records to be preserved;
5. Suspend booking facilitation with the relevant operator; or
6. Exercise other contractual remedies.

49.4 The Company shall not automatically accept responsibility for acts or omissions of independent operator personnel merely because transportation was facilitated through its Digital Platform. This does not exclude liability that may legally arise from Setura's own conduct or statutory obligations.

Chapter X — Customer Communication, Escalation and Service Governance

50. Customer Communication Standards

50.1 Setura shall endeavour to communicate with Passengers in a professional, factual, respectful and non-misleading manner.

50.2 All communications should distinguish between:

1. Information independently verified by Setura;
2. Information supplied by the Passenger;
3. Information reported by the Bus Operator; and
4. Information that remains unverified or pending.

50.3 Employees shall not communicate speculative findings as established facts.

50.4 Employees shall not promise a guaranteed recovery, compensation, refund, replacement or delivery date unless expressly authorised and supported by the relevant arrangement.

50.5 Communications should avoid unnecessary disclosure of another Passenger's identity, personal details or confidential information.

51. Internal Escalation

51.1 Setura may adopt the following internal escalation framework:

51.2 Escalation shall be based on the nature, severity and complexity of the incident.

51.3 Complaints involving high-value property, alleged theft, suspected criminal activity, personal data exposure, injury or regulatory notices should be escalated without undue delay.

52. Response and Processing Targets

52.1 The Company may adopt indicative internal service targets as follows:

52.2 These are internal management targets and not unconditional guarantees of recovery or resolution.

52.3 The actual time required may depend on the availability of the bus, personnel, records, physical search opportunities and cooperation of independent third parties.

52.4 Any mandatory statutory grievance timelines shall prevail over the indicative internal targets.

52.5 Delays should be recorded with a reasonable explanation where practicable.

53. Complaint Closure

53.1 A Lost and Found complaint may be administratively closed where:

1. The article has been returned;
2. The Bus Operator confirms that it could not be located after reasonable search;
3. The Passenger withdraws the complaint;
4. The Passenger does not provide reasonably necessary verification information;
5. The article has been transferred to a competent authority;
6. The Claimant's entitlement remains materially disputed;
7. The claim is found to be knowingly false or fraudulent; or
8. Further facilitation is not reasonably practicable.

53.2 Before closing a complaint on account of insufficient information, Setura should, where reasonably practicable, request the missing information from the Passenger.

53.3 The closure communication should contain the complaint reference, outcome and any relevant next steps.

53.4 Closure of the Company's internal complaint record shall not extinguish a statutory right or automatically determine the legal merits of any subsequent claim.

Chapter XI — Data Protection, Confidentiality and Information Security

54. Personal Information Collection

54.1 Setura may collect and process personal information reasonably necessary to administer Lost and Found enquiries.

54.2 Such information may include:

1. Passenger name;
2. Mobile number and email address;
3. Booking and journey information;
4. Article descriptions and photographs;
5. Ownership evidence;
6. Communication records;
7. Details of an authorised representative; and
8. Other information reasonably necessary for verification and resolution.

54.3 Information shall be collected and used for legitimate and specified purposes in accordance with applicable law.

54.4 Setura shall endeavour to apply appropriate data minimisation principles and avoid collecting unrelated or excessive personal information.

55. Sharing with Bus Operators

55.1 Setura may share relevant information with the Bus Operator for the limited purpose of:

1. Identifying the relevant journey;
2. Locating the relevant vehicle;
3. Conducting a physical search;
4. Verifying the article;
5. Coordinating collection or delivery; and
6. Addressing a complaint or legal requirement.

55.2 Such sharing should be limited to the information reasonably necessary for the stated purpose.

55.3 The Company should establish appropriate contractual confidentiality, security and data-handling obligations with its Bus Operators.

55.4 A Bus Operator receiving Passenger information shall not use it for unrelated marketing, solicitation, profiling or other unauthorised purposes.

56. Data Security and Access Control

56.1 Setura shall maintain appropriate administrative, technical and organisational safeguards for personal information within its control.

56.2 Access to Lost and Found records should be restricted to authorised personnel with a legitimate operational or legal need.

56.3 Where reasonably practicable, the Company should maintain access logs and other appropriate security records.

56.4 Employees and third-party service providers shall be subject to confidentiality and information-handling requirements.

56.5 Suspected unauthorised access, disclosure, alteration or loss of personal information shall be escalated under the Company's applicable information security and incident-response procedures.

57. Cctv, Gps and Digital Evidence

57.1 CCTV footage, GPS information, booking records, electronic logs and other operational information may assist in investigating a Lost Property complaint.

57.2 The availability and physical management of CCTV systems installed in a Bus Operator's vehicle shall ordinarily remain with the relevant Bus Operator.

57.3 Setura does not guarantee that a Bus Operator's vehicle contains CCTV facilities or that relevant footage exists or remains available.

57.4 Requests for preservation or disclosure may be forwarded to the Bus Operator.

57.5 Disclosure of CCTV footage or other personal information shall be subject to applicable law, privacy rights, security considerations and lawful directions.

57.6 Setura shall not promise direct CCTV access to a Passenger merely because the Passenger submits a Lost Property complaint.

58. Data Retention and Record Disposal

58.1 Lost and Found records may be retained for legitimate purposes including:

1. Complaint resolution;
2. Audit and governance;
3. Prevention of fraud;
4. Contractual compliance;
5. Legal proceedings;
6. Regulatory requirements; and
7. Establishment or defence of legal claims.

58.2 Retention periods shall be determined under the Company's approved retention schedule, taking into account the nature of the information, applicable statutory requirements and legitimate business purposes.

58.3 Personal information shall not be retained indefinitely merely because a Lost and Found complaint has been registered.

58.4 When retention is no longer legally or operationally justified, the information should be deleted, anonymised or otherwise securely disposed of, subject to any lawful preservation requirement.

58.5 The Company's privacy policy and applicable data protection framework shall govern the exercise of relevant data rights.

Chapter XII — Liability, Disclaimers and Risk Allocation

59. General Limitation of the Company's Role

59.1 Setura's involvement in Lost and Found matters shall ordinarily be confined to the technology-enabled administrative, communication, coordination and facilitation functions described in this Policy.

59.2 The Company does not, merely by providing a Digital Platform, become the physical operator of a bus, the custodian of Passenger belongings or the insurer of articles carried by Passengers.

59.3 The physical handling, inspection, recovery, storage and handover of articles shall ordinarily be undertaken by the Bus Operator or other person having actual possession or control, subject to applicable law.

59.4 The allocation of responsibilities under this Policy shall not relieve Setura from any independent obligation or liability arising from its own acts, omissions, representations, contractual commitments or statutory duties.

60. No Guarantee of Recovery

60.1 Setura does not warrant or guarantee that any missing article will be found, recovered, identified, preserved or returned.

60.2 The recovery of an article may depend on factors beyond the Company's direct control, including:

1. The time at which the loss is reported;
2. The accuracy of the Passenger's description;
3. Availability of the relevant vehicle;
4. The vehicle's subsequent deployment;
5. Availability of onboard personnel;
6. Physical accessibility of the location;
7. Conduct of other Passengers or third parties;
8. Availability of CCTV or other records;
9. Cooperation of the Bus Operator; and
10. Other circumstances beyond the Company's reasonable control.

60.3 Any recovery-related communication by Setura shall be based on information available to the Company at the relevant time and shall not constitute a guarantee of a particular outcome.

61. Third-Party Operator Acts and Omissions

61.1 Subject to applicable law, Setura shall not automatically assume liability for the independent acts or omissions of a Bus Operator or its personnel merely because the transportation booking was facilitated through its Digital Platform.

61.2 Such acts or omissions may include:

1. Failure to conduct a physical search;
2. Failure to report a recovered article;
3. Unauthorised access to recovered property;
4. Theft, misappropriation or wrongful retention;
5. Mishandling or physical damage;
6. Inaccurate reporting;
7. Unauthorised disclosure of Passenger information;
8. Failure to maintain appropriate records; and
9. Failure to follow agreed operator procedures.

61.3 The Company may exercise contractual remedies against a Bus Operator where the relevant operator agreement permits.

61.4 Nothing in this provision shall exclude liability where Setura's own actionable conduct, representations, undertaking, agency relationship, negligence or statutory responsibility gives rise to liability under applicable law.

62. No Automatic Entitlement to Compensation

62.1 The mere fact that an article is reported missing or cannot be recovered shall not, by itself, establish an automatic entitlement to compensation from Setura.

62.2 Any demand for reimbursement, replacement, compensation, damages or monetary relief shall be assessed on the basis of:

1. The facts and circumstances of the Incident;
2. The identity and legal responsibility of the relevant party;
3. Actual possession or custody, where relevant;
4. Applicable contractual arrangements;
5. Available evidence;
6. Causation and legally recognised loss; and
7. Applicable statutory rights and remedies.

62.3 Setura shall not be required to reimburse an asserted value merely because it has been declared by a Passenger.

62.4 The Company may request supporting documents, including invoices, receipts, proof of ownership, repair estimates or other relevant material, where reasonably necessary to assess a claim.

62.5 No clause in this Policy shall restrict a consumer from pursuing a remedy before a competent consumer commission or other lawful forum.

63. Exclusion of Certain Categories of Loss

63.1 To the maximum extent legally permissible, Setura shall not be liable for remote, indirect, incidental, special or consequential losses that are not legally recoverable from the Company.

63.2 Such losses may include:

1. Loss of anticipated business profits;
2. Loss of future commercial opportunities;
3. Loss of anticipated income;
4. Loss of goodwill;
5. Loss arising from an inability to use an article;
6. Costs of substitute arrangements; and
7. Other indirect financial consequences.

63.3 This clause shall not operate to exclude any liability that cannot lawfully be excluded, including any legally recoverable direct loss attributable to Setura's own actionable conduct.

64. Passenger Responsibility for Personal Belongings

64.1 Passengers are advised to exercise reasonable care in keeping their personal belongings, luggage, valuables and documents secure.

64.2 Passengers should ensure that:

1. All personal belongings are collected before disembarking;
2. Valuable items are not left unattended;
3. Electronic devices and documents are kept secure;
4. Luggage is appropriately labelled;
5. Essential medicines and sensitive documents are carried with appropriate care; and
6. Any suspected loss is reported promptly.

64.3 Passengers should not leave prohibited, hazardous or unlawful articles in a bus or transportation facility.

64.4 The above responsibilities shall not relieve any other party of liability arising from its own acts, omissions or applicable legal obligations.

65. No Automatic Insurance or Replacement Obligation

65.1 Setura does not provide insurance for Passenger belongings merely because a journey has been facilitated through its Digital Platform.

65.2 Setura shall not be required to replace a lost article, purchase a substitute item, arrange repair or make a payment in the absence of an applicable contractual or legal obligation.

65.3 Any independently available insurance coverage shall be governed by the relevant insurance policy and the terms of the insurer.

65.4 The Passenger may be advised to contact the relevant insurer where an insured article is reported missing or damaged.

66. Third-Party Services

66.1 Where a courier, logistics provider, security service or other third party is involved in the recovery process, the relevant service shall be subject to its own applicable terms and contractual arrangements.

66.2 Setura shall not be deemed to have guaranteed the performance of an independent service provider merely by facilitating communication or sharing relevant information.

66.3 Where Setura directly engages a third-party service provider in its own capacity, the Company's responsibilities shall be determined by the actual engagement, applicable law and relevant contractual commitments.

67. Force Majeure and Events Beyond Reasonable Control

67.1 Setura shall not be responsible for a failure or delay in providing facilitative assistance to the extent directly caused by circumstances beyond its reasonable control.

67.2 Such circumstances may include:

1. Natural disasters;
2. Floods, earthquakes and fires;
3. Riots, civil disturbances or public disorder;
4. War, terrorism or security emergencies;
5. Governmental restrictions or lawful directions;
6. Widespread telecommunications or internet failures;
7. Serious infrastructure disruptions;
8. Third-party system outages; and
9. Other comparable events.

67.3 The affected party shall, where reasonably practicable, take appropriate steps to minimise the effects of such circumstances.

67.4 This provision shall not exclude liability for independent actionable conduct or statutory obligations that cannot legally be excluded.

Chapter XIII — Passenger Undertakings and Fraud Prevention

68. Passenger Declarations

68.1 Every Passenger submitting a Lost Property claim shall be deemed to represent, subject to applicable law, that:

1. The information provided is true and accurate to the best of their knowledge;
2. The claim is made for a legitimate purpose;
3. The Passenger has a lawful basis to claim the article;
4. Documents submitted are genuine and have not knowingly been falsified;
5. The Passenger shall cooperate with reasonable verification; and
6. The Passenger shall not knowingly make duplicate or fraudulent claims for the same article.

68.2 Where the Claimant acts on behalf of another person, the Claimant shall disclose that fact and provide appropriate authorisation.

69. Fraudulent and Misleading Claims

69.1 Setura may conduct reasonable verification where a claim appears suspicious, inconsistent or unsupported.

69.2 Circumstances warranting enhanced verification may include:

1. Multiple claims for the same article;
2. Conflicting ownership descriptions;
3. Material inconsistencies in booking details;
4. Altered or suspicious supporting documents;
5. Unusual demands for compensation;
6. Repeated false complaints;
7. Attempts to collect an article without authorisation; and
8. Other reasonably identifiable indicators of fraud.

69.3 Where a claim is reasonably suspected to be fraudulent, Setura may temporarily suspend facilitation pending clarification.

69.4 The Company may reject a claim where it is established, on reasonable grounds, that the Claimant has knowingly submitted materially false information.

69.5 Setura may preserve relevant evidence and refer suspected unlawful conduct to the appropriate authority.

69.6 Any suspension or rejection shall be proportionate and shall not be used arbitrarily to deny legitimate claims.

70. Misuse of Customer Support Channels

70.1 Setura may adopt reasonable communication standards for the use of its customer support channels.

70.2 A Passenger shall not:

1. Threaten or intimidate employees;
2. Submit knowingly false information;
3. Repeatedly submit duplicate complaints to manipulate the recovery process;
4. Impersonate another person;
5. Attempt unauthorised access to another Passenger's information;
6. Demand unlawful access to confidential records; or
7. Use customer support channels for unlawful purposes.

70.3 Setura may restrict abusive or malicious communication, subject to applicable law and without preventing a Passenger from exercising legitimate grievance or statutory rights.

71. No Unauthorised Promises or Admissions by Employees

71.1 No employee, contractor, representative or customer support agent shall have authority to waive this Policy, admit legal liability or promise compensation unless expressly authorised under the Company's delegation of authority.

71.2 Customer support personnel shall not independently:

1. Accept liability for alleged theft;
2. Admit negligence;
3. Guarantee recovery;
4. Confirm an unverified article value;
5. Promise reimbursement;
6. Commit the Company to replacement; or
7. Enter into a settlement on behalf of Setura.

71.3 Any proposed settlement, reimbursement or exceptional commercial resolution shall be reviewed and approved under the Company's internal authority matrix.

71.4 Nothing in this clause shall restrict the authority of a competent employee or authorised officer to discharge a statutory duty or comply with a lawful direction.

Chapter XIV — Bus Operator Contractual Accountability

72. Mandatory Operator Compliance

72.1 Setura may require every participating Bus Operator to comply with the Lost and Found obligations incorporated into its Operator Agreement.

72.2 Such obligations should include:

1. Appointment of a designated Lost and Found representative;
2. Implementation of an internal recovery procedure;
3. Appropriate vehicle inspection procedures;
4. Maintenance of recovered-property records;
5. Reasonable safekeeping of articles in physical custody;
6. Timely communication with Setura;
7. Cooperation in ownership verification;
8. Compliance with applicable data protection requirements;
9. Preservation of relevant evidence; and
10. Lawful handover and disposal procedures.

72.3 The Bus Operator shall ensure that its employees and agents are adequately informed of these requirements.

73. Operator Representations and Warranties

73.1 The Bus Operator shall represent and undertake, to the extent applicable, that:

1. It has the legal right and authority to operate the relevant vehicle and provide the relevant transportation service;
2. It shall comply with applicable transport and safety requirements;
3. It shall maintain appropriate internal procedures for recovered articles;
4. It shall not knowingly misuse or misappropriate Passenger property;
5. It shall provide accurate information concerning Lost and Found incidents;
6. It shall cooperate with reasonable investigations;
7. It shall maintain appropriate confidentiality and data security safeguards; and
8. It shall comply with lawful directions from competent authorities.

73.2 The Bus Operator shall promptly notify Setura of any material incident involving alleged theft, loss, damage, unauthorised transfer or suspected misconduct by its personnel, to the extent such incident relates to a journey facilitated through Setura.

74. Operator Indemnification

74.1 The Operator Agreement should include a suitably drafted indemnification provision requiring the Bus Operator to indemnify and hold harmless Setura, its directors, officers and employees against losses, liabilities, claims, costs and reasonable legal expenses to the extent directly arising from:

1. The Bus Operator's breach of its contractual obligations;
2. Negligence, wilful misconduct or unlawful conduct of the Bus Operator or its personnel;
3. Unauthorised handling, retention, disposal or misappropriation of articles in its custody;
4. Materially false or misleading information supplied by the Bus Operator;
5. Breach of applicable law by the Bus Operator;
6. Unauthorised disclosure or misuse of Passenger information by the Bus Operator; and
7. Failure to comply with agreed Lost and Found procedures.

74.2 The indemnity shall be subject to applicable law, appropriate causation requirements and exclusions for losses attributable to Setura's own acts or omissions.

74.3 The procedure for notification, defence, settlement and mitigation of indemnified claims should be specified in the Operator Agreement.

74.4 The indemnity shall survive termination of the Operator Agreement in respect of claims arising from events occurring during its subsistence, to the extent legally permissible.

75. Insurance and Risk Management

75.1 Setura may require the Bus Operator to maintain insurance policies appropriate to its transportation operations and legal obligations.

75.2 The operator should provide evidence of insurance coverage upon reasonable request.

75.3 Insurance shall not automatically be treated as covering all Passenger belongings or Lost and Found incidents.

75.4 Any insurance claim shall be governed by the terms, conditions, exclusions and procedures of the relevant policy.

76. Audit and Monitoring Rights

76.1 Setura may, where contractually permitted, request information concerning the Bus Operator's Lost and Found procedures.

76.2 Such information may include:

1. Lost and Found registers;
2. Recovery and handover records;
3. Relevant employee reporting procedures;
4. Complaint resolution records;
5. Corrective action reports; and
6. Data protection and confidentiality arrangements.

76.3 Any audit or verification shall be proportionate, subject to confidentiality requirements and limited to the legitimate purpose of monitoring contractual compliance.

77. Suspension and Termination

77.1 Setura may exercise its contractual rights to suspend or terminate the facilitation of services involving a Bus Operator where:

1. The operator repeatedly fails to respond to Lost Property enquiries;
2. The operator materially breaches its agreed recovery procedures;
3. Serious misconduct or misappropriation is reasonably established;
4. The operator refuses to cooperate with a lawful investigation;
5. The operator materially breaches data protection obligations; or
6. Other contractual grounds for suspension or termination arise.

77.2 Any suspension or termination shall be undertaken in accordance with the relevant Operator Agreement and applicable law.

77.3 Setura may require an appropriate corrective action plan before restoring booking facilitation.

Chapter XV — Corporate Governance, Compliance and Internal Controls

78. Policy Ownership

78.1 The Legal & Compliance Department or another designated department shall be the policy owner.

78.2 The policy owner shall oversee:

1. Policy interpretation;
2. Periodic review;
3. Legal updates;
4. Internal compliance guidance;
5. Operator contractual alignment;
6. Escalation of material incidents; and
7. Recommendations for corrective amendments.

79. Employee Responsibilities

79.1 Employees dealing with Lost and Found enquiries shall:

1. Follow the approved procedure;
2. Maintain factual and professional communications;
3. Avoid unauthorised promises;
4. Protect Passenger information;
5. Record relevant communications;
6. Escalate serious incidents;
7. Avoid accepting physical custody without authority; and
8. Maintain appropriate confidentiality.

79.2 The Company may conduct internal training for customer support and operations personnel.

80. Internal Recordkeeping

80.1 Setura should maintain an electronic Lost and Found complaint register for complaints received through its official channels.

80.2 The register may contain:  Complaint reference number.  Date and time of receipt.  Booking reference.  Passenger contact details.  Relevant Bus Operator.  Article description.  Complaint category.  Date forwarded to operator.  Operator response.  Status of search.  Verification outcome.  Collection or delivery status.  Date of administrative closure.  Escalation details.  Supporting records, where necessary.

80.3 Records shall be maintained in accordance with the Company's approved retention and information security policies.

80.4 Access shall be restricted to authorised personnel.

81. Management Reporting

81.1 The Company may prepare periodic internal management reports relating to Lost and Found incidents.

81.2 Such reports may include:

1. Total complaints received;
2. Complaints resolved;
3. Articles recovered;
4. Unresolved enquiries;
5. Operator response times;
6. High-value incidents;
7. Alleged theft and damage cases;
8. Data protection incidents; and
9. Repeated operator non-compliance.

81.3 Management reports may be used for assessing operator performance, identifying operational weaknesses and implementing corrective measures.

81.4 Such reports shall not unnecessarily disclose personal information or confidential Passenger details.

82. Internal Audit and Review

82.1 The Company may periodically review the implementation of this Policy.

82.2 Reviews may examine:

1. Whether complaints are being recorded properly;
2. Whether operator responses are being received;
3. Whether handover documentation is available;
4. Whether high-risk incidents are escalated;
5. Whether Passenger data is appropriately protected;
6. Whether unauthorised promises are being made;
7. Whether contractual protections are adequate; and
8. Whether policy provisions remain aligned with applicable law.

82.3 Material deficiencies may be referred to management for corrective action.

83. Regulatory and Legal Cooperation

83.1 Setura shall cooperate with lawful notices, investigations, summons, orders and requests issued by competent courts, tribunals, regulatory authorities and law enforcement agencies.

83.2 Information shall be disclosed only to the extent legally required or otherwise lawfully permitted.

83.3 Where a matter involves potential criminal conduct, Setura may refer the issue to the appropriate authority.

83.4 Employees shall promptly escalate receipt of any legal notice, police communication, consumer complaint or regulatory direction to the designated Legal & Compliance Department.

84. Consumer Rights and Mandatory Obligations

84.1 Nothing in this Policy shall be construed to deprive a Passenger of rights available under the Consumer Protection Act, 2019 or other applicable legislation.

84.2 Nothing herein shall exclude liability arising from deficiency in service, unfair trade practice, negligence or other actionable conduct where legally established.

84.3 The Company shall not use this Policy to make misleading representations regarding the availability, scope or quality of services.

84.4 Where Setura is legally required to respond to a consumer grievance, it shall comply with the applicable requirements notwithstanding the administrative allocation of responsibilities between the Company and the Bus Operator.

84.5 The Passenger's right to approach a competent consumer commission shall remain unaffected.

85. Bailment and Custody Principles

85.1 The legal relationship concerning a recovered article shall be determined by reference to actual delivery, possession, control, intention and applicable contractual arrangements.

85.2 Where a Bus Operator or another person accepts physical custody of an article, that person's legal obligations shall be determined under applicable law.

85.3 Where Setura itself accepts physical custody or undertakes a specific custodial arrangement, the Company shall be subject to the corresponding legal obligations.

85.4 No disclaimer shall be interpreted as eliminating mandatory duties arising from actual custody.

86. Prevailing Law

86.1 If any provision of this Policy conflicts with a mandatory provision of applicable law, the statutory provision shall prevail.

86.2 The remaining provisions shall continue to operate to the maximum extent legally permissible.

Chapter XVI — Miscellaneous and Final Provisions

87. Amendment and Modification

87.1 Setura reserves the right to amend, modify, supplement, replace or withdraw this Policy from time to time.

87.2 Amendments may be made in response to:

1. Changes in applicable legislation;
2. Regulatory directions;
3. Changes in the Company's business model;
4. Changes in the Company's relationship with Bus Operators;
5. Operational developments;
6. Technology changes;
7. Internal audit findings; or
8. Other legitimate corporate requirements.

87.3 Amendments shall be approved in accordance with the Company's internal governance and delegated authority framework.

87.4 Revised provisions shall be published or communicated through appropriate channels.

88. Severability

88.1 If any provision of this Policy is declared invalid, unlawful or unenforceable by a competent authority, such provision shall be modified or severed to the minimum extent necessary.

88.2 The remaining provisions shall continue in full force to the extent legally permissible.

89. No Waiver

89.1 Any failure or delay by Setura in exercising a right under this Policy shall not constitute a waiver of that right.

89.2 Any waiver shall be effective only to the extent lawfully made by an authorised representative.

90. No Automatic Third-Party Rights

90.1 This Policy shall not, by itself, create a separate contractual entitlement in favour of unrelated third parties.

90.2 Nothing in this provision shall restrict any right arising under applicable consumer protection law, contract law or other mandatory legislation.

91. Relationship with Other Policies and Contracts

91.1 This Policy shall be read in conjunction with:

1. Setura's Terms and Conditions;
2. Privacy Policy;
3. Passenger Terms and Conditions;
4. Cancellation and Refund Policy;
5. Customer Grievance Redressal Policy;
6. Bus Operator Agreement;
7. Other applicable company policies.

91.2 In the event of inconsistency:

1. Mandatory applicable law shall prevail;
2. Specific contractual provisions shall govern the relevant contractual relationship to the extent legally permissible;
3. This Policy shall govern the Company's Lost and Found administrative framework to the extent consistent with the foregoing.

91.3 No provision of this Policy shall amend an existing contract unless expressly incorporated through an appropriate written contractual amendment or other legally effective mechanism.

92. Governing Law and Jurisdiction

92.1 This Policy shall be governed by the laws of India.

92.2 Any dispute shall be addressed before the appropriate court, tribunal, consumer commission or other competent forum in accordance with applicable law.

92.3 Subject to mandatory statutory jurisdiction, the parties may rely upon the jurisdiction clause in the applicable underlying agreement, where legally enforceable.

92.4 Nothing herein shall restrict a Passenger from approaching a consumer forum having jurisdiction under applicable law.

93. Effective Date and Periodic Review

93.1 This Policy shall become effective from the date of approval by the authorised corporate authority.

93.2 It shall be reviewed at least once every twelve months or earlier if a material legal or operational change occurs.

93.3 The Legal & Compliance Department shall maintain the current approved version.

93.4 Any superseded version shall be archived in accordance with the Company's document management and retention procedures.