CODE OF CONDUCT GUIDELINES FOR THIRD PARTY (3RD) CLIENTS & SERVICES ON CELLULANT TECHNOLOGY
In strict compliance and conformity to the existing and relevant rules and regulations of the National
Communications Commission, the Mobile Network Operators, the National Lottery Regulatory Commission
and the Consumer Protection Council, herein identified as duly licensed statutory and regulatory bodies
governing and regulating the practice and conduct of legitimate, ethical and acceptable provisioning,
management and service delivery of Value added services (VAS) on mobile devices ,content providers, third
party applications and services, content aggregators etc. in collaboration with Cellulant Nigeria limited( a VAS
company duly licensed and operating under the subsector of The Nigerian Telecommunications Industry)
hereby request Cellulant and her 3rd party clients/customers to legally observe and ensure strict adherence
to the following code of conduct:
A. SERVICE CONTRACTS
A copy of the contract regarding the provision of any of its services to customers and potential customers, shall be
made available to customers on request, within the shortest time possible.
B. DESCRIPTION OF SERVICES
The following services shall be offered to consumers: Disbursement of funds and bulk payments
services; Payment and scheme management solutions; Loyalty services solutions; secure technology
integration and seamless payment suite to make and receive payment on various e-channels and
services. In addition, customers shall be provided with clear and complete information regarding any
upgrade or migration terms in relation to any of its services rendered, including any changes or
challenges in service performance or delivery and any duly approved fees or charges resulting from
the upgrade or migration, within the shortest time possible. No liability shall however be incurred for
any failure to provide a service due to circumstances beyond its control.
C. SERVICE SUBSCRIPTION
Interested customers may subscribe to any of the services provided by Cellulant via its designated web
portal, cellulant.com.ng/services.html or by sending email to firstname.lastname@example.org. Once a customer
subscribes to a subscription service, a notification message shall be sent to such person containing the
name of the subscription service, cost and frequency of charges and instructions for unsubscribing
from the service. Customers shall not be automatically subscribed to any subscription service without
express request from the customer.
D. CONTRACT TERM AND CONDITIONS
All terms and conditions of a contract regarding the provision of any of its services shall be clearly
stated in the contract or agreement. Furthermore, contracts entered into by Cellulant with its
customers shall have a specific duration which shall commence on a definite date to be stated in the contract and shall terminate on a certain date albeit in accordance with the termination provisions in
E. AVAILABILITY OF SERVICE
Services provided shall be available to all class of customers requiring the use of such service. In the
event that there are geographical or technical limitations known, which substantially affects the
performance of the service or the availability of such service to customers, such limitation shall be
clearly and concisely stated in any advertising material which promotes such service offer.
F. ADVERTISEMENT OF PACKAGED SERVICES
Any service provided as a component of a service package shall be made supplied as a whole to all
consumers. In the event Cellulant is or may be unable to supply any component of the package,
appropriate information about this limitation must be included in the advertising materials.
G. SMS NOTIFICATION
VAS SMS for any new service should only be disseminated to customers who have opted-in to receive
such. For existing customers, the option to opt-out free of charge must always be kept open.
Communications of VAS services must include a clear notification of the customers? rights in this
regard. Notwithstanding, where a customer has opted-in to receive SMS, the frequency of such SMS
must be limited so as not to become a nuisance to the customer. The timing shall be reasonable and
in line with the Nigerian Communications Commission?s directive restricting the delivery of SMS
between the hours of 8am and 8pm.
H. SMS CONTENT
The content of all SMS must be in conformity with the applicable statutory and regulatory provisions,
as well as the terms of the Cellulant Memorandum of Understanding (MoU) governing commercial
agreements and Non-Disclosure Agreement (NDA) binding technical agreements. In addition, any
short code or messaging channel originating such messages which does not comply risks being
DEACTIVATED WITH IMMEDIATE EFFECT.
I. UNSOLICITED MESSAGING
On no account should spam SMS be sent to customers; these are and not limited to messages that are
politically deviced, anti-ethnic and porn and sexually related messages. The mobile operators (Airtel,
Mtn, Etisalat & Glo) will implement measures to forestall the delivery of spam SMS to our customers.
Cellulant shall take proactive measures to prevent the dissemination of spam SMS through her
respective platforms (bulk sms platform, allocated short codes, music rights, content, routing
applications& devices) and reserve the right to take appropriate enforcement and protective measures
if this regulatory requirement is breached.
J. COMPLAINT PROCESSES
All written complaints shall be acknowledged and acted on promptly in accordance with the time
frames set out in the Commission?s Quality of Service Regulations (or as otherwise directed by the
Commission from time to time). Such acknowledgement may be done either verbally or in writing or
in any manner requested by the complainant.
K. FURTHER RECOURSE
In the event consumers remain dissatisfied with the outcome of a complaint, they may refer the
complaint to identified persons or departments, within the Nigerian Communications Commission.
L. DATA COLLECTION AND ANALYSIS OF COMPLAINTS AND OUTCOME
An appropriate recording system for complaints and their outcomes shall be set up and such system
shall store all complaints in a discernible manner for easy identification.
M. RETENTION OF RECORDS
Any information collected and recorded as part of complaint handling processes shall be retained for
at least twelve (12) months following the resolution of a complaint or as directed by the Nigerian
Communications Commission from time to time.
N. OPT-IN OPT-OUT
Subscription services and non-replyable messages must have the opt-in and opt- out options and every
customer shall have the right to exercise these options. The opt-out instruction must be included in
every non-replyable message and advertising materials which promote such subscribed service offer.
O. BILLING INFORMATION
Bills issued shall contain the following information: a) the consumer billing name and address, b) the
billing period and c) a unique way of identifying the bill.
P. TIMING FOR ISSUANCE OF BILLS AND BILLING FREQUENCY
All bills regarding the provision of services by Cellulant shall be issued within thirty (30) days of the
closure of each billing period. Customers may be provided with an advance written notification of any
proposed changes in billing period.
Q. PAYMENT CONFIRMATION
Consumers shall be able to verify their bill payment by acknowledgment of payment on the next bill
issued, telephone confirmation, or such other appropriate and accessible methods as may be made
R. COMPLIANCE WITH LAW
Evidence of an approved license should be obtained from the National Sports Lottery Plc. as a
precondition for running a lottery and award of huge cash prizes etc.
For mobile promotion campaigns by Fast Moving Consumer Goods (FMCGs) companies, corporate
bodies, reality shows etc. that involves the collation of results, selection of winners and administration
of prizes shall be done in the full glare of the public with external auditors and presence of the media
(Television, Radio, Print) to ensure and certify the transparency, accountability and integrity of the
In circumstances where there are unique variations in the dynamics and mechanics of the proposed
service and as such not embodied in this document, the service provider/third party client will submit
a letter of undertaking stipulating the specifics of the service and vouching strict adherence to the
provisions and guidelines of this document.