Customer Code of Practice

CODE OF CONDUCT GUIDELINES FOR THIRD PARTY (3RD) CLIENTS & SERVICES ON CELLULANT TECHNOLOGY PLATFORM.

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 info@cellulant.com.ng. 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 such contract.

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 available.

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.

S. PROMOTIONS

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 service.

T. VARIATION

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.


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