Consumer Code of Practice

Introduction

Scope and Objectives

1. VAS2Nets Technologies Limited (“VAS2Nets”), Consumer Code of Practice (the “Code”) made in pursuance of Section 106(2) of the Nigerian Act 2003(“the Act”) and Regulation 4(1) of the Consumer Code of Practice Regulations 2007 (“the Regulations”).

Definitions

2. Terms used in this Code are given their ordinary meaning within the framework of the business or VAS2Nets’s document. Clause headings are inserted for convenience of reference only and shall not affect the interpretation of this Code. Words importing the plural shall, except where the context otherwise requires, include the singular and vice versa: references to the masculine gender shall include the feminine or neuter genders and vice versa; and references to persons shall be construed as references to an individual firm, company, corporate body, statutory board, government body, incorporated body of persons, association or trust as the context may require.

Application of Code

3. The Code shall govern the provision of services to consumers by VAS2Nets. In the event of a conflict between the Code and the General Code, to the extent that the terms of the codes are not less favorable to the Consumers than the General Code, this Code shall apply.

4. VAS2Nets shall provide Consumers with information on their services that is complete, accurate, and up-to-date and in simple, clear language. This would be made available to both the customer service department of the company, web portal and also in the welcome message after opting in for a service.

5. VAS2Nets shall endeavor to respond in a timely manner to Consumer requests for information on their services and such information shall be provided free of charge and shall include at least the following : (a) Current service, arrangements, including information about the services and tariff for all services offered to the public, shall be readily available via appropriate media including electronic format on VAS2Nets’s web site. (b) Any request in tariff changes would be done under the auspice of VAS2nets in consultation with the Service provider. Approval shall be gotten for any tariff change and also adequate information with an option to opt out shall be given to the user/subscriber. (c) VAS2Nets shall also endeavor to ensure that subscribers have good Service Level Agreement.

Description of Services

6. VAS2Nets offers USSD and Bulk SMS Services. This service caters to customer’s need for SMS broadcast in areas such as marketing campaigns, promotion activities, and customer notifications.

Service Contracts and Duration

7. VAS2Nets shall supply, or make available on request, a copy of the contract or agreement for the provision of services, and such contracts shall be written in plain and clear language.

Service Subscription

8. Customers may subscribe to the service via a convenient electronic or web channel. VAS2Nets upon receipt of subscription will issue email or Short Message Service confirmation.

Contract Terms and Condition

9. All terms and conditions of a contract regarding the provision of any of our services shall be clearly stated in the contract or agreement. Furthermore, contracts entered into by VAS2Nets 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.

Availability of Service

10. VAS2Nets services are available on all mobile networks , however our services are network dependent, services will be restricted to certain areas within Nigeria where mobile network service is available as contained in promotion materials.

Advertising of Packaged Services

11. (1) Where VAS2Nets represents in advertising materials that a service is provided as part of a package, VAS2Nets shall ensure it is able to supply all components of the service package. In the event that VAS2Nets is or may be unable to supply any component of the package, appropriate information about this limitation shall be included in the advertising materials. (2) Where advertising materials indicate the price of a component of a service package, VAS2Nets shall include in the advertising materials a statement of the minimum total charge for the package, and indicate any Conditions that may apply to obtain the component at the stated price.

Complaint Processes

12. VAS2Nets operates a customer service desk which is reachable during working hours from 8:00am to 5:00pm and outside working hours via e-mail. All consumers can contact the help desk via telephone; 234- 8141329581 email: info@vas2nets.com. Before you contact our support desk please make sure that you have details of the transaction initiated, your mobile number, and summary of the complaint. This will enable us process and resolve your complaints quickly.

Further Recourse

13. In the event that the complaining customer remains dissatisfied with the outcome/resolution of the complaint, has the right to refer the complaint to Nigerian Communication Commission (NCC).

Data Collection and Analysis of Complaints and Outcomes

14. An appropriate recording system for complaints and their outcome/resolution shall be set up and such system shall have all complaints and resolution stored in a discernible manner for easy identification.

Retention of Records

15. Any information collected and recorded as part of complaint handling processes shall be retained for at least twelve (12) months following the resolution of complaints or as directed by NCC from time to time.

Opt-in and Opt-out

16. Upon request for any service, VAS2Nets shall provide the consumer with Opt-in and Opt-out options in clear, simple and understandable terms.

17. VAS2Nets shall provide the consumer with access to a HELP function to obtain information on services they are at the time of request, subscribed to and how to opt out in clear plain English.

Billing information

18. VAS2Nets shall ensure that, at a minimum, the following information is included in any billing or charging notifications issued by it or on its behalf: (a) The name of the service for which the consumer has been billed (b) The type of the service for which the consumer has been billed and the service delivery medium (c) The period over which the service associated with the charge will be provided (d) The total amount billed or charged to the consumer’s prepaid account.

Itemization of Charges

19. VAS2Nets shall ensure that each consumer has access to itemized details to all charges pertaining to subscribers on that mobile network and VAS2Nets shall ensure that all such itemized details are available for 12 months after the billing/charges effect has occurred.

Timing for Issuance of Bill

20. VAS2Nets shall bill Consumers at the point of activation and shall equally ensure that in instances where a service for which a consumer has been billed cannot be delivered, the consumer will be subsequently offered the service at no extra cost for a period of time equal to the period over which the service should have been delivered but was not. Where the circumstances will not permit the service to be delivered (due to circumstances beyond the reasonable control of VAS2Nets, such as an event of force majeure or a technical system failure at the mobile network resulting in service interruption), VAS2Nets shall liaise with the mobile network operator to establish a suitable resolution path that will ensure that consumers do not lose any value and are appropriately refunded and compensated.

Payment Confirmation

21. VAS2Nets shall ensure that Consumers are able to verify their bill payment by acknowledgment of payment on the next bill issued, with such appropriate and accessible methods as may be made available by VAS2Nets.

Billing Frequency

22. VAS2Nets shall provide Consumers with advance written notification of any proposed changes in billing before any such changes are implemented via any channel over which VAS2Nets services are offered. Consumers shall be informed in all such notifications of how to opt out of the service to avoid experiencing the proposed changes in billing.