Individual Consumer Code of Practice

1.1 About This Code

This Individual Consumer Code of Practice (“the Code”) sets out the standards of conduct, service quality, consumer protection, complaint handling, and compensation that consumers can expect from Ruach Networks Infrastructure Limited (“Ruach Networks”, “the Company”, “we”, “us”) across all telecommunications services provided by the Company under licenses issued by the Nigerian Communications Commission (“the Commission” or “NCC”).

The Code has been prepared in accordance with the Consumer Code of Practice Regulations, 2007, the NCC General Consumer Code of Practice, the Nigerian Communications Act, 2003, the Quality of Service Regulations, and other applicable regulatory instruments issued by the Commission. It is a single, company-wide code: the same standards apply regardless of which licensed service a consumer uses.

1.2 Licensed Services Covered by This Code

This Code applies to the Company’s full portfolio of licensed telecommunications services, including without limitation:

Where a provision of this Code is specific to a particular service category (for example, premium-rate tariff announcements or SMS opt-out rules), this is stated expressly; all other provisions apply to every service.

1.3 Who This Code Protects

The Company’s services involve two distinct categories of consumer, and this Code protects both:

2.1 Service Information and Transparency

Ruach Networks shall, in respect of every service offered:

• Provide complete, accurate and up-to-date information on service descriptions, tariffs, terms and conditions, in plain language, before any contract is concluded;
• Publish current tariff information for all chargeable services on the Company website and make it available free of charge at its offices;
• Notify Corporate Subscribers in writing at least thirty (30) days before any tariff increase or material change to terms, and obtain Commission approval where required before implementing tariff changes;
• Ensure that all advertising and promotional material is accurate, not misleading, and complies with the Nigerian Code of Advertising Practice and NCC requirements.

2.3 SMS and USSD Services — Consumer Protections

For messaging and USSD services delivered over the Company’s platform, the following binding rules apply:

• Sender ID Integrity: The Company shall register and use only approved Sender IDs in accordance with NCC and industry sender-ID registration requirements, and shall not permit spoofed, misleading or unregistered sender identities on its platform;
• Do-Not-Disturb (DND) Compliance: The Company shall honour the NCC DND framework (short code 2442) and shall not deliver promotional messages to lines with an active full-DND status; Corporate Subscribers shall be contractually bound to classify their traffic (transactional vs promotional) accurately;
• Opt-In / Opt-Out: Promotional messaging campaigns shall be delivered only to recipients who have opted in, and every promotional message shall include a functional, free opt-out mechanism which takes effect within 24 hours;
• Premium USSD/SMS Billing Transparency: Any USSD or SMS service that attracts a charge beyond standard network rates shall disclose the charge to the End-User within the session or message before the charge is incurred, with an option to cancel;
• Content Standards: The Company shall not knowingly transmit content that is unlawful, fraudulent, or deceptive, and shall suspend any Corporate Subscriber’s service found to be used for scam, phishing or unlawful lottery messaging, pending investigation;
• Delivery Integrity: The Company shall not artificially inflate, duplicate or misreport message delivery, and delivery receipts provided to Corporate Subscribers shall accurately reflect handset or network delivery status.

2.4 Service Activation and Provisioning (Corporate Subscribers)

2.5 Quality of Service Commitments

The Company commits to the following measurable service standards, consistent with the NCC Quality of Service framework:

3.1 Billing Principles

• All charges shall be accurate, itemized, and based solely on tariffs disclosed in advance and, where applicable, approved by the Commission;
• Corporate Subscribers shall receive itemized monthly invoices showing rentals, usage charges (voice minutes, SMS units, USSD sessions), and any professional service fees, with supporting Call Detail Records and delivery logs available on the self-service portal;
• No charge shall be levied for services not requested, not provisioned, or not delivered; SMS units shall not be charged for messages rejected by the platform before submission to the network;
• Billing records shall be retained for a minimum of twelve (12) months and made available to the billed party on request, and CDRs/message logs retained in accordance with NCC retention requirements;
• For premium-rate services, the End-User’s charge is collected by the End-User’s own network operator through the aggregator settlement chain; the Company shall maintain reconciliation records sufficient to verify every premium charge attributed to its platform.

3.2 Billing Disputes

• A Corporate Subscriber or End-User may dispute any charge within six (6) months of the charge date;
• Disputed amounts shall not be subject to collection action, service suspension, or interest while the dispute is under investigation;
• The Company shall acknowledge a billing dispute within 24 hours and resolve it within ten (10) business days, providing a written explanation of the outcome;
• Where a charge is found to be incorrect, correction and refund/credit shall be effected in accordance with the Compensation Policy in Section 6;
• Unresolved disputes may be escalated to the Commission as described in Section 5.4.

4.1 Protection of Consumer Information

• The Company shall collect only the personal information reasonably required to provide the service, and shall use it only for the purposes disclosed at collection;
• Consumer personal data — including phone numbers, message content transiting the platform, call recordings and USSD session data — shall be processed in accordance with the Nigeria Data Protection Act, 2023, the NDPR, and the NCC’s data protection requirements;
• Message content shall be processed solely for delivery, troubleshooting, anti-fraud and lawful-compliance purposes, and shall never be mined for marketing or disclosed to third parties;
• Call recordings shall be made only with appropriate disclosure, stored encrypted, access-controlled, and retained no longer than necessary;
• Consumer information shall not be sold, shared, or disclosed to third parties without consent, except as required by law or by lawful order of the Commission or a court;
• Consumers may request access to, correction of, or deletion of their personal data, subject to statutory retention obligations, by contacting the Company’s Data Protection Officer via the contacts in Section 8.

4.2 Unsolicited Communications

• The Company shall not use its platforms to originate unsolicited voice or messaging marketing, and shall contractually prohibit its Corporate Subscribers from using the Company’s services for unsolicited communications in breach of NCC direction, including the DND framework;
• Any consumer may report suspected unsolicited, spam or fraudulent traffic originating from the Company’s platform, which shall be investigated as a priority complaint under Section 5.

5.1 How to Complain

Consumers (both Corporate Subscribers and End-Users) may lodge complaints free of charge through any of the following channels:

5.2 Complaint Handling Standards

No fee shall be charged for making a complaint, and no consumer shall suffer any service detriment for having complained. Complaint records shall be retained for a minimum of twenty-four (24) months and statistical summaries reported to the Commission as required.

5.3 Priority Procedure — Fraud and Unsolicited-Traffic Complaints

Complaints in the following categories receive priority handling given their elevated consumer risk:

• Complaints of scam, phishing, or fraudulent SMS/USSD/voice traffic attributed to the Company’s platform shall be triaged within 4 business hours, with the implicated traffic source suspended pending investigation where the complaint is prima facie substantiated;
• DND-violation complaints (promotional messages delivered to DND-active lines) shall be investigated within 2 business days, with the offending campaign halted immediately upon confirmation;
• Where a Corporate Subscriber’s content, marketing or traffic is found to breach this Code, the Company shall (a) compensate affected End-Users per Section 6, (b) require immediate remediation by the Subscriber, and (c) suspend or terminate the Subscriber’s service for repeated or serious breaches;
• Confirmed fraud shall be reported to the Commission and, where appropriate, law-enforcement authorities within 48 hours.

5.4 Escalation to the Commission

If a consumer is dissatisfied with the outcome of the Company’s complaint process, or the Company fails to resolve a complaint within the timelines above, the consumer may refer the matter to the Nigerian Communications Commission:

• NCC Consumer Affairs Bureau — toll-free line 622;
• Online: consumer portal at www.ncc.gov.ng;
• In writing: Nigerian Communications Commission, Plot 423 Aguiyi Ironsi Street, Maitama, Abuja.

The Company shall cooperate fully with the Commission in the investigation and resolution of any escalated complaint, and shall implement any direction of the Commission arising therefrom.

This Section constitutes the Company’s Compensation Policy and forms an integral, binding part of this Code. It defines the circumstances in which consumers are entitled to compensation, the applicable remedies, and the timelines for payment. It applies across all licensed services of the Company.

6.1 General Principles

• Compensation under this Policy is provided as of right where the stated criteria are met — the consumer does not need to prove loss beyond the qualifying event;
• Payment of compensation under this Policy does not limit any additional rights the consumer may have at law or under Commission regulations;
• Compensation shall be paid or credited within ten (10) business days of the determination, and confirmed in writing;
• Where a qualifying event affects multiple consumers (e.g., a platform outage), compensation shall be applied proactively to all affected accounts without the need for individual claims.

6.2 Compensation Schedule — Corporate Subscribers (All Services)

6.3 Compensation Schedule — End-Users

End-User refunds are processed through the settlement chain (End-User’s network operator ↔ aggregator ↔ the Company) and the Company shall initiate the refund instruction within five (5) business days of determination. Where the settlement chain cannot effect a refund to a specific End-User, the Company shall offer an equivalent direct remedy (e.g., airtime transfer or bank transfer) at the End-User’s election.

6.4 Exclusions

Compensation under this Policy does not apply to service interruptions or events caused by:

• Planned maintenance for which the required advance notice was given;
• Force majeure events (natural disaster, war, civil unrest, government action) beyond the Company’s reasonable control — provided that the Company shall still use best endeavours to restore service per its Disaster Recovery Plan;
• Failures within the End-User’s own network operator, or the Corporate Subscriber’s own equipment, applications or networks;
• Rejection or filtering of traffic by a Mobile Network Operator pursuant to that operator’s own policies or regulatory direction, where the Company has complied with all applicable submission requirements;
• Suspension of service lawfully effected for non-payment (after due notice) or for breach of the Service Agreement or of this Code.

No-Fault Restoration Commitment: Even where an exclusion applies, Ruach Networks remains committed to restoring service in accordance with its NCC-submitted Disaster Recovery Plan and to keeping affected consumers informed throughout.

• The Company’s Consumer Affairs Desk shall provide priority handling for consumers with disabilities, including extended call-handling time and the option of written (email) communication throughout;
• IVR services designed by the Company shall include a low-complexity path to a human agent (“press 0”) at every menu level for Corporate Subscribers operating live-agent services;
• Tariff and service information shall be made available in accessible formats (large print, screen-reader-compatible electronic documents) on request, free of charge;
• The Company shall ensure that elderly consumers and consumers with limited literacy are not disadvantaged, including through the availability of service information in major Nigerian languages (English, Hausa, Yoruba, Igbo) on request.

• This Code shall be published on the Company website, displayed at the Company’s offices, and provided free of charge to any consumer on request;
• All customer-facing and technical staff shall be trained on this Code before assuming their roles, with annual refresher training;
• Compliance with this Code shall be monitored by the Head of Regulatory & Compliance, who shall report quarterly to the Managing Director and maintain records available to the Commission;
• This Code shall be reviewed annually, and whenever the Commission amends the General Consumer Code of Practice or issues relevant new regulations; material amendments shall be submitted to the Commission for approval before taking effect;
• As the Company acquires additional licenses or launches additional licensed services, such services shall automatically fall within the scope of this Code without the need for a separate code, subject to any service-specific provisions the Commission may require;
• Nothing in this Code limits or removes any right conferred on consumers by the Nigerian Communications Act, 2003, Commission regulations, or any other applicable law. In the event of conflict, the stricter consumer protection prevails.