Code of Conduct

The provisions of this Code are in addition to the obligations of Termii under its License and under the Nigerian Communications Act (the “Act”). Nothing in this Code affects your statutory rights, and this Code does not form part of a contract or collateral contract between Termii and any of its consumers.

This Code helps to explain what to do if things go wrong. It gives information on how to get a full explanation together with a remedy, sets out the complaints procedure, and explains how to use it should the need arise. Copies of this Code may be obtained by contacting Customer Care.

1. Provision of information

(A) Description of service

Termii offers value-added services (content services using short code numbers) through its cloud communications platform, enabling global businesses with messaging channels to verify and authenticate customer transactions — helping businesses build connected experiences across all stages of the customer journey through SMS, WhatsApp and Voice.

In providing its services, Termii shall give consumers complete, accurate and up-to-date information in clear language, avoiding unnecessary technical terms — including specific information on compensation, refund or other arrangements where contracted quality of service levels are not met, and the procedures for resolving disputes.

(B) Service contract and duration

Prior to a consumer signing up, Termii shall make available in plain, clear language the service contract for the provision of the service. All clients are expected to read and sign before services commence. This contract governs the relationship between Termii and its consumers and contains complete information on services, advertising and representation, billing, charging, collection and credit practices, consumer rights and obligations, protection of consumer information, complaints handling, and concise information on contacting Termii.

(C) Service subscription

Termii shall provide consumers with clear information and instruction on the medium and procedure for subscribing to its services.

(D) Contract terms and conditions

Termii shall make available on request a copy of a contract or agreement for the provision of services, set out in plain, clear language, containing information on:

• The term of the contract — commencement date, minimum contract term and period, the manner and consequences of termination, and how charges payable on early termination are calculated.
• Conditions and terms of renewal, where applicable.
• Terms relating to interruption, suspension or discontinuation of the service.
• Terms relating to delivery, installation or activation of the service.
• Conditions, terms and fees for disconnection and reconnection.
• The service quality level offered, waiting time for initial connection, and any service areas and coverage maps available.
• Any compensation, refund or other arrangements applying if contracted quality of service levels are not met.
• The procedures and methods for resolving disputes in respect of the service contract.
• Any contractual warranty relating to the services, how it may be obtained, and information on maintenance services offered.
• Where a contract is subject to upgrade options — clear and complete information on upgrade terms, including changes in service performance and any resulting fees or charges.

(E) Opt in and opt out

Termii shall inform consumers of their right to opt out of any subscribed service, and maintain readily accessible mechanisms to subscribe to, renew or discontinue a service so consumers avoid incurring further charges.

2. Advertisement and representation of services

(A) Availability of service

Termii shall endeavour to publish in advertising materials any known geographical and technical limitations on the availability of its services, and clearly state where such a limitation restricts the offering to a particular group of people, zone or geographical area, period of time, or through limited availability of equipment or facilities.

(B) Advertisement of packaged services

Termii shall ensure it can supply all components of a service package as advertised — and where it may be unable to supply any component, appropriate information about the limitation shall be included. Termii complies with the Nigerian Code of Advertising Practice, Sales Promotion and all applicable rules and regulations.

(C) Disclaimers

Any disclaimer placed in an advertisement shall acknowledge the intended consumer, be written in clear and plain language, and not negate the principal message or object of the advertisement.

(D) Tele-marketing

Termii shall be entitled to engage in unsolicited telemarketing in accordance with the general code (section 28) and shall, at the time of communication, afford consumers the opportunity to cancel the agreement by calling a dedicated telephone number.

3. Complaint handling

(A) Complaint process

Termii maintains customer complaints handling procedures which ensure that:

• Information on complaint handling is provided in various media and formats and is easily understandable, and any changes to the process are made available to the customer.
• Customers can easily identify how a complaint may be lodged.
• Consumers with physical disabilities or other special needs can access the process themselves or through authorized representatives.
• Timelines are established for resolving complaints.
• A dispute resolution process exists, including the right to refer any complaint to the Commission if dissatisfied with Termii’s resolution.
• Contact is available by email at company@termii.com and by telephone at +234 813 775 1523 or +1 669 241 1742.
• All complaints are treated with the highest degree of professionalism and deference to the customer’s right to complain.
• No customer complaint is left unresolved for more than ninety (90) days.
• Complaint handling is free of charge, except where an investigation requires retrieving records more than twelve (12) months old.
• Information recorded in the complaint handling process is retained for at least twelve (12) months following resolution.

(B) Further recourse

Termii shall acknowledge written complaints and act on them within the timeframes set out in the Commission’s Quality of Service Regulations. A complaint not resolved within the provided resolution period shall be escalated to the Commission for resolution in accordance with its Dispute Resolution Guidelines.

(C) Data collection and analysis of complaints

Termii maintains an appropriate system for recording complaints and their outcomes in conformity with the Commission’s Quality of Service Regulations. Complaints are recorded, tracked, analysed and categorised to ascertain causes and prevent recurrence, and every logged complaint carries a reference number for future retrieval.

(D) Prevention of unsolicited SMS

No unsolicited short message service shall transit through Termii’s network. Termii shall ensure that a consumer can choose the option of stopping every unsolicited SMS.

4. Consumer obligations

To enable us to provide the highest quality of service, Termii asks its customers to faithfully comply with the relevant statutory and regulatory instruments governing the use of telecommunication facilities:

• Customers are bound by Termii’s terms of service, whether signed and returned to Termii or clearly accepted by receiving the service after its terms have been provided.
• Customers are not authorized to re-sell any service provided by Termii without its formal authorization.

5. Protection of consumer information

(A) Data gathering

Termii may collect details relating to a customer only where relevant and necessary for providing the service or product, or for other legitimate purposes made known to the customer before the details were obtained. Customer details are used only for permitted purposes, which include:

• Termii’s internal marketing, billing and other purposes necessary for the provision of the service.
• Purposes made known to the customer prior to the time the details are collected.
• Other purposes with the customer’s prior consent, whether given expressly or impliedly.
• Where disclosure is required by law, a court of law, a statutory organisation (such as the Police), a regulatory body (such as the Commission), or is in the public interest.

(B) Data storage

Termii is committed to protecting its customers’ information in accordance with data protection regulations. We take appropriate technological and organizational measures to protect and secure consumer information, and ensure our employees do not disclose any data or information obtained in the course of providing our services.

(C) Data sharing

Termii ensures that any other service provider or third party with whom it shares or discloses customers’ information adopts and implements an appropriate and efficient protection of consumer information policy.

6. Consumer billing

The objective of Termii’s consumer billing policy is to ensure billing is accurate, timely and verifiable, with sufficient detail on invoices for customer verification. Records of customer invoices and related charges are retained for at least twelve (12) months.

Customer bills include: billing name and address, Termii’s business name and registered number, bill number, billing period, description of charges, total amount billed, applicable credits and discounts, date of issuance, methods of payment, and guidelines for billing enquiries and complaints.

Bills are issued within ten (10) days of the closure of each billing period unless otherwise agreed in the service contract, and customers receive sufficient advance notification of any proposed changes to billing periods.