Individual Consumer Code of Practice (ICCP) Nigeria

Individual Consumer Code of Practice (ICCP) Nigeria

1. Introduction

Mode NG is a subsidiary of LendTech Investment Holdings (Ezra). This Individual Consumer Code of Practice (ICCP) is developed in line with the Nigerian Communications Commission (NCC) Consumer Code of Practice Regulations and other applicable laws.

The purpose of this ICCP is to:

  • Protect consumer rights
  • Promote transparency and fairness
  • Define service obligations
  • Establish complaint resolution procedures
  • Ensure data privacy and security
  • Prevent unsolicited communications

This ICCP applies to all consumers, partners, agents, and staff involved in Mode NG’s VAS operations.

2. Provision of Information to Consumers

2A. Description of Services

  1. Mode NG operates a digital airtime and data lending service through Short Code Numbers, which enables eligible consumers to access airtime and/or data on a credit basis.
  2. Mode NG shall provide consumers with full, accurate, and up-to-date information on its digital airtime and data lending services, including:
    – Nature and scope of the service
    – Service functionality and limitations
    – Access channels (USSD, SMS, web, API, or mobile platforms)
    – Network dependencies and compatibility
  3. Service descriptions shall be published through:
    – Official website
    – Subscription prompts
    – Customer support channels
    – Promotional materials
  4. Technical constraints, service downtime risks, or coverage limitations shall be clearly disclosed.

2B. Service Contract and Duration

  1. Each VAS offering shall be governed by a service contract, which may be electronic or digital.
  2. The contract shall clearly specify:
    – Contract commencement date
    – Service duration (fixed, recurring, or usage-based)
    – Renewal terms(automatic or manual)
    – Conditions for suspension or termination
  3. Consumers shall not be bound by indefinite or unclear contract durations.

2C. Service Subscription

  1. Subscription to any Mode NG service shall be based strictly on explicit consumer consent (opt-in).
  2. Subscription channels may include:
    – USSD codes
    – SMS confirmation
    – Web portals
    – Official mobile applications
  3. Subscription instructions shall:
    – Be simple and user-friendly
    – Clearly state the service name and cost
    – Require affirmative confirmation before activation
  4. Consumers shall be able to unsubscribe at any time without penalty.

2D. Contract Terms and Conditions

  1. Mode NG shall make all Terms and Conditions available prior to subscription.
  2. Terms shall cover:
    – Service scope
    – Pricing and billing structure
    – Consumer obligations
    – Mode NG’s responsibilities
    – Limitation of liability
    – Dispute resolution mechanisms
  3. Terms shall be written in clear, plain language without misleading clauses.

2E. Disclaimer, Telemarketing and Prepaid Service

  1. Mode NG shall use reasonable efforts to provide reliable and uninterrupted services. However, service availability may be affected by maintenance, technical faults, network congestion, force majeure or other circumstances beyond the reasonable control of Ezra. Nothing in this Disclaimer shall limit or exclude any rights or remedies available to subscribers under applicable law or the directives of the NCC.
  2. Mode NG may send subscribers information on its products, services and promotions in accordance with applicable laws and the directives of the NCC. Mode NG shall respect subscribers’ communication preferences and the DoNot-Disturb (DND) framework. Subscribers may opt out of marketing communications at any time using the prescribed opt-out mechanism.
  3. Mode NG provides prepaid telecommunications services subject to its approved tariffs and applicable laws. Subscribers are responsible for maintaining sufficient credit to access the services of Ezra. Charges shall be deducted from the subscriber’s prepaid balance in accordance with the applicable tariff, and Ezra may suspend services where the available credit is insufficient or as otherwise permitted by law or the directives of the NCC.

3. Advertisement and Representation of Services

3A. Availability of Service

  1. All advertisements shall accurately reflect:
    – Service availability
    – Network coverage limitations
    – Operational dependencies on Mobile Network Operators(MNOs)
  2. Mode NG shall not misrepresent uptime guarantees or service continuity.

3B. Advertisement of Packaged Services

  1. All promotional materials shall clearly state:
    – Total cost of the service
    – Billing cycle
    – Subscription duration
    – Any recurring or renewal charges
  2. No hidden charges or deceptive promotional claims shall be permitted.
  3. Free trials (if any)shall clearly indicate:
    – Trial duration
    – Conversion to paid service
    – Cancellation procedure

4. Complaint Handling and Dispute Resolution

4A. Complaint Processes

  1. Mode NG shall maintain a dedicated Consumer Complaint Management System.
  2. Consumers may lodge complaints via:
    – Address: 1261A Adeola Hopewell Street, Victoria Island, Lagos State
    – Email: legal@ezra.world
    – Telephone call centre: +234 902 212 1888
    – SMS/USSD
    – Website contact forms
  3. Every complaint shall:
    – Receive an acknowledgment within 24 hours
    – Be assigned a reference number
  4. Resolution shall be completed within 5 working days, where practicable.

4B. Further Recourse

  1. Where a complaint is unresolved, consumers shall be informed of escalation options.
  2. Consumers may escalate complaints to:
    – Mode NG’s senior management
    – The Nigerian Communications Commission (NCC)
  3. Mode NG shall cooperate fully with NCC investigations.

4C. Data Collection and Analysis of Complaints and Outcomes

  1. Mode NG shall maintain a centralized complaint database capturing:
    – Nature of complaint
    – Resolution timeline
    – Outcome status
  2. Periodic analysis shall be conducted to:
    – Identify recurring issues
    – Improve service delivery
    – Reduce consumer dissatisfaction

4D. Retention of Records

  1. All complaint records shall be retained for a minimum of 24 months.
  2. Records shall be securely stored and made available for regulatory audits.

5. Prevention of Unsolicited SMS

5A. Opt-In and Opt-Out Options

  1. Mode NG shall comply strictly with NCC directives on unsolicited messages.
  2. No promotional SMS shall be sent without prior consumer consent.
  3. All messages shall include:
    – Clear identification of Mode NG
    – Simple opt-out instructions(e.g., “STOP”)
  4. Opt-out requests shall be processed immediately and confirmed to the consumer.

6. Consumer Billing Practices

6A. Billing Information

  1. Billing information shall be transparent and itemized, including:
    – Service description
    – Amount charged
    – Billing period
    – Applicable taxes
  2. Consumers shall have access to billing history upon request.

6B. Timing for Issuance of Bill

  1. Bills shall be issued within 10 days after the end of the billing cycle.

6C. Payment Confirmation

  1. Upon successful payment, consumers shall receive immediate confirmation via:
    – SMS
    – Email
    – App notification
  2. Failed or reversed payments shall also be communicated promptly.

6D. Billing Frequency

  1. Billing shall occur every 60 days, unless otherwise disclosed.
  2. Consumers shall receive at least 120 days’ notice before any billing change.

6E. Retention of Billing Records

  1. Billing records shall be retained for 24 months for audit and dispute resolution purposes.

7. Consumer Data Protection

7A. Data Gathering

  1. Mode NG shall collect only data necessary for:
    – Service provisioning
    – Billing
    – Customer support
  2. Data collection shall be lawful, fair, and transparent.

7B. Data Storage

  1. Consumer data shall be securely stored using:
    – Encryption
    – Access controls
    – Secure servers
  2. Access to data shall be limited to authorized personnel only.

7C. Data Sharing

  1. Consumer data shall not be shared with third parties without consent except:
    – Where required by law
    – Where necessary for service delivery under strict confidentiality
  2. All third-party partners shall comply with data protection obligations.

8. Consumer Education and Awareness

  1. Mode NG shall actively educate consumers on:
    – Service usage
    – Subscription and cancellation procedures
    – Complaint resolution channels
  2. Educational materials shall be accessible via digital platforms and customer support.

9. Compliance, Monitoring, and Review

  1. This ICCP shall be reviewed annually or as required by NCC regulations.
  2. Mode NG shall ensure staff training and internal compliance monitoring.
  3. Non-compliance by employees or agents shall attract disciplinary measures.