I. Purpose and Applicability

This Code of Conduct is released to promote and ensure the absolute integrity of WajeTech's business dealings with its employees, customers, contractors, partners, etc. It is intended to establish clear compliance standards and ethical principles to be obeyed.

This Code reflects an extension of our culture of integrity and our continued commitment to ethical business practices and complying with all necessary laws. We expect all of our employees and representatives to understand and comply with our Code and exercise good judgment when making business decisions. The Code summarizes the principles and policies that govern our company. This Code must apply to every business decision in every area of the company worldwide.

II. Legal Compliance

1. General Legal Compliance

Customers must comply with applicable laws and regulations in force in their place of incorporation and the places in which they operate as well as any applicable international laws and regulations.

2. Labor Protection

At WajeTech, we provide our employees with a healthy work environment where they are treated with dignity and fairness and ensure that employees are free from discrimination or harassment for any reason whatsoever, including but not limited to skin color, ethnicity, age, gender, sexual orientation, religion and political affiliation.

3. Environmental Compliance

Employees must conduct operations in an environmentally responsible business manner and in strict compliance with applicable environmental laws and standards.

4. Government

Employees must comply with all applicable bidding or procurement laws when conducting business with governments, public institutions, state-owned enterprises, governmental departments, quasi-governmental bodies or local authorities where such bidding or procurement regulations apply.

5. Anti-Bribery

At WajeTech, employees shall not directly or indirectly offer, promise to offer, make or receive any form of bribe to or from government officials, political parties, or commercial-sector (non-public sector) parties, in order to win or retain business or seek to influence a business decision inappropriately. Such inappropriate activities include but are not limited to offering or providing any gift or hospitality which is excessive or inappropriate in nature for the purpose of obtaining any improper advantage or illicit benefit.

6. Cyber Security

WajeTech respects the privacy of our customers, consumers and employees consistent with privacy and data protection laws and strictly abides by all applicable laws and regulations regarding cyber security and data protection of Nigeria and countries in which we operate, and shall not infringe the freedom of communication and privacy of end users.

Our customers, consumers and others must be able to trust that we will only collect, store, share and use their personal information for defined legitimate business purposes and to support and enhance our relationships with them. We do not sell our consumers' or customers' personal information. We appropriately safeguard our consumers' and customers' information and comply with internal policies and applicable laws.

In addition, we protect and appropriately use the personal information of our employees consistent with all legal requirements.

III. Business Ethics

1. Complete and Truthful Materials

WajeTech, its employees, partners and contractors ensure that all materials provided to customers and end users are truthful, factual, legitimate, and valid and that full authorization has been obtained from third parties if the materials contain any confidential information related to a third-party. Customers must also acknowledge that all information they provide to WajeTech are truthful, accurate, and complete.

2. Unauthorized Commitments

Employees shall not make commitments to customers, consumers and end users or any third party on matters in which they have not been authorized in writing with such express authority to do so.

Any losses incurred by WajeTech due to an employee's unauthorized commitment or its failure to reject the unauthorized commitment of a customer's employees shall result in suspension, termination of employment or worse.

3. Defamation

Employees must operate with integrity and shall not defame or disparage WajeTech or its customers. Employees are prohibited from making false or misleading statements regarding competitors or their products and services.

4. Bribing WajeTech Employees

Customers are not allowed to bribe or transfer illicit benefits to any WajeTech employee in any forms whatsoever, including but not limited to cash, negotiable securities, and payment vouchers, in an attempt to obtain illicit benefits or maintain cooperation with WajeTech. In addition, customers are not allowed to give WajeTech employees inappropriate gifts and/or etiquette that is far beyond the propriety of the situation, or any other conduct that could be construed as inappropriate. Whether entertainment or gifts are appropriate business etiquette shall be determined by WajeTech at its discretion, taking into account various factors including whether those involved in the giving or receiving would be embarrassed should such events or actions be made known to the public.

This clause also applies to the family members and other close relatives of a WajeTech employee.

5. Conflict-of-Interest Relationship

Customers shall not allow those who currently work at WajeTech or their family members to have a stake in their company. In the event that a WajeTech employee or his/her immediate family member(s) works for a customer, or acts as an employee, consultant, board member, executive, or shareholder of the customer, the customer shall report such situations to WajeTech immediately.

6. Intellectual Property Rights and Confidential Information

Employees, customers and contractors shall respect WajeTech's intellectual property rights. Without prior permission, no party shall disclose any confidential information they have access to during their dealings with WajeTech, nor use any WajeTech intellectual property without permission from WajeTech.

7. Gifts, Entertainment, Corporate Hospitality & Travel

At WajeTech, our relationships with partners, customers and others must be based entirely on sound business decisions and fair dealing. While gifts, entertainment and corporate hospitality can help build relationships, they can also make it harder to be objective in business dealings. We may never:

• Solicit, offer, accept or provide any gifts, entertainment, corporate hospitality or travel if it will obligate or appear to obligate the person who receives it.
• Solicit, offer, accept or provide to anyone cash or cash equivalents, lavish or frequent gifts or entertainment, or anything that might look like a bribe.
• Provide or accept sexually-oriented gifts or entertainment.

With appropriate approval, you may give or accept customary entertainment or business courtesies, such as meals, provided the expenses are reasonable and are not prohibited by law or by either party's policies or standards of conduct. You must receive pre-approval from your manager before accepting any travel from, or providing any travel to, any customers, suppliers, vendors or other third parties.

Laws concerning providing gifts, hospitality and travel to government officials (which include executives and employees of government-owned corporations, newspapers, television stations, universities and other entities affiliated with governments, and public international organizations like the U.N.) are complex and can vary from country to country. In many cases, it is illegal and improper to provide gifts to government officials. We take special care in this highly regulated area, as WajeTech wishes to avoid even the appearance of impropriety. No gift or business courtesy may be provided to a government official or employee unless applicable approval conditions are met and only if allowed under WajeTech's Global Gift, Entertainment, Corporate Hospitality and Travel Policy.

Contact the ECO, the Legal Department or Government Affairs for guidance about the rules that apply in your area.

IV. Compliance Management

1. Establishing a Compliance System

WajeTech encourages all customers to establish their own internal compliance management system to ensure compliance with all applicable laws and regulations.

2. Communicating WajeTech's Principles

The Compliance team shall make this Code of Conduct available to departmental heads and ensure full adherence to the Code.

3. Strict Employee Management

Managers and departmental heads must strictly manage the conduct of employees, ensuring employees abide by WajeTech's business conduct guidelines, as well as this Code of Conduct.

V. Miscellaneous

1. Consequences of Any Violation of This Code of Conduct

Any violation of this Code of Conduct may result in reduction of incentives partners are entitled to, or the immediate termination of the business relationship with WajeTech. In addition, WajeTech reserves the right to request partners to indemnify all losses caused to WajeTech due to the violation of this Code of Conduct.

2. Version Update

WajeTech reserves the right to supplement and change this Code of Conduct at any time. Partners are expected to monitor the website regularly for changes to this Code of Conduct.

3. Submitting Questions or Reporting Violations

If you have any question about this Code of Conduct or become aware of any violations of this Code of Conduct that is believed in good faith to be either an actual or potential violation of this Code of Conduct, please send an email to info@wajetech.com. Please submit questions or report any suspicious behavior which may constitute a violation with your real name attached.

Please note that the information that you provide to WajeTech must be truthful, accurate and complete to the greatest extent possible. If necessary, WajeTech expects you to reasonably assist with any investigations into the incident or situation that you report, including providing reasonable access to any associated documentation within partner control. Reporting misleading or defamatory information to WajeTech may result in WajeTech's immediate termination of your business relationship with us.

WajeTech Limited is committed to conducting business with integrity, transparency and compliance with all applicable Nigerian and international laws, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act.

This anti-bribery policy exists to set out the responsibilities of WajeTech Limited and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption.

It also exists to act as a source of information and guidance for those working for WajeTech Limited. It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

WajeTech Limited is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. WajeTech has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships in Nigeria.

WajeTech Limited will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the Federal Republic of Nigeria, in regard to our conduct both at home and abroad.

WajeTech recognizes that bribery and corruption are punishable by up to ten years of imprisonment and a fine in accordance with the Corrupt Practices and other Related Offences Act 2000. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

At WajeTech, we are mindful of adhering to applicable laws, honesty and integrity requirements for public officials, and WajeTech's Anti-Bribery Policy when engaging with public officials. Public officials include individuals who perform duties on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, or international organizations; candidates of political parties; and other personnel who perform public services according to the law.

1. Zero-Tolerance on Bribery and Corruption

WajeTech strictly prohibits any form of bribery, corruption or improper advantage involving public officials or private persons.

2. Gifts and Hospitality

Under no circumstances should WajeTech employees, motivated by a corrupt intent, be allowed to directly or indirectly offer gifts or hospitality to public officials, customers, or partners, or solicit gifts or hospitality from partners. WajeTech employees must always bear in mind the company's anti-bribery policy and evaluate if the company's reputation will be affected when giving or accepting gifts and hospitality.

The following requirements must be met before giving or accepting gifts and hospitality:

• It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It is in compliance with local law.
• It is given in the name of the company, not in an individual's name.
• It does not include cash or a cash equivalent (e.g., a voucher or gift certificate).
• It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
• It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
• It is not above a certain excessive value, as pre-determined by the company's compliance manager (usually in excess of NGN 100,000).
• It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company's compliance manager.

Where it is inappropriate to decline the offer of a gift (i.e., when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

WajeTech Limited recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

3. Charitable Contributions and Donations

In the pursuit to fulfill our corporate social responsibilities, WajeTech accepts (and indeed encourages) the act of donating to charities either through services, knowledge, time, or direct financial contributions (cash or otherwise), and agrees to disclose all charitable contributions it makes.

Partners must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. It's forbidden to use charitable contributions and donations to disguise corrupt activities. Effective measures must be taken to ensure transparency and legitimacy in making charitable contributions and donations.

We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

WajeTech does not directly or indirectly participate in the political activities of any political party, nor does WajeTech sponsor local political parties, their candidates, associated persons, or affiliates.

4. Third-Party Management

Third parties include service providers, suppliers, downstream dealers, agents, consultants, and other partners. Cooperation between WajeTech and third parties must be authentic and legitimate. WajeTech requires its partners to comply with their own codes of conduct, the principles of honesty and integrity, and this Policy.

• WajeTech believes that due diligence, complete agreement clauses, and corresponding control procedures are key to ensuring that third parties comply with WajeTech's Anti-Bribery Policy.
• It's forbidden to utilize, aid, abet or conspire with a third party to engage in bribery.
• Third parties are forbidden from paying bribes on behalf of WajeTech or when working with WajeTech in any capacity. This prohibition includes bribes in the form of gifts or hospitality offered to WajeTech employees, when the gift or hospitality offered does not comply with common business practices.

5. Books and Records

• At WajeTech, appropriate bookkeeping and records will be provided in a transparent and honest manner to support business decisions and archived as required.
• We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given in line with our document retention policy, to facilitate future inspection and understand that gifts and acts of hospitality are subject to review.

6. Prohibition of Facilitation / Grease Payments

Facilitation or grease payments are strictly prohibited, irrespective of amount, local custom or urgency.

7. Consultation and Report

• If you have any questions about this Policy, please consult your immediate supervisor. If they cannot answer your questions, then consult the compliance team.
• If you know of or suspect a violation of this Policy, please notify us by writing to info@wajetech.com.
• WajeTech will launch investigations and protect the whistleblower from threats or retaliation by ensuring utmost secrecy.

8. Monitoring and Reviewing

WajeTech Limited's compliance team is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

This policy does not form or establish any contractual relationship, and WajeTech Limited may amend it at any time so as to improve its effectiveness at combatting bribery and corruption.

WajeTech recognizes the importance of preventing money laundering and terrorism financing and is therefore committed to the highest standards of Anti-Money Laundering and Combating Terrorist Financing in Nigeria.

Subject to applicable laws designed to prevent money laundering, including legislation such as: the Terrorism Prevention Act 2013, the Money Laundering Prohibition Act 2011 (as amended), and others.

As a Designated Non-Financial Institution (DNFI), WajeTech, in its commitment to fulfil this, has established internal policies and procedures.

This Policy establishes standards which its employees, contractors and partners should observe.

1. Scope

Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for "clean" money or other assets with no obvious link to their criminal origins.

Criminal proceeds may take any form, including money or money's worth, securities, tangible property and intangible property.

Terrorism Financing is defined as providing, depositing, distributing or collecting funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially used, for the committing of terrorist acts.

This Policy is aimed at preventing any company or individual from using Waje Technologies Limited for money laundering or terrorist financing activities.

2. Our Policy

Customer Due Diligence

To prevent money laundering, Waje Technologies Limited will implement processes and procedures in its Lines of Business (LOBs) to conduct appropriate customer due diligence through WajeTech's screening processes, which includes identifying the customer and verifying the customer's identity on the basis of the following "Know Your Customer" principles:

• Customer-provided documentation (verification checking);
• Information on the customer obtained from reliable and independent sources (ownership checking);
• Compliance with WajeTech's Business Codes and policies.

Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the Compliance department.

Risk-Based Approach

At WajeTech, the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business our customers carry out or the customer's location.

WajeTech will classify its customers based on a risk level in its applicable line-of-business processes and procedures.

Identifying the potential risk will help to effectively manage these risks, implementing controls to mitigate the identified risk, if any.

High-Risk Customers

WajeTech will not do business with the following segments of customers:

• Persons or organizations included in any official lists of sanctions, contradictory to WajeTech's business policy and code of conduct;
• Persons or organizations indicating possible involvement in criminal activities, based on available information about them;
• Persons or organizations with businesses in which the legitimacy of activity or source of funds can't be reasonably verified;
• Persons or organizations refusing to provide the required information or documentation; or
• Entities whose shareholder/control structure cannot be determined.

Record Keeping

Customer documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken, and copies of, or reference to, the documentation of the customer must be kept.

Records should be kept for as long as the relationship endures with the customer, and for at least five (5) years after the relationship ends. In countries where this period exceeds the established period of time, the legally established time period will be considered to comply with local law.

Anti-Money Laundering Compliance

At WajeTech, the Compliance team is the designated Anti-Money Laundering department responsible for:

• Considering internal reports of money laundering;
• Reporting suspicions of money laundering to the responsible authorities; and
• Acting as key liaison with the money laundering authorities;
• Advising the company and training its employees on money laundering;
• Submitting weekly Anti-Money Laundering reports;
• Advising on the proper course of action after a report of suspicion of money laundering has been raised; and
• Designing and implementing Anti-Money Laundering processes and procedures.

3. Reporting Suspicious Activity

WajeTech expects that, if any employee, contractor or business partner becomes aware of any suspicion or knowledge of possible money laundering activity, this is reported without undue delay to the compliance department. This can be done by contacting directly any member of the compliance department.

A report on suspicious activity should contain, at least, the following verifiable information:

• Identity of the person raising the suspicion;
• Date of the report;
• Who is suspected of money laundering or terrorist financing activities;
• Other individuals involved otherwise;
• Deliverance of facts;
• What is suspected and why; and
• Any possible involvement of Waje Technologies Limited.

The Compliance team may make reasonable enquiries within WajeTech to confirm these suspicions or obtain additional information to confirm these suspicions. After this assessment, the team will determine whether or not it is necessary to file an official report to the responsible money laundering authority.

Details of internal reports will be held by the team separately, excluded from customer files, to avoid inadvertent or inappropriate disclosure.

4. Training

WajeTech has a high commitment to compliance, and all employees and contractors are required to complete mandatory compliance training, including provisions on anti-money laundering, on an annual basis.

Job-specific and comprehensive anti-money laundering training should be provided to the relevant employees to help recognize and deal with transactions which may lead to money laundering or terrorist financing.

5. Policy Review and Audits

Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by the WajeTech Internal Audit function. This provides Executive Management and the Board Audit Committee with the necessary assurances and information regarding the operating effectiveness of Waje Technologies Limited's controls and processes relating to this Policy.

1. Introduction

At Waje Technologies Limited ("We," "Our," or "Us"), we are committed to protecting the personal data of our clients, prospects, employees, vendors, and website users. This Privacy Policy explains the types of personal information we collect, how we use and safeguard it, and the choices you have regarding your data.

In line with our commitment and compliance with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019, we have developed this Privacy Policy to outline how personal information is collected, used, disclosed, retained, and protected by Waje Technologies Limited.

2. Definition of Terms and Keywords

• Company, "we", "us" or "our" refers to Waje Technologies Limited (WajeTech), responsible for the protection of Data under this Privacy Policy.
• Cookies refers to small data files stored on a user's browser by a website to remember preferences, provide analytics, and personalize content.
• Data Subject means an identifiable person to whom Personal Data relates.
• Personal Data means any information relating to an identified or identifiable natural person, directly or indirectly.
• Client refers to the company, organization, or person that engages WajeTech products/services or uses our website to interact with us.
• IP address is the numerical label assigned to each device connected to the Internet which may identify the approximate location of the device.
• Device means any internet-connected equipment (e.g., phone, tablet, computer) used to access the WajeTech website or services.
• Personnel or Reps refers to individuals employed by or under contract with WajeTech to perform services on our behalf.
• Service(s) refers to one or more services provided by WajeTech as described on our website and in the relevant terms.
• Website means our site accessible via: WajeTech.com

3. Consent

By using our website, submitting forms, registering an account, engaging our services, or communicating with us, you consent to this Privacy Policy and agree that we may collect, process, store, and disclose your Personal Data in accordance with it. Where required by law, we will seek your explicit consent before processing certain categories of data.

You may withdraw consent at any time where consent is the legal basis for processing; however, withdrawal will not affect the lawfulness of processing prior to withdrawal.

4. What Data Do We Collect?

• Identity & Contact: name, title, company, email address, phone number, postal address.
• Usage & Technical: IP address, device information, browser type, pages visited, referral sources, interaction timestamps.
• Communications: inquiries, support chats, emails, meeting notes.
• Marketing: newsletter preferences, event registrations, campaign interactions.
• Recruitment (where applicable): CV/resume data, qualifications, references, background checks subject to applicable laws and consent.

We may also collect data through:

• Engagement on social media platforms (LinkedIn, X/Twitter, Facebook, Instagram).
• Newsletter subscriptions and event sign-ups.
• Third-party service providers or partners in the course of delivering services to you.
• Job applications, contact forms, and surveys with express consent where required.

5. What We Do With Processed Data

We process Personal Data for the following purposes and lawful bases (such as consent, contract, legal obligation, or legitimate interests):

• Service delivery, account administration, and customer support.
• Internal record keeping and audit/compliance requirements.
• Improving our website, services, security, and user experience.
• Sending service communications and, with consent where required, marketing messages about products or events.
• Recruitment assessments, background checks, and workforce administration.

6. How Do We Collect Data?

Direct collection:

• Evaluation and enquiry forms
• Digital touchpoints on our website and portals
• Email and phone conversations
• Live chats and support tickets

Third-party data collection: Information provided by our clients, partners, recruiters, and service providers for the purpose of conducting our business and delivering services, subject to appropriate legal bases and safeguards.

7. International Data Transfers

Information collected via our website or through interactions with us may be transferred to our offices, personnel, or trusted third parties globally. By using our services, you consent to such cross-border transfers and hosting. Where required, we implement appropriate safeguards to protect your data during transfer.

8. Affiliates

We may disclose information about you to our Corporate Affiliates (entities that control, are controlled by, or are under common control with WajeTech). Any Personal Data shared will be handled in accordance with this Privacy Policy.

9. Cookies & Similar Technologies

We use cookies and similar technologies to recognize your device, improve website performance, remember preferences, and analyze traffic patterns. You can control cookies through your browser settings; however, disabling cookies may affect site functionality.

10. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes set out in this Privacy Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Unless a longer period is required by law, we generally retain Personal Data for up to five (5) years after the end of our relationship with you.

11. Your Rights as a Data Subject

Subject to applicable law, your rights include:

• Access: to know if we process your data and to receive a copy.
• Rectification: to correct inaccurate or incomplete data.
• Erasure: to request deletion under certain conditions.
• Restriction: to request limited processing in certain cases.
• Portability: to request transfer of data where technically feasible.
• Objection: to processing based on legitimate interests and to direct marketing.

To exercise your rights, please contact us using the details in Section 16. We may request verification of your identity before responding.

12. How We Protect Your Personal Data

We implement technical, organizational, and administrative safeguards designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. These measures include access controls, encryption where appropriate, secure networks, and staff training. However, no system is completely secure; while we strive to protect your information, we cannot guarantee absolute security.

13. Remedies for Breach and Timeframe for Remedy

If a breach affecting Personal Data occurs, our Data Protection Officer (DPO) will investigate and take appropriate remedial action. We aim to redress breaches within seven (7) days and, where required by law, notify affected Data Subjects and regulators without undue delay.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Updates will be posted on this page. Continued use of our services after changes become effective constitutes your acceptance of the updated Policy.

15. Governing Law

This Privacy Policy is governed by the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019. You consent to the exclusive jurisdiction of the competent courts in connection with any dispute arising from or relating to this Privacy Policy.

16. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or how we handle your Personal Data, please reach out via the contact page below:

Contact Us