Consumer Code
of Practice.

Mindray Technologies Limited (the Company) is a duly licensed Value-Added Service (VAS) Provider by the Nigerian Communications Commission (NCC).

The Company provides SMS/MMS-based services, including alerts, notifications, subscriptions and information dissemination to consumers, and IVR (Interactive Voice Response) and USSD-based services that provide interactive content delivery and user engagement through mobile networks.

In fulfilment of the conditions of our VAS License and in full compliance with the Nigerian Communications (Consumer Code of Practice) Regulations, 2024 (the Regulations), the Company hereby establishes this Individual Consumer Code of Practice (ICCP) for Compensation for Loss of Service and Downtime Mitigation.

This Code demonstrates our commitment to delivering reliable, high-quality VAS, including SMS management solutions, information/directory services, mobile financial integrations and custom applications to individual consumers across Nigeria. It outlines the Company's obligations regarding service quality, downtime mitigation, consumer notification during outages and fair compensation for qualifying service disruptions.

The Company operates in partnership with licensed Mobile Network Operators (MNOs) and NCC-approved VAS Aggregators, and remains fully committed to upholding the highest standards of consumer protection as mandated by the Nigerian Communications Act, 2003 and the NCC Consumer Code of Practice Regulations, 2024.

This ICCP shall be submitted to the Commission for review and shall be reviewed annually or upon any material changes in our operations or regulatory requirements.

The Company shall supply, or make available on request, a copy of the contract or agreement for the provision of services. Such contracts shall be written in plain and clear language and must clearly specify the duration.

The Company shall provide consumers with clear instructions on the medium and procedure for subscribing to a service.

Contracts with consumers shall include standard provisions covering commencement dates, minimum contract terms, renewal, termination conditions, early termination consequences and applicable penalties, where relevant.

The Company shall inform consumers that it is their right to opt in or opt out if the need arises.

The Company shall clearly disclose any geographical or technical limitations that may materially affect service availability or performance and that are known at the time of service promotion.

Where the Company states in advertising materials that a service is provided as part of a package, the Company shall ensure it is able to supply all components of the service package. In the event that the Company is or may be unable to supply any component of the package, appropriate information about this limitation shall be included in the advertising materials.

Where advertising materials indicate the price of a component of a service package, the Company 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.

All advertisements and promotional materials relating to the Company's services shall be clear, accurate and not misleading, in accordance with the Advertising Regulatory Council of Nigeria and other applicable laws. Any disclaimer included in the Company's advertisements shall be clear, understandable and written in plain language. Disclaimers shall not negate or undermine the principal message or purpose of the advertisement. The Company will ensure the intended consumer or recipient of the advertisement will be clearly specified.

The Company shall ensure that all telemarketing activities are conducted in a fair, transparent and responsible manner in accordance with applicable laws. Consumers shall not be contacted for marketing purposes without their prior consent or where they have opted out or registered on any applicable Do Not Disturb (DND) facility.

The Company operates a customer service desk which is reachable during working hours from 8:00 am to 5:00 pm and outside working hours via email. All consumers can contact the help desk using the telephone, email and address below.

The Company shall ensure it embeds the following information in its packages to assist clients when contacting Mindray for resolution of complaints: Before you contact our support desk, please make sure that you have details of the transaction initiated, your mobile number and a summary of the complaint. This will enable us to process and resolve your complaints quickly.

If the complaining customer remains dissatisfied with the outcome or resolution of the complaint, they have the right to refer the complaint to the Nigerian Communications Commission (NCC).

The Company shall maintain appropriate systems for recording all complaints received and their outcomes. Such records shall be properly categorised and analysed to identify recurring issues and areas requiring service improvement. The Company shall inform consumers that records of complaints are maintained and, upon request, provide a clear description of the complaint tracking system in use.

Any information collected and recorded as part of complaint handling processes shall be retained for at least twenty-four (24) months following the resolution of complaints or as directed by NCC from time to time.

The Company will take all necessary steps to prevent unsolicited messages and will adhere to all guidelines set by the Nigerian Communications Commission regarding unsolicited messages, including but not limited to the Do Not Disturb (D-N-D) policy.

Consumers shall provide true and complete details when registering for the services provided by the Company and update them when the need arises. Consumers shall also use the services only for legal purposes and settle invoices within the agreed timelines under the service contract.

The Company shall collect consumer information only for specified, legitimate and service-related purposes, and shall do so in a lawful, fair and transparent manner in accordance with applicable laws and its Protection of Consumer Information requirements. Consumers shall be informed of the purpose of data collection at the point of collection and, where required, their consent shall be obtained. The Company will not collect excessive or irrelevant information beyond what is necessary for the provision of services.

The Company shall implement appropriate technical and organisational measures to safeguard consumer information against unauthorised access, loss, misuse or disclosure. Consumer information shall be retained only for as long as necessary to fulfil the purpose for which it was collected or as required by applicable laws and regulations. The Company shall also ensure secure disposal or anonymisation of data when it is no longer required, in compliance with applicable laws.

The Company shall ensure that consumer information is kept confidential and shall not be disclosed to any third party except with the prior consent of the consumer, where necessary for the provision of services, or where required by law or a competent regulatory authority. In all such cases, the Company shall ensure that adequate safeguards are in place.

The Company shall ensure that all bills issued include, at a minimum:

• Operator billing name and address: Mindray Technologies Limited, Plot 8 Providence Street, Lekki Phase 1, Lagos State.
• Unique bill reference identifiers.
• Description of charges.
• Billing period.
• Total amount billed and net amount payable.
• Bill issuance date and bill due date.
• Method of contact for complaints and billing inquiries.
• Accepted payment methods.

The Company shall process and issue a bill within 10 days of the end of each billing period and shall include all charges incurred during that period, except where there is a separate agreement with the consumer or a valid reason for delay such as the need to include information from other suppliers, system errors that require correction, consumer-initiated changes to billing frequency, disputed charges, or circumstances beyond the VAS provider's control, including force majeure. In such cases, the Company shall promptly take steps to resolve the delay and issue the bill without further undue delay.

The Company shall ensure that consumers are able to verify their bill payment by acknowledgement of payment on the next bill issued, with such appropriate and accessible methods as may be made available by the Company.

The Company shall provide consumers with advance written notification of any proposed changes in billing before any such changes are implemented via any channel over which the Company's services are offered. Such advance notification shall be at most equal to two of its applicable billing periods of a minimum of 60 days. Consumers shall be informed in all such notifications of how to opt out of the service to avoid experiencing the proposed changes in billing.

The Company shall ensure that all prepaid services are provided in a transparent and consumer-friendly manner. Consumers should be clearly informed of all applicable charges, validity periods, renewal terms and any conditions attached to the service before subscription. No deductions shall be made without the consumer's prior consent, and consumers shall have access to simple and cost-free mechanisms to opt in or opt out of services. The Company shall also ensure that consumers can easily access information on their balances and usage and shall not unfairly forfeit any valid prepaid value except in accordance with disclosed terms and applicable regulations.