The Code of Conduct is a collection of rules and principles intended to assist employees and directors in making decisions about their conduct in relation to the firm’s business. The Code is based on the fundamental understanding that we are all responsible for conducting business ethically and in compliance with the law everywhere we operate. No one should ever sacrifice integrity — or give the impression that they have — even if they think it would help the firm’s business.

OBJECTIVE

The purpose of the Code is to set acceptable standards of conduct aimed at ensuring a high standard of service and the highest possible level of satisfaction for customers who have received or plan to receive digital loans under consumer credit. The Code is based on the principles of fair business practice, professional integrity, consumer protection, acting in good faith and in accordance with the best knowledge, experience and responsible lending.

THE PHILOSOPHY

The basic principles followed by directors and employees who are deeply committed to being ethical, accountable and honest in all business dealings across the globe.

The Code of Conduct represents our shared obligation to operate with the highest level of integrity and ethical conduct. We do the right thing — even when it’s not expedient. We abide by the letter and spirit of the laws and regulations everywhere we do business and have zero tolerance for unethical behavior. Personal accountability and ownership are priorities at our firm.

The basic principles followed include:

• Consumer Protection
• Acting in good faith towards both Consumers, employees as well as business partners
• Acting in accordance with business ethics, respecting other participants of the digital loan services market
• Providing services in an innovative manner while respecting the market practices and social norms
• Granting digital loans to Consumers in a safe, transparent and convenient way
• Providing Consumers with complete, honest, understandable and unambiguous information about the cost of the digital loan, including interest and the total amount to be refunded, as well as information about the repayment date along with the repayment schedule, as well as the consequences of late payment or lack thereof
• Conducting, when necessary, educational activity in the area of personal finances emphasizing that the digital loans taken should be spent on improving the quality of life of the borrower or speeding up the realization of consumer goals that otherwise would be unachievable and which would not be achieved without further inconvenience or loss
• Addressing and combating attitudes suggesting that short-term credit commitments can be an effective way to deal with long-term financial problems

OUR RESPONSIBILITIES

• Gbowy Capital and Investment Services Limited commit to apply good market practices, industry customs and other commonly used industry guidelines, as long as they do not conflict with legal provisions and implement the principles of responsible lending and professional trading in the consumer credit market
• Gbowy Capital and Investment Services Limited will conduct their activities in accordance with the law, complying with the regulations governing their functioning, established jurisprudence, as well as binding decisions, instructions and guidelines of supervisory institutions and any other regulator in the Financial Services Sector in Nigeria
• Gbowy Capital and Investment Services Limited during each activity related to the conclusion and performance of a digital loan agreement, provide comprehensive information on the rights and obligations of the Consumer, so as to enable him to make a conscious and unhampered decision regarding incurring and fulfilling the obligation
• Gbowy Capital and Investment Services Limited undertake to provide appropriate training to employees and subcontractors so that employees, subcontractors and other representatives in the business know and apply the provisions of this Code

RULES FOR GRANTING AND REPAYING DIGITAL LOANS

1. In order to ensure that the proposed digital loan corresponds to the Consumer's financial capabilities and to prevent the Consumer from incurring excessive financial obligations, Gbowy Capital and Investment Services Limited will use their best knowledge and experience and solutions available on the market to evaluate Consumer’s ability to meet their obligations with the repayment of the digital loan.

2. Gbowy Capital and Investment Services Limited will ensure Consumers have access to clear pricing and are empowered to make informed decisions on the loan product that best meets his or her needs. Gbowy Capital and Investment Services Limited will separate key terms such as principle, interest, fees, tenure and other items into separate line items. Gbowy Capital and Investment Services Limited should include visual representations (such as calendars) to indicate due date(s) for payment, when past-due periods begin and other key timelines.

3. Gbowy Capital and Investment Services Limited should will include explicit Terms & Conditions in multiple locations including in the application store and the application itself for the users to access before borrowing and the Terms and Conditions requires the customers to verify that they have read the terms and conditions before applying for a loan.

4. Gbowy Capital and Investment Services Limited ensures that information about refusal to offer a digital loan is communicated to Consumers in a professional manner.

5. Gbowy Capital and Investment Services Limited will may grant another loan to a Consumer who has not fully paid the previous liability, if the analysis of his financial situation indicates that he has the appropriate creditworthiness.

6. When assessing the creditworthiness of a potential Consumer, Gbowy Capital and Investment Services Limited is obliged to make efforts to determine his/her actual financial situation, also based on data from external databases.

7. Gbowy Capital and Investment Services Limited take care to ensure the highest quality of contracts is concluded with Consumers, in particular their compliance with the provisions of the current applicable law, in particular they pay special attention to their content, and the volume did not affect transparency and legibility for the average recipient.

8. Gbowy Capital and Investment Services Limited explains to the Consumer how and through which channels of communication they can contact the Gbowy Capital and Investment Services Limited, and indicate how and through what means Gbowy Capital and Investment Services Limited will contact the Consumer.

9. Consumers are able to obtain information from Gbowy Capital and Investment Services Limited at any time about the amount of the obligation, its components and loan repayment schedule.

10. Gbowy Capital and Investment Services Limited support Consumers in the amicable settlement of overdue liabilities. In the event of a change in the repayment schedule of the overdue loan, every effort is made to ensure that it responds to the Consumer's financial situation and capabilities. Gbowy Capital and Investment Services Limited provide support to Consumers in the event of an application to change the digital loan schedule or restructuring and provide complete and clear information on the risks and costs associated with such a change.

CONSUMER PROTECTION

Gbowy Capital and Investment Services Limited guiding principles:

1. Presenting clear offers to Consumers;
2. Avoidance of use of advertising means and methods as well as other financial or insurance products aimed at forcing Consumers to conclude digital loan agreements;
3. Providing pre-contractual information and content of contracts on dates that allow Consumers to get acquainted with all their terms freely;
4. Providing information in a non-misleading way;
5. Providing reliable information, explanations and assistance to Consumers at the stage of applying for a digital loan;
6. Conclusion of contracts in accordance with the relevant regulations in force at the date of signing the contract;
7. Transparent, correct and full presentation of digital loan costs to Consumers;
8. Informing Consumers about obligations related to borrowing.

Gbowy Capital and Investment Services Limited undertake to:

1. Keep all information about the Consumer confidential, except in cases where the law allows or obliges the Institution to disclose such information to authorized institutions under the law;
2. Provide security measures necessary to process and store the Consumer's personal data with full confidentiality and in accordance with applicable law;
3. Ensure the transfer of Consumer's personal data only to authorized entities;
4. Provide the Consumer with the information necessary to make a decision on borrowing;
5. Provide the Consumer with clear and unambiguous information on the total cost of the digital loan, the method of repayment of the digital loan, as well as the consequences resulting from a possible failure to fulfill obligations under the digital loan agreement;
6. At the Consumer's request, provide explanations regarding the provisions contained in the digital loan agreement and other information that will be provided to the Consumer (including information about payments made by the Consumer);
7. Inform the Consumer about the law, consequences and time limit for withdrawing from the digital loan agreement;
8. Implement procedures and systems aimed at preventing fraud.

ADVERTISING AND MARKETING

Gbowy Capital and Investment Services Limited ensures that the digital loan offers and marketing activities advertised meet the accepted market standards and emphasize the readability and quality of the advertising message. Advertising messages does not contain terms and expressions that could mislead the Consumer, regardless of the form of communication (written, verbal and / or pictorial).

COOPERATION WITH INTERMEDIARIES

Gbowy Capital and Investment Services Limited is obliged to establish cooperation only with such intermediaries where the intermediaries can guarantee that:

• They are guided by the good of the Consumers, respect for the obligations arising from honesty, dignity and decency, perform professional activities according to the best knowledge, in a reliable manner and with due diligence.
• They do not charge and do not collect from the Consumers an additional commission on digital loans in which they mediate.
• The information they provide and advertising are objective, reliable and balanced, in accordance with ethical standards, morality and compliance with applicable laws.
• All facts, data and information received from Consumers will be kept confidential except in the cases provided for in separate acts.

Gbowy Capital and Investment Services Limited is obliged to establish cooperation with online affiliate networks and publishers, which:

• Adhere to good market practices, and in particular do not use methods aimed at extorting commissions, e.g. cookie stuffing (consisting in sending cookies, without actually redirecting to the advertiser's website).
• Do not mislead the Consumer, in particular as to the advertised functionality of products and services.

DEBT COLLECTION

If the Consumer's debt goes into arrears, Gbowy Capital and Investment Services Limited will strive for an amicable resolution of the case and should first propose measures and methods of payment that will allow the repayment of outstanding liabilities in the least inconvenient manner for the Consumer.

When taking action against a Consumer whose claims are in a debt collection procedure or in court proceedings, it must be ensured that the actions taken against the debtor meet ethical standards and are aimed at cooperation and an amicable solution to the problem of non-repayment.

Gbowy Capital and Investment Services Limited places information on its website that a borrower who may have a problem with the repayment of obligations on time should immediately notify Gbowy Capital and Investment Services Limited. Gbowy Capital and Investment Services Limited indicates the communication channel necessary to carry out such notification.

If the Consumer is late with the repayment of the digital loan, Gbowy Capital and Investment Services Limited contacts him in order to determine the reason for the delay and to indicate possible solutions.

Gbowy Capital and Investment Services Limited while choosing debt collection providers are guided by their best knowledge and professionalism in the market, taking into account that debt collection activities should be conducted in accordance with the standards and customs of this market.

Gbowy Capital and Investment Services Limited supervises the activities of external providers of debt collection services and investigates reported cases of infringement of Consumers' rights as a result of debt collection activities.