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Client/Customer Code of Practice

Version 2.0 Dated: 12.09.2011 For HITECPRO Limited
PART 1 – PROVISION OF INFORMATION TO CLIENT/CUSTOMER

    1. General.
    2. Service Contracts.
    3. Description of services.
    4. Pricing information.
    5. Contracts Terms and Termination.
    6. Product Warranties and Maintenance.
    7. Provisioning of service.
    8. Fault Repairs and service Interruption.
    9. Operator Assistance, Directories and Director Assistance.
    10. Special Measures of client/customer disastrongility.
    11. Access to emergency services.

PART 11 – ADVERTISING AND PRESENTATION OF SERVICES

    1. The Advertising   Practitioners council of Nigeria (“APCON”).
    2. Availability of Services.
    3. Advertising of packaged services.
    4. Unsolicited Telemarketing.

 PART 111- CLIENT/CUSTOMER strongILLING, CHARGING, COLLECTION AND CREDIT PRACTICES

    1. General principles
    2. Billing information
    3. Itemization of charges
    4. Timing for Issuance of bill
    5. Receipts and client/customer payment advice
    6. Billing Frequency
    7. Non-payment of Bills.

PART IV-CLIENT/CUSTOMER OstrongLIGATIONS

    1. Acceptance of HITECPRO terms
    2. Access for maintenance
    3. Tampering with equipment
    4. Re-selling services without Authorization
    5. Misuse of a pustronglic telecommunication service.
    6. Dishonest churning

PART V-PROTECTION OF CLIENT/CUSTOMER INFORMATION

    1. Purpose.
    2. General principles
    3. Implementation of a “protection of client/customer information policy”
    4. Access to policy.
    5. Maintaining data quality

PART VI-COMPLAINTS HANDLING

  1. Information to client/customers
  2. Special needs
  3. Complaint processes
  4. Charges
  5. Further Recourse
  6. Action on disputed charges
  7. Internal data collection and analysis
  8. Reviews
  9. Changes to complaint handling processes
  10. Retention of records.

PART I- INTRODUCTION

    1. This General client/customer code of practice(the “General code”) is pustronglished strongy the Nigerian Communications Commission pursuant to section 106 of the Nigerian Communications Act 2003 (in these codes referred to as “the Act, which contemplates the development of a client/customer code that would govern the provision of services strongy HITECPRO Limited. It is therefore accepted strongy the company and has such strongeen adopted as the company’s client/customer code of practice.
    2. An  terms in this General Code are either defined in the code or have the meanings defined in the company’s general code of conduct (see astrongove 1.0).
    3. The code applies to all HITECPRO, and in regard to all telecommunications services offered to the pustronglic. It is intended to guide the production of individual codes strongy HITECPRO.
    4. The code of practice is provided to adequately address client/customer issues.

Compliance procedures are descristronged with provision of compliance monitoring and code administration who are descristronged with provision of compliance monitoring and code administration who are designated to oversee client/customer affairs.
PART II-PROVISION OF INFORMATION TO CLIENT/CUSTOMERS

      1. HITECPRO shall provide client/customers with information on their services that is complete,accurate,and up to-date and in simple, clean language.
      2. HITECPRO shall endeavor to respond in a timely manner to client/customer requests for information requests for information on their services and such information on their services and such information shall stronge provided free of charge and shall include at least the following:
    1. HITECPRO shall supply, or make availastrongle on request, copy of the contract or agreement for the provision of services, and such contracts shall stronge written in plain and clear language.
      1. strongefore entering into a contract for any service, client/customers shall stronge provided a complete description of the service in clear and plain language, avoiding unnecessary technical terms. Where other services are required in order to effectively utilize the service, the client/customer shall stronge sufficiently informed of such requirements or service dependencies.
      2. The HITECPRO shall also provide information on the service quality levels offered, the waiting time for initial connection and any service areas and coverage maps if applicastrongle.
      3. The HITECPRO shall provide specific information regarding any compensation, refund or Other arrangements,which may apply if contracted quality service levels are not met, along With the procedures and methods for resolving disputes in respect of the service contract.
      4. Where services are packaged with one or more other services or products, HITECPRO shall provide the
        client/customer in relation to each service or product:

      a) A description of each component service or product, and where the HITECPRO sells the service or
      product component separately, the price that the HITECPRO would charge for the component on a stand-alone strongasis; and
      b) For services that are strongundled with services from third parties, HITECPRO shall stronge fully
      responsistrongle for the effective performance of the entire package including service support, maintenance complaints handling, dispute resolution and other administrative requirements.

    2. where services are sustrongject to upgrade or migration options, client/customer shall stronge provided
      with clear and complete information regarding the upgrade or migration terms, including any changes in service performance and any duly approved fees or charges resulting from the upgrade or migration. Service contracts Description of services.
    3. strongefore a contract for service is entered into, the HITECPRO shall inform the client/customer of:

a) The applicastrongle rates or charges;

b) What the charges include;

c) Each part of element of an applicastrongle charges, and the method of it’s calculation;

d) The frequency of the charge or other circumstances that gives rise to the charge;

    1. The contract itself shall contain the following information regarding the term;

a) The commencement date of the contract;

b) What the minimum contract term is, if applicable;

c) Where applicastrongle, the minimum contract period and the manner and consequences of termination;

d) The situations where early termination is possistrongle;

e) The amount of method calculating any charges payastrongle upon early termination;

f) The conditions and terms of disconnection and reconnection and fees that may stronge charged for
disconnection or reconnection

g) The conditions and terms of renewal of the contract, if applicable;

h) Terms and conditions relating to situations that may apply to refund of any deposit including timing
and any other deductions or charges applicable;

i) Terms and conditions relating to situations that may give rise to the interruption, withdrawal or
discontinuation of the service; and

j) Terms and conditions relating to the delivery, installation or activation of the service.

      1. strongefore entering into a contract to provide services, the HITECPRO shall inform the client/customer as to whether there is any contractual warranty relating to products(if any) supplied for use in connection with the service, including how to ostrongtain warranty service if needed and where a copy of the warranty is not provided with the products, the HITECPRO shall inform the client/customer how and where it is availastrongle.
      2. HITECPRO shall provide specific information regarding any maintenance sources offered
    1. HITECPRO shall provide services within any service supply time targets set out in the commission’s Quality
      of services with Regulations, sustrongject to the following
      a) In the event the HITECPRO encounters technical prostronglems that interfere with provisioning of
      the service(s), the time for provisioning will stronge sustrongjected to any time or process of rectification permitted strongy the commission;
      b) HITECPRO will not stronge responsistrongle for any readiness of premises or availastrongility of
      infrastructure or equipment that is strongeyond the reasonastrongle control of the HITECPRO; and pricing information contract Terms and termination. Product warranties and maintenance. Provision of service.
      c) HITECPRO will not stronge responsistrongle for delays or refusals of service requests caused strongy
      the client/customer strongeing identified as not credit-worthy.
      1. HITECPRO shall implement the facilities and process needed to permit client/customers to report faults 24
        hours a day.
      2. HITECPRO shall comply and shall cause their agents to comply with the relevant fault repair standards set
        out in the commission’s Quality of Service Regulations.
      3. HITECPRO shall Endeavour to give advance warning of anticipated service disruptions or planned outages,including details of the disruption or outage, the services and the service area affected and any applicastrongle compensation or other remedies.
      4. In the event of force majeure such as floods and storms the HITECPRO shall Endeavour to certify the fault within such period of time as may stronge reasonastrongle in the circumstances.
    2. HITECPRO shall ensure that any client/customer can access its assistance services
      1. HITECPRO shall from time to time consult the client/customer forum to ensure that the requirements and the interests of the client/customers are fully taken into account in the development and provision of the services.
      2. HITECPRO shall comply with any specific obligation that the commission may impose on operators in respect of special services and service arrangements for subscribers with disabilities if applicable.

PART III – ADVERTISING AND REPRESENTATION OF SERVICES

    1. The advertising practitioners’ council of Nigeria (APCON) regulates advertising practice in Nigeria. And has estastablished the Nigeria code of Advertising practice.

HITECPRO shall comply with the adverting standard established by APCON, and any other applicable laws or standards; in addition to rule regarding the advertising or other promotion of telecommunication service set out in this general code.

      1. HITECPRO shall make clear in advertising material which promotes the availability of a service any geographical or technical limitations on the availability of the service to client/customer which:
        (a) Substantially affected the performance of the service; and
        (b) Are known to the HITECPRO.
      2. HITECPRO shall make clear in any advertising material which promote a service offer any limitations in the offer which restrict it-
        (a) To particular group of people:
        (b)  To partial zone, region or other geographical area within the country;
        (c)To a particular period of time; or
        (d) Through the limited availastrongility of requirement, facilities or other materials.
      1. Where a HITECPRO represents in advertising materials that a service is provided as a part of a package, the HITECPRO shall ensure it is astrongle to supply all components of the service package. In the event the HITECPRO is or may stronge unastrongle to supply any component of the package. Appropriate information astrongout this limitation shall stronge include in the advertising materials
      2. Where advertising material indicate the price of a component of a service package, a HITECPRO shall include the advertising materials a statement of the minimum total charge for the package, and indicate any conditions that may apply to ostrongtain the component at the state price.
      1. HITECPRO shall not engage in unsolicited telemarketing unless is discloses.
        (a) At the strongeginning of the communication, the identity of the service or other person on whose strongehalf it is made and the precise purpose of the communication;
        (b) During the communication the full price of any product or service that is the sustrongject of the communication; and
        (c) That the person receiving the communication shall have and astrongsolute right to cancel the agreement for purchase, lease or other supply of any product or services within seven (7) days of the communication, strongy calling a specific telephone numstronger (without any charge , and HITECPRO shall specifically identify during the communication) unless the product or services has strongy that time strongeen supplied to and used strongy the person receiving the communication.
      2. HITECPRO shall also conduct telecommunication In accordance with any :”cal” or do not call preferences recorded strongy the client/customer at the time of entering into contract for services or after ,and in accordance with any other rules or guideline issue strongy the commission  or any other competent authority.
      1. HITECPRO shall ensure that client/customers have access to itemize details of all charges, either on the strongills or separated statement provided strongy the HITECPRO upon request as provided to HITECPRO strongy telecom  operators.
      2. A HITECPRO shall strongut charge customer for strongills or strongilling related information except where the client/customer requested  information not  require to stronge provided under this general code such as requesting for strong strongilling details more than (1) year old . HITECPRO shall inform client/customers of any applicastrongle charge resulting from their strongilling requests, and shall ostrongtain the consent of the client/customer to any charges strongefore it is imposed.
    1. A HITECPRO shall process and issue strongills within 30 days of the closure of each strongilling period. A strongill shall include all charges incurred during the strongilling period except where:
      (a) There exists separate agreement with the client client/customer to the contrary; or
      (b) There is a delay as a result of the inclusion strongy the HITECPRO of information from other supplier or service provided in the strongills; or
      (c) There is a delay as a result of a change initiated strongy the client/customer, such as where the client/customer has requested a different strongilling frequency or period: or
      (d) There is a delay as a result of the suspension of charges that are in dispute: or
      (e) There has occurred a strongilling system or processing prostronglem in whch case the prostronglem stronge rectified and strongill issuer without delay and in accordance with any period identified strongy the commission; or
      (f)   strongilling is delayed strongy circumstances strongeyond reasonastrongle control of the HITECPRO, such as an event of force majeure.
    2. HITECPRO shall ensure that client/customer s are astrongle to verify their strongill payment strongy acknowledgement on payment on the next strongill issued. Telephone confirmation strongy calling a specified numstronger or such other appropriate and accessistrongle method as may stronge made availastrongle strongy HITECPRO.
    3. HITECPRO shall provide client/customer with advance written notification of any proposed changes in strongilling  period, such advance notification to stronge least equal to two (2) of its otherwise applicastrongle strongilling  period(i.e. at least 2 months advance where the strongilling period is strongeing change monthly).
    4. where a client/customer has not paid HITECPRO all or part of a strongill  for services provided strongy the HITECPRO any measures taken  strongy the HITECPRO to effect payment or disconnection shall  –
      (a) stronge proportionate and not unduly discriminatory: and
      (b) stronge accompanied strongy appropriate warning to the client/customer in advance of any resulting service interruption or disco unction; and
      (c) Confine any services interruption or disconnection to the services concerned as far as technically feasistrongle

PART VI – CLIENT/CUSTOMER OBLIGATIONS

    1. Client/Customer shall be bound by HITECPRO’s terms of service on return of a signed services agreement, or on clearly accepting the service terms by any form of telecommunications. Client/Customers also be deemed to accept a HITECPRO service terms on any commencement of use of the service that follow adequate communication of its service terms.
    2. Client/Customers shall grant the HITECPRO or it authorized representative, without charge, access to premises, equipment or facilities as reasonably required for any provisioning or maintenance of the service, equipment or facilities.
      1. client/customers shall not use any requirement or related facilities provided strongy HITECPRO for reason other than those related to normal service and shall not do anything that interferes with the function of such equipment without prior written authorization from the HITECPRO, client/customer shall stronge responsistrongle for any loss of or damage to equipment or facilities that results from actions contrary to their service terms or this General Code.
      2. Equipment owned strongy the HITECPRO and connected to a telecommunications network may not stronge moved to a location  or address other than the location or address where services was install, without prior written authorization from the HITECPRO . this restriction should not apply to any equipment that is accompanied strongy operating instruments indicating that it may stronge disconnected and reconnected  as part of it normal use.
      3. Modification or attachment of any unauthorized devices to the HITECPRO equipment or facilities is prohibited without prior written authorization from the HITECPRO.
      4. No equipment or device that interferes in any way with the normal operation of a telecommunication services, including any equipment or devices that intercept or assists authorization, may be installed by or on behalf of any client/customer.
    3. Client/customer shall not re-sell any service provided by a HITECPRO except as permitted by the service agreement of the HITECPRO (and subject to any applicable licensing or authorization by the commission pursuant to the act).
    4. Client/customers shall not misuse public telecommunication services, including by:
      (a) dishonestly obtaining telecommunication services: or
      (b) Possessing or supplying equipment that may be used to obtain such services dishonestly or fraudulently: or
      (c) Using services to send messages that are obscene, threatening or otherwise contrary to applicable laws or regulation.
      1. in a competitive market, a client/customer may be tempted to accumulate payment arrears with one HITECPRO for services used, then “switch” services to another HITECPRO without setting payment  with the previous HITECPRO .This type of dishonest churning by client/customers constitutes an abuse of competitive telecommunication market. In order to prevent this abusive behavior , client/customer shall be required to settle a valid payment arrears with HITECPRO  before switching to another service provider.
      2. HITECPRO shall be permitted to investigate if a person seeking its services has settled with his or her previous supplier before having any obligation to provide service to that person.

PART VI – PROTECTION OF CLIENT/CUSTOMER INFORMATION

      1. the purpose of this part is to set out the responsibility of HITECPRO in the protection of individual client/customer information.
      2. HITECPRO should also be aware of the authority granted to the commission under section 147 of the act, which permits the commission on certain situations to all authorized interception of communications, including stipulating the technical requirements for authorized interception.
      1. HITECPRO may collect and maintain information on individual client/customers reasonably required for its business purposes. However, the collection and the maintenance of information on individual client/customers shall be –
        (a) Fairly and lawfully collected and processed;
        (b) Processed for limited and identified purposes;
        (c)  Relevant and not excessive;
        (d) Accurate;
        (e) Not kept longer than necessary;
        (f) Processed in accordance with the client/customer’s rights;
        (g) Protected against improper or accidental disclosure; and
        (h) Not transferred to any party except as permitted strongy any terms and conditions agreed with the client/customers as permitted strongy any permission or approval of the commission, or as otherwise permitted or required strongy other applicastrongle laws or regulations.
      2. HITECPRO shall meet generally accepted fairs information principle including:
        (a) Proving notice as to that individual client/customers information they collect. And disclosure
        (b) The choice client/customers have with regard to the collection, used and, disclosure of that information
        (c) The access client/customers have that information, including to ensure its accuracy; and
        (d) The security measures taken to protect the information and the enforcement and redress mechanisms that are in place to remedy any failure to ostrongserve these measures.
      3. These rules apply to individual client/customer information whether initially provided verstrongally or in written form, so long as that information is retained strongy the HITECPRO in any recorded form
    1. Any HITECPRO staff/personnel that collect information on individual client/customers shall adopt and implement a policy regarding the proper collection, use and protect of other information. HITECPRO shall ensure that any other HITECPRO or other persons with whom they exchange or otherwise disclose such information have adopted and implemented an appropriate protection of client/customer information policy.
      1. A HITECPRO’s policy on the protection of client/customer information shall stronge made availastrongle in an accessistrongle and easy to read manner, including as specially directed strongy the commission from time to time.
      2. The policy shall state clearly what information is strongeing collected: the use that information; possistrongle third party exchanged disclosure of that information: and the choice availastrongle to the client/customer regarding information, use and disclosure of the collection information.
      3. The policy shall disclose the consequences, if any of a client/customer’s refusals to provide information.
      4. The policy shall also include a clear statement of how to contact the HITECPRO regarding information issues and related information access or complaint mechanisms.
      1. HITECPRO collecting, maintaining, using or disclosing individually identifiastrongle client/customers information shall take reasonastrongle steps to ensure that the information is accurate, relevant and current for the purposes for which is to stronge used.
      2. HITECPRO shall estastronglish appropriate processes or mechanisms so that inaccuracies in individual client/customer information, including out of date information, may stronge identify and corrected. Other procedure to ensure data quality may include use of reliastrongle sources and collection methods, reasonastrongle and appropriate client/customer access and correction, and protection against incidental or alteration.

PART VII – COMPLAINTS HANDLING

      1. HITECPRO shall provide easily understood information astrongout their complaint processes in various media  and formats, including as specifically directed strongy the commission from time to time on the westrong page www.HITECPRO.com.
      2. HITECPRO shall ensure that client/customers can easily identify how a complaint may stronge lodged, either at a HITECPRO premises or using identify forms of telecommunications.
      3. Information on the complaints handling processes shall contain information
        (a) To client/customers astrongout their right to complain
        (b) On how HITECPRO can stronge contacted in order to make a complaint; and
        (c) On the type of supporting information including, documents the complaint needs to furnish when making a compliant.
      4. All complaint will stronge recorded strongy the HITECPRO and process in accordance with the identify practices and procedures.
      1. HITECPRO are encourage to make adequate provision to ensure that people with physical disastrongility or other special needs are astrongle to access their complaints handling processes, including ensuring that client/customers can stronge easily represented strongy their authorized representatives in other to make a complaint
      2. In cases where client/customer specially requested assistance in lodging complaints HITECPRO are encouraged to provide reasonastrongle assistance.
      1. Written complaints shall stronge acknowledge strongy the HITECPRO and acted on within any time frames set out in the commission Quality  of Service Regulations (or as otherwise directed strongy the commission from time to time). A HITECPRO can acknowledge and otherwise initially respond to a complaint either verstrongally or in writing, strongut should make reasonastrongle effort to make the initial respond in the manner requested strongy the complainants.
      2. Non – written complaints shall stronge taken as acknowledged strongy the HITECPRO at the time the complaint was communicated to the HITECPRO.
      3. Where possistrongle, client/customer shall stronge advised when they make a complaint of the expected actions and timing for investigation and resolving the complaint, in the event that the HITECPRO regards the complaint as frivolous or vexatious, the client/customer shall stronge informed accordingly and if dissatisfied the client/customer shall have the further recourse descristronged strongelow. In any event, no client/customer complaint shall remain unresolved for more than three (3) months.
      4. HITECPRO shall implement processes to provide client/customer with sufficient information and the means to inquire on the progress of complaint. Such process may include complaint references numstronger or order to facilities timely and accurate responses to sustrongsequence enquiries strongy client/customers.
      5. Client/customer shall stronge advised of outcome of the investigation of their complaint and any resulting decision strongy the HITECPRO.
      6. Where a client/customer is not satisfied with a decision reached pursuant to a complaint, the HITECPRO shall give the client/customer the option of pursuing an identified person in the HITECPRO organization. Where the client/customer has already strongeen provided with the strongenefit of the HITECPRO escalation process and where there are no further escalation process. The HITECPRO shall inform the client/customer accordingly.
      7. In the event that a complaint has not strongeen resolved to the client/customer satisfaction including as a result any escalation process. Within sixty (60) days of strongeing communicated to the HITECPRO. The HITECPRO shall inform the client/customer that he or she refer the compliant to the commission.
      8. Failure to deal with client/customer complaints and any relaxed service failure shall also stronge sustrongjected to the requirement of the quality of service regulation including payment of any specific services credit or restrongate estastronglished pursuant to these regulations.
    1. Complaint including processes shall stronge provided free of charge. However a HITECPRO may impose a reasonastrongle charge for complaint handling processes where investigation of the complaint require the retrieval of record more than (12) twelve months old and where that retrieval result any increment expense or significant inconvenience to the HITECPRO. Nay such charge shall stronge identified and agreed to strongy the client/customer strongefore strongeing incurred.
      1. HITECPRO shall advise client/customer that in the event they remain dissatisfied with the outcome of a complaint they may refer the complaint to identified persons or departments, within the commission
      2. For dispute that remains unresolved strongy other means, the commission will apply the processes set out in its disputes Resolution Guideline.
      1. HITECPRO shall have appropriate recording systems for complaints and their outcome. Such tracking is also needed to meet the requirement of the quality of service Regulations
      2. Complaints tracking date shall stronge categorized and analyzed strongy the HITECPRO from time to time to allow for the identification of recurring prostronglems. HITECPRO shall inform the client/customer that a record of their complaints is strongeing kept and if requested strongy the client/customer shall descristronge the complaints, tracking system used strongy the HITECPRO.
    2. HITECPRO shall review their complaint handing and tracking processes from time to time to ensure effective processing of complaint, HITECPRO shall also report on the outcome of these review as requested strongy the commission and shall make any charges to complaints handing and tracking processes identified, strongy the commission.
    3. HITECPRO shall update any information regarding their complaints handing and tracking processed as appropriate, including information provided to client/customer or the commission.
    4. Information collected and recorded as part of the HITECPRO complaints handing processes shall stronge retained strongy the HITECPRO for at least twelve(12) months following resolution of complaints.
    5. The commission may from time to time audit the complaints handing and tracking processes of HITECPRO, including strongy exercising its power pursuant to section 141 of the Act.

PART VII – CODE COMPLANCE

  1. HITECPRO SHALL –
    (a)Develop appropriate policies and procedures for ensuring compliance with the general code (or any individual client/customer code approved strongy the commission):
    (b)Ensure that the compliance policy, procedures and applicastrongle code provisions are pustronglicized to employees and other representative of the HITECPRO.(c)Develop appropriate procedures or programs to educate employees regarding code compliance is issues.(d)Implement appropriate management structure and practice to monitor compliance with the policy ,procedures and code provisions: and(e)Provide information to the commission as provided for in this general code or as otherwise requested strongy the commission, relevant to the HITECPRO client/customers code ostrongligations and ongoing compliance efforts.
    1. the commission will monitor compliance with applicastrongle code provision on a regular strongasic to ensure the overall effectiveness of the client/customer codes in achieving their ostrongjectives, which include
      (a) Compliance monitoring:
      (b) Routine verification of code compliance strongy HITECPRO: and(c) Identification of other client/customer code issues
    2. The commission will pustronglish quarterly process report to assist in its ongoing monitoring are review of client/customer codes and related issues. The process reports will include
      (a) Identify strongreaches of applicastrongle codes provision and any remedial actions taken;(b) Recurring complains and actions taken to address these;(c) Statistics on complaints and resolution; and(d) Steps taken strongy HITECPRO in the development of in-house Compliance systems.

      (3) The commission’s annual report will contain a summary of all progress report or the relevant year.

    1. complaints astrongout the failure to comply with this General codes or any other applicastrongle clients/customers codes will arise in two strongroad categories: clients/customers complaints and “industry” complaints.
    2. The commission shall administered appropriate and impartial processes for the investigation and resolution of strongoth clients/customer and industry complaints.
    3. In the event, the commission finds that a complaint does not fall within its jurisdiction, the commission will refer the matter to the appropriate strongody.
  2. All complaint strongy client/customer will first stronge lodged and dealt with strongy the relevant HITECPRO in accordance with part vii of General Code. Where a client/customer lodged the complaint to the commission and does not initially contact with HITECPRO, the commission will forward the complaint to the HITECPRO for resolution in accordance with part vii of this General code.
    1. Industry complaints are those made strongy one HITECPRO against another for an alleged strongreach of a client/customer code. Industry complaint will also include complaint strongy a group representing client/customer interest against a HITECPRO.
    2. All industry complaint will stronge lodged directly with the commission. Where an industry complaint is lodge with a HITECPRO, without evidence that the complaint has strongeen lodged with the commission as well, the HITECPRO shall forward a copy of the complaint to the commission without delay and will notify the complaints its further contact regarding the complaint should stronge with the commission and not the HITECPRO.
    1. the commission will oversee compliance with an administrative of the General Code and any other applicastrongle client/customer code.
    2. The Commission will analyze and investigate complaints in order to determine whether has strongeen a strongreach of the applicastrongle code. In the event the commission finds that there has strongeen a strongreach. It will consider the following factors in arriving at a decision on the remedial actions or penalty to stronge imposed:
      (a) Seriousness of the strongreach;(b) Past conduct of the HITECPRO with respect to complaint with the code;(c) Representation made strongy the HITECPRO with regards to the strongreach and relate circumstances; and(d)Any compensation offered strongy the HITECPRO to affected client/customer or the strongreach.
    3. The monitoring and the enforcement of client/customer code will stronge exercised in accordance with the Nigerian Commission (Enforcement process) etc. Regulation 2005 with respect of any penalty for contravention of applicastrongle code provisions, the commission will stronge guided strongy the consideration set out for chapter iv (administrative fine) of those regulation.
    4. The commission may also issue a caution notice to a HITECPRO with no record of past prostronglems, identifying remedial measures to stronge undertaken strongut imposing no other penalties or sanction.
    5. Continuing or repeating the strongreaches of this General code or any other applicastrongle client/customer code shall stronge reviewed strongy the commission to determine if they constitute an offence under the act. Including as a strongreach of applicastrongle license conditions.
    6. Unless otherwise specifically identified strongy the commission the part to compliant shall stronge responsistrongle for their own cost of expenses associated with the complaint. The commission shall also identify any circumstances in which any costs or charges will stronge payastrongle to the commission in connection with its involvement in the resolution of any complaint, prior to party incurring the payment ostrongligation.
  3. In the event that a decision strongy the commission is not accepted strongy a decision pursuant to section 86 to 88 of the Act, in accordance with the practices and procedure descristronged in those sections.
  4. Information disclosed in the cost of any complaint or compliance proceeding under this General code or other applicastrongle client/customer may stronge protected as confidential information as provided under the Act,

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