Consumer Protection Policy

Introduction

Good Consumer Protection Policy facilitates smooth relationships between the company and  customers. Customers should be able to obtain correct and unbiased information about the  products and services an entity offers. In the same vein, customers should be able to air their  grievances and displeasure in the event of such occurrence. In light of this, the Central Bank of  Nigeria (CBN) released the Consumer Protection Regulations and the Federal competition and  consumer protection commission (FCCPC) released the FCCPA.



The Regulations provide minimum  standards required of all Institutions under the regulatory purview of the Apex Bank and the federal  public of Nigeria on fair treatment of consumers, disclosure and transparency, business conduct,  complaints handling and redress in order to protect the rights of consumers and to hold the  institutions accountable.

Objectives

Kora’s objective of formulating the Consumer Protection Policy is to ensure that customers are  protected from:

• Unfair and exploitative practices
• Unethical or Predatory practices that may undermine their confidence in the use of Kora’s  products and services
  
• Inadequate and misleading information or failure to disclose material information
• Inaccessibility to complaint redress mechanisms that are free, fair, timely, and transparent.

Fair treatment of consumers

1. In fulfilment of our obligation(s) to treat all customers fairly, Kora:
   
2. treats consumers equitably without bias at all stages of the relationship
3. gives consumers who meet the minimum legal and non – discriminatory eligibility  requirements, equal access to basic services without regard to their social status, physical  ability, marital status, gender, age, religion, tribe or ideology
4. treats consumers with courtesy and respect and shall not engage in practices such as threats,  intimidation, use of abusive or offensive language, humiliation, misrepresentation, deception  or unfair inducements
5. promptly obliges consumers’ request for account closure or to switch providers, without  unreasonable closing/switching barriers.
6. responds to customers’ enquiries/requests within 24 hours of receiving the  enquiries/requests.
7. communicates a decision (acceptance or decline) on applications for waivers, extensions,  and other concessions to a customer within Four (4) working days.
8. does not act in a manner that is inconsistent with the terms and conditions of its contracts  with customers
9. will not intentionally include in its agreement with customers, unfair terms which occasion  imbalance in rights and obligations and are detrimental to the customers

Disclosure and transparency

In order to promote transparency and enhance disclosure practices, Kora:

1. Ensures that documents provided or made available to consumers are clear, legible and  written in plain English language
   
2. Publishes on its website, accurate and up to date information on all its products and services.
3. Discloses to the consumer in writing, all Terms and Conditions of a transaction agreement
4. Clearly explains technical terms used in documents to the consumer to aid understanding
5. Complies with the rates, fees, charges, or prices published or disclosed at all the engagement  points (website, sales calls, adverts etc)
6. Bears all costs associated with disclosures to customers required by the Regulations
7. Ensures that content of advertisements are factual and unambiguous, expressed in clear and  simple language and shall not be offensive, misleading, deceptive, injurious, or exaggerate  the benefits of the products or services being advertised
8. Discloses its contact details in any advertisement or promotional material.
9. Fully discloses the nature and value of benefits, where an advertisement refers to, or is linked  to other value adding benefits.
10. Ensures that unsolicited advertisements through emails, text messages, voice calls and other  channels shall be at no cost to the consumer and shall contain an opt-out provision for future  advertisements.

11. Complies with the following additional disclosure requirements for specific product types in  any proposed contract, letter of offer or final contract:

    • minimum balance and any other limit on account balances and transactions (if applicable);
    • types of payments for which the instrument may not be used;
    • expiration date which may be applicable to the payment instrument;
      
    • processes and procedures to report mistaken and fraudulent transactions.

Responsible business conduct

To promote good business practices, Kora will:

• Conduct its business in a responsible, professional and ethical manner
• Train its staff to promote competence, efficiency and professionalism in the discharge of their  duties.
• Provide clear information about products and services, features, terms and conditions and  the applicable fees and charges
• Provide and informs consumers of the channels to make enquiries and complaints
• Notify customers of circumstances or situations that may affect the terms of their contracts  or relationships.
• Not impose any product, service or channel on consumers.
• Not compel consumers to buy a product or service as a condition for the purchase of another  product or service unless where the products or services are directly dependent
• Provide information that would aid consumers’ decisions.
• Carry out marketing of products and services in an ethical and professional manner
• Establish a process to periodically check and monitor the competence and conduct of sales  and marketing staff.
• Ensure that sales and marketing staff are properly trained and competent to perform their  functions

Data protection and privacy

To ensure data protection and privacy, Kora:

• shall maintain a comprehensive & up-to-date privacy policy and cookie policy for its website. 


• shall comply with applicable data privacy laws (NDPR and GDPR)
• shall protect the privacy and confidentiality of consumer information and assets against  unauthorized access, and be accountable for acts or omissions in respect thereof
• always obtains the consent of consumers to collect and process their personal data for specific  purpose and provides them with the option to withdraw the consent at any time
• does not transfer personal data of consumers to a third party without their express consent,  except in compliance with a legal obligation.
• Informs consumers whenever their data is exchanged with an authorized third party, stating  details of the exchange.
• Reviews data processing and privacy procedures to ensure that the purpose(s) for which initial  consent was granted remained valid
• regularly make filings to the NITDA (National Information Technology Development Agency)
• Keeps accurate and updated data of consumers always.
• Will maintain a record of all customer complaints for a period of 5years (minimum) after which  the overage information will be meticulously destroyed.
  

Complaints/Enquiries as regards Koras data protection and privacy program should be channeled  to the Compliance Team [email protected] 


Complaints handling and redress

In situations of customers complaints being lodged, Kora:


• is solely responsible for the resolution of disputes
• has documented processes on Complaints Handling that guarantees fairness, transparency,  responsiveness and independence of the complaint handling mechanism
• shall Allocate adequate resources for complaints handling/redress and the processes  manned by skilled and well-trained members of staff.
• At all customer engagement points, discloses channels and contact details for lodging  complaints, timeframe for resolution, and options for escalation.
• provides multiple dedicated channels to receive and handle consumer dispute complaints  such as filling this form https://forms.gle/bCtqkQpYUtV3RWvg6 or sending us a mail on [email protected]
• Ensure channels are effective, functional, efficient and accessible always
• Provides emergency channels for reporting time-sensitive issues especially fraud-related  complaints at all times (email - [email protected])

• Upon receipt of a complaint, will communicate to the consumer within 24 hours, an acknowledgment containing:

  • a unique identification or tracking number,
    
  • contact details of the complaints desk,
  • expected resolution timeline,
  • escalation options,
  • an assurance that the complaint is being addressed.
• Uses the unique identification or tracking number in all correspondence with the complainant.
• has established Internal Dispute Resolution (IDR) structures and processes for the effective management of consumer complaints and refund requests

Resolution communications will be in SRC format

Kora has designated the Compliance unit to ensure complaints handling independent of other  products or business functions taking into consideration, the nature and complexity of their business


The Compliance team will ensure staff responsible for handling complaints shall be required to  declare any conflict of interest that may affect their objectivity in handling a complaint.

SRC format includes

• the basis for the decision(s)
  
• the right of appeal available to the complainant for a second level review by the Institution c. the right of escalation to the CBN, or other Alternative Dispute Resolution (ADR) avenues where  the complainant is not satisfied with decisions arrived at.

Internal dispute resolution process flow for Merchant Success

Compliant & enquiry analysis and intelligence

Periodic review of the complaint and enquiry log shall be jointly carried out by the Merchant  success and Compliance team to extract intelligence from the log, prominently to identify customer  pain points, liaise with responsible business owners and carry out a root cause analysis.

Consumer protection oversight functions and stakeholder 

The board of directors:

Kora’s Board of Directors shall be primarily responsible for approving and overseeing the implementation of the Consumer Protection Policy. The roles of the Board shall include: 


• Approve the Consumer Protection Policy
  
• Monitor Staff Performance
• Ensure accountability of Senior Management
• Review and approve Consumer Protection Policy periodically
• Provide adequate resources for implementing consumer protection principles.

Senior management

Kora’s Senior Management shall be responsible for implementing the Consumer Protection Policy  approved by the Board of Directors.. The roles of Senior Management shall include:

• Overall management and delivery of the Consumer Protection Policy
  
• Embedding the consumer protection principles across the internal and external ecosystem
  
• Ensure timely reporting to the Regulators
  
• Effective management of daily customer protection activities.

Compliance & risk mgt


Kora’s Consumer protection is part of the overall compliance program. The roles of compliance shall  include:

• Develop the Consumer Protection Policy
  
• Ensure adherence to the Consumer Protection Policy as approved by the Board of  Directors.
  
• Ensure timely submission of monthly returns on ‘Nature and Volume of Customer  Complaints’ and quarterly returns on ‘ Root Cause Analysis Report’ to the Central Bank of  Nigeria.
  
  
• Ensure that the workforce undergo Consumer Protection Training annually.

Merchant success and operations

Kora's merchant success team are key stakeholders in the consumer protection program. their roles  include:

• Serving as a point of contact for merchants during complaints and enquiries.
  
• Ensuring transparent and comprehensive communications with merchants while addressing  complaints.
  
• Keeping records of merchants complaints, enquiries and evidence of response/resolution.
  
• Ensure responses are provided to merchants within 24hours, if resolution is unavailable  holding responses must be communicated within the aforementioned timeline.
• Identify recurring complaint types, identify their root cause(s), implement remedial measures e. Identify recurring complaint types, identify their root cause(s), implement remedial measures

Regulatory obligations

In lieu of our regulatory obligations as a licensed entity, Kora will:

• Notify the Director, Consumer Protection Department of the CBN prior to the commencement  of advertisement of product or service by submitting a description of the content of the  advertisement.
  
• Identify recurring complaint types, identify their root cause(s), implement remedial measures,  and generate a Root Cause Analysis Report (RCAR) which is rendered on monthly and  quarterly basis to the Central Bank of Nigeria (14th day of January, April, July and October  respectively).
  

Related policies

Please see the below policies for further information:

• Our Dispute resolution policy: for further information on how we receive, evaluate, and resolve  transaction disputes (chargebacks, refunds, and settlements)
  
• Our anti-bribery and corruption policy: for further information on how we manage our ABC risk  and ensure that we curb bribery and corruption internally.
  
• Our Privacy policy: for further information on how we handle, process, retain and dispose of  your personally identifiable information.
  
• Our code of conduct and ethics policy: for further information on what is classified as ethical  behaviour and proper business conduct at Kora.