CODE OF PRACTISE

HILL PHOENIX LIMITED (HPL)

Prepared by HILL PHOENIX LIMITED (HPL)       JULY 31ST 2025

CONSUMER CODE OF PRACTICE

HILL PHOENIX LIMITED (HPL)

SALES AND INSTALLATION OF TERMINAL EQUIPMENT INDIVIDUAL CLASS LICENCES

CONSUMER CODE OF PRATICE DOCUMENT

1.     INTRODUCTION:

HILL PHOENIX LIMITED (HPL) is a telecommunications infrastructure provider in Nigeria. The Nigerian Communications Commission (NCC) regulates HILL PHOENIX LIMITED (HPL).

Hill Phoenix Limited is committed to conducting business in accordance with the highest ethical standards and in accordance with all applicable laws and regulations of the countries in which we operate,

We also consider honesty and integrity to be the hallmarks of long-term success, which ultimately contributes to the ethical wellbeing of us all.

Our professional standards are therefore exceptionally high, and we have systems and processes in place to ensure compliance with anti-bribery and corruption laws. Amongst the most fundamental operating principles are adherence with all laws and regulations applicable to our business.

This Code of Practice is issued pursuant to the Consumer Code of Practice Regulations 2007 The matters which the Code aims to address shall include but not limited to the under listed matters:

• Reasonable meeting of Consumer requirements

• Handling Consumer complaints and disputes

• Consumer compensation in case of breach

• Protection of information

• Billing

2.  DEFINITIONS AND INTERPRETATIONS

Unless otherwise defined, or the context otherwise requires, expressions defined in the General Consumer Code of Practice shall have the same meanings in this document including recitals and schedules:

“Quality of Service Regulation” means the Quality of Service Regulations 2013

“Host” means the Licensee/HILL PHOENIX LIMITED (HPL)

“Consumer” means the customer

3.  PROVISION OF INFORMATION TO CONSUMERS

• HILL PHOENIX LIMITED (HPL) upon request HPL will provide a copy of the contract or agreement for the provision of services and such contracts shall be in clear language.
  • Copies of duly approved individual Code will be available to consumers on request

4.  DESCRIPTION OF SERVICES

• HILL PHOENIX LIMITED (HPL) Provide service in the area of telecommunication sites build and sale installation of terminal equipment to telecoms and corporate bodies.

5.  PRICING INFORMATION

• Contract shall not take effect until parties mutually agree on the pricing and composition thereof. Pricing components may include but not limited to applicable rates or charges, calculation basis of each charge element, frequency, or basis of the

Collection of the charge, information as to whether charges are subject to change and the frequency of such changes and how information on such matters will be communicated to the Consumer.

6.  CONTRACT TERMS AND TERMINATION

• Infrastructure sharing contracts with Consumer will incorporate standard clauses relating to commencement date, minimum contract term (where applicable), manner and consequences of premature termination and calculation basis for payment of any penalty therefrom, situations where early termination may be permitted, renewal terms, installation, connection and decommission terms, and refund policies. Furthermore, all terms and conditions of a contract regarding the provision of any of our services shall be clearly stated in the contract or agreement in clear and plain language.

7.  PRODUCT WARRANTIES AND MAINTENANCE

• Where applicable, the HILL PHOENIX LIMITED (HPL) will inform the consumer of any contractual warranty relating to any shared infrastructure. Such information, where applicable, will include how to obtain such warranty services
  • There will be specific information to the consumers on the availability and provision of any maintenance service by the Host party

8.  PROVISIONING OF SERVICES

• Provision of services by HILL PHOENIX LIMITED (HPL) in accordance with the service supply time targets set out in the NCC Quality of Service regulations annexed to this Code. HILLPHOENIX LIMITED (HPL) will not be liable for any delays or refusals of service requests, lack of site availability or infrastructure availability that is beyond its reasonable control.
  • Further to clause 8.1 above, HILL PHOENIX LIMITED (HPL) bear no responsibility for service delays or refusals where such is attributable to the lack of credit worthiness of the Consumer.

9.    FAULT REPAIR AND SERVICE INTERRUPTION

• Relevant facilities and processes will be implemented to ensure reporting of faults 24 hours a day by Consumer
  • The standard of fault repair as set out in the annexed Quality of Service regulations shall apply to the fault repair standards established by the Host
  • HILL PHOENIX LIMITED (HPL) Endeavourto give adequate notification of any planned downtime including details of the disruption or outage, the services and service area affected and any corresponding compensation or other remedies if applicable.

10.  AVAILABILITY OF SERVICE

1. HILL PHOENIX LIMITED (HPL) will ensure that marketing presentation materials to potential Consumer s indicate any known geographical or technical limitations, which may substantially affect the performance of the Consumer services

1. In addition to the above, marketing materials must indicate any limitations which restrict a particular group of persons, geographical area, particular period of time or limited availability of infrastructure or other materials.

11.          ADVERTISING OF PACKAGED SERVICES

1. The consumer will be entitled to the supply of all components of a serviced package where the Host has marketed the provision of its service as part of a package
   1. Appropriate information to potential Consumer will be included in marketing materials by HILL PHOENIX LIMITED (HPL) where it may be unlikely to supply any component of the service package
   1. The marketing materials may contain information on the pricing of the component of a service package; where this is so, the marketing materials shall also incorporate an estimate of the minimum total charge for the package and indicate any terms and conditions applicable to obtaining the component at the stated price

12.                 BILLING INFORMATION

1. The following information will be contained in invoices issued to the Consumer:

• Consumer name and billing address

• HILL PHOENIX LIMITED (HPL) current business name address and registered number
  • Unique identification or invoice number

• Date of invoice and billing period

• Description of the services provided by HILL PHOENIX LIMITED (CTL) for which consumer is charged • Historical summary of charges including total amount billed, applicable credits, advance payments or discounts, net amount payable by Consumer or repayable by Host as the case may be
  • Payment/refund due date

• Method of payment

• Method of contact for complaints and billing inquiries

13.  ITEMIZATION OF CHARGES

1. HILL PHOENIX LIMITED (HPL) willensure that consumers have access to itemize details of all charges either on the bill or on a separate statement provided to the Consumer upon request

14.  TIMING FOR ISSUANCE OF BILL

1. HILL PHOENIX LIMITED (HPL) will issue bills and include all charges incurred within the specified billing period within 10 days of the closure of each billing period.
   1. Exceptions may occur whereby not all charges are included on the invoice because of separate agreement between parties, or any other reason.

15.  RECEIPT AND CONSUMER PAYMENT ADVICE

1. HILL PHOENIX LIMITED (HPL) will make available appropriate and accessible methods of verification of bill payment by the Consumer.

16.  BILLING FREQUENCY

1. Consumer shall be provided with sufficient and advance written notification of any proposed changes to the billing period. The advance written notification shall be deemed sufficient by parties where it provides a minimum notification period of twice the usual billing period(s).

17.  NON-PAYMENT OF BILLS

1. In the event of non-payment of bills to HILL PHOENIX LIMITED (HPL), HILL PHOENIX LIMITED (HPL) will take necessary measures (which includes but not limited to referring the issue of non-payment by the consumer to the NCC) to effect such payment or disconnect the consumer’s equipment.
   1. Necessary measures as referred to above shall be commensurate and not unduly discriminatory

18.  INFORMATION TO CONSUMERS

1. HILL PHOENIX LIMITED (HPL) will ensure that its complaints procedure is accessible in various media and formats or as directly specified by the NCC from time to time. Information on the complaints procedure shall include:
   1. Consumers right to lodge complaint

• Mode of lodging the complaint to the Host

• Requisite documents required to lodge a valid complaint

• Means to enquire on status of complaint

1. The procedure must be expressed in clear language and the Consumer must be able identify how to lodge a complaint either physically or via dedicated online platforms
   1. Consumer complaints will be duly recorded and processed in accordance with identified practices and procedures

19.  SPECIAL NEEDS

1. Adequate provisions will be made by HILL PHOENIX LIMITED (HPL) to ensure that people with special needs are able to access the complaint handling processes
   1. HILL PHOENIX LIMITED (HPL) will use its best endeavors to provide reasonable assistance to Consumer who may request assistance with lodging complaints.

20.  COMPLAINT PROCESS

• Complaints shall be acknowledged by HILL PHOENIX LIMITED (CTL) verbally or in writing but preferably in the mode or manner requested by the Consumer complainant. Consumer shall forward complaints to the registered address of the Host HILLPHOENIX LIMITED (HPL) as stated below:

NO 52 Tafawa Balewa crescent offAdeniranOgunsany Road SurulereLagos Nigeria,

Telephone number: 234 08083260392 info@hillphoenixlimited.com

Website; www.hillphoenixlimited.com

• Where possible, the Consumer will be provided with an expected outcome or estimated timeframe within which the complaint shall be investigated and resolved. Notwithstanding the forgoing, complaints including those which require further recourse for lack of acceptable resolution, shall be acted upon within the set time frame as directed by the NCC from time to time or as provided in the annexed Quality of Service Regulations and this shall not exceed a period of three calendar months
  • An identified escalation process will be accessible to the Consumer where Consumer is dissatisfied with the outcome of a complaint resolution. Such escalation process involve further complaint examination by a suitably qualified authorized representative of the Host.
  • Consumers will be duly informed where resolution via the escalation process has been exhausted and there are no further escalation processes.
  • Oral or non-written complaints willbe deemed acknowledged by HILL PHOENIX LIMITED (HPL) at the time such was communicated to HILL PHOENIX LIMITED (HPL)

21.    CHARGES

• HILL PHOENIX LIMITED (HPL) Complaint handling processes will be provided free of charge. However, any complain that requires the retrieval of records more than Twenty four (24) months will attract charges, which the consumers must be informed and agreed to.

22.    FURTHER RECOURSE

• In addition to the complaint process set up by HILL PHOENIX LIMITED (HPL), the consumer reserves the right to escalate unsatisfactorily resolved or unresolved disputes to the Nigerian Communication Commission (NCC)
  • HILL PHOENIX LIMITED (HPL) will inform consumer after 60 days of non- resolution of the complaint to the satisfaction of consumer to proceed to refer the complaint to the NCC

23.    ACTION ON DISPUTED CHARGES

• Where a Consumer has initiated a complaint through the laid down process and investigation is ongoing, HILL PHENIX LIMITED (HPL) will be stopped from taking any action with regard to credit management action or disconnection of installed equipment or related apparatus pending the resolution of the dispute.

24.    INTERNAL DATA COLLECTION AND ANALYSIS

• HILL PHOENIX LIMITED (HPL) will ensure availability of appropriate recording system for complaints and outcomes which shall comply with the requirements of the Commission’s Quality of Service Regulations such that recurring issues are easily tracked for effective processing

25.    CHANGES TO COMPLAINT HANDLING PROCESS

• HILL PHOENIX LIMITED (HPL) will ensure that Consumer is properly updated with any information regarding the changes in the Company’s complaint handling process, if any.

26.  RETENTION OF RECORDS

• Information collated and recorded by Host in respect of the complaint handling procedure initiated by the Consumer shall be retained for at least twenty four (24) months Telemarketing involves selling or promoting products/services over the phone. It can be:
• Inbound (receiving customer calls)

• Outbound (making calls to potential customers)

Telemarketing is used in various industries, including sales, customer service, and marketing.

Here are some key points on telemarketing strategies, best practices, and industry trends:

Telemarketing Strategies:

1. Targeted calling: Focus on specific demographics or customer segments.

• Personalization: Tailor your pitch to the customer’s needs and interests.

• Building rapport: Establish a connection with the customer to increase trust.

• Clear scripting: Use a well-structured script to ensure consistency.

• Follow-up calls: Schedule follow-ups to nurture leads.

• Best Practices:

1. Respect customer time: Keep calls concise and to the point.

• Be transparent: Clearly disclose product/service details.

• Train your team: Invest in ongoing training for telemarketing staff.

• Use technology: Leverage CRM systems and call tracking tools.

• Monitor and evaluate: Regularly assess performance and adjust strategies.

• Industry Trends:

1. Omnichannel engagement: Integrating telemarketing with other channels (email, social media, etc.).
2. AI-powered telemarketing: Using AI to optimize calls and improve customer experience.
3. Data-driven decision-making: Analyzing data to inform telemarketing strategies.

• Customer experience focus: Prioritizing customer satisfaction and experience.

• Regulatory compliance: Adapting to changing regulations (e.g., Do Not Call lists).

27.  Internet Connection

Hill Phoenix Limited, will ensure Internet connectivity as a service refers to the provision of internet access and related services to individuals, businesses, or organizations. Will meet the customer demand, This can include:

• Internet Service Providers (ISPs): that our offer internet access via various technologies, such as fiber, DSL, or cable.

Managed Services: HPL, Providers manage and maintain internet infrastructure, ensuring reliable and secure connectivity.

• Cloud-based Services: Cloud providers offer scalable and on-demand internet-based services, such as cloud storage, applications, and infrastructure.

Key Benefits

• Reliability: Consistent and stable internet connectivity.

• Scalability: Ability to adjust bandwidth and services according to needs.

• Security: Enhanced security measures to protect against cyber threats.

• Flexibility: Access to various internet-based services and applications. Applications
• Remote Work: Enables remote teams to stay connected and productive.

• Online Education: Facilitates access to online learning resources and platforms.

• E-commerce: Supports online businesses and transactions.

• IoT: Enables connectivity for Internet of Things (IoT) devices. Challenges
• Network Congestion: Managing high traffic and ensuring quality of service.

• Security Threats: HPL,will ensure Protecting against cyber attacks and data breaches.
• Digital Divide: HPL will Ensuring equal access to internet connectivity for all.

27.3 Future Developments

• 5G Networks: HPL,will ensure wireless technology promising faster speeds and lower latency.

• Fiber-optic Expansion: HPL, will ensure Increasing deployment of fiber-optic infrastructure for faster and more reliable connectivity.
• Satellite Internet: Expanding satellite internet services for remote and underserved areas.

28.  Prepaid Service

Hill Phoenix limited, will ensure Prepaid services allow customers to pay for a product or service before using it. This model is commonly used in various industries, including:

• Telecommunications: HPL will ensure Prepaid mobile plans where customers pay for minutes, texts, or data before using them.

Benefits of Prepaid services

• Flexibility: Customers can control their expenses and usage.

• No Surprise Bills: Customers know exactly how much they will pay.

• No Contract: Customers are not locked into a contract.

Challenges with Prepaid services

• Usage Tracking: Customers need to monitor their usage to avoid running out of credits.
• Top-up Requirements: Customers need to regularly top up their accounts to continue using the service.

Applications

• Mobile Phones:HPL, Prepaid mobile plans are popular among customers who want to control their expenses.
• Internet Services: Prepaid internet plans are suitable for customers who want flexibility and control over their internet usage.

Key Features

• Pay-as-you-go: Customers pay for services before using them.

• No Monthly Bills: Customers do not receive monthly bills.

• Flexibility and Control: Customers have control over their expenses and usage.

Disclaimer Policy

A disclaimer policy, Hill Phoenix limited, disclaimer policy statement clarifies the limitations, risks, and responsibilities associated with a product, service, or content. It helps protect the provider from potential liabilities and informs users of potential risks. Key Elements

• Limitation of Liability: HPL policy Specifies the extent of liability for damages or losses.
• No Warranty: HPL policy Clarifies that the product or service is provided “as is” without warranties.
• Risk Assumption: HPL, Policy Informs users that they assume certain risks when using the product or service.
• Intellectual Property: Specifies ownership and usage rights for intellectual property. Purpose

• Protect Provider: HPL, policy Limits liability and protects the provider from potential claims.
• Inform Users: Clearly communicates risks and limitations to users.

• Establish Boundaries: Defines the scope of responsibilities and obligations. Common Applications
• Software and Technology: Disclaimer policies are often included in software licensing agreements.
• Financial Services: Financial institutions may include disclaimers in investment products or services.
• Content Providers: Websites, blogs, and other content providers may include disclaimers to clarify the accuracy and reliability of their content.

Best Practices

• Clearly Written: HPL, Disclaimers is written in clear and concise language.

• Prominent Display: HPL, Disclaimers is prominently displayed where users can easily access them.
• Regular Review: HPL Disclaimers is regularly reviewed and updated to ensure they remain relevant and effective.