Bergen Horn

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Consumer Code of Practice

Effective Date: January, 2025 | Last Updated: January, 2026

BERGEN HORN LIMITED

CODE OF PRACTICE FOR CONSUMER AFFAIRS

1. INTRODUCTION

This Code of Practice for consumer affairs (this “Code”) is published pursuant to Condition 7 of the Aggregator Service (the “License”), granted to Bergen Horn Limited (“Bergen Horn” or the “Company’’). The provisions of this Code are in addition to and not in reduction of the obligation of Bergen Horn Limited under the License and under the Nigerian Communications Act (the “Act”). Nothing in this Code affects your statutory rights and this Code does not form part of a contract or collateral contract between Bergen Horn Limited and you.

WHO WE ARE

Bergen Horn Limited is a licensed Telecom, Mobile, and Digital Services Aggregator that bridges the gap between businesses and mobile network operators. Bergen Horn facilitates the distribution of digital services, enhances customer engagement, and drives content monetization across a range ofmobile channels, including SMS, USSD, and other value-added platforms.

Bergen Horn Limited has been granted an Aggregator Services License by the Nigerian Communications Commission (the “Commission”), authorizing it to operate in Nigeria as an official aggregator for content-based and value-added services in partnership with mobile network operators.

1.2 Objectives of the Code

This Code reflects Bergen Horn’s commitment to delivering high-quality service to our customers and handling queries and complaints quickly and fairly. It outlines the services offered by Bergen Horn, where to get help, how to raise complaints, and how disputes are resolved, in alignment with the Nigerian Communications (Consumer Code of Practice) Regulations, 2024.

1.3 License Conditions

It is a condition of the License that Bergen Horn ensures its customers and employees are properly guided regarding service provision and complaint resolution. Bergen Horn aligns with ethics, regulatory standards, and industry practices in the fulfillment of this Code.

2. QUALITY OF SERVICE

2.1 Bergen Horn shall comply with the quality standards set by the Commission, ensuring prompt delivery of contracted services within agreed timelines.

2.2 Customers shall be provided with service-level agreements that detail quality expectations, timelines, and remedies for failures.

3. PROVISION OF SERVICE INFORMATION TO CUSTOMERS

3.1 Service Contracts and Duration

Bergen Horn Limited shall supply, or make available on request, a copy of the contract or agreement for the provision of services, and such contracts shall be written in plain and clear language.

3.2 Description of Services

Bergen Horn Limited offers USSD and Bulk SMS Services. This service provides interactive services across various mobile channels-SMS, IVR, WAP portals such as; SMS chats, Messenger, Voice chat, Music on demand, Voice portal and Mobile social networking.

3.3 Subscription of Service

  • Bergen Horn Limited will ensure that clear, step-by-step instructions are provided to customers on how to subscribe to any service offered through its platform.
  • Subscription methods (SMS opt-in, USSD menu, web form, or mobile app) will always require explicit user consent before activation.
  • Customers will also be informed of how to opt-out or deactivate services easily and at no cost.
  • Subscription processes shall comply with NCC VAS Guidelines and consumer protection standards, ensuring that no deceptive or automatic subscriptions occur.

3.4 Contract Terms and Conditions

  • All contracts must specify commencement and termination dates, renewal options, and termination procedures
  • The contract will detail:
    • Conditions for renewal, suspension, or termination.
    • Obligations upon termination (including data retention, settlement, and exit procedures).
  • Any amendments to contract terms will be documented and communicated in writing to all concerned parties before implementation.

3.5 Opt-In and Opt-Out:

  • Upon request for any service, Bergen Horn Limited shall provide the consumer with Opt-in and Opt-out options in clear, simple and understandable terms
  • Bergen Horn Limited shall provide the consumer with access to a HELP function to obtain information on services they are at the time of request, subscribed to and how to opt out in clear plain English.

4. ADVERTISEMENT & REPRESENTATION OF SERVICES POLICY

4.1 Availability of Services

Bergen Horn Limited services are available on all mobile networks; however, our services are network dependent, services will be restricted to certain areas within Nigeria where mobile network service is available as contained in promotion materials.

4.2 Advertising Packaged Services

Where Bergen Horn Limited represents in advertising materials that a service is provided as part of a package, Bergen Horn Limited shall ensure it is able to supply all components of the service package. If Bergen Horn Limited 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, Bergen Horn Limited 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.

4.3 Disclaimers

All marketing materials shall remain simple, with clear disclaimers without legal or technical jargon. They will state key service conditions, charges, and limitations, and will be subject to review by the Legal/Compliance Department before publication.

4.4 Telemarketing Conduct

Bergen Horn Limited and its partners will avoid unsolicited or harassing calls/messages. Telemarketing shall only target consenting customers, with clear identification and opt-out options. Misleading or aggressive sales tactics are prohibited.

5. COMPLAINTS HANDLING

5.1 Complaint Processes

  • The complaint process shall be simple, transparent, and responsive.
  • Customers may lodge complaints through:
  • Upon receipt of a complaint:
    • 1. The customer will be issued a unique tracking ID.
    • 2. The complaint will be acknowledged within 24 hours.
    • 3. Resolution shall be provided within 5 to 10 working days, depending on the nature of the issue.
  • If a customer is not satisfied with the resolution, they may request an escalation to the NCC Consumer Affairs Bureau.

5.2 Further Recourse:

If the complaining customer remains dissatisfied with the outcome/resolution of the complaint, has the right to refer the complaint to Nigerian Communication Commission (NCC).

Where a Consumer is not satisfied with a decision reached pursuant to a complaint made Bergen Horn Limited will give Consumer the option of an identified escalation process, whereby the decision reached after investigation may be examined by a senior personnel or other persons suitably qualified and very knowledgeable in that regards. Where the company has exhausted all available means of resolving the complaint made by Consumer, Bergen Horn Limited shall inform the Consumer accordingly.

In the event that a complaint has not been resolved to the Consumer’s satisfaction within sixty (60) days of being communicated to the company, including as a result of a dissatisfied result of any escalation process, Consumer may refer the complaint to the Commission.

5.3 Data Collection & Analysis of Complaints

  • Each complaint shall have a unique tracking ID for monitoring and reporting.
  • Complaints shall be logged in the Bergen Horn Customer Support Management System (CSMS) with details such as:
    • Date/time received
    • Customer information
    • Nature of complaint
    • Resolution action taken
    • Date/time closed
  • The data shall be analysed periodically to:
    • Identify recurring issues
    • Improve service delivery
    • Support management decision-making
  • A quarterly Complaints Analysis Report shall be presented to the management team.

5.3 Data Collection & Analysis of Complaints

  • Each complaint shall have a unique tracking ID for monitoring and reporting.
  • Complaints shall be logged in the Bergen Horn Customer Support Management System (CSMS) with details such as:
    • Date/time received
    • Customer information
    • Nature of complaint
    • Resolution action taken
    • Date/time closed
  • The data shall be analysed periodically to:
    • Identify recurring issues
    • Improve service delivery
    • Support management decision-making
  • A quarterly Complaints Analysis Report shall be presented to the management team.

5.4 Retention of Records

  • Complaint records shall be securely stored for at least 24 months after resolution, in accordance with NDPR.
  • Records include:
    • Complaint forms, emails, and correspondence
    • Investigation reports
    • Resolution outcomes
    • Customer acknowledgements
  • All records shall be stored in encrypted digital form within Bergen Horn’s secure data systems and may only be accessed by authorized personnel.

5.5 Prevention of Unsolicited SMS

Bergen Horn Limited is committed to safeguarding consumer rights by ensuring that subscribers are protected from receiving unsolicited Short Message Service (SMS) communications, in line with the NCC’s Do-Not-Disturb (DND) directives. By enforcing these standards, Bergen Horn Limited reaffirms its commitment to respecting consumer choices and ensuring a safe, spam-free digital environment.

6. PROTECTION OF CONSUMER INFORMATION

6.1. Data Gathering

Bergen Horn Limited ensures that only accurate, relevant, and necessary consumer data is collected strictly for delivering value-added services. This includes basic identification details, mobile numbers, service preferences, and usage analytics. Consumers are informed at registration about the purpose of data collection and their rights to consent, access, and correction. All data collection processes comply with data minimization and transparency principles, and every digital or physical form must include a clear privacy notice.

6.2. Data Storage

All consumer data is securely stored in access-controlled and encrypted environments that meet industry standards. Terms & Conditions and Privacy Policies are provided at registration to explain data handling and retention. BERGEN HORN enforces strict retention schedules, preventing unauthorized access or modification through audits, controls, and staff training. Regular data backups are maintained in line with disaster recovery and business continuity policies.

6.3. Data Sharing

Bergen Horn Limited safeguards consumer trust by preventing unauthorized data sharing. Consumer data is not transferred or disclosed without explicit consent, except when required by law. All third-party partners undergo due diligence and must sign Data Processing Agreements (DPAs) to ensure compliance with confidentiality and security standards. Data transfers use end-to-end encryption and secure transmission protocols, and sharing is limited to operational, service delivery, or regulatory purposes — never for commercial exploitation.

7. CONSUMER BILLING, CHARGING, COLLATION & CREDIT PRACTICE

7.1 Billing Information

Bergen Horn Limited shall ensure that all consumer bills, whether physical or electronic, contain complete and accurate billing details. Each bill shall include, at a minimum:

  • Billing Name: Full registered name of the customer or account holder.
  • Billing Address: Customer’s designated contact or mailing address (physical or electronic).
  • Billing Period: Clear indication of the service period covered by the charges.
  • Billing ID/Account Number: A unique identifier that allows tracking and reconciliation.y
  • Customer Service Contact: Email and/or phone number for billing inquiries and dispute resolution.

7.2 Timing of Bill Issuance

Bills shall be generated, verified, and issued within ten (10) days of the closure of each billing cycle. Bergen Horn Limited’ billing department shall implement automated and manual controls to ensure accuracy, timeliness, and integrity of all issued bills.

7.3 Receipts & Consumer Payment Verification

Upon receipt of payment, customers shall receive an electronic or printed acknowledgment (receipt) showing the following:

  • Payment date and reference number.
  • Payment amount and method.
  • Outstanding balance (if any).

Customers must be able to verify their payment on the subsequent bill, ensuring traceability and continuity. Bergen Horn Limited will maintain complete transaction logs to enable seamless reconciliation between customers, service providers, and mobile network operators (MNOs).

7.4 Billing Frequency and Notifications

Bergen Horn Limited shall maintain consistent billing frequency in line with customer agreements. Any changes to the billing period or method will be communicated to consumers in writing at least sixty (60) days prior to implementation. Such notification shall clearly state:

  • The reason for the change.
  • The effective date.
  • Any impact on service continuity or payment schedule.

7.5 Prepaid Services

Bergen Horn Limited shall ensure all prepaid services are delivered promptly upon successful billing activation. Consumers shall receive clear information about service charges, validity periods, and limits prior to activation. All unused value associated with prepaid services shall be preserved and made available to the consumer within the applicable validity period.