Regulatory Compliance

1 Corporate Existence & Legal Status

TRIFIX ARTISAN NETWORK LTD (hereinafter referred to as "Trifix" or "the Company") is a private company limited by shares, duly incorporated in the Federal Republic of Nigeria under the Companies and Allied Matters Act (CAMA) 2020, with Registration Number RC: [CAC Registration Number].

As a registered legal entity, Trifix possesses the capacity to:

• Enter into legally binding contracts with Clients, Artisans, and third-party service providers;
• Sue and be sued in its corporate name;
• Own property and assets in its own right;
• Maintain corporate bank accounts and process payments through licensed financial intermediaries.

This corporate structure provides Clients and Artisans with a higher degree of accountability and recourse compared to informal or unregistered marketplace operators.

2 Artisan Vetting & Background Verification

Trifix employs a multi-layered vetting protocol designed to mitigate risks associated with engaging independent service providers. While no vetting process can eliminate all risks, our procedures align with industry best practices and Nigerian legal standards for identity verification.

2.1 Mandatory Verification Requirements

All Artisans must undergo and pass the following minimum checks prior to activation on the Platform:

• Government-Issued Identity Verification: Artisans must provide a valid National Identification Number (NIN), Nigerian Driver's Licence, or International Passport. We verify this information against issuing authority databases where accessible.
• Facial Biometric Matching: A live photograph is captured and compared against the submitted ID document to prevent identity fraud and impersonation.
• Address Verification: Artisans must provide a verifiable residential or business address within their service area.
• Skills Assessment: Depending on the service category, Artisans may be required to demonstrate competency through practical assessments, certification verification, or portfolio review.

2.2 Enhanced Due Diligence (High-Risk Services)

For services involving significant property access, high-value installations, or sensitive environments (e.g., electrical, plumbing, security installations), Trifix may require additional safeguards, including:

• Provision of credible guarantors who are verified Nigerian residents;
• Criminal background checks through authorized channels, where legally permissible and with the Artisan's explicit consent;
• Verification of relevant trade certifications or licenses (e.g., NEMSA certification for electricians, COREN registration for engineers).

3 Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF)

Trifix is committed to preventing the use of its Platform for money laundering, terrorist financing, or other illicit financial activities. We have implemented an AML/CFT Compliance Programme in accordance with:

• The Money Laundering (Prohibition) Act, 2011 (as amended);
• The Terrorism (Prevention) Act, 2011 (as amended);
• Central Bank of Nigeria (CBN) AML/CFT Regulations for Other Financial Institutions;
• Special Control Unit Against Money Laundering (SCUML) guidelines.

3.1 Know Your Customer (KYC) Procedures

We apply a risk-based approach to KYC, which includes:

• Customer Identification Programme (CIP): Collection and verification of full name, date of birth, residential address, and government-issued ID for all Users (both Clients and Artisans).
• Transaction Monitoring: Automated monitoring of transaction patterns to detect unusual or suspicious activity (e.g., unusually large transactions, rapid successive high-value bookings, structuring).
• Enhanced Due Diligence (EDD): Applied to Users deemed higher risk, including Politically Exposed Persons (PEPs) and Users from high-risk jurisdictions.
• Suspicious Transaction Reporting (STR): We are obligated to report any suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) without notifying the affected User.

3.2 SCUML Registration

As a Designated Non-Financial Business and Profession (DNFBP), Trifix is in the process of registering with the Special Control Unit Against Money Laundering (SCUML) under the Economic and Financial Crimes Commission (EFCC). Upon registration, our SCUML certificate will be displayed here.

4 Payment Processing & Escrow Compliance

Trifix is not a bank, deposit-taking institution, or payment service provider. We do not hold Client funds directly. All payment processing, Escrow management, and payout services are facilitated exclusively through our licensed third-party payment partners:

Our payment partners operate under strict regulatory oversight from the Central Bank of Nigeria and are compliant with:

• Payment Card Industry Data Security Standard (PCI-DSS) Level 1;
• CBN Guidelines on Electronic Payments;
• CBN Guidelines on Transaction Switching Services.

Trifix's role is limited to instructing our payment partners to hold funds in a segregated Escrow account pending job completion and to release funds upon receipt of a valid Completion Code or resolution of any dispute. Trifix does not commingle Client funds with its operating capital.

5 Tax Compliance

TRIFIX ARTISAN NETWORK LTD is registered for tax purposes with the Federal Inland Revenue Service (FIRS) and the Akwa Ibom State Internal Revenue Service. Our Tax Identification Number (TIN) is [TIN Number].

We comply with all applicable Nigerian tax laws, including:

• Companies Income Tax Act (CITA): We file annual corporate income tax returns and pay assessed taxes.
• Value Added Tax Act (VATA): VAT is charged on our service fees where applicable and remitted to FIRS.
• Personal Income Tax Act (PITA): Artisans are independent contractors responsible for their own tax obligations. However, Trifix maintains transaction records and may be required to report Artisan earnings to tax authorities in compliance with future regulations (e.g., the Finance Act).
• Tertiary Education Trust Fund (TETFund): Applicable levies are deducted and remitted as required by law.

We maintain accurate books of account and transaction records for a minimum period of six (6) years in compliance with CAMA and FIRS requirements.

6 Health, Safety & Environment (HSE) Standards

Trifix is committed to promoting a safe working environment for both Clients and Artisans. While we do not directly supervise or control the work of independent Artisans, we require all Artisans to acknowledge and adhere to fundamental safety protocols as a condition of Platform access.

6.1 Artisan Obligations

Artisans on the Trifix Platform are required to:

• Use appropriate Personal Protective Equipment (PPE) relevant to their trade (e.g., gloves, safety goggles, hard hats, insulated tools for electrical work);
• Comply with all applicable safety regulations under the Factories Act and other relevant legislation;
• Refrain from working under the influence of alcohol, drugs, or any substance that may impair judgment or performance;
• Immediately report any accidents, injuries, or unsafe conditions encountered during a job to Trifix and the Client;
• Maintain their own tools and equipment in safe working condition.

6.2 Client Obligations

Clients engaging services through Trifix are expected to:

• Provide a safe and accessible working environment for the Artisan;
• Inform the Artisan of any known hazards on the premises (e.g., exposed wiring, gas leaks, structural weaknesses, aggressive pets);
• Ensure children and pets are kept away from the work area;
• Not request or pressure an Artisan to perform work that is illegal, unsafe, or outside the scope of their verified expertise.

6.3 Insurance

Artisans are independent contractors and are not covered by Trifix's corporate insurance policies. Artisans are strongly advised, but not required, to maintain their own appropriate insurance coverage, including public liability insurance and, where applicable, professional indemnity insurance. Clients are advised to verify their own home or business insurance coverage before engaging any service provider.

7 Consumer Protection Compliance

Trifix is committed to fair and transparent dealings with Consumers (Clients) in accordance with the Federal Competition and Consumer Protection Act (FCCPA) 2018 and the oversight of the Federal Competition and Consumer Protection Commission (FCCPC).

Our consumer protection measures include:

• Transparent Pricing: Service fees and estimated costs are disclosed to Clients before booking confirmation. No hidden charges.
• Escrow Protection: Funds are held securely and only released upon satisfactory job completion, protecting Clients from paying for unrendered services.
• Dispute Resolution Mechanism: A structured process for resolving disputes between Clients and Artisans, with Trifix acting as a neutral facilitator.
• Right to Cancel: Clients may cancel bookings subject to the cancellation policy outlined in our Terms of Service.
• Complaint Handling: A dedicated channel for consumer complaints, with a commitment to acknowledge complaints within 48 hours and resolve them within 14 business days.

Consumers who are dissatisfied with Trifix's resolution of a complaint retain the right to escalate the matter to the FCCPC via their official channels (fccpc.gov.ng).

8 Intellectual Property & Platform Integrity

Trifix respects the intellectual property rights of others and expects Users to do the same. We comply with the Nigerian Copyright Act and the Trademarks Act.

• All content, trademarks, logos, and software on the Trifix Platform are owned by or licensed to Trifix and are protected by Nigerian and international IP laws.
• Users may not copy, reproduce, distribute, or create derivative works from Trifix IP without express written permission.
• We respond to valid notices of alleged copyright infringement in accordance with applicable law.
• Users are prohibited from uploading content that infringes third-party IP rights.

9 Regulatory Inquiries & Cooperation

Trifix cooperates fully with all lawful requests and inquiries from Nigerian regulatory and law enforcement agencies, including but not limited to:

• Economic and Financial Crimes Commission (EFCC);
• Independent Corrupt Practices and Other Related Offences Commission (ICPC);
• Nigeria Police Force (NPF);
• Federal Competition and Consumer Protection Commission (FCCPC);
• National Information Technology Development Agency (NITDA);
• Federal Inland Revenue Service (FIRS);
• Corporate Affairs Commission (CAC).

We may disclose User information to such agencies when required by law, court order, or in the good-faith belief that such disclosure is necessary to comply with legal process, protect the safety of individuals, or address fraud or security issues.

10 Future Regulatory Developments

The regulatory landscape for digital platforms and gig-economy marketplaces in Nigeria is evolving. Trifix actively monitors developments, including:

• The proposed Nigeria Data Protection Act;
• Potential sector-specific regulations for gig platforms;
• CBN guidelines on digital lending and Escrow services;
• FCCPC guidelines on digital marketplace conduct.

We are committed to adapting our policies and practices to maintain full compliance with all applicable laws and regulations as they come into effect.

11 Reporting Violations & Whistleblowing

Trifix maintains a zero-tolerance policy for fraud, corruption, bribery, and violations of applicable laws or regulations. We encourage Users, employees, and the public to report any suspected misconduct, including:

• Attempts to bypass the Platform's payment system (circumvention);
• Fraudulent job postings or completion codes;
• Bribery or kickback requests by any User;
• Safety violations or unsafe working conditions;
• Discrimination or harassment;
• Data privacy breaches.

Reports may be submitted confidentially to our Compliance Officer: