Anti-Racism Policy

COMMITMENT TO ANTI-RACISM POLICY

1. Introduction
Vezeti Services Limited is committed to fostering an inclusive, equitable, and anti-racist
environment in all aspects of our operations. We recognize that systemic racism and racial
discrimination persist globally and must be actively dismantled. This policy reaffirms our
dedication to upholding human rights, promoting diversity, and ensuring fairness in our
interactions with employees, customers, suppliers, and government entities—both locally
and internationally.

Vezeti, a telecommunications company licensed in the USA and operating in the United
Kingdom under the same brand name, understands the challenges of working in a multiracial environment. To promote equality and inclusion, Vezeti has adopted this policy in
Nigeria for best global practice.

This policy aligns with:
• The United Nations Universal Declaration of Human Rights (UDHR, 1948)
• The International Convention on the Elimination of All Forms of Racial
Discrimination (ICERD, 1965)
• The African Union’s Agenda 2063 (aspiring for an Africa free from discrimination)
• The Nigerian Constitution (1999, as amended) – particularly Section 42, which
prohibits discrimination based on race, ethnicity, or place of origin.
• The Nigerian Anti-Discrimination Act (2018), which explicitly prohibits racial
discrimination in employment and service provision.

2. Policy Statement
Vezeti has zero tolerance for racism, racial discrimination, xenophobia, or any form of
prejudice.

We commit to:
• Ensuring equal opportunities in employment, promotions, and professional
development: Vezeti guarantees that all employment decisions—including
recruitment, compensation, training, promotions, and career advancement—are
based solely on merit, qualifications, and performance, without regard to race,
ethnicity, nationality, or any other discriminatory factor. We actively monitor
workforce diversity, implement unbiased hiring practices (such as blind recruitment
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where applicable), and provide mentorship programs to ensure equitable growth
opportunities for all employees.

Additionally, we regularly review promotion
criteria and leadership pipelines to dismantle systemic barriers, fostering a
workplace where talent thrives in an environment of fairness and inclusion.

• Providing services without bias or discrimination based on race, ethnicity, or
nationality: Vezeti is committed to delivering fair, respectful, and unbiased
services to all clients, partners, and stakeholders, irrespective of race, ethnicity,
nationality, or cultural background. We strictly prohibit any form of racial profiling,
discriminatory treatment, or exclusionary practices in customer interactions, service
delivery, or access to company resources. Our staff undergo regular training to
recognize and eliminate unconscious bias, ensuring that every engagement—
whether in person, online, or through third-party channels—reflects our core
values of equality and inclusion.

Additionally, we implement transparent service
protocols and feedback mechanisms to promptly address and rectify any concerns
related to discrimination, upholding our pledge to provide equitable and dignified
service to all
• Engaging with suppliers, partners, and government bodies in a manner that
respects diversity and inclusion.
• Regularly reviewing our policies and practices to eliminate systemic barriers.

3. Scope
This policy applies to:
• All employees, contractors, and board members of Vezeti.
• All business operations, including recruitment, customer service, procurement, and
partnerships.
• Interactions with local and international stakeholders, including government
agencies.

4. Prohibited Conduct
Racist behavior—whether explicit or implicit—will not be tolerated.

Prohibited conduct
includes but is not limited to:
• Racial slurs, derogatory remarks, or jokes: Vezeti maintains a strict zero tolerance policy against racial slurs, derogatory remarks, or jokes in any form—
whether verbal, written, or digital. Such behavior, whether intentional or casual,
fosters a hostile environment and undermines our commitment to inclusivity and
mutual respect. This prohibition applies to all workplace interactions, company
communications, customer engagements, and external partnerships. Any violation,
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including racially insensitive ‘humor’ or coded language, will be treated as
misconduct and subject to immediate disciplinary action, up to and including
termination of employment or contract.

We encourage all employees and
stakeholders to speak up against such behavior through our confidential reporting
channels, ensuring a safe and dignified environment for everyone
• Discriminatory hiring, promotion, or service denial based on race: Vezeti
prohibits any form of discriminatory practices in hiring, promotions, or service
provision based on race, ethnicity, or national origin. Our recruitment and career
advancement processes are designed to evaluate candidates solely on their
qualifications, skills, and merit, with zero tolerance for bias or prejudice.

We
implement structured interviews, diverse hiring panels, and regular audits of
promotion decisions to ensure fairness and transparency at all levels. Similarly, our
service delivery standards mandate equal treatment for all clients, with no denial
or alteration of services permitted on racial grounds. Any verified instance of racial
discrimination in employment decisions or customer service will result in
immediate corrective action, including potential termination and legal
consequences, as we uphold our commitment to being an equitable and anti-racist
organization.
• Unfair treatment of suppliers or business partners due to racial bias: Vezeti
unequivocally condemns any unfair treatment of suppliers, vendors, or business
partners motivated by racial bias or discriminatory practices. Our procurement and
partnership decisions are based strictly on objective criteria including quality, value,
reliability, and contractual compliance, without regard to race, ethnicity, or national
origin. We actively monitor our supply chain relationships through diversity audits
and require all employees involved in vendor selection to complete anti-bias
training. Any instance of preferential treatment or exclusion rooted in racial
prejudice will be thoroughly investigated and addressed through immediate
corrective measures, including contract termination where appropriate.

We
encourage suppliers and partners to report any concerns through our dedicated
ethics hotline, as we strive to build business relationships that reflect our core
values of fairness, inclusion, and mutual respect in every market where we operate.
• Retaliation against individuals who report racism: Vezeti strictly prohibits any
form of retaliation – including intimidation, harassment, demotion, termination, or
unfavorable treatment – against employees, customers, suppliers, or stakeholders
who report incidents of racism, file discrimination complaints, or participate in
related investigations. We recognize that fear of retaliation often prevents
individuals from speaking up, and we actively foster a culture of protection and
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support for whistleblowers. All retaliation claims will be treated with equal
seriousness as the original discrimination complaint, investigated promptly and
independently, and met with appropriate disciplinary action against perpetrators,
up to and including termination of employment or contracts. Our anti-retaliation
protections extend to all reporting channels, whether internal (HR department,
managers) or external (regulatory bodies, civil rights organizations), ensuring
comprehensive safeguards for those who courageously uphold our commitment
to racial equity.

5. Reporting & Accountability

5.1 Reporting Mechanism
Employees, customers, or partners who experience or witness racism are encouraged to
report via:
• Email: admin@vezeti.com
• Anonymous Hotline: 0201 887 1515 (+234-201-887-1515)
• HR Department: Direct reporting to Human Resources.

5.2 Investigation & Disciplinary Actions
• All reports will be investigated promptly and confidentially. All reports of racism,
discrimination, or retaliation will be investigated promptly, thoroughly, and with
strict confidentiality to protect all parties involved. Vezeti ensures that
investigations are conducted by trained, impartial personnel following
standardized protocols that respect due process while safeguarding whistleblower
identities to the fullest extent possible. We maintain secure, encrypted systems for
report documentation and limit information access strictly to those directly
involved in resolution. Throughout the process, we balance transparency of
outcomes with privacy rights, disclosing findings only to necessary stakeholders
while providing anonymous aggregate reporting to demonstrate our
accountability. Any breach of confidentiality by staff during investigations will itself
be treated as a serious policy violation. We commit to completing initial
investigations within 14 business days when possible, with regular updates
provided to complainants about case status, while always complying with
applicable data protection laws including Nigeria’s Data Protection Act (2023) and
GDPR requirements for international operations.
• Perpetrators will face disciplinary action, up to and including termination or
contract termination. Vezeti enforces strict consequences for verified acts of racism,
discrimination, or retaliation, with disciplinary actions tailored to the severity of the
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offense while maintaining principles of progressive discipline where appropriate.
Perpetrators may face sanctions ranging from mandatory anti-bias training and
formal warnings for minor first offenses, to suspension without pay, demotion, or
immediate termination for serious or repeated violations. In cases involving
suppliers or business partners, corrective measures include contract renegotiation
with diversity clauses, probationary status with monitoring, or permanent
termination of the business relationship.

All disciplinary decisions are documented
in accordance with Nigerian labor laws (particularly Section 254C of the Labor Act)
and our internal policies, with a right to appeal through our grievance procedure.

We maintain consistency in enforcement across all organizational levels, ensuring
that leadership is held to the same – if not higher – accountability standards as
other employees when addressing discriminatory conduct.
• False accusations made in bad faith will also be addressed under company policy.
Vezeti recognizes that false accusations of racism or discrimination made
maliciously or in bad faith can undermine trust in our reporting systems and harm
innocent individuals. Any claim found to be intentionally fabricated or misleading
after thorough investigation will itself be treated as a serious violation of company
policy, subject to disciplinary action up to and including termination. However, we
maintain a critical distinction between false allegations made with malicious intent
and unsubstantiated reports made in good faith – only deliberate dishonesty, not
honest disagreements or inconclusive findings, will incur consequences. This policy
is implemented in accordance with Section 375 of the Nigerian Criminal Code (on
false accusations) while carefully balancing our commitment to encouraging
legitimate reporting. All determinations of bad faith will require conclusive
evidence reviewed by both legal and HR leadership before any disciplinary
measures are taken.

6. Training & Awareness
• Mandatory anti-racism training for all employees annually.

1. Vezeti requires all employees to complete comprehensive anti-racism training
annually, ensuring continuous education on racial equity, unconscious bias, and
inclusive workplace practices.
2. These mandatory sessions cover topics such as microaggressions, systemic
racism, and all ship, equipping staff with tools to foster a discrimination-free
environment.
3. Training is tailored for different roles, with leadership modules addressing bias
in decision-making and frontline employee workshops focusing on inclusive
customer interactions.
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4. Completion is tracked as part of performance evaluations, with non-compliance
resulting in restricted access to promotions or bonuses until fulfilled.
5. We regularly update training content to reflect evolving best practices,
incorporating feedback from employees and global anti-racism frameworks to
ensure relevance and impact.
• Regular workshops on unconscious bias and cultural competency. Vezeti conducts
regular, interactive workshops on unconscious bias and cultural competency to
deepen employees’ understanding of systemic inequities and foster an inclusive
workplace. These sessions utilize real-world scenarios, self-assessment tools, and
group discussions to help staff recognize and mitigate hidden prejudices in
decision-making, collaboration, and customer engagement. Department-specific
modules address unique challenges (e.g., bias in recruitment for HR teams,
inclusive marketing practices for creative teams), while cross-functional workshops
promote enterprise-wide learning. Participation metrics and pre-/post-training
assessments are analyzed to measure behavioral shifts and identify knowledge
gaps. We may collaborate with certified diversity practitioners and anti-racism
organizations if need be to ensure content aligns with global standards (e.g., UN
Sustainable Development Goal 10) while remaining contextually relevant to our
African operations.”
• Public commitment to anti-racism through corporate communications and
partnerships with civil rights organizations.

7. Supplier & Partner Engagement
We will:
• Prioritize suppliers who demonstrate a commitment to diversity and anti-racism.
• Include anti-discrimination clauses in all contracts.
• Cease business with entities found engaging in racist practices.

8. Compliance with Laws
Vezeti adheres to:
• Nigerian Anti-Discrimination Act (2018)
• African Charter on Human and Peoples’ Rights (Article 2 & 19 – nondiscrimination)
• UN Guiding Principles on Business and Human Rights

9. Policy Review
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This policy will be reviewed annually to ensure alignment with evolving best practices
and legal standards.

10. Leadership Commitment
The Board of Directors and Executive Management of Vezeti fully endorse this policy and
will ensure its implementation at all levels.

Approved by:
Nosakhare Philip Evbuomwan
Chief Pricing and Strategy Officer
Vezeti Services Limited
Date: August 18th 2022