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.


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 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.

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, 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 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 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 measure

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.
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
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:
The Board
Vezeti Services Limited
Date: August 18th 2022