SENDAM PLATFORM COMPLIANCE POLICY

This Compliance Policy outlines the operational, legal, and communication practices adopted by Sendam Technologies to ensure that its asset co-ownership and lease platform remains compliant with Nigerian laws and regulations, including but not limited to the Investment and Securities Act (ISA), the SEC Rules, and consumer protection frameworks.

1. NATURE OF THE PLATFORM

1.1 Sendam is not an investment company and does not offer investment products.

1.2 The platform facilitates the co-ownership of tangible gym equipment which is leased to partner gyms.

1.3 Monthly earnings are usage-based lease payouts and are not guaranteed profits or returns on investment.

2. OWNERSHIP STRUCTURE

2.1 Users on the platform are registered as co-owners of specific gym equipment.

2.2 Each user's ownership share corresponds directly to their monetary contribution and is digitally recorded.

2.3 Equipment is tagged and tracked to ensure accountability and transparency.

3. LEASING AND EARNINGS

3.1 All equipment is leased to operational gyms by Sendam, acting as a leasing agent.

3.2 Users receive a flat monthly payout (e.g., 2.5% of their purchase amount) as lease revenue.

3.3 Payouts are based on pre-agreed usage metrics, not investment performance or profit realization.

4. TERMINOLOGY USAGE

4.1 The following terms are prohibited on the platform and in all marketing materials: 'invest', 'investment', 'ROI', 'returns', 'yield', 'dividends'.

4.2 Approved alternatives include: 'own', 'co-own', 'lease payout', 'usage earnings', and 'equipment share'.

4.3 This is to ensure the platform is not misconstrued as an investment offering under Nigerian law.

5. EXIT AND SELL-OFF

5.1 Users may exit by selling off their share through the 'Sell-Off' feature on the Sendam App.

5.2 Sell-off values are based on equipment depreciation and usage, not market speculation.

5.3 Proceeds are remitted within 7 business days of confirmation.

6. LEGAL COMPLIANCE

6.1 Sendam consults licensed legal professionals to ensure all documents and processes comply with the Investment and Securities Act (ISA) and SEC Rules.

6.2 All agreements are provided in writing and accepted digitally by users.

6.3 Data protection and consumer rights are also observed under the Nigeria Data Protection Regulation (NDPR).

7. DISCLAIMER

7.1 Sendam is not a capital market operator.

7.2 Users are not investing in securities or financial instruments but co-owning physical assets for operational lease.

7.3 Earnings are based on lease terms and asset usage, not speculative investments.