AIRTEL MONEY SHOP DEALER AGREEMENT

BETWEEN

Airtel Mobile Commerce Zambia Limited

And

(Name)
___________________________________

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 AIRTEL MONEY SHOP DEALER AGREEMENT

This Agreement is made the ……………. day of……………….201……

1.0 PARTIES

AIRTEL MOBILE COMMERCE ZAMBIA LIMITED, a company incorporated under the

Companies Act and whose registered office is at Airtel House Corner of Addis Ababa Drive and Great
East Roads, Lusaka in the Republic of Zambia (Hereinafter referred to as the “Airtel Money” which
expression shall include its successors in title and permitted assigns) of the first part

AND

…………………………………………………. of……………………………………
…………………………………………………………………………………………
………………………….. (Hereinafter referred to as “The “DEALER” which expression shall
include its successors in title and permitted assigns) of the second part;

WHEREAS

1.1 Airtel Money is duly licensed to operate a Payment System under the National Payments Systems
Act No. 1 of 2007 under the laws of Zambia to perform money transfer services in Zambia.

1.2 The DEALER desires to establish and operate a Business and for this purpose to use Airtel Money
’s business system and Intellectual Property rights.

1.3 Airtel Money hereby licenses such use to the DEALER, subject to the terms and conditions
of this Agreement.

1.4 Airtel Money and the DEALER have entered into a tripartite lease agreement (the “Lease”) with
a third party landlord (the “Landlord”) for shop number _____________ (the “Airtel Money
Shop”) to be used by the DEALER for the sale and promotion of Airtel Money products and
services.

2. Grant of License

Airtel Money hereby grants to the DEALER a license to operate the Airtel Money Shop
Business, sell Airtel Money Products and Services and use the Airtel Money Intellectual
Property together with Airtel Money’s business system strictly in accordance with the terms
and conditions of this Agreement.

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3. TERM

This Agreement will commence with effect from the date the last signature is appended to this
agreement, and shall terminate after a period of 3 (Three) years subject to the DEALER’s
performance or upon termination in accordance with the provisions of this Agreement.

4. FRANCHISE FEE

4.1 As a precondition to the commencement of this Agreement, the DEALER shall be expected to
make non-refundable capital contribution of K__________________________ only to Airtel
Money on the date of the last signature of this Agreement. Should this fee remain unpaid by
such date, Airtel Money shall have the right to terminate this Agreement.

4.2 The DEALER shall furnish details of payment to Airtel Money for confirmation of receipt of
payment and Airtel Money shall confirm receipt of this payment to the DEALER in writing.

4.3 Airtel Money shall make sufficient Investment in Capital Expenditure in the Airtel Money Shop
to bring it to operational standard as per Airtel Money brand guidelines.

5. SCOPE OF DEALER’S SERVICES

5.1 The DEALER undertakes, in accordance with the terms of this Agreement. to:

5.1.1 Use its best endeavors to activate new customers and agents for the Airtel Money
Services;
5.1.2 Facilitate and undertake Cash-in Transactions and Cash-out Transactions for both
customers and Airtel Money Agents pursuant to Annexure B;
5.1.3 Purchase E-value and distribute it amongst the Agents located within the DEALER’s
zone;

5.2 Perform such other services and functions ancillary to the above in connection with the Airtel
Money Services as may be specified by Airtel Money from time to time.

5.3 The DEALER shall for the duration of this Agreement exclusively sell Airtel Money services
(the “Services”) and shall not deal in any other mobile money operators in the Airtel Money
Shops.
5.4 Airtel Money shall reserve the right to terminate this Agreement forthwith in the event that
the DEALER is in breach of the conditions of this clause.

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6. LEASED PREMISES

6.1 The DEALER shall be responsible for the timely payment of the rentals to the Landlord of the
premises.

6.2 In the event that this agreement is terminated, the DEALER shall have no claim over the fittings
and furniture in the leased premises and these shall remain the property of Airtel Money subject
to clause 6.4.

6.3 Where the Lease in respect of the Airtel Money Shop is terminated less than one (01) year after
the effective date of this Agreement, (by the DEALER or by the Landlord, due to default by
the DEALER), the DEALER shall be obligated to pay the Landlord Six (06) months rentals
notwithstanding the refund of the Franchise Fee due to it pursuant to clause 4.4.

6.4 The DEALER shall ensure that all the necessary written approvals are obtained from the Landlord
before any work can be commenced on the Airtel Money Shop.

7. OBLIGATIONS OF AIRTEL MONEY

7.1 Airtel Money will at its own cost ensure that the Airtel Money Shop operated by the DEALER is
provided with appropriate outside brand visibility which may include articles such as a wall
paper, fascia painting and ABS boards and other such branding materials as Airtel Money may
deem fit.

7.2 Airtel Money, in consultation with the DEALER, will, from time to time, as necessary, determine
which of the DEALER's employees will undergo training in the Airtel Money Business System
(the length, frequency and nature of which shall be determined by Airtel Money in its sole
discretion from time to time). This training will take place at the commencement of this
Agreement, and whenever deemed necessary by Airtel Money, at a place chosen by Airtel
Money. The extent and duration of any training will be determined by Airtel Money.

7.3 To pay all commissions due to the DEALER as an aggregate of all shops operated, once a month
upon provision of such consolidated invoice tabulating all commissions due for that month.
All fees and commission will be paid in accordance with annexure B as amended from time to
time at Airtel Money’s sole discretion.

7.4 Airtel Money shall at all times reserve the right to withhold commissions or to set-off from future
commissions due where it is found that the DEALER had fraudulently claimed and been paid
commissions.

7.5 Airtel Money shall ensure that the DEALER’s SIM card is enabled to perform the relevant
functionality with respect to the performance of the services under this Agreement.

7.6 Airtel Money reserves the right to disable the DEALER’s SIM Card or otherwise disconnect the
DEALER from the Airtel Money System at any time if it determines, at its sole discretion, that
the DEALER’s SIM Card or connectivity is being used unlawfully or for purposes other than

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 in connection with the Airtel Money Services or that the DEALER is not complying with the
terms of this Agreement and/or the Airtel Money DEALER Manual.

7.7 Airtel Money excludes warranties of all kinds to the extent permissible by law and shall not be
liable for any costs, loss, liability or damage whether direct, special or consequential whatsoever
and howsoever arising whether from any suspension or termination of this Agreement or
otherwise provided due notice of suspension or termination has been provided to the
DEALER.

7.8 Airtel Money will provide the relevant equipment and o the DEALER as soon as is practicable
after execution of this Agreement.

7.9 Airtel Money shall have the right at any time during the Contract Period to inspect the DEALER’s
business premises, Outlets and business operations so far only as it relates to the services herein
to ensure compliance with the terms of this Agreement provided that advance written notice
of inspection is provided to the DEALER and that the inspection is carried out at reasonable
hours.

7.10 Airtel Money reserves the right to vary the terms of the Airtel Money DEALER Manual and the
rates at which the Commission is payable at any time and for any reason whatsoever. Variations
will be notified by way of letter, Agent Bulletin; advertisement in a daily newspaper, or on Airtel
Money’s Website and/or by using any other suitable means and the DEALER shall be deemed
to have been notified of any such variations whether or not they have actually come to the
DEALER’s attention. By continuing to use the DEALER’s SIM Card after any such variation
the DEALER shall be deemed to have agreed to the variations.

8. OBLIGATIONS OF THE DEALER

8.1 The DEALER will operate the Airtel Money Shop business strictly in accordance with the Airtel
Money business system and will ensure strict adherence to the Airtel Money requirements,
supplemented by any specifications and directions, written or otherwise, as may be laid down
or given by Airtel Money from time to time. The DEALER will have the right to use, and
undertakes to use, the Intellectual Property in relation to the Airtel Money Shop business,
provided that the DEALER conducts the Airtel Money Shop Business strictly in accordance
with the terms of this Agreement and the Airtel Money business system.

8.2 The DEALER will maintain sufficient float and cash as prescribed by Airtel Money to service
agents.

8.3 The DEALER will maintain sufficient float and cash as prescribed by Airtel Money to service end
customers.

8.4 The DEALER will not do, cause or permit anything to be done which may adversely affect the
Intellectual Property or the Proprietor’s or Airtel's rights in the Intellectual Property. The
DEALER will forthwith bring to the attention of Airtel Money, any infringement of the
Intellectual Property that may come to its attention. The DEALER will give all reasonable
assistance to Airtel Money to enable the latter to further or defend its rights in the Intellectual
Property.

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8.5 The DEALER acknowledges and confirms that Airtel is the owner or licensee of all rights of
whatever nature in the Intellectual Property including all additions, modifications, changes or
updates to the Business System and the Intellectual Property, and that it has no claims of any
nature to either the Business System or to any element of the Intellectual Property.

8.6 The DEALER shall not allow onto the Premises, any Mobile Money products which have not
been authorized by Airtel Money.

8.7 The DEALER agrees to comply in all respects and at all times with its obligations as set out in
this Agreement and to follow all procedures laid down herein and in the Airtel Money
DEALER Manual.

8.8 The DEALER shall ensure that at all times during the Contract Period the Balance shall not fall
below the Minimum Balance.

8.9 The DEALER shall use its best efforts to ensure that they are in a position to undertake Cash-in
Transactions and Cash-out Transactions requested by Customers at all times during the
Contract Period.

8.10 In order to facilitate Cash-in Transactions, the DEALER shall ensure that the Balance does not
fall below the Minimum Balance and in the event that the Balance does fall below the Minimum
Balance, the DEALER shall immediately effect a Payment of a sufficient amount of money to
raise its Balance to at least the Minimum Balance.

8.11 In order to facilitate Cash-out Transactions, the DEALER shall ensure that all times he maintains
a minimum Float of Zambia Kwacha………………... and Cash of
……………………………. or such other amount as may be specified by Airtel Money from
time to time.

8.12 The DEALER must ensure that in undertaking any Cash-out Transactions, cash payments are
only made:

(a) Upon sufficient sums being available in its Cash Float,

(b) Upon checking the accuracy and completeness of the relevant Confirmation SMS, and
(c) Upon being satisfied that the recipient of the cash payments is the owner of the mobile
Phone on which the relevant Airtel Money Instruction with respect to the Cash-Out
Transaction is being transmitted by verifying the Customer’s ID against the details provided
in the Confirmation SMS.

8.13 In the event that the DEALER has insufficient cash funds available in his Cash Float
to effect a Cash-out Transaction, it must decline to carry out the Cash-out Transaction

8.14 All Equipment supplied to the DEALER by Airtel Money pursuant to the delivery of
the Airtel Money Services shall remain the property of Airtel Money and Airtel Money
shall replace any lost Equipment or Equipment damaged by wear and tear except where
such loss or damage was caused by the DEALER’s neglect or lack of care.

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8.15 Notwithstanding the clause above, the DEALER shall keep and maintain all
Equipment and the Mobile Equipment in working order to the best of its ability, for
use only for the purposes of facilitating the DEALER Services and in connection with
the Airtel Money Services and shall ensure that any damage to or loss or theft of the
Equipment is immediately reported to Airtel Money, forthwith and in any event within
Twenty-four (24) hours after the occurrence of such damage loss or theft. The
DEALER shall indemnify Airtel Money against all claims, costs and consequences that
may arise as a result of any breach of this clause.

8.16 The DEALER shall only use the Airtel Money Trademarks for the purposes of
promoting the Airtel Money Services and for providing the DEALER Services during
the Contract Period and for no other purpose whatsoever.

8.17 The DEALER shall at all times comply with the terms of this Agreement and the
procedures set out in the Airtel Money DEALER Manual as updated from time to
time.

8.18 The DEALER shall notify Airtel Money of any event or circumstance that may have a
material adverse effect on the DEALER’s business and its ability to perform its
obligations hereunder immediately and in any event within Five (5) calendar days of the
occurrence of such event or circumstance.

8.19 The DEALER shall comply in all respects with all applicable laws, ordinances,
regulations, rules and orders applicable to it, its business and the use by it of the
Equipment and Mobile Equipment, as well as in connection with the DEALER
services including, but not limited to, any anti-money laundering and anti-terrorist
financing laws and regulations.

8.20 The DEALER shall obtain and maintain all applicable licenses and permits required to
conduct its business.

8.21 The DEALER shall not be entitled to assign this Agreement to any other person.

8.22 The DEALER shall comply with any instructions and/or directions that Airtel Money
may give the DEALER from time to time in connection with the provisions of the
DEALER Services and/or the Airtel Money Services

8.23 It is specifically agreed between the parties that the DEALER shall ensure that all
monies are stored in a safe and secure area.

8.24 The DEALER shall at its own cost, take out an insurance policy against all risks
inherent in the business which insurance policy shall as a minimum cover the
replacement/ sales value of the Products, DEALER’s premises and the persons
transacting business therein.

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9. RETENTION & SET OFF

9.1 Airtel Money shall be entitled to recover or retain from the DEALER any rebates, incentives,
special discounts and/or discounts paid or which would otherwise be payable by Airtel if in
Airtel’s reasonable opinion, such rebates, special discounts and/or discounts are not due and
payable because of gross misconduct / negligence, fraud, delayed repayment or debt,
misrepresentation or non-bonafide connections by the DEALER s or its agents/sub-agent. In
addition, in such circumstances, Airtel Money shall be entitled to set off against any further
payments due to the DEALER in terms of this Agreement, such sums of money as may be
necessary to recover any losses or damages sustained by Airtel Money as a result of the aforesaid
actions of the DEALER s or its agents referred to above.

10. NO CESSION, ASSIGNMENT, SALE OR LEASE

The rights and obligations of the DEALER are personal and may not be ceded, assigned, let
or otherwise encumbered or disposed of in any manner whatsoever without the prior written
consent of Airtel Money, nor may the DEALER at any stage appoint any agent without prior
written consent.

11. TERMINATION OF THIS AGREEMENT

11.1 Subject to clause 4.4, this Agreement may be terminated for convenience by either party by giving
the other party 90 days’ notice.

11.2 Airtel Money will be entitled to terminate this Agreement forthwith on written notice to the
DEALER in the event of any of the following and Airtel shall not be liable to pay the early
termination payment as highlighted in the clause above:

i. The DEALER in any other way breaching the terms and conditions of this Agreement, all of
which are declared to be material for the purposes of this clause, and failing so to remedy the
breach within 7 (Seven) days of written notice by or on behalf of Airtel, calling upon the
DEALER to remedy the breach complained of;

ii. If the DEALER commits an act of insolvency or is sequestrated, provisionally or finally, or is

placed under a provisional or final winding-up or receivership or if the DEALER makes an
assignment for the benefit of any of its creditors, or if the DEALER attempts to enter into
any compromise with any of its creditors, or becomes incapacitated in any way including, but
not limited to, being placed under curatorship by reason of ill health (mental or otherwise),

12. CONSEQUENCES OF TERMINATION

12.1 The terminating of this Agreement, for whatever reason, will not affect the rights of a Party
which may have accrued as at the date of termination, and will further not affect any rights and
obligations which specifically or by their nature survive the termination of this.

13. DOMICILIUM CIANDI ET EXECUTANDI

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 13.1 The Parties choose as their domicilium address for all purposes including the service of
court process the following:
Airtel: Airtel Mobile Commerce Zambia Limited
Airtel House
Stand 2375
Cnr Addis Ababa & Great East Road
P.O.Box 320001
Lusaka

Tel: +260977915000
Fax: +260979738025

AGENT: As set out in Annexure “A” clause A

13.2 A Party may change its domicilium address by giving 30 (thirty) days' written notice to
such effect to the other Party.

14. DISPUTE RESOLUTION

14.1 If the Parties are unable to resolve any dispute arising out of or in connection with this Agreement
within 7 (seven) days after such dispute having arisen or such extended time period as the
Parties may have agreed to in writing, then such dispute shall be submitted to the senior
executives/managers of the Parties who shall endeavor to resolve the dispute within 7 (seven)
days of it having been referred to them.

14.2 Should the dispute not be resolved in the aforesaid manner within 21 (twenty-one) days after the
dispute has arisen, either party shall have the discretion to refer the matter for determination
in the Courts of Law.

15. GOVERNING LAW

15.1 This contract shall be governed by thse Laws of Zambia.

16. INDEMNITY AND LIMITATION OF LIABILITY

16.1 Airtel Money will not be under any liability (excluding liability for negligence and willful conduct)
for any loss or damage or injury to the DEALER whatsoever or howsoever arising and will not
be liable for any claim whatsoever made against the DEALER by any third party.

16.2 Airtel Money shall not be under any liability for any indirect or consequential losses (whether
financial or in respect of profits, anticipated business or otherwise) costs, expenses or other
claims for consequential compensation whatsoever whether caused by the negligence of Airtel
Money, its employees or otherwise howsoever arising and whether foreseeable or not.

16.3 Save to the extent expressly provided in this Agreement, Airtel makes no warranties or
representations whatsoever in respect of the Airtel Money Services supplied by it to the

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 DEALER in terms of this Agreement. All other statutory, express, implied or tacit terms and
conditions or warranties are excluded.

16.4 The DEALER shall indemnify Airtel Money, and keep Airtel indemnified, from and against all
loss, damage or liability suffered and all costs and expenses incurred by Airtel Money as a result
of any breach of this Agreement by the DEALER including any breaches caused by any act,
neglect or default of the DEALER’s employees, or as a result of any third party claim in respect
of any matter arising from the DEALER’s conduct, provided that the liability has not been
incurred directly through any default by Airtel Money in relation to its obligations under this
Agreement.

16.5 The provisions of this clause shall survive any termination of this Agreement for any reason.

17. NO PARTNERSHIP OR AGENCY

Nothing in this Agreement shall be construed as constituting either Party as agent of the other
or granting any authority to one Party to represent the other or to give any warranties or
representations of whatsoever nature on behalf of the other or constituting a partnership
between the Parties.

18. INTELLECTUAL PROPERTY RIGHTS

18.1 Subject to clause 2 herein above, nothing in this Agreement shall give the DEALER any right in
any trade name, trademark or other intellectual property right used by Airtel in relation to the
Airtel products or Airtel services; provided that where Airtel permits the DEALER to transmit
any electronic Product into physical form, such print shall conform to Airtel’s specification and
be procured from a designated Airtel printer.

18.2 The DEALER shall promptly notify Airtel Money, immediately it comes to its notice, of any
actual, threatened or suspected infringement of any trade name, trademark or other intellectual
property right belonging to Airtel Money or of any allegation that the Airtel Money products
or services infringes, or of any intellectual property rights of any third party.

18.3 The DEALER shall take such steps as are stipulated by Airtel Money in order to protect and
maintain the intellectual property rights of Airtel Money; provided that Airtel Money shall
refund to the DEALER any reasonable expenses incurred by the DEALER in relation thereto
and provided further that Airtel Money’s prior written consent for any such costs has been
obtained.

18.4 The DEALER shall immediately upon becoming aware thereof, bring to the attention of Airtel
Money, any improper or wrongful use of Airtel Money’s intellectual property rights and shall
upon request by Airtel Money assist Airtel Money in any legal proceedings against any third
party improperly or wrongfully using such intellectual property rights. Airtel Money shall
indemnify the DEALER against any reasonable costs incurred in assisting Airtel Money in
relation to any such legal proceedings.

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18.5 The DEALER hereby agrees and confirms that any and all goodwill accruing to any of Airtel
Money trademarks or trade names by virtue of the use thereof by the DEALER in accordance
with this Agreement shall accrue to Airtel Money and that the DEALER acquires no right in
any of the said trademarks or trade names or anything so closely resembling them as to be likely
to cause confusion and the DEALER will take all reasonable steps necessary to ensure that its
employees, servants, agents and the like do not use the said trademarks or any resemblance
thereto in contravention of the terms of this Agreement.

19. CONFIDENTIALITY

19.1 Both of the parties shall throughout the terms of this Agreement and for a period of two years
after its termination, keep confidential any and all information it receives from either party in
respect of any customer. Each party shall use such information only to the extent necessary to
perform its obligations in terms of this Agreement or as may be required by law.

19.2 The DEALER acknowledges that the duties of the DEALER include a duty of confidentiality
and trust to act in the best interest of Airtel Money. Furthermore, either party shall not directly
or indirectly during the period of this Agreement procure the services of any employees of
either party, without the prior written consent of both parties.

20. FORCE MAJEURE

20.1 If and to the extent that on account of force Majeure (as hereinafter defined) any party fails to
perform any of its obligations under this Agreement, such failure shall not constitute a breach
of this Agreement provided that the other party has been notified promptly in writing of the
same. Either party shall be entitled to terminate this Agreement forthwith by written notice if
by reason of Force majeure any party is unable to perform its obligations for a period
exceeding Fifteen (15) days.

20.2 Force Majeure in this Clause means any event or circumstances (whether arising from natural
causes or otherwise) beyond the control of the party in question including (in so far as beyond
that control and without prejudice to the foregoing) strikes, lockouts or other labor disputes,
riots, civil commotion, acts of God, earthquake, fire, lighting, electrical storms, loss, delay at
sea or in air transport, equipment breakdown, war, national emergencies, prohibitive decisions
by the Government.
20.3 Termination of this Agreement shall not release either Party from payment of any sums that may
be due and owing to the other at the date of such termination.

20.4 The termination of the Agreement shall not prejudice any rights that may have accrued to Airtel
prior to the termination.

21. GENERAL

21.1 No waiver by a Party of any breach, failure or default in performance by the other Party, and no
failure, refusal or neglect by a Party to exercise any right hereunder or to insist upon strict
compliance with or performance of the other Party's obligations under this Agreement, shall
constitute a waiver of the provisions of this Agreement and a Party may at any time require
strict compliance with the provisions of this Agreement.

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21.2 This Agreement constitutes the entire agreement between the Parties who acknowledge that there
are no other oral or written understandings or agreements between them relating to the subject
matter of this Agreement. No amendment, cancellation or other modification of this
Agreement shall be valid or binding on a party hereto unless reduced to writing and executed
by both Parties hereto.

21.3 The Parties agree that each and every provision of this Agreement is severable from the remaining
provisions of this Agreement and should any provision of this Agreement be in conflict with
any applicable law, or be held to be unenforceable or invalid for any reason whatsoever, such
provision should be treated as, and shall be, severable from the remaining provisions of this
Agreement which shall continue to be of full force and effect.

21.4 The headings of the clauses are intended for convenience only and shall not affect the
interpretation of the Agreement.

In Witness Whereof: The Parties hereto through their duly authorized signatory have set their hand
the day and year first before written.

SIGNED at on this day of 201

(Signature) _______________________________________

For: (insert full name) _______________________________

Name of Signatory:
Capacity

(Signature) __________________________________________
For: Airtel Mobile Commerce Zambia Limited Name of
Signatory:
Capacity:
Annexure A
Particulars specific to the DEALER

Trading name

Full Corporate Name

Registration Number

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Airtel Money Shop Owner (full names)

ID No.

Contact numbers
Premises List of_______ number of Airtel Money shops and
locations to be given separately by DEALER on closure
in period of 30 days from start of agreement
DEALER bank account details

Airtel bank account details (For Account Name: Airtel Mobile Commerce Zambia
Purposes of Airtel Money) Limited

Domicilium

ANNEXURE B – Commissions and Penalties

1. Airtel Money Tariff and Agent Commissions

CASH OUT CUSTOMER FEE

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 TRANSACTION BAND CUSTOMER CASH AGENT COMMISSION
(ZMW) OUT FEE (ZMW)
5 - 150 2.5 1%

151 - 300 5 1%

301 - 500 10 1%

501 - 1000 20 1%

1001 - 3000 30 ZMW15

3001 - 5000 50 ZMW20

5001 – 10000 or more 100 ZMW20

Tier 2 : Dealer Commission on agent deposits

A Commission of ………..% will be paid to the Dealer on all Agent E-Value

Purchases whereas the Dealer will purchase E-value from Agents at a discount of

…… %.

2. Airtel Money Activations

The Dealer shall receive a commission of ……………. for all new Airtel Money Customer

activations that perform a Cash In transaction of at least K……. and proceed to perform

an Airtel Money Transaction of at least K……. within …………. Hours of Activation/

3. Change in Commission Structure

The Dealer acknowledges and accepts that the commission structure indicated herein

shall be subject to change at Airtel Money’s sole discretion with notice being given to

the Dealer in writing as provided in the Agreement herein.

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 4. Irregularities and Penalties

Ranking 3 Grave irregularity affecting the profitability and that affect regulatory compliance with
(high) KYC (Know your customer) regulations of Airtel Money

Ranking 2 Serious irregularity affecting the reputation and KYC regulations of Mobile
(medium) Money based on the legally binding Agreement between Airtel Money Agents and
Airtel Money Mobile Commerce Zambia Limited

Ranking 1 Irregularities demonstrating negligence of Airtel Money Agents internal processes

(low)

Offence Irregularity Implication Frequency of Agreed penalty

Ranking occurrence
3 Multiple/Direct deposits
1stoccurrance Suspend Agent line
Breaking down of deposits to Loss of revenue to performing action.
earn more commission Airtel Money Send warning letter to
Mobile Commerce Company proprietor
Facilitating customers’ Direct Zambia Limited detailing results of
Deposits to avoid charges/ or investigation
because customer is not Reverse revenue
registered underserved from specific
Agent line

2ndOccurranc
Share detailed report of
e investigation

25% deduction
Penalize Agent(proprietor)
with on end
month commission

3rd
Blacklist the Agent
Occurrence

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3 Fraud
Not providing float despite
customer giving cash/emoney
Giving customer less money
than what is due to them
Withdrawing customer float
without their consent
1stoccurrance Blacklist the agent
Breaking KYC
regulations set by And recover underserved
Regulator(loss of commissions/revenue lost
license) from Agent at end of the
month

Fraudulent SIM swap to

defraud Airtel Money
customers

3
Not conforming to 1:1.5 rule Loss of revenue to 1st Suspend Agent line
Airtel Money Occurrence performing action.
AM Agents are required to caused by failure to Send warning letter to
maintain 1.5 times the service the AM Company proprietor
amount of float held in the customers detailing results of
previous month. adequately. investigation

2 False registrations
Loss of revenue to 1stOccurrence Warning letter to Agent
False Registrations to earn Airtel Money detailing results of
undeserving commissions Increase in investigation.
ghost/inactive
Not using Identification when subscribers Recover underserved
registering customers commissions /revenue
Breaking KYC lost from Agent at end of
Registration forms not duly regulations set by the month
filled and signed Regulator(loss of
license)
2 Agents not conforming to Risk of law suit to 1stoccurrence Warning letter to Agent
KYC regulations be brought against
Company/Agent
Agents transacting without for Fraud
seeing customer IDs
Tarnishing Airtel
Money /Product 2nd Blacklist the Agent
image Occurrence
Assistants signing
registration/log books on
Breaking KYC
behalf of customers and
Logbooks not filled regulations set by
Regulator(loss of
license)

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1
Agents not conforming to Risk of law suit to 1st and 2nd Warning letter to Agent
Transaction requirements: be brought against occurrence detailing results of
Company/Agent investigation.
Charging customers for for Fraud
registrations Recover underserved
Tarnishing Airtel commissions/revenue lost
Charging customers for Money /Product from Agent at end of the
image month
transactions

Charging customers for

Mobile Money swaps or SIM Breaking KYC Blacklist the Agent
cards above recommended regulations set by
3rd
price Regulator(loss of
Occurrence
license)
1 Risk of Fraud/loss 1st and 2nd Warning letter to Agent
Relocation of Tills/ Agent of funds invested occurrence after 3 occurrence
lines without Authorization by the Agent
from AM Team
3rd Blacklist the Agent
Occurrence

ANNEXURE C

1. The Dealer shall perform Airtel Money Dealer/Agent Services on the following Mobile Lines:

a) …………………………………………………..
b) …………………………………………………..
c) …………………………………………………..
d) …………………………………………………..
e) …………………………………………………..

2. The Dealer confirms that it has been trained by Airtel Money to perform the services listed herein
and is familiar with the legal obligations arising thereof.

3. The Dealer shall not transfer, assign, sell or otherwise dispose of the Mobile Lines referred to in 1.
Above and any action in breach of this shall entitle Airtel Money to suspend the Dealer’s Lines
and/or terminate this Agreement forthwith.

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