Trust & Safety Policy (SEC-Aligned)

 

*Last Updated: June 2026*

 

1. Regulatory Positioning & Scope

 

MortFund Management Services Ltd (“MortFund”, “we”, “us”) operates a donation-based crowdfunding platform designed for charitable, medical, social, and community fundraising.

 

Under Nigerian law:

 

* The Securities and Exchange Commission (SEC) Rules on Crowdfunding (2021) apply primarily to investment-based crowdfunding (equity/debt)

* Donation-based and reward-based crowdfunding are generally excluded from SEC’s direct regulatory scope

 

Accordingly, MortFund:

 

* Does NOT offer securities, investment instruments, or profit-sharing opportunities

* Does NOT facilitate equity, debt, or peer-to-peer lending crowdfunding

* Operates strictly as a non-investment, donation-based platform

 

However, we voluntarily adopt SEC-style compliance, transparency, and anti-fraud safeguards to protect users and maintain market trust.

 

2. Platform Classification & Legal Compliance

 

To ensure continued compliance with Nigerian law:

 

* All campaigns must be donation-based only (no ROI, profit, interest, or equity promises)

* Campaign creators are prohibited from:

   * Offering shares, returns, or financial incentives

   * Structuring campaigns that resemble investment schemes or pooled funds

 

* MortFund reserves the right to remove any campaign that may:

 

   * Be interpreted as a public securities offering

   * Violate the Investment and Securities Act (ISA)

 

3. Anti-Fraud, KYC & AML Compliance

 

Although donation crowdfunding is not directly regulated by SEC, MortFund implements financial integrity controls consistent with Nigerian regulatory expectations:

 

* Mandatory Know Your Customer (KYC) verification for campaign creators

* Identity and document verification before fund withdrawals

* Continuous transaction monitoring for suspicious patterns

* Compliance with:

 

  * Anti-Money Laundering (AML) laws

  * Counter-Terrorism Financing (CTF) obligations

 

We may:

 

* Request additional documentation

* Delay or block withdrawals

* Report suspicious activity to relevant authorities

 

4. Transparency & Disclosure Standards

 

In alignment with SEC disclosure principles:

 

Campaign creators must provide:

 

* Accurate and verifiable campaign descriptions

* Clear explanation of use of funds

* Supporting documentation where applicable (e.g., medical reports, invoices)

 

Prohibited:

 

* False, misleading, or exaggerated claims

* Concealment of material facts

 

MortFund  may:

 

* Require campaign updates

* Flag or suspend campaigns lacking transparency

 

5. Risk Disclosure (Donor Awareness)

 

While donations are not investments, users must understand:

 

* Donations are voluntary contributions with no financial return

* MortFund does not guarantee outcomes or results

* Funds may be subject to misuse despite verification efforts

 

We prominently display risk notices to ensure:

 

* Donors make informed decisions

* Users understand platform limitations

 

6. Fund Handling & Safeguards

 

To enhance trust and align with best practices:

 

* Funds are processed via secure payment infrastructure

* Withdrawals are subject to:

 

  * Identity verification

  * Fraud checks

* MortFund may freeze funds where fraud is suspected

 

In cases of verified fraud:

 

* Funds may be recovered or refunded at our discretion

 

7. Prohibited Activities

 

The following are strictly prohibited:

 

Financial Misconduct

 

* Fraudulent fundraising

* Misuse of donated funds

* Structuring campaigns as disguised investments

 

Legal Violations

 

* Money laundering or terrorist financing

* Campaigns supporting illegal activities

 

Content Violations

 

* Hate speech, harassment, or exploitation

* Unauthorized use of personal data

 

Violations may result in:

 

* Campaign removal

* Account suspension

* Legal reporting

 

8. Platform Monitoring & Moderation

 

MortFund implements:

 

* Pre-publication campaign review

* Ongoing monitoring of live campaigns

* Automated and manual fraud detection

 

We reserve the right to:

 

* Edit, restrict, or remove campaigns

* Suspend repeat offenders

 

9. Reporting & Complaints Mechanism

 

Users may report:

 

* Fraudulent campaigns

* Suspicious transactions

* Privacy violations

 

MortFund maintains a formal complaint-handling process, aligned with SEC expectations for platform accountability and transparency

 

10. Data Protection & Security

 

We comply with:

 

* Nigeria Data Protection Act (NDPA)

* Industry-standard cybersecurity practices

 

Measures include:

 

* Encryption of sensitive data

* Restricted internal access

* Continuous system monitoring

 

11. Children & Vulnerable Persons

 

* Users under 18 cannot create campaigns

* Campaigns involving minors must be managed by verified adults

* Misuse of vulnerable individuals’ data results in immediate removal

 

12. Enforcement & Sanctions

 

MortFund may take the following actions:

 

* Issue warnings

* Suspend or terminate accounts

* Freeze or reclaim funds

* Report to regulators or law enforcement

 

13. Alignment with Nigerian Regulatory Ecosystem

 

Although not directly regulated by SEC, MortFund operates in alignment with:

 

SEC principles on transparency, disclosure, and anti-fraud

Central Bank of Nigeria (CBN) AML requirements

Economic and Financial Crimes Commission (EFCC) AML Act

Corporate Affairs Commission (CAC) requirements for entities

Applicable consumer protection laws

 

14. Policy Updates

 

We may update this policy to reflect:

 

* Regulatory changes (including SEC or ISA updates)

* Emerging risks or fraud patterns

* Platform improvements

 

15. Contact Information

 

For Trust & Safety issues:

 

Office: Libra Plaza, 87–89 Baale Animashaun Road, Alakuko, Lagos, Nigeria

Email: support@mortfund.com

Phone: +234 802 387 4201

Website: https://www.mortfund.com

 

MortFund Management Services Ltd (RC 1909233)