Vlaian Limited

Supplier Code of Conduct

Version 1.0 · 28 September 2026

1. Why this Code exists

1.1Vlaian Limited, trading as Vlaian Group and through its divisions ("Vlaian"), serves individuals, families and organisations who entrust us with the most private parts of their lives. The partners we work with carry that trust alongside us.
1.2This Code sets out the standards we expect of every supplier, partner, contractor and freelancer who provides goods or services to Vlaian or to our clients on our behalf (a "Supplier"). It applies to your business, to your employees, and to any subcontractor you engage for work connected to Vlaian.
1.3This Code forms part of every agreement between Vlaian and a Supplier. Where an agreement sets a stricter standard, the agreement applies.

2. Discretion

2.1You will keep private everything you learn about a Vlaian client through your work with us. This includes their identity, their family, their movements, their homes, their preferences, their purchases and the recipients of their gifts. This duty applies whether or not the information has been marked as confidential, and it continues after your work with us ends.
2.2You will not photograph, record or film a client, their family, their home, their documents or their belongings, except where the service itself requires it and we have agreed it in writing.
2.3You will not mention, depict or tag any Vlaian client, engagement or location on social media, in marketing, in a portfolio or in conversation, and you will not describe your work with us in a way that could identify a client.
2.4You will not contact a Vlaian client directly, except as the service requires, and you will not offer your services to a client introduced to you through Vlaian outside your work with us.
2.5Where a client's information is especially sensitive, such as a travel itinerary or the details of an official, you will share it within your business only with the people who need it to deliver the service.

3. Personal information

3.1You will handle any personal information you receive from Vlaian or our clients in line with the Nigeria Data Protection Act 2023 and any other law that applies to you, and only for the purpose of delivering the service we have engaged you for.
3.2You will protect that information with appropriate security, including restricted access, secure storage and secure transmission.
3.3You will tell us within 24 hours of becoming aware of any loss, theft, unauthorised access or disclosure of information connected to Vlaian or our clients, and you will cooperate fully with our response.
3.4When your work is complete, or whenever we ask, you will return or securely delete the information we have given you, unless the law requires you to keep it.
3.5Where you process personal information on our behalf, you will sign our data processing terms before you begin.

4. Integrity and anti bribery

4.1You will not offer, promise, give, request or accept any bribe or improper payment, whether directly or through another person. This applies to dealings with public officials, embassy and immigration staff, customs officers, and private individuals alike.
4.2You will not make facilitation payments, meaning small unofficial payments made to speed up or secure a routine official action, even where they are customary.
4.3You will not give any gift, hospitality or favour to a member of the Vlaian team with a value above ₦50,000, and you will not give anything of value to a member of our team at any time to win or keep our business. You will not offer any commission or reward to a member of our team personally.
4.4Any commission, fee or benefit you pay to Vlaian must be agreed in writing with Vlaian Limited and paid only to its company account.
4.5You will not offer or give anything of value to a Vlaian client in a way that could influence our advice or recommendations.

5. Financial crime and sanctions

5.1You will comply with the anti money laundering and counter terrorist financing laws that apply to you.
5.2You will accept payments connected to Vlaian only through the channels we have agreed, and you will tell us immediately if anyone asks you to receive or route funds in an unusual way.
5.3You will tell us before starting work if you, your owners or your directors are subject to sanctions imposed by the United Nations, the United Kingdom, the United States or the European Union. You will not involve any sanctioned person or place in work connected to Vlaian.

6. Honesty and authenticity

6.1Every item you supply will be genuine, lawfully obtained, and as described. You will never supply counterfeit, stolen, smuggled or misrepresented goods, and you will provide proof of authenticity and provenance when we ask.
6.2You will never prepare, alter or submit false or misleading documents or information to any authority, and you will not advise anyone to conceal facts from an authority. If a client or anyone else asks you to do so, you will refuse and tell us.
6.3The information you give us about your prices, capacity, availability, qualifications and timelines will be accurate and complete.

7. Licences and lawful operation

7.1You will hold, and keep current, every registration, licence, certification and insurance your work requires. Examples include:
·professional licences for immigration practitioners in the country where they practise
·air operator certification for private aviation
·NAFDAC registration for food, beverages, cosmetics and fragrances supplied in Nigeria
·permits for events and venues
7.2You will provide copies whenever we ask, and you will tell us immediately if any of them lapses, is suspended or is withdrawn.
7.3You will comply with customs, import and export laws, and with the rules on restricted goods, including alcohol, cultural objects and protected species, in every country your work touches.

8. People and working conditions

8.1You will not use forced, bonded or trafficked labour, and you will not retain the identity documents of your workers.
8.2You will not employ children below the minimum age set by the law that applies to you, and you will not engage young workers in hazardous work.
8.3You will pay your workers at least the legal minimum wage, on time, and provide working hours and conditions that comply with the law.
8.4You will treat your workers and ours with dignity, free from harassment, abuse and unlawful discrimination.
8.5You will provide a safe and healthy workplace, and you will take particular care where your work places your people in a client's home or presence.

9. Safety and quality

9.1Everything you supply will be safe for its intended use and will meet the standards required by law.
9.2For food and beverages, you will follow safe handling practices and provide accurate ingredient and allergen information.
9.3For transport and aviation, you will use properly maintained vehicles and aircraft, and qualified and rested drivers and crew.

10. Conflicts of interest

10.1You will tell us of any personal, family or financial relationship between your business and a member of the Vlaian team, or between your business and a Vlaian client, that could affect, or appear to affect, our dealings.

11. Conduct in a client's presence

11.1When you are in a client's home, vehicle, venue or company, you will be courteous, discreet and appropriately presented, and you will follow any reasonable instruction from Vlaian on conduct.
11.2You will not accept any gift, payment or favour from a client connected to your work with us without telling us.

12. Subcontracting

12.1You will not subcontract work connected to Vlaian without our prior written consent.
12.2Where we consent, you remain responsible for your subcontractor, and you will ensure they meet this Code.

13. Raising a concern

13.1If you become aware of any breach of this Code, or of any conduct connected to Vlaian that concerns you, please tell us at conduct@vlaian.com. You may also raise it directly with a senior member of our team.
13.2We will look into every concern properly and discreetly. We will not penalise, and we will not allow anyone to penalise, a Supplier or any person who raises a concern in good faith.

14. Monitoring and consequences

14.1We may ask you to confirm your compliance with this Code, to provide supporting documents, or, on reasonable notice, to allow us to review your practices connected to our work.
14.2If you breach this Code, we may require you to put the matter right, suspend our work with you, or end our relationship immediately, in addition to any other right we have under our agreement or the law.
14.3Where the law requires us to report a matter to an authority, we will do so.
Vlaian