Terms & Conditions


The Brassica Capital App (herein after referred to as “App, Brassica or Brassica App”) is governed and guided by the rules and regulations as outlined herein and shall be amended from time to time and these rules and regulations including updates made to them are binding on all who use the Brassica App.

1. The Agreement

These Terms and Conditions (“Terms,” Terms andConditions, Terms of Use, Terms of Service) govern your (you, user, customer, client,investor) relationship with the Brassica App as operated by Brassica CapitalLimited. This Terms and Conditions comprises all terms of use in this document,all directives, instructions, and terms on the Brassica App and any other termthat Brassica Capital Limited may make available to client. It is important foryou to read and understand these Terms and Conditions. You can only access anduse the Brassica App if you accept these Terms and Conditions. These Terms ofUse apply to all users who use the Brassica App. By accepting or using the BrassicaApp you agree to be bound by these a) Terms & Conditions and b) DataProtection and Privacy Notice. Brassica Capital Limited reserves the right tomake changes to and update “a” and “b” to meetstatutory, regulatory, contractual, business, customer requirements and anyother requirement that Brassica Capital Limited deems fit.   If you disagree with any part of these Termsand Conditions, then you cannot access the Brassica Capital App for purposes ofinvestment.

2. Definitions

The following relate to these Terms and Conditionsand/or the Brassica App

2.1. “Account”Means a)    registrationon the Brassica App using a username and password in order to use the BrassicaApp for purposes of investment b)    Aninvestment – the account into which contributions are made and redemptions aretaken from.

2.2. “Account Holder” refers to the individual (person or business)in whose name both a and b under 2.1. are

2.3. “Account Mandate” Means a six (6) digit PIN that functions as anelectronic signature for validating transactions.

2.4. “App” Means Brassica Capital App or App or Brassica or Brassica App

2.5.“Account Verification” or “Verification” or “Account Authentication” or “Authentication” Means a series of security checks performed to ascertain that:

i) Client owns and operates the investment account on which the verification is being done

ii) Actions relating to an investment account are being initiated or done by the owner of the account.

2.6.“Bank Account” Means financial account into and out of which money is paid and moved.

2.7. “Brassica Alpha Fund PLC” Means a money market mutual fund licensed by the SEC to receive investments from clients in exchange for shares of/in the fund.

2.8. “Brassica” Means App, Brassica App

2.9. “Benefactor” Means the legal person who holds an investment account for the benefit of another, beneficial owner

2.10. “Beneficial Owner” Means a person or business who enjoys the benefits of the    investment account created for them by benefactor

2.11. “Cell Phone” Means a telecommunication device that uses radio waves over a networked area (cell) and is used to access telecommunication services.

2.12. “Client” Means a person or persons who created an investment account on the  BrassicaApp for the purpose of investment. This has the same meaning as customer.

2.13. "Club” or “Investment Club" Means a group of persons with a clear leadership (executive or executives) who come together to contribute funds towards the achievement of legally valid goals.

2.14. “Contribution(s)” Means putting money into your investment account with the aim of generating gain. Also means the total amount client has made into their investment account.

2.15. “Credit” Means putting money into both client's investment account and client’s  redemption account.

2.16. “Current Balance” Means the total amount of contribution and gains or loess minus all withdrawals.

2.17. “Debit” Means movement of money from your Source of Fund

2.18. "Deposit" has the same meaning as contribution.

2.19. “E-mail” Means electronic mail sent via computer and computer networks.

2.20. “Fund” Means the name given to a pool of money into which money from investorsI invested.

2.21. “Fund Price” Means the value of a share of the fund calculated daily based on the  value of the underlying assets of the fund.

2.22. “Fund Growth” Means a computation of the rate of appreciation/depreciation of the value of assets of the fund measured over a period of time.

2.23. “Gain” Means increase in value of investments attributable to growth in value of  assets of the fund.

2.24. “GSM” Means the Global System for Mobile communications as defined in the European Technical Standards Institute's list of specifications.

2.25. “Individual Account” Means an investment account that belongs to only one natural person.

2.26. “Institutional Account” Means an investment account opened and managed by an entity duly registered in Ghana.

2.27. “Investment Knowledge” Means a set of questions that clients are asked in order to appreciate how well client understands investment and investment related matters.

2.28. “Period of Investment” Means the length of time within which client intends to run their investment.

2.29. “Risk Tolerance” Means the level to which client tolerates investment risk.

2.30. “In-Trust-For Account” Means an investment account opened by a person of legal age for another, the beneficial owner.

2.31. “Joint Account” Means an investment account owned and operated by two persons of legal age.

2.32. “KYC Information”Means all information required by Brassica Capital Limited for purposes of creating and operating client’s investment account.

2.33.  “Mobile Money” Means electronic money held with any of the providers of such  services.

2.34.  “Mobile Money Wallet Means the electronic account into and out of which money is paid and moved.

2.35. “NIA” Means NationalIdentification Authority

2.36. “Net Asset Value (NAV)” Means the value of the fund’s assets less its liabilities, divided by the total number of shares issued.

2.37. “Personal Identification Number (PIN)” Means the secret code you choose for your Mobile   Money Wallet and Bank account which is required to allow transactions.

2.38. “Redemption” Means client’s withdrawing money from their investment account.

2.39. “Redemption Amount” Means the amount that is being or has been withdrawn from a client’s investment account.

2.40. “Redemption Account” Means the mobile money wallet or bank account into which client’s redemption from their investment is paid into.

2.41.  “Resident Non-Ghanaian” Means a foreigner who stays in Ghana.

2.42. “SignUp” Means the process of registering on the Brassica App using a username and password.

2.43. “Selfie”Means a photograph that one takes of themselves.

2.44. “SMS” Means a Short Messaging Service consisting of text message.

2.45. “Source of Fund” Means the Mobile Money Wallet or Bank Account which is added to a user’s account on the Service.

2.46. “Source of Income” Means where a client's deposits into their investment account comes from.

2.47. “Statement” Means a list of all transactions (deposits/contributions, withdrawals/redemptions, and fees) on client’s investment account made over a specified period.

2.48. “Suspension”Means the process of making the Brassica Capital App and investment account inaccessible to the client.

2.49.  “Transact” or “Transaction” means the deposit of money into client’s investment account and withdrawal of money from client’s investment account.

2.50.  “Username” refers to a combination of characters combined with a password to gain access into the Brassica App.

2.51.  “Wallet” Means a customer’s Mobile Money transactional account which is accessed primarily through their cellphone.

2.52.  “We” or“Us” or “Our” refers to Brassica Capital Limited

2.53. “You” or “Your” or“Client”refers to the holder of an investment account on the Brassica App.

DATA YOU GIVE
DATA 
WE COLLECT
ACTION

You request a demo of Bearer

We call you

You use Bearer

You receive emails from us

You chat with us for customer support

You opt-in to marketing messages

3. The Brassica Capital App

3.1. The Brassica Capital App is a mobile application that manages investment digitally and is available on Android and iOS mobile phones.

3.2.     Functions of the Brassica Capital App.

The Brassica App is and shall be used for the following:

i.     Create investment account(s) with BrassicaCapital Limited
ii.    Deposit money into investment account(s)
iii.   Withdraw money from investment account(s)
iv.   Monitor the performance of investment.
v.    Upgrade investment account(s) (E.g., from Tier1 to Tier 2 and from Tier 2 to Tier 3
vi.   Set and manage investment goals.
vii.  Create and manage the investments of clubs called Investment Clubs on the app.
viii. Educate investors on investment topics

3.3. Users of the Brassica Capital App will be informed of the availability of any services and features as and when those services and features become available.  

4. Accessibility and Sign Up

4.1. The Brassica App can be accessed on theGoogle Play Store for Android phones and on App Store for iOS (Apple) phones.

4.2. To be able to use the App, Android users must be on Android version 5 or above and iOS users would have to be iOS version 13 or above.

4.3. The Brassica App is only available on mobile devices with the specific operating systems mentioned in 4.2.

4.4. Updates may be done to the app from time to time to optimize its quality and performance. It is advised that client downloads and installs the latest update for full functionality and user experience.

4.5. To use the Brassica App, clients must signup.

4.6. Signing up on the Brassica App requires the client to set a username and password.

4.7. Username and password shall be required each time to gain access into the Brassica App.

5. Ghana Card Verification

5.1. The process of sign up requires client to provide information some key information about themselves.

5.2. Brassica Capital reserves the right to revise this information from time to time as may be demanded for business purposes and to satisfy regulatory and statutory requirements.

5.3. Such information shall include but not limited to:

i.              Client’s full name as captured on client’s Ghana Card
ii.             Date of Birth
iii.            Ghana Card ID Number
iv.            Passport-like Selfie picture
v.             Residential Address

5.4. The Ghana card number together with the selfie are used to verify the profile of the customer from the NIA database.

5.5.  Without the verification in 5.4 prospective clients cannot sign up for the Brassica App.

5.6. The BrassicaApp can only be used by persons 18 years and above and with a valid Ghana Card. This includes resident foreigners with a valid issued Non-resident Ghana card.

5.7. Brassica reserves the sole right to decline registration or sign up onto the Brassica App without any explanation whatsoever to client.

5.8. If upon verification Brassica Capital Limited is not satisfied with the information provided Brassica Capital may decline client registration or sign up.

5.9. For customers of Brassica Pay Limited who want to become clients of Brassica Capital Limited,Ghana Card information clients provided to Brassica Pay Limited would be extracted and presented to client.

5.10. Client must verify the information as true and accurate about themselves.

6. Creating An Investment Account

6.1. Before a client sets up an investment account, client must first accept this Terms and Conditions. Failure to accept these terms of use would mean that the client cannot  create their investment account.

6.2. The Client must select account type (either Individual Account, Joint Account, or In-Trust-For Account).

6.3. The Client can open and run different account types concurrently.

6.4. The Individual Account type is opened and run by one client only.

6.5. The Joint Account type can be held by more than one client.

6.6. The In-Trust-For Account type is opened and run on behalf of minors (persons who have not attained the legal age of 18).

6.7. For a client to set up their investment account, the client must select a tier.

6.8. There are 3 tiers on the Brassica App for clients to select from.

6.8.1. Resident Ghanaians can run all three tiers can be run by resident in Ghana only.

6.9. Non-resident Ghanaians and non-resident foreigners cannot operate any of the tiers.

6.10. Resident non-Ghanaians can run only tier 2and tier 3.

6.11. Client cannot downgrade to a lower tier after being on or upgrading to a higher tier.

6.12. Clients are to pay attention to and adhere to all information on each tier on the    Brassica App.

6.13. Client must provide all required information about beneficial owners (See 2.10).

6.14. All information provided about beneficial owner(s) must be correct and true.

6.15. Brassica Capital Limited, its employees or subcontractors shall not be held liable for any incorrect and or untrue information provided by client about beneficial owners.

6.16. Client shall bear solely the responsibility of any misrepresentation, incorrect or untrue information about beneficial owner(s).

7. Source Of Funds

7.1 Source of funds for operating the investment account can be more than one.

7.2. Source(s) of funds can be added at any time on the App.

7.3. All security measures including the use of PIN provided by the wallet service provider or bank shall apply to client’s source of fund on the Brassica App.

7.4. The security measures remain the sole responsibility of the client.

7.5. Sources of fund can be mobile wallets only, bank accounts (only or a combination of both.

7.6. It is highly advised that sources of fund from which client funds their investment account belong to or is in the name of client.

7.7. In adding, source(s) of fund, client will get a code which will be sent to the phone  number client used in signing up for the Brassica App.

7.8.  Client must enter this code into the field provided on the app.

7.9. This verification helps Brassica CapitalLimited know that the account being added as source of fund belongs to the person operating the Brassica App.

8. Account Mandate

8.1. To authorize redemption from any account, clients will be asked to enter the six-digit number which they created under account mandate during the investment account creation process.

8.2. For the individual account type, redemption shall be authorized by the owner of the account only and by entering the six-digit number.

8.3. For joint account, redemptions shall be authorized by both parties to the account. One person initiates the redemption by submitting it to the other party who then approves by way entering the six-digit number.

8.4. Redemption for In – Trust – For account shall follow the same procedure as that of individual account in 8.2 above.

8.5. Account Mandate is a unique and secret number that should be known to only client.

8.6. Account Mandate shall be required for the following:

a) withdrawing money from investment account
b) viewing total contributions, total gain, and total redemption.

8.7. We advise that client selects an account mandate that is very difficult to determine but easy to remember.

8.8. We advise client changes Account Mandate periodically to maintain its security and integrity.

8.9. Client is hereby advised not to share Account Mandate with any unauthorized person(s).

8.10. Brassica Capital Limited, its employees, its subcontractors and appointees bear no liability whatsoever and should client share with or have their Account Mandate compromised.

8.11. If client suspects their Account Mandate has been breached, client can all the Brassica CapitalCall Center, so the account is blocked until such a time that the investment account is deemed safe.

8.12. In updating or changing account mandate, client would be asked to enter the old account mandate.

8.13. Client will also be asked to enter the new account mandate and re-enter it to confirm it.

8.14. Client has a maximum of three (3) attempts within which to enter the correct mandate.

8.15. Failure to enter the correct account mandate on the third  attempt will automatically lead to a suspension of client’s account.

8.16. In the event that account is blocked for reasons stated in 8.15, client is expected to call the Brassica Capital Call Center.

8.17. Client will then answer a few questions to prove that they are the true owner(s) of the  investment account.

8.18. Upon successfully authenticating  the investment account, Brassica Capital  will send a code to client’s phone number  used in registering on the Brassica App.

8.19.  Client is then expected to enter this code in the relevant field and change their account mandate.

8.20. After successfully entering the old account mandate and the new mandate, the three (3) security questions will be asked.

8.21. Client is expected to remember and choose those same questions and provide the same answers client provided when client created the investment account.

8.22. All three questions must be answered correctly before account mandate change can be successful.

8.23. A question can be answered only three (3)times.

8.24. In the event that client is unsuccessful inall three  attempts, client’s investment account will be automatically suspended for security reasons.

8.25. Client can call the Call Center of BrassicaCapital Limited and answer a few questions in order to authenticate that they are the true owners of the account, and that client is the one attempting a change of account mandate.

8.26. Brassica Capital Limited reserves the right to vary the form and duration of this account authentication process without recourse to client.

8.27. Client is hereby advised to keep and remember all security questions and their respective answers.

8.28. Brassica Capital Limited, its employees, agents, subcontractors, and appointees shall  not in any way whatsoever be  held liable for any damage be it collateral or consequential suffered by client as a result of such account suspension in 8.15 and 8.24

9. Redemption Account

9.1.  To be able to withdraw your investment (redemption), client must onboard either a mobile money account (momo account), or a bank account or both.

9.2. Client can only have one of each redemption account type.

9.3. In setting up a redemption account (whether mobile money or Bank), client will be sent a code to client’s phone number that was used to setup account on the app in  case of setting a bank account. For mobile money account the code will be sent to      the mobile money number.

9.4. This helps Brassica Capital Limited confirm that the owner of the redemption account is the owner of the account on the Brassica App.

9.5. The account must be in the name  at all times  setting the account  on the Brassica App.

9.6. Brassica Capital Limited, its agents, subcontractors, its employees, and appointees will not be held liable for any damages or compensations should this account not belong   to client or for any act of omission or misrepresentation in setting up this redemption  account.

9.7. Client can change their redemption account.

9.8. In changing clients’ redemption account, an SMS with a code will be sent to the    phone number client used in signing up for the Brassica App.

9.9. Client must then enter the code in the SMS into the relevant field provided on the Brassica App.

9.10. Client cannot continue to add a redemption account if this is not done.

9.11. To change one’s redemption account, client is requested to provide the needed (asked)information about the new account.

9.12. Client then clicks the “submit”button to submit the request to change redemption account.

9.13. Upon receiving change of redemption account request from client, Brassica Capital Limited will perform a few security checks within three days to ascertain that the  request is indeed coming from the owner(s) of the investment account.

9.14.  Brassica Capital Limited  reserves the right to vary the form of  this account authentication process  without recourse to client.

9.15. After a successful verification of the request, Brassica Capital  Limited shall switch the redemption account of client from the old one to the new one.

9.16. Brassica Capital Limited shall send an SMS to client notifying them of the successful change of their redemption account to the new one.

9.17. Brassica Capital reserves the right to reject the change of redemption account request should fraud be suspected and suspend the investment account automatically.

9.18. Brassica Capital shall subsequently communicate such suspension and the reason to client via SMS on the phone number client used to register on the Brassica App.

9.19. Client upon receiving such SMS communicating the suspension of their account the reasons shall take every reasonable step to contact Brassica Capital Limited.

9.20. Upon suspension of the account, BrassicaCapital will call client for client to answer  few questions.

9.21. SMS is considered received by client once the delivery status of SMS is “Delivered”

9.22. Password change, account mandate change

9.23. Brassica Capital Limited, its employees, agents, subcontractors, and appointees shall not in any way whatsoever be held liable for any damage be it collateral or consequential suffered by client as a result of such account suspension in 9.17.

10. Mutual Fund Selection

10.1. BrassicaCapital Limited, based on the answers client provided to Period of Investment, Investment Knowledge, and Risk Tolerance, are required to recommend asuitable mutual    fund to client.

10.2. Clienth as the right to reject any mutual fund suggested by Brassica Capital Limited and select their preferred fund.

10.3. In the event that Brassica Capital Limited suggests a fund to client and client accepts, client’s acceptance shall betaken to mean a sole decision by client to run such a fund and that Brassica Capital Limited cannot be held responsible for such a decision.

11. Mutual Fund Terms and Conditions

11.1. In order to create the investment account, client must ACCEPT the terms and conditions  relating to the mutual fund they have selected to be on.

12. Direct Top

12.1. In order to fund their investment account, client can do direct top from their source(s) of fund that were added to Brassica App

12.2. Once shares are purchased, client will get an SMS that shows the total amount of shares bought

12.3. Client can top up their investment account either through a mobile money account or bank account.

12.4. Client can make direct top-ups using only the Brassica App

12.5.  All security measures applied by service providers of both mobile money and banking services still apply to your accounts on the Brassica App in the process of doing direct top- ups.

12.6. BrassicaCapital Limited, its employees, subcontractors, agents, and appointees will not be held liable for any damages either collateral or consequential suffered by client in the event   that the security measures provided by service providers of mobile money and banking fail and the relevant sanctions are applied

12.7. At the point of doing a direct top up, client can change the account (mobile money or bank) from which they want to do the top-up.

12.8. Client will go through the same process of adding a source of fund account in changing a source of fund account.

12.9. Direct top-ups can be made at any time or periodically at regular intervals.

12.10. Unsuccessful top-ups (client account debited with amount of deposit but investment account is not credited) will automatically be refunded.

13. Redemptions

13.1. Client can withdraw the gain generated on their investment or can withdraw gain plus contributions (deposits) on their investment account.

13.2. Client can only withdraw money from their investment into the redemption account (mobile money account or bank account) which they added.

13.3. At the time of redemption, client can change their existing redemption account and  all the terms and conditions that apply to change of redemptions account in these  terms of use will apply to such change.

13.4. The account (mobile money or bank account)into which clients is redeeming or   withdrawing their investment MUST be owned by client.

13.5. At the point of redemption, client will be shown the balance on their investment as “CurrentBalance

13.6. The total amount client withdraws cannot exceed the total of the current    balance on the account.

13.7. By clicking the “Redeem Now” button on the redemption page of the Brassica App, client has initiated a redemption process.

13.8. The completion of the redemption and successful credit of client’s redemption account will be done within five (5) business days from the date client initiated the  redemption process.

13.9. Upon successfully crediting client’s redemption account, Brassica Capital Limited shall send an SMS to client notifying them of the successful redemption and the redemption amount.

14. Performance

14.1. To enable client, track the performance of their investment, the Brassica App has  section designated for “Performance.”

14.2. The performance section displays the following

i.              Total Investment – this is the sum of all contributions and gains available on the account as the time client is                 viewing the performance
ii.             A line graph that displays client’s contribution or deposit trend over set of periods as seen on the App. iii.            Fund Information – these are public information that relate to the fund and include:

a.     Fund’s Net Asset Value
b.     Fund Price
c.     Fund Growth

14.3.  To be able to view client's total investment, client will be required to enter their    account mandate.

14.4. Client has a maximum of three (3) attempts in entering their account mandate to view their total investment.

14.5. If upon the third attempt, client fails to enter the correct account mandate, client’s           account will be automatically suspended.

14.6. In the event client account is suspended client must follow steps in 8.16 to 8.19 for  the account to be reactivated.

14.7. Brassica Capital Limited hereby states that, all information displayed under the “Performance” section of the Brassica Capital App, may change frequently as their calculations are based on very dynamic market factors over which Brassica Capital Limited has no control

14.8. Brassica Capital Limited, its employees, subcontractors, agents, and appointees shall not be held liable for any decision taken based on the data displayed.

15. Statement

15.1. Client can request a statement on their account from the Brassica App.

15.2. Statement can either be a mini report (a report over a short period of time) or a Detailed one   (report over a longer period of time).

15.3. Request for mini statement will be processed by Brassica Capital Limited instantly

15.4. Detailed Reports shall be delivered instantly upon submission

15.5. The processed statement shall be sent as a notification to the Brassica App and as a downloadable PDF document” section of the App and a notification shall be sent to client via the App.

15.6. Processed statements shall be sent via in-app and/or email.

15.7. Client can download the statement onto their phone.

15.8. All statement shall be password protected.

15.9. BrassicaCapital shall send quarterly statements to client via email, in-app, or any

16. Investment Calculator

16.1. In order to empower client to be investment savvy and plan their investment properly, the Brassica App has section labelled “Calculator”

16.2. Client can do the following types of calculation:

i.              Know expected gain on a lump sum. That is client can know the gain (estimated) they can expect if they invest a certain amount over a specified period.
ii.             Know how much to invest periodically, that is given a certain target which client wants to reach, client can know how much to invest at a certain regular time interval.
iii.            Know how long to invest. That is given a certain target amount that client wants to reach and contributing at a certain regular interval, client can know how long (in weeks, months, or years) they can invest to reach the target amount.

16.3. It is hereby statement that, the results of any type of calculation are based on:

i.              Entries made by client
ii.             Dynamic market factors over which BrassicaCapital has no control.

16.4. Results are therefore not actuals but estimates that give client a fair view (but not exact) of what estimated gain to expect, how much to invest and how long to invest.

16.5. Actual results may differ for any type of calculation on the App may differ.

17. Manage Goal

1.1. The Brassica App has a Manage Goal section that allows client set an investment goal and track performance towards the achievement of the goal.

17.2. The help client achieves the investment goal they have set, the manage goal section uses relevant entries made by client to calculate the period or how long client would have to contribute to achieve their investment goal.

17.3. Just as it stated under Calculators, the actual result (how long it takes client to achieve their investment goal) may differ from the estimated one that the calculation under manage goal gives.

17.4. The calculation of how long it takes for client to achieve their investment goal is dependent on dynamic factors that Brassica Capital Limited does not have any control over.

18. Investment Club

18.1. The Brassica App allows a club to create an investment account.

18.2. To be able to an investment account on theBrassica App, the club must have the  following:

i.              A Club Constitution
ii.             Club must have at least two (2) executives for purposes of implementing controls on the investment club account

18.3. Clubs that have a soft copy of their constitution can click on the “submit constitution”     button on the “Investment Club Requirement” screen to upload and submit the  constitution.

18.4. If the club does not have at least two executives at the time of onboarding wanting on    the app, it is required that club members appoint two members as executives.

18.5. After submission of a valid constitution, client can go ahead and create the investment.

18.6. Brassica Capital Limited upon receipt of the constitution will vet it and approve.

18.7. In the event that the constitution is identified as not valid, Brassica Capital Limited  will by SMS and/or call inform the executive(s) of the club of such invalidity.

18.8. Brassica Capital Limited shall inform executives(s) of the reasons for the invalidity and  direct executives on what constitutes a valid constitution for the investment club.

18.9. Upon receipt of such information communicating the invalidity of their constitution, the executive or executives have 2 weeks to present a valid constitution.

18.10. Failure to present the valid constitution as directed by Brassica Capital Limited within the two (2) weeks shall lead to an automatic suspension of the club's investment  account.

18.11. Only executives are allowed to create an investment account for a club on the BrassicaApp.

18.12. Only executives can run the investment account for the club1.

18.13.  In creating a club on the Brassica CapitalApp, the name of the club must be exactly  the same as the name in the club constitution.

18.14. Any name inconsistency will be flagged, and executives alerted to correct it.

18.15. Only executives can invite members (both executives and non-executive members) to join the investment club on the Brassica App.

18.16. Any member (be it executive or non-executive)who wishes to join the club on the App must first create an investment account.

18.17. Club members who wish to join the investment club on the app would be sent an invitation link to join the club on the app.

18.18. All club members who are part of the club on the app will be able to make deposit using only the Brassica App.

18.19. The club can agree to deposit money with an executive who in turn makes lump sum deposits on behalf of the club at regular intervals agreed by the club.

18.20. Brassica Capital Limited does not have any influence on what deposit decision the club makes.

18.21. All members of the club (executives and non-executives) who are on the App can monitor the performance of the club’s investment account.

18.22.  Withdrawal (redemption) of funds from the club’s investment can be done by ONLY executives.

18.23. An executive authorized to withdraw fund scan initiate a redemption process.

18.24.  On the App, two (2) other executives are required to approve the redemption request.This will be done by an in-app notification sent to the other two approving executives.

18.25. If the two approving executives do not approve the redemption request, Brassica  CapitalLimited will not go ahead to process the redemption request.

18.26. Upon the identification of several attempts of an executive to withdraw funds without the approval of the two approving executives, Brassica Capital Limited will automatically suspend the account,

18.27. Brassica Capital Limited, upon suspending the account, will send an SMS alerting all executives of the attempt at withdrawal from the account.

18.28. The other executives upon receipt of the SMS alert are expected to call the Brassica CapitalCall Center and answer a few questions for the account to be reopened.

18.29. The club must create a redemption account into which all withdrawals will be credited. All steps and terms relating to the creation of redemption account captured in this terms and conditions apply toa club creating a redemption account.

18.30. Clubs can change their redemption account just as an individual account holder can.

19. Round-Up

19.1. Round-up is a feature on the Brassica App that enables deposits to be made effortlessly.The feature works such that an amount of money (fixed or variable        willingly chosen by client) is always deducted from client’s source of fund with BrassicaPay Limited (i.e., on the Brassica Pay side of the Brassica App).

19.2. This deduction from client’s source of fund is done anytime client performs a transaction on the Brassica Pay side of the App.

19.3. By accepting these terms and conditions for the round-up feature, client authorizes Brassica Pay Limited (aggregators of funds for Brassica Capital Limited) to make such deductions.

19.4.  Acceptance to use and setting up the round-up is done on the Brassica Capital side of the  app.

19.5. To use round-up as a means of making deposits into an investment account with  BrassicaCapital Limited, client MUST be client of Brassica Pay Limited by onboarding on the Brassica Pay side of the App.

20. Types of Round-up

20.1. There are three (3) types of round-up that client can choose to set up.

i.              Fixed Value Round–up: Underthis round-up, client MUST choose a fixed amount that is always deducted from client’s source of fund when client performs a transaction on Brassica Pay.

Example: Let us say client choose GHS100 to be deducted any time they perform transaction.That means regardless of the value of the transaction, GHS will be deducted from the client’s source of funds and deposited into client’s investment account with Brassica Capital Limited.

ii.             Percentage Round-up:Under this round-up type, client chooses a certain percentage that should always be applied to the value of any transaction they perform on the BrassicaPay side of the App. The amount that is obtained after applying the chosen percentage is then deposited into client’s investment account with Brassica CapitalLimited.

Example: Let us say client chooses 10% and performs two transactions with the first transaction having a value of GHS1,000 and the second GHS2,000. Under this percentage round-up, it means GHS100 (i.e., 10% multiplied byGHS1000) will be deducted from client’s source of funds and deposited into client's investment account with Brassica Capital Limited. For the second transaction GHS200 (10% multiplied by GHS2,000) will be deducted and deposited in client's investment account.

iii.            Nearest Value Round-up:under this round-type, the value of transactions is rounded up to the nearest“whole Ghana Cedi(s). There are 3 sub-division under this round-up type.

a)    Nearest GHS1 Round-Up: under this, transaction value is rounded up to the nearest whole Ghana Cedis. The difference between the value of the transaction and the nearest whole Ghana Cedis is then deposited in client's investment account with Brassica Capital Limited.

Example: Let us say client transaction value is GHS2.80. This figure will be rounded to the nearest whole cedi which is GHS3. The difference between the value of the transaction GHS2.80 and the nearest whole Ghana Cedis GH3 is then deducted. Inthis example the difference is GHS0.20 (or 20 pesewas). This 20 pesewas is then deposited into client’s investment account.

b)    Nearest GHS10 Round-Up: under this, transaction value is rounded up to the nearest whole Ghana Cedis which is a multiple of 10. The difference between the value of the transaction and the whole Ghana Cedis is then deposited in client's investment account withBrassica Capital Limited.

Example: Let us say client’s transaction value is GHS5.5. The nearest whole Ghana Cedis which is a multiple of 10 is GHS10. So, the transaction value of GHS5.5 will be rounded up to GHS10. The difference between the value of the transaction GHS5.5and GH10 is then deducted. In this example the difference is GHS4.5This GHS4.5is then deposited into client’s investment account.

c)     Nearest GHS100 Round-Up: Under this, transaction value is rounded up to the nearest whole Ghana Cedis which is a multiple of 100. The difference between the value of the transaction and the whole Ghana Cedis is then deposited in client's investment account withBrassica Capital Limited.

Example:Letus say client’s transaction value is GHS110. The nearest whole Ghana Cediswhich is a multiple of 100 is GHS200. So, the transaction value of GHS110 willbe rounded up to GHS200. The difference between the value of the transactionvalue GHS110 and GH200 is then deducted. In this example the difference isGHS90. This GHS90 is then deposited into client’s investment account.

20.2. Client can at any time decide that round-up should not apply to a particular transaction by switching the round-up toggle on the payment off. This happens on the Brassica Pay side of the app.

20.3. Client will receive both SMS and in-app alert notifying them of a successful deposit of funds from round-up into their investment account.

20.4. Client can only be on one round-up type at a time.

20.5. Client can at any time change the type of roundup they are on to another.

20.6. Client can at any time decide to stop funding their investment account using round-up. Client can then use the direct top-up alternative to fund their investment account.

20.7. If money taken from client’s source of fund through round-up fails to be credited to client’s account, an automatic reversal of that transaction shall be made.

21. Reporting on Round-up Deposits

21.1. After client sets up their round-up, client will now see all deposits made through the various round-up they chose if the click the round-up button the Brassica Capital homepage of the app.

21.2. All deposits made under each round-up type(assuming clients used more than one round-up type) will be displayed on this screen.

22. Investment Account Closure

22.1. If client wants their investment closed, client must send a formal either via a call or email to Brassica Capital Limited address at: info@brassicagroup.com or send a letter to BrassicaCapital Limited at: 2nd Floor, Sky Light Square, Osu Badu St, Accra.

22.2. For purposes of improving the investment service Brassica Capital Limited offers,  BrassicaCapital Limited may ask client a few questions.

22.3. Client reserves the right to answer or decline the questions.

22.4. Brassica Capital Limited shall within 3 days close client's account.

22.5. Upon closure of clients account, the total investment on the account of client shall be paid to client.

22.6. All fees, charges, legal charges, and any payment due Brassica Capital Limited shall be deducted before the remaining amount is paid to client.

23. Notices and Advertisement

23.1. The cell phone number and/or email address you provide when signing up for the app are regarded as your chosen address for receiving notices, promotional messages,   documents, and any formal communication from us.    You must notify us immediately (with your new cell phone number and/or email address) should the cell phone     number and/or the email address you provided during onboarding change.

23.2. Brassica Capital Limited is entitled to send any notices to your cell phone number and/or email address, or the new ones provided. These communications will be regarded as having been received by you unless the contrary is proven.

23.3. You can make any complaints, enquiries or requests to our Call Center Phone Number or send a communication to our email address and/or to our social media platforms at Brassica Capital GH or through theGoogle or App Store channels.

23.4. Any legal notice should be sent to our official email address at  info@brassicagroup.com or delivered in writing to our office at: 2nd Floor, Sky Light   Square, Osu Badu St.Accra. You acknowledge and agree that this agreement will be regarded as having been entered into in Accra and any breach of this agreement will be considered as having taken place in Accra.

24. Fraud Prevention

24.1. All anti-money laundering laws, regulatory directives, best practices, and conventions form part of these terms and conditions.

24.2. Upon the detection of a fraudulent activity or any resemblance of it, Brassica Capital Limited shall automatically suspend client’s investment account and notify client of such suspension and the reasons for the suspension.

24.3. Brassica Capital Limited shall then invoke all relevant anti-money laundering and cyber fraud laws, regulatory directives and best practices and conventions to investigate the  fraudulent activity.

24.4. Brassica Capital Limited shall only reopen the account after it is satisfied from the investigation that client and their investment account are free from any fraudulent activity.

24.5. In the event that Brassica Capital Limited’s investigation establishes the case of fraud, you consent to Brassica Capital Limited;

24.6. To cooperating with the Ghana Police Service or any fraud prevention or any security agency or any entity as mandated by law to conduct identity checks; to release any    information we have on you and to investigate you for any fraudulent activity that we  believe you may have carried the app.

25. Confidentiality

25.1. Any information whether personal or non-personal, obtained from client in signing up for and using the Brassica App shall be used purposely for running the investment account and shall not be disclosed to any third party without prior consent by client.

25.2. Brassica Capital Limited shall without consent from client share client information with any security service or any entity deemed fit by law to have such information for  purposes of preventing and investigating fraud and any other matter that the law may prescribe.

26. General

26.1. We may at any time amend these terms and conditions and notify customers of such amendments. Any amendment will not constitute a novation of this agreement.

26.2. You shall not vary any of these terms and conditions.

26.3. You agree that we may sue you in a court of competent jurisdiction in the event that any provision in these terms and conditions is breached by you.

26.4. A favor or concession we may give you will not affect any of our rights against you.

26.5. These terms and conditions are governed by the laws of Ghana.

26.6. We will not be responsible and liable to you for any indirect, consequential, or special damages arising from any act or omission by us or by any third party for whom we are         responsible and whether arising in contract, statute, or tort.

26.7. You are responsible for your connection to the internet and all costs associated with that internet connection.

26.8. You must notify us immediately of any change to any information you provided during your onboarding and app sign up.

26.9. You agree that your information, including your personal information, your telephone conversations with our call center and on all our communication channels as provided    for in this terms and conditions and as shall be updated from time to time and your transactions shall be recorded for purposes of improving the service we provide to           you, for improving our business operations and to resolve any disputes or conflict that may arise.

26.10. Same information as mentioned in clause 26.9 shall be recorded and kept for a period of 5 years upon suspension or closure of your account with Brassica Capital Limited.

26.11. All copyrights, trademarks and other intellectual property rights used and/or contained   in our notices, documents, communications or as part of our services remain the  property of Brassica CapitalLimited and you do not have any rights whatsoever to any    of these.

26.12. You accept that all transactions effected on the Brassica App are subject to other terms and conditions on Brassica Website and from our call center.

27. Sanctions

27.1. Any abusive and/or fraudulent use of the Brassica App and any false declaration will be punishable by the laws of Ghana.

27.2. Any costs whether monetary or non monetary incurred by us as a result of your abusive and/or fraudulent use of the Brassica App will be borne by you.

27.3. Any transactions or actions from you through the Brassica App triggering a malfunction of our systems and requiring technical intervention will be charged to and  by you.

28. Client Responsibilities

27.1. It is the responsibility of the clientto ensure that they provide accurate information (ersonal and nonpersonal) to Brassica Capital Limitedthrough the Brassica App. To  thisend, the client undertakes to Brassica Capital Limited that any information   provided is true and accurate and that clientis obligated to provide any additional           informationfailure of which shall result in the suspension or closure of client’s account.

27.2. Client is responsible for paying all fees, charges and taxes on any transaction that is conducted on both the BrassicaCapital side of the Brassica App whether these were made by you or someone else with or without your authority or knowledge.

27.3. You must not use the Brassica App to commit any offense – Fraud and Money Laundering and any other financial offense that is not allowed under the relevant laws of the country or contravenes theElectronic Payment Act 772 and the Money Laundering Regulation of Ghana, 2011.

27.4. In case of any complaints regarding the use of the Brassica App, client must lodge the said complaints within thirty (30) calendar days from the date of detection of the anomaly.

27.5. Client can use one of the following media in lodging any complaints:

1) An email to the Brassica using info@Brassicagroup.com
2) by calling our CallCenter.

27.6. Customer must comply with any instructions issued by Brassica Capital Limited from  time to time for the use of the Brassica App.