IBE System Agreement and Rules

Last Updated: August 12, 2025
Effective Date: August 12, 2025

1. IBE System Overview

The IBE (Ismael Byiringiro Enterprise) System is a comprehensive financial platform that facilitates secure transactions between registered agents and clients for share investments and financial services. This system operates under strict regulatory compliance and maintains the highest standards of financial integrity.

2. Agent Registration and Eligibility

2.1 Eligibility Requirements

• Must be at least 18 years of age
• Valid national identification documentation
• Completed educational requirements (minimum secondary education)
• Clean financial and criminal background
• Successful completion of IBE certification training

2.2 Registration Process

• Complete accurate personal and professional information
• Submit required documentation for verification
• Pass background checks and compliance screening
• Accept all terms and conditions
• Account activation subject to admin approval

3. Agent Responsibilities and Duties

3.1 Professional Conduct

• Maintain the highest standards of professional integrity
• Provide accurate, honest, and transparent financial advice
• Act in the best interests of clients at all times
• Maintain client confidentiality and data protection
• Complete all required continuing education and training
• Comply with all local and international financial regulations

3.2 Transaction Management

• Process all client transactions accurately and promptly
• Maintain detailed records of all client interactions
• Follow established protocols for investment recommendations
• Ensure all transactions comply with regulatory requirements
• Report any technical issues or discrepancies immediately

3.3 Client Relations

• Provide exceptional customer service to all clients
• Respond to client inquiries within established timeframes
• Educate clients about investment risks and opportunities
• Maintain regular communication with active clients
• Handle client complaints professionally and promptly

4. Commission Structure and Compensation

4.1 Commission Calculation

• Commissions based on client investment amounts and transaction types
• Tiered commission structure rewards high-performing agents
• Performance bonuses available for exceptional results
• Commission rates subject to change with 30-day notice
• Special incentives for client retention and growth

4.2 Payment Terms

• Commission payments processed monthly
• Payments made via approved financial institutions
• Tax obligations are the responsibility of the agent
• Disputed commissions subject to investigation and resolution
• Payment delays may occur due to regulatory compliance

5. Compliance and Regulatory Requirements

5.1 Legal Compliance

• All activities must comply with local financial laws
• Agents responsible for understanding applicable regulations
• Regular compliance audits and reporting required
• Cooperation required with regulatory investigations
• Immediate reporting of compliance violations mandatory

5.2 Anti-Money Laundering (AML)

• Strict KYC (Know Your Customer) procedures must be followed
• Suspicious transactions must be reported immediately
• Client identity verification required for all accounts
• Regular monitoring of transaction patterns
• Compliance with international AML standards

6. System Owner Authority and Governance

6.1 Ultimate Authority

• The system owner maintains ultimate authority over all platform operations
• All policy decisions and changes are at the discretion of the system owner
• Account suspension or termination decisions are final and binding
• System owner reserves the right to modify commission structures
• Final arbiter in all disputes and conflicts

6.2 Platform Management

• System owner controls all technical aspects of the platform
• Regular updates and maintenance may cause temporary disruptions
• New features and functionality introduced at owner's discretion
• System owner may delegate certain responsibilities to administrators
• Platform availability and uptime targets established by owner

7. Prohibited Activities

The following activities are strictly prohibited:

• Any form of fraud, deception, or misrepresentation
• Unauthorized access to system components
• Sharing login credentials with unauthorized parties
• Manipulating client accounts without permission
• Soliciting clients outside approved channels
• Using the platform for illegal activities
• Attempting to reverse-engineer system components
• Violating intellectual property rights

8. Account Termination and Consequences

8.1 Termination Conditions

• Violation of any terms and conditions
• Fraudulent or unethical behavior
• Failure to maintain required certifications
• Excessive client complaints or disputes
• Non-compliance with regulatory requirements
• Extended periods of inactivity

8.2 Consequences of Termination

• Immediate loss of access to all system functions
• Forfeiture of unpaid commissions and bonuses
• Potential legal action for damages
• Reporting to relevant regulatory authorities
• Permanent ban from re-registration

9. Limitation of Liability

The IBE system and its owners shall not be liable for:

• Market losses or investment performance
• Technical failures or system downtime
• Third-party service interruptions
• Regulatory changes affecting operations
• Force majeure events beyond reasonable control

10. Modifications to Terms

The system owner reserves the right to modify these terms and conditions at any time. Agents will be notified of significant changes, and continued use of the platform constitutes acceptance of modified terms.

11. Contact Information

For questions about these terms and conditions, please contact:

• Support Email: info@ibe.rw
• Support Contact: +250788452095

ISMAEL BYIRINGIRO ENTERPRISE - STAFF CONDUCT OF INTEGRITY

1. Generalities

1.1. Purpose of the Code

The purpose of this Code of Conduct is to assist staff to know and understand the minimum standards of conduct and behavior expected of them as an employee of IBE.

This reflects the basic requirements of professionalism, integrity and courtesy needed to ensure that we provide a quality performance to our stakeholders, and that a pleasant and safe working environment exists for all staff.

1.2. Coverage

The Code applies to all employees of IBE, including – without being exhaustive - permanent, temporary, and casual employees as well as interns, volunteers, and ‘bénévoles’. This Code forms part of the staff member's employment contract with the Enterprise.

1.3. Principles

The Code of Conduct establishes three principles of conduct which all staff members are expected to observe:

1. They should fulfil their lawful obligations to IBE with high professionalism and integrity.
2. They should perform their official duties honestly, faithfully and efficiently, respecting the rights of the stakeholders, the Enterprise community and their colleagues.
3. They should not bring their employer into disrepute through their activities, whether inside or outside the Enterprise. Activities outside the Enterprise are not likely to be acceptable if they:
   1. damage the standing or reputation of IBE because of the position the employee holds in it;
   2. interfere with the proper performance of the employee’s duties.

1.4. Shared Expectations

IBE can operate effectively and provide high-standards outcome when there is a shared expectation between the Enterprise (as the employer) and its employees. This is a two-way commitment that benefits both the employer and employee when expectations are met.

Set out below is a summary of the expectations that IBE, as the employer, has of its staff, and the expectations that an employee may have of IBE.

1.4.1. IBE Expectations of Staff

IBE expects any staff to:

1. work within the law with honesty and integrity;
2. comply with all lawful and reasonable instructions;
3. comply with the policies of the Enterprise;
4. work diligently and meet the requirements of employment agreement;
5. respect the rights of colleagues, stakeholders and the Enterprise community.

1.4.2. Obligations of IBE to Staff

As a good employer, IBE is committed to meeting the following staff expectations:

1. a commitment to the spirit and principles of the Universal Declaration of Human Rights;
2. opportunities for equal employment; equal pay for equal duties principle;
3. impartial and open selection and appointment procedures;
4. fair rates of remuneration for skill, responsibilities and performance;
5. an up-to-date job description that provides clear statements of employee’s duties and employer's expectations;
6. adequate training and equipment to perform duties;
7. regular and appropriate feedback and communication on work performance;
8. effective communication of information;
9. good and safe working conditions;
10. opportunity for the enhancement of staff abilities;
11. freedom from harassment or discrimination in the workplace;
12. a commitment to a supportive and confidential employee assistance programme;
13. appropriate disciplinary and dispute procedures and the opportunity for redress against unfair or unreasonable treatment by the employer.

2. Codes of Behavior

The employee is to avoid any activity, either work-related or private, which could reflect badly on IBE in its relationships with its stakeholders. This means that they are to inform their manager in writing if:

1. they apply for bankruptcy or become bankrupt;
2. any criminal charges or convictions that may occur while they are employed by IBE are of such a nature that it would be inappropriate for them to continue to be employed in the same capacity. This may include, for example, charges that involve loss of trust between the employee and the Enterprise, or charges that damage the reputation of the Enterprise;
3. secondary employment – permission from employer – doesn’t interfere with primary duties.

2.1. Performance of Duties

Employees are expected to carry out their duties in an efficient and competent manner. This means that they are expected to:

1. comply with the law;
2. comply with all lawful and reasonable instructions and work as directed by the employer or the duly delegated representative;
3. perform their duties according to the legislation, policies and procedures of IBE;
4. comply with any other code of ethics or practice that may apply to their profession;
5. perform their work to an agreed standard;
6. show proper and reasonable care when using Enterprise’s property, resources or funds;
7. contact their direct supervisor (within 30 minutes of their normal starting) if you are to be absent from work due to sickness or an emergency.

They are also expected to obtain permission from the employer to:

1. be absent from their workplace during work hours;
2. enter into any contract or agreement on behalf of IBE. The Enterprise will not accept responsibility for any unauthorized action.

2.2. Appropriate Relationships with clients

Employees should recognize the sensitivity of the situation of clients seeking support (especially legal services) from IBE and show respect for and protect their dignity.

1. No employee is to have a sexual relationship with any person under the age of 18 or any client of the Enterprise.
2. No employee is to have a sexual, familial or financial relationship with a client or young person with whom they have a professional relationship arising from their employment with the IBE.

They must inform their employer if a person to whom they are related, or with whom they are having or previously had any personal, sexual or financial relationship, comes within the ambit of their professional responsibilities.

2.3. Respect for the Rights of Others

While employed by IBE, employees have a duty to treat their colleagues, clients and the public with courtesy and respect. This means that they are expected to:

1. Avoid behavior that might distress other employees or disrupt the workplace.
2. Ensure that any workplace relationships do not have a negative effect on their work performance.
3. Respect the privacy of individuals when dealing with personal information.
4. Be non-judgmental by not harassing or discriminating against their colleagues or clients on the basis of their gender, age, disability, marital status, and ethnicity, religious or ethical beliefs or sexual orientation.
5. They must not have or bring into the workplace any material that may be viewed as racist or sexist, that is pornographic, or that is otherwise offensive to the Enterprise or its staff.

2.4. Conflicts of Interest and Integrity

Employees are expected to be honest, fair and impartial when they perform their duties. This means that:

1. They should not show bias to an individual client or stakeholder. Everyone should be treated fairly.
2. In general, they are not to approve anything that will result in expenditure in respect of themselves (eg: increased salary, travel expenses, a training course, their own overtime).
3. They are not to lend money to, or borrow money, or otherwise enter into financial relationships with staff or clients. The amount of money lent or borrowed could imply indebtedness that could lead to a conflict of interest in formal work relationships.
4. They must inform IBE if they are involved in, or have a personal or financial interest or commitment to, any activity that may conflict, or could be seen by others to conflict, with the performance of their duties and the goals of the Enterprise. This includes situations such as:
   1. having a close family member, relation or partner working with you;
   2. when a member of your family or a person that you know enters into a professional relationship with the Enterprise. Under no circumstances are they to become professionally involved, or in any way try to influence that relationship, or obstruct staff in performing their duties.

A financial interest or commitment includes:

1. Enterprise directorships;
2. shareholdings;
3. offers of additional employment outside the Enterprise.

5. They must inform IBE if they are a member of (or plan to become a member of) or have a family involvement in a trust or community organization which is funded by or otherwise linked to the Enterprise.
6. Some employees, such as lawyers, are required to abide by a professional code of ethics. These employees must inform IBE if there are any conflicts between their professional codes of ethics and the duties they are directed to perform.
7. They should consult with their employer before taking up other paid employment where that other paid employment could conflict with the performance of their duties at IBE.
8. They should speak to their employer if they are unsure whether or not a particular situation is, or could be seen to be, a conflict of interest.

2.4.1. Gifts and Rewards

Employees may not seek any form of reward (including gifts, favours, prizes or fees) for performing their duties as an employee. Gifts or rewards can be seen as bribes or inducements that put them under an obligation to someone other than IBE. While it is acceptable to receive a gift of a low value, if you are offered any form of reward or gift valued at Rwf 100,000 or more, you should inform your employer who will decide the appropriate response.

2.4.2. Participation in public bodies or voluntary associations

Employees must inform the employer if they are participating in a public or voluntary organization (or intend to) and there are actual or potential conflicts between their responsibilities and duties as a staff member of IBE, and their responsibilities and duties to the other organization. Where it is considered there is a potential conflict of interest, appropriate arrangements will need to be made to avoid or resolve the conflict.

For example:

1. It could be interpreted as a conflict of interest if they are a member of (or plan to become a member of) or have a family involvement in a trust or community organization which is funded by or otherwise linked to IBE.
2. If they intend to stand for any elective political position, they must discuss this with the employer, to arrange leave.

2.5. Security/Confidentiality

Staff are expected to maintain the highest standards of confidentiality and security in the workplace. This means that they are not to:

1. use the Enterprise’s computer systems in any way that may corrupt or disrupt their normal function;
2. access, or attempt to access, machines or networks by unauthorized means – for example unauthorized use of dial-in modems;
3. use information related to the Enterprise’s systems for anything other than authorized purposes;
4. bring into the workplace via the email or Internet system, or by any other means, any material that is pornographic, or that may be viewed as racist or sexist;
5. give their computer password/security card to any other members of staff without good and justifiable reason;
6. leave a record of their password anywhere obvious so that someone else may see it.

2.5.1. Ownership of Information

IBE owns all data stored on its computer systems. Management has the right to access and view this information at any time. The network is being continually monitored and staff found using the system inappropriately may face disciplinary action.

2.5.2. Data Storage on Computer Systems and Servers

Only business information can be stored on computer systems. Staff are not permitted to store any personal data on the computer system, including documents, spreadsheets, databases, games and jokes.

2.5.3. Computer Software

Only software authorized by the Enterprise can be loaded onto IBE computer systems. Any software loaded onto any IBE equipment must have a valid license with proof of ownership. No software owned by IBE may be copied and used on another PC or taken home and loaded onto a personal device, as this contravenes software licensing laws.

2.5.4. Use of the Email System

The email system is for the Enterprise’s purposes and must not be misused. While it is acceptable to send or receive business messages from outside the Enterprise, users should be aware that this information might not be secure outside the Enterprise. This needs to be considered before they send email. Personal information, such as documents, spreadsheets, databases, games, jokes and other non-business-specific email must not be circulated via the email system.

2.5.5. Internet

The use of the Internet is for work purposes only. Staff are not to retrieve, distribute or store unapproved or non-business-related material from the Internet. They must have approved access and this is provided on an individual basis. The use of social networks during work hours is strictly prohibited, unless it is closely related to the Enterprise’s activities.

2.5.6. Retention of Data

IBE is required to retain information. This means that staff cannot delete business-critical data from the computer system without permission.

2.6. Official Information

The disclosure or release of official information is subject to the Enterprise’s board decision. Information related to IBE, its donors, suppliers, clients, or the users of its services is to be treated at all times as confidential to the Enterprise and is to be used by employees for official purposes only.

Employees of IBE are also subject to the principle of privacy. The main object of this principle is to promote and protect personal information and it seeks to give individuals some measure of control over personal information about themselves.

2.6.1. Release of Official Information

Official information must only be released by authorized employees, and only in accordance with the procedures as stated in the Rwanda Access to Information Law (2009). IBE instructions about the release of official information must also be followed.

It is not to be released to the media or the public without the proper authorization. For example, staff may not remove or copy Enterprise documents or records for external use without approval from their manager. It should never be used for personal motives.

2.7. Public Comment

Staff members should not respond to requests from the media for comment on matters relating to the Enterprise. Only authorized staff members should respond to media requests for comment on such matters. If the media makes an approach to any staff member, the concerned staff has to inform the competent person so they can respond to the media request.

3. Breaches of the Code of Conduct

This Code of Conduct describes the standards of behavior expected of staff. As outlined in the Code, behavior or actions that are considered unacceptable by IBE may result in disciplinary action against the employee concerned, which could include termination of employment.

3.1. Disciplinary Action

Disciplinary action is about problem solving. IBE is concerned to identify problems associated with performance or behavior, and to make sure that the process for fixing those problems is prompt, consistent and fair. In general, disciplinary procedures include informal or formal disciplinary action along the following lines:

3.1.1. Informal Disciplinary Action:

• discussion of the problem;
• assistance to help overcome the problem;
• referral to the organ superior to the employee’s level, if appropriate;
• temporary transfer to other duties.

3.1.2. Formal Disciplinary Action:

• oral warning;
• written warning;
• removal of discretionary conditions of employment (ie: delegations, flexible working hours, etc.);
• transfer to another position at existing salary;
• transfer to another position with reduced pay (but not below the minimum rate for that position);
• suspension (with or without pay);
• dismissal with notice;
• dismissal without notice.

Other options may be considered, depending on the circumstances of the case.

Whether disciplinary action is informal or formal, IBE will make sure that the disciplinary procedures are fair. This means that:

1. The concerned employee must be told of their right to request union, legal or other assistance and/or representation.
2. The concerned employee must be told of the specific behavior or performance that is causing concern, and given a reasonable opportunity to provide an explanation.
3. The concerned employee must be told, where appropriate, of the action that is required to amend or improve their behavior or performance, and be given a reasonable opportunity to do so.
4. Competent organ must undertake an appropriate investigation before any substantive disciplinary action is taken.
5. If the offence is sufficiently serious, an employee is to be placed on suspension pending investigation.
6. An oral warning would usually precede a written warning, depending on the seriousness of the misconduct.
7. It is a requirement that the process and result of any disciplinary action are recorded in writing, read and signed by the concerned employee, and then placed on their personal file.

In general terms, no disciplinary papers will go on the employee’s file unless they (employee) have seen them or have been given a genuine opportunity to see them. If they are not satisfied with the disciplinary action taken, they can appeal to the superior organ within the Enterprise. The latter organ’s decision is deemed final.