Anti-Fraud & Security Policy

Gloseg B2B Limited Effective Date: August 16, 2026 Version: 2.2

Definitions

"Gloseg" means Gloseg B2B Limited, headquartered in Accra, Ghana, with registrations in Nigeria and the United Kingdom, operator of the Platform.

"Platform" means the Gloseg B2B marketplace, including its website, applications, and related services connecting Seller Organizations in 54 African countries with Buyer Organizations worldwide.

"Organization" means the registered business entity, Seller or Buyer, on whose behalf Users act on the Platform.

"User" means an individual with an account associated with an Organization, including owners, administrators, and team members.

"Organization Administrator" means a User granted administrative rights over an Organization's account, including the ability to add, remove, or modify team members and permissions.

"Fraud" means any act or attempted act of deception, misrepresentation, or manipulation carried out on or through the Platform for the purpose of obtaining a financial, informational, or competitive advantage to which the actor is not entitled.

"Escrow" means the mechanism by which Buyer funds for an Order are held by Gloseg's payment infrastructure pending satisfaction of release conditions.

"Payout" means the transfer of Escrow-released funds to a Seller's verified bank account, triggered by Gloseg operations.

"RFQ" means a Request for Quotation submitted by a Buyer Organization describing goods or services it wishes to procure.

"Quote" means a Seller Organization's priced response to an RFQ.

"Order" means a binding transaction formed on the Platform following acceptance of a Quote or listing purchase.

"Invoice" means a billing document generated within an Order for payment, milestone, or final settlement purposes.

"Transaction Hold" means a temporary suspension of Escrow release, Payout, or account functionality pending review.

"Abuse Report" means a submission by a User or third party alleging conduct that violates this Policy or other Gloseg policies.

"Reviewer" means a member of Gloseg operations or trust and safety personnel authorised to examine reports, transaction data, and account activity and to determine outcomes under this Policy.

1. Purpose and scope

1.1 Purpose

1.1.1 Objective

This Policy sets out the conduct Gloseg treats as fraudulent or abusive on the Platform, the measures Gloseg operations takes to detect and respond to such conduct, the obligations placed on Organizations and Users to protect their own accounts, and the remedies available to Users who are affected by fraud.

1.1.2 Relationship to other policies

This Policy supplements the Terms of Service, the Verification & Trust Policy, the Sanctions & Trade Compliance Policy, the Payments, Escrow & Payouts Terms, and the Acceptable Use Policy. Where those documents address a specific category of conduct, they control for that context, subject to the general standards set out here.

1.2 Scope

1.2.1 Application

This Policy applies to every Seller and Buyer Organization, every User acting on their behalf, and every RFQ, Quote, Order, Invoice, message, review, and payment instruction processed through the Platform.

2. Prohibited fraudulent conduct

2.1 Payment diversion

2.1.1 Description

A User or Organization must not attempt to redirect a Buyer's payment, an Escrow funding instruction, or a Payout to an account, instrument, or party other than the one properly designated and verified for that transaction, whether by altering bank details in correspondence, impersonating a counterparty's finance contact, or submitting falsified payment instructions.

2.2 Off-platform payment solicitation

2.2.1 Description

A User must not solicit or agree to a Buyer or Seller making or receiving payment for a Platform-originated RFQ, Quote, or Order outside the Platform's Escrow mechanism, including by requesting direct bank transfer, cash, informal payment channels, or a duplicate transaction structured to appear unrelated to the Platform. Off-platform payment defeats Escrow protection and dispute processes and is treated as a serious violation regardless of whether the underlying trade itself is legitimate.

2.3 Impersonation of verified organizations

2.3.1 Description

A User must not create or operate an account that impersonates, or is confusingly similar to, a verified Organization, its officers, or its authorised representatives, or that falsely claims affiliation with a verified Organization for the purpose of diverting business, payments, or communications.

2.4 Fake or falsified documentation

2.4.1 Description

A User must not submit forged, altered, borrowed, or otherwise falsified business registration documents, tax certificates, export licences, bank statements, identity documents, address proof, or product certifications, whether for Verification purposes or in support of a Listing, RFQ, Quote, or Order.

2.5 Invoice fraud

2.5.1 Description

A User must not generate, alter, or present an Invoice that misstates the agreed price, quantity, milestone status, or payment recipient, or that duplicates or fabricates an Invoice for goods or services not ordered or not delivered, for the purpose of obtaining payment or Escrow release to which the Organization is not entitled.

2.6 Account takeover

2.6.1 Description

A User must not access, or attempt to access, another User's account or an Organization's account without authorisation, including through stolen credentials, social engineering, session hijacking, or exploiting an offboarded team member's retained access.

2.7 Collusive ratings and reviews

2.7.1 Description

A User or Organization must not arrange, incentivise, or participate in reciprocal, fabricated, or coordinated ratings or reviews intended to inflate or deflate an Organization's reputation on the Platform, including through affiliated accounts, paid review schemes, or retaliatory review campaigns.

2.8 Shill RFQs

2.8.1 Description

A Buyer, Seller, or affiliated party must not submit an RFQ that is not a genuine procurement intent, including RFQs submitted to extract a competitor's pricing or terms, to manipulate Seller ranking or responsiveness metrics, or to create a false impression of demand for a category of goods.

2.9 Other manipulative conduct

2.9.1 Residual category

The categories above are illustrative, not exhaustive. Gloseg operations may treat any deceptive or manipulative conduct directed at another User, at Gloseg, or at the integrity of the Platform's RFQ, Quote, Order, Escrow, Payout, or review systems as Fraud under this Policy, whether or not expressly listed.

3. Detection and monitoring

3.1 Automated risk signals

3.1.1 General description

Gloseg's systems generate automated risk signals from account behaviour, transaction patterns, messaging content, and Verification data. These signals inform prioritisation of manual review and are not disclosed in detail, to preserve their effectiveness against circumvention.

3.2 Fraud detection logs

3.2.1 Recording

Gloseg maintains logs of flagged activity, review outcomes, and actions taken under this Policy, for use in investigations, appeals, pattern analysis across Organizations, and cooperation with law enforcement where required.

3.3 Manual review

3.3.1 Role of reviewers

Flagged accounts, transactions, Abuse Reports, and Verification anomalies are examined by Reviewers, who assess available evidence against the standards in this Policy and determine whether a Transaction Hold, account restriction, or other action under Section 8 is warranted.

3.4 Transaction holds

3.4.1 Purpose and effect

A Transaction Hold suspends Escrow release, Payout, or specific account functionality while a Reviewer examines a transaction or account. A Transaction Hold is a protective and investigative measure, not a finding of wrongdoing, and is lifted once the review concludes that no violation occurred.

3.4.2 Duration

A Transaction Hold is maintained only for as long as reasonably necessary to complete the relevant review, and the affected Organization is notified of the hold and, where appropriate, the general reason for it, subject to Gloseg's ability to withhold detail where disclosure would compromise an active investigation.

4. Account security obligations

4.1 General user obligations

4.1.1 Credential hygiene

Every User is responsible for maintaining the confidentiality of their login credentials, using a unique and sufficiently strong password for their Gloseg account, and not sharing credentials with any other person, including colleagues within the same Organization.

4.1.2 Multi-factor authentication

Where Gloseg offers multi-factor authentication for an account or action, Users are strongly encouraged to enable it, and Organization Administrators are strongly encouraged to require it for team members with access to Escrow, Payout, or Verification functions.

4.1.3 Reporting compromise

A User who suspects their credentials have been compromised, or who observes unfamiliar activity on their account, must change their password immediately and notify legal@gloseg.com without undue delay.

4.2 Organization administrator obligations

4.2.1 Team member management

An Organization Administrator is responsible for granting team members only the access appropriate to their role, reviewing team member access periodically, and promptly removing access for individuals who leave the Organization or change role.

4.2.2 Offboarding

An Organization Administrator must remove a departing team member's access to the Organization's Gloseg account no later than the individual's last working day for the Organization, and must revoke any device sessions, API credentials, or delegated permissions associated with that individual.

4.2.3 Responsibility for team member conduct

An Organization is responsible for the actions taken on its account by its team members, including actions taken by a team member whose access was not timely revoked following departure, without prejudice to Gloseg's right to investigate and take action against the individual directly where appropriate.

5. Platform security measures

5.1 General description

5.1.1 Scope of disclosure

Gloseg maintains security measures designed to protect the confidentiality, integrity, and availability of Platform data and transactions. This section describes those measures at a general level. Gloseg does not disclose specific configurations, thresholds, or control logic, as doing so would assist those seeking to circumvent them.

5.2 Encryption

5.2.1 Data in transit

Data transmitted between Users and the Platform, including account credentials, Verification Documents, messages, and payment instructions, is encrypted in transit.

5.3 Role-scoped access

5.3.1 Internal access control

Access to Organization data, Verification Documents, and payment functions within Gloseg's systems is scoped to personnel whose roles require it, consistent with the principle of least privilege.

5.4 Audit logging

5.4.1 Internal accountability

Gloseg maintains audit logs of significant account and transaction events, including Verification State changes, Escrow and Payout actions, and administrative actions taken on Organization accounts, to support investigations and internal accountability.

6. Escrow and payout safeguards

6.1 Operator-triggered payouts

6.1.1 No automatic release

Payouts are not released automatically on a fixed schedule. Escrow release and Payout are triggered by Gloseg operations against defined conditions associated with the Order, including confirmation of delivery milestones, expiry of an inspection or dispute window, or resolution of a dispute.

6.2 Hold and release conditions

6.2.1 Grounds for hold

Gloseg operations may place or maintain a hold on Escrow release or Payout where a Transaction Hold under Section 3.4 is active, a sanctions or Verification screening match is unresolved, an Abuse Report or dispute concerning the Order is pending, or the Organization's Bank Verification is incomplete or has failed.

6.2.2 Release

Escrow funds are released and Payout is made once the applicable conditions are satisfied and no unresolved hold applies, consistent with the Payments, Escrow & Payouts Terms.

6.3 Forfeiture in confirmed fraud cases

6.3.1 Withholding pending payouts

Where an investigation under Section 8 confirms Fraud by a Seller Organization in connection with an Order, Gloseg operations may withhold and, where the funds are attributable to the fraudulent conduct, forfeit the Seller's pending Payout for that Order, and may apply the funds toward a refund to the affected Buyer, without prejudice to any other remedy available to Gloseg or the Buyer.

7. Reporting suspected fraud

7.1 How to report

7.1.1 Channels

A User may report suspected Fraud through the Platform's Abuse Report function within the relevant Order, RFQ, or Organization profile, or by emailing legal@gloseg.com with sufficient detail to identify the parties and conduct concerned.

7.2 Evidence to provide

7.2.1 Useful evidence

A report is most effectively investigated when it includes the Order, RFQ, or Quote reference, screenshots or copies of relevant messages, a description of the suspected conduct and when it occurred, any payment instructions or account details involved, and identification of the Organization or User believed responsible. A Reviewer may request further information during the investigation.

7.3 Good faith reporting

7.3.1 Protection against retaliation

A User who submits an Abuse Report in good faith, even if the report is ultimately not substantiated, will not face retaliation from Gloseg for having made the report. Knowingly false reports made to harass or disadvantage a counterparty are themselves a violation of this Policy.

8. Investigation process, timelines, and outcomes

8.1 Process

8.1.1 Steps

On receipt of an Abuse Report or an automated risk signal indicating possible Fraud, a Reviewer examines available account activity, transaction records, messages, and submitted evidence, may place a Transaction Hold under Section 3.4 pending review, may request further information or documentation from the parties involved, and reaches a determination based on the evidence available.

8.2 Indicative timelines

Stage	Indicative duration	Notes
Acknowledgement of report	1 to 2 business days	Automated acknowledgement where submitted through the Platform
Initial triage and risk assessment	1 to 3 business days	May result in an immediate Transaction Hold
Substantive investigation	5 to 15 business days	Extended for cross-border evidence gathering or law enforcement liaison
Notification of outcome	Following completion of investigation	Provided to the reporting party and, where appropriate, the subject of the report

These are indicative service targets, not contractual commitments. Gloseg does not guarantee any fixed investigation timeline, particularly where the matter involves cross-border evidence or third-party cooperation.

8.3 Possible outcomes

8.3.1 Escalation ladder

Finding	Possible action
No violation found	Transaction Hold lifted, account restored to normal standing
Minor or first-time violation, low risk of recurrence	Formal warning, required corrective action
Confirmed violation with financial or reputational impact	Account restriction (limits on RFQs, Quotes, Orders, or Payouts), extended Transaction Hold
Serious or repeated violation	Account suspension pending further review
Confirmed serious Fraud, sanctions-related conduct, or repeat offending	Permanent account closure, forfeiture of pending Payouts attributable to the fraudulent conduct under Section 6.3
Conduct indicating criminal activity	Referral to law enforcement or relevant regulatory authorities, in addition to any of the above

8.3.2 Discretion and proportionality

Gloseg operations exercises judgment in selecting an outcome proportionate to the severity, intent, financial impact, and repetition of the conduct found. Gloseg is not obliged to apply outcomes in the sequence shown and may proceed directly to suspension or closure where warranted by the severity of the conduct.

9. Cooperation with law enforcement and lawful disclosure

9.1 Cooperation

9.1.1 Scope

Gloseg cooperates with law enforcement and regulatory authorities investigating suspected Fraud, sanctions evasion, or other unlawful conduct connected to the Platform, including by responding to lawful requests for account, transaction, and Verification records.

9.2 Disclosure standard

9.2.1 Basis for disclosure

Gloseg discloses User and Organization information to law enforcement or regulators only pursuant to a valid legal process, a lawful request consistent with applicable data protection law, or where necessary to prevent imminent harm, fraud, or a violation of this Policy.

10. User remedies and limitations

10.1 No chargeback subsystem

10.1.1 Explicit statement

Gloseg operates no chargeback subsystem. Buyers do not have the ability to reverse a completed payment through a card network or bank chargeback process routed through the Platform. The contractual remedy for a Buyer who has not received goods or services as agreed, or who believes an Order was procured through Fraud, is the Escrow and dispute resolution process described in the Payments, Escrow & Payouts Terms and the Dispute Resolution Policy.

10.2 Escrow and dispute as the contractual remedy

10.2.1 Primary remedy

Where Escrow funds remain held for an Order affected by suspected Fraud, a Buyer may raise a dispute within the applicable window, and Gloseg operations will determine Escrow release, refund, or continued hold based on the outcome of the dispute and, where relevant, the fraud investigation under Section 8.

10.2.2 Limits where funds have already been released

Where Escrow funds have already been released and Payout made before Fraud is identified, recovery of those funds from the Seller Organization is not guaranteed, and Gloseg's ability to assist is limited to the actions described in Sections 6.3 and 9, its own investigation and enforcement powers, and lawful cooperation with authorities. Gloseg is not a guarantor of any Seller's performance or solvency.

10.3 No warranty of fraud-free trading

10.3.1 Disclaimer

Gloseg's fraud detection and prevention measures are designed to reduce the incidence and impact of Fraud on the Platform, not to eliminate it entirely. Gloseg does not warrant that any Organization or transaction is free of fraudulent conduct, and Users remain responsible for exercising reasonable commercial diligence proportionate to transaction size and risk.

11. Record retention

11.1 Retention period

11.1.1 Standard

Fraud detection logs, Abuse Reports, investigation records, and related evidence are retained for the period necessary to satisfy AML, sanctions, tax, and dispute-resolution obligations under applicable law in Ghana, Nigeria, the United Kingdom, and other relevant jurisdictions, and in any event no longer than necessary for those purposes, after which they are securely deleted or anonymised.

12. Amendments and notice

12.1 Changes to this policy

12.1.1 Notice

Gloseg may amend this Policy from time to time to reflect evolving fraud typologies, technology, or legal requirements. Material changes are notified through the Platform or by email to registered Organization contacts at least fourteen days before taking effect, except where required sooner to address an active or emerging security threat.

13. Governing law and jurisdiction

13.1 Governing law

13.1.1 Primary law

This Policy is governed by the laws of Ghana. Nothing in this Policy limits the application of mandatory local law in the Organization's jurisdiction of establishment.

13.2 Jurisdiction

13.2.1 Forum

Subject to any mandatory local consumer or employment protections, the courts of Ghana have non-exclusive jurisdiction over disputes arising from this Policy.

Contact

Legal notices, questions about this document, data protection requests and compliance enquiries: legal@gloseg.com

Data subject requests may also be submitted through the Privacy & My Data surface at /privacy/my-data.

Gloseg B2B Limited Accra, Ghana, West Africa