Public Notice

Fees & Pricing Schedule · AML/KYC Notice · eNGN Public Disclosure · Regulatory Status Disclosure

Effective Date: July 14, 2026 | Last Updated: N/A

This page contains four short, plain-language disclosures intended for Upesa users:

• (A) the Fees & Pricing Schedule;
• (B) the AML/KYC Notice for Users;
• (C) the eNGN Public Disclosure; and
• (D) the Regulatory Status Disclosure.

Each is designed to stand alone as a linked page, and each supplement, without replacing:

• (A) Upesa's Terms of Use
• (B) Privacy Policy
• (C) Privacy Notice &
• (D) Cookie Policy.

This Fees & Pricing Schedule sets out the fees that may apply to your use of the Upesa Platform. It supplements Section 7 (Fees and Charges) of Upesa's Terms of Use. Fees shown are illustrative and subject to change on reasonable notice; the fees applicable to a specific transaction are always shown to you before you confirm it.

• Fees applicable to a specific transaction are shown to you before you confirm the transaction; there are no hidden fees.
• Upesa may update this Fees & Pricing Schedule from time to time; where a change is material, Upesa will provide reasonable notice through the Platform before the change takes effect.
• A historical version of this schedule is available on request.

This Privacy Notice is a short-form summary provided at the point personal data is collected (for example, during registration or KYC verification). It supplements, and should be read together with, our full Privacy Policy in Part A, which contains complete details of our data processing practices.

Upesa is the data controller of your personal data. Full contact details are set out in Section A15.

Regulators (including the NDPC, SEC, and CBN), banking and payment partners, counterparty virtual asset service providers (for Travel Rule purposes), identity verification and sanctions-screening providers, IT and cloud service providers, and professional advisers. We do not sell your personal data.

Your personal data is primarily processed and stored in Nigeria. Where it is transferred abroad (for example, to a cloud provider or a counterparty VASP), we apply safeguards recognised under the NDPA, the GAID, and, where relevant, the GDPR, as detailed in Section A8.

We generally retain KYC, transaction, and Travel Rule data for a minimum of seven (7) years after your relationship with us ends, in line with AML/CFT requirements, or longer if required by law. See Section A10 for full details.

You can ask us to give you a copy of your data, correct it, delete it (subject to legal retention obligations), restrict or object to certain processing, move it elsewhere, and withdraw any consent you've given — at any time and free of charge, using the contact details in Section A15. You can also complain to the NDPC or, if you're in the EU/EEA, your local data protection authority. Full details of these rights are set out in Section A9 of the Privacy Policy.

Contact our Data Protection Officer using the details in Section A15 of the Privacy Policy.

eNGN is a Naira-denominated utility token issued by Upesa. It is used within the Upesa wallet to represent your Naira balance; for example, after you convert a stablecoin to Naira, or before you withdraw funds to your bank account. Every unit of eNGN is redeemable 1:1 for Naira through Upesa.

• eNGN is not legal tender.
• eNGN is not a bank deposit and is not covered by any deposit insurance scheme.
• eNGN is not offered, sold, or marketed to the public as an investment, and carries no prospect of profit, yield, or appreciation.
• eNGN is not listed or tradable on any exchange or secondary market.
• eNGN cannot be sent or transferred to any wallet, account, or person outside the Upesa Platform.
• eNGN is not the same as the Central Bank of Nigeria's eNaira. eNaira is a central bank digital currency issued directly by the CBN; eNGN is a privately issued, reserve-backed utility token issued by Upesa.

Every unit of eNGN in circulation is backed at least 1:1 by Naira held in a designated reserve account with a CBN-regulated financial institution, separate from Upesa's own operating funds. These reserve funds are not lent, invested in risk-bearing instruments, or used for Upesa's business expenses.

You can redeem your eNGN for Naira at any time, subject to standard identity verification and processing timeframes, by initiating a withdrawal on the Platform. Redemption will not be unreasonably delayed or withheld.

Upesa obtains periodic independent attestation confirming that Naira held in reserve is at least equal to the total eNGN in circulation.

(We can attach this once we have.)

For more detail on how eNGN works, contact us at [email protected]

Upesa is currently working on participating in the Securities and Exchange Commission of Nigeria's ("SEC") Accelerated Regulatory Incubation Program ("ARIP"). ARIP is a supervised on-ramp that allows fintech innovators, including virtual asset service providers, to operate in a regulated test environment while working toward full SEC registration. Upesa's participation in ARIP means we will operate under SEC oversight during this period, but as at the date of this disclosure, Upesa has not yet completed ARIP or full SEC registration as a licensed virtual asset service provider.

We will update this page as our registration status progresses, and we encourage you to check the SEC's public register of licensed capital market operators for the most current confirmation of any operator's status, including Upesa's.

• Upesa is not a licensed bank, and funds and digital assets on the Platform are not deposits and are not covered by any deposit insurance scheme.
• Upesa's wallet architecture for third-party digital assets is non-custodial — you retain independent control of your assets, as described in our Terms of Use.
• eNGN is a Upesa-issued utility token, not a publicly offered investment product — see our eNGN Public Disclosure for detail.
• Upesa complies with applicable anti-money laundering, data protection (NDPA 2023 / GAID 2025), and, where relevant, GDPR requirements, as described in our Privacy Policy and AML/KYC Notice.

You can verify Upesa's current registration status directly on the SEC Nigeria website's registered operator lookup tool, or by contacting the SEC directly. We will never ask you to trust a claim of regulatory status without the means to independently confirm it.

For questions about our regulatory status, contact us at [email protected]