Governance
and how we work.

Patrick Enwerem Limited is a Nigerian private company. This page is the regulatory policy. It tells a buyer, a ministry, or counsel how the firm is set up, how money moves, how data is treated, and where we stop talking.

It is not a certificate. It is not a licence we do not hold. It is not a promise that every project will succeed.

If you only need the short version, use the Trust hub. If you need language you can paste into a memo, stay here.

Legal identity

Legal name: Patrick Enwerem Limited. Trading name: PEL. Registration number: RC 9180331. Statute: Companies and Allied Matters Act 2020. Registered office: Bodija, Ibadan, Oyo State, Nigeria. Public mail: info@penwerem.com.

PELPortal is a product name. SalesLever is a product name. Neither is a separate company. We have not filed PELPortal Inc. A purchase order that names only a wordmark will be sent back. Name the legal company.

You may look up RC 9180331 through the Corporate Affairs Commission. If a page on this site and the CAC record ever disagree, the CAC record wins until we correct the page.

We operate from Ibadan. We take foreign clients. We invoice in United States dollars. We remain a Nigerian company when we do that. We do not pretend to be a Delaware corporation, a UK Ltd, or a holding company in a third country.

The director is accountable for the firm. Extra governance seats, including extra members of the Ethics Committee, may still be filling. Until they are seated, the director signs reviews that those seats would sign. That is written so you do not imagine a board we have not named.

What this company sells

We sell professional services and software access. The contract that matters is the statement of work. Terms on this site set the default. The SOW can narrow a default. The SOW cannot invent a licence, a certificate, or a close rate.

Typical work includes:

Outbound systems run from the director's LinkedIn, not from a client's personal account, unless a later SOW says otherwise. Assessment work: a teardown, a scorecard, a written report, and when scoped, a voice walkthrough. Automation work inside a client's operation, scoped in writing. Advisory that stops at a document, a workshop, or a decision memo.

We do not sell Calendly as our booking product. Booking is Zoho Bookings. Mail is Zoho Mail. Books is Zoho Books. Payments by card go through Paystack. The trading name on Paystack is PEL. The legal name on the invoice is Patrick Enwerem Limited.

We do not sell the two hundred and fifty dollar GTM audit on this website. That offer lives on saleslevergtm.com. A $250 payment does not turn outbound on. A setup or retainer can. Those are different products and different people.

We do not sell retired internal names. We do not use those names in outreach. We do not sell a 100 percent close. We do not sell an unhackable system.

How to buy

Write to info@penwerem.com or book time on the Zoho booking link used across PEL sites. Bring the problem, the constraint, and the person who can sign. We will say whether we can help. If we can, we send a SOW. If we cannot, we say no.

A SOW should name:

The legal parties. The work. The fee in USD. VAT at 7.5 percent. When payment is due. What data we will touch. Who can stop a live system. What happens if a sector rule applies. What we are not doing.

If your procurement pack needs a watermarked PDF of policies, ask. It is issued to your agency, not posted as a public file that goes stale.

Money, tax, and invoices

Currency is USD. That is true for Nigerian clients and for foreign clients.

VAT is 7.5 percent. It is added to every invoice. We do not treat a foreign client as zero rated by default. If a specific FIRS rule applies to a specific invoice, finance will write that on that invoice. We will not hide VAT in a footnote.

Withholding tax is not applied by default. If a Nigerian payer withholds, we reflect it. We do not invent a WHT line so a form looks familiar.

Payment is due in thirty days unless the SOW says otherwise. If late interest is charged, it will not exceed 1.5 percent per month or the legal maximum, whichever is lower.

Invoices come from Zoho Books as info@penwerem.com. The invoice PDF should show the legal name and RC 9180331. If you need a remittance note that matches your ERP, ask before the first invoice, not after the third reminder.

Liability language, when used, is built around fees paid under that SOW in the prior twelve months, and it excludes consequential damages. A signed SOW can state the cap. This page does not invent a cap for a deal we have not written.

If your accounts payable team cannot pay USD, say so before work starts. If your purchase order system cannot store a Nigerian RC number, put it in the description line. Do not replace the legal name with a nickname.

Records we keep as a company

We keep the statutory registers a CAMA company must keep. We keep tax records for the period FIRS requires. We keep contracts and change notes. We keep access logs for a limited time. We do not keep a public diary of every sign-in.

If a public body needs to inspect a record that the law says they may inspect, they should write to info@penwerem.com and cite the power. We will not argue with a lawful request. We will argue with a fishing trip that has no basis.

Data protection under NDPA 2023

The Nigeria Data Protection Act 2023 is the baseline for personal data. Privacy is the notice. This section is the posture in longer form.

Controller: Patrick Enwerem Limited, RC 9180331, Bodija, Ibadan, Oyo State, Nigeria.

A data protection function is appointed. Contact: info@penwerem.com. We do not publish a private home address for that function.

Categories of people we may hold data about: clients, people who work for clients, people who submit a brief, site visitors, and, when a client authorises a connection, professional data used to run a contracted outbound or research job.

We do not sell personal data. We do not use a brief or portal content to train a third-party model.

Lawful bases we actually use:

Contract, when we need the data to do the SOW. Legitimate interests, for B2B operations and security, where that test holds. Consent, for non-essential cookies or marketing mail. Legal obligation, when a statute says keep or disclose.

Rights: access, correction, deletion, portability, restriction, objection, withdrawal of consent. Write to info@penwerem.com. We answer inside the statutory time. You may also complain to the Nigeria Data Protection Commission.

Transfers outside Nigeria happen when cloud hosting or a named processor sits abroad. We will not pretend every byte lives in one room in Ibadan if it does not. Transfers need a lawful mechanism and safeguards. A current processor list is available on request. We do not print API keys on this page.

Retention: for the life of the account or SOW, then as the law requires. We do not keep marketing lists that people asked us to delete.

Cookies: essential cookies run the site. Analytics cookies wait for the banner. The banner is the consent moment, not a buried line in this policy.

Children are not our market. If a data set includes children, the SOW must say so before a source is connected.

If this section and Privacy ever disagree, tell us. We will align them. Until then, treat the more specific operational sentence as the one we must fix, not as a loophole.

Sector regulators

We name CBN, NCC, NUPRC, and NAFDAC on the Trust hub because those are the rooms our clients often sit in. Naming them is not a licence.

Central Bank of Nigeria. We may build or run systems for a bank or a fintech. We do not claim to be a bank. We do not claim a CBN licence. If your job needs one, the licensed party is named in the SOW.

Nigerian Communications Commission. Same rule. We may work for an operator. We are not an operator.

Nigerian Upstream Petroleum Regulatory Commission. Same rule for energy work.

National Agency for Food and Drug Administration and Control. Same rule for health or consumer work.

If your sector is none of these, we still do not invent a regulator. We ask you which rule book applies and we write it down.

Local content commitments are written when the client requires them. They are not a slogan on a slide. If a job needs Nigerian staff on Nigerian soil for a defined share of hours, the SOW says so. If we cannot meet that share, we say no before kickoff.

NITDA

We treat NITDA practice as the target for information work. The Trust chip says NITDA-registered IT company. Ask for the current letter if you need it in a bid file. Do not invent a registration number from this sentence. If the letter and the chip ever drift, the letter wins.

Anti-bribery

Zero tolerance.

No staff member, contractor, or agent may offer, give, ask for, or take a bribe. A bribe includes cash, a gift, a job, a trip, or a favour that is meant to move a bid, a score, or a signature.

Modest hospitality that would look normal on an invoice may be accepted if it cannot move a decision. If you are not sure, refuse. If you already accepted and you are not sure, write info@penwerem.com the same day.

We do not pay facilitation fees. We do not hire a cousin to unlock a door. We do not donate to a private account because a form is slow.

Report a concern to info@penwerem.com. You may also use any statutory channel that applies to you. We will not punish a good faith report. We will investigate a bad faith smear.

Public-sector bids are written as if someone will read them in a newspaper. Private bids are written the same way.

Conflicts

If we already work for a direct competitor on the same narrow problem, we will say so or we will decline. We will not use one client's brief to feed another client's outbound.

The director's LinkedIn is used for outreach in the locked operating model. That is not a conflict with a client. It is the model. A client who wants outreach from their own executive account is asking for a different design. That design is not the default. Do not assume it.

Subprocessors and vendors

We use other companies to host, to store, to send mail, to take cards, and to book time. A current list is available on request. The public facts you already have:

Paystack for cards. Zoho for mail, bookings, and books. A cloud database with encryption at rest and row-level security. Object storage for files such as voice output when that work is in scope. Cloudflare in front of public sites.

We do not put secrets in git. We do not put secrets in a chat. We do not put secrets in a screenshot.

If a vendor fails, we owe you notice when the failure touches your data or your live system. We do not owe you a novel about every third-party outage that never reached you.

Security, in the compliance sense

Compliance is not the same as a finished information security manual. The security page is the honest list. In one paragraph, so this page can stand alone:

Transport uses TLS. Data at rest is encrypted at the database provider. Access is by role. Client data is separated by row-level security. ISO/IEC 27001 is a target. We are not certified. We are not unhackable.

If your score sheet requires certified ISO 27001, we fail that row today. We will not buy the row with a badge.

How live commercial systems are governed

A $250 audit buyer may enter the portal to see a result. They do not get Outreach Setup. They do not get a mailbox. They do not get outbound. The payment must not switch outbound on.

A subscribed client, after setup or retainer, may set who counts as a success: a positive reply, an invite accepted, or a new connection. Admin uses the same three choices on Outbound Config.

When outbound runs, it runs from the director's LinkedIn through Unipile. Account status events that mean stop are deletion, stopped, error, and credentials. Those events are treated as a stop, not as a hint to keep sending.

Reply handling is locked. A hot lead can be booked once and the cadence stops. An objection can get one audit path and the cadence can stay on. Out of office gets one warm path and the cadence stops. Not interested is lost and the cadence stops. Neutral alerts Telegram only and the cadence stays on. An audit path never books a meeting and never turns outbound on.

Those rules are operations. They belong here because a compliance reader will ask who can start a message and who can stop it. The answer is: the contracted system, under those locks, with a human able to pause.

Make scenarios stay off until a human go / no-go. That is an internal switch. It is not a client feature.

Employment, contractors, and access

People who work on your job get the access they need and not a tour of every other client. When they leave the job, the access should leave with them. We will not give a contractor a standing key because it is convenient.

Contractors sign confidentiality. They do not become the controller of your data.

We do not publish a global headcount. If you need named people for a bid, ask for the team on your job.

Intellectual property

Default split: you own your data and the paid work product named in the SOW. We keep pre-existing tools, products, methods, and models. PELPortal and SalesLever remain ours. A SOW can buy extra rights. A SOW should not pretend a project fee bought the platform unless that is the deal in writing.

Open source components stay under their licences. We will not tell you we wrote a library we forked.

Confidentiality

Each side keeps the other's non-public information close. Public facts on this site are public. A SOW, a brief, a lead list, and a password are not public.

If a law requires disclosure, we disclose what the law requires and we tell you if we are allowed to tell you.

Public statements

We do not promise a close rate in a case study. Work examples on /work are illustrative until a named client gives permission. If a page uses the word illustrative, believe it.

Press should use the legal name. Press should not call the firm an unhackable shop. Press should not put retired internal names in a headline about us.

Complaints that are not data-rights requests

If the work is late, wrong, or harmful, write info@penwerem.com. Name the SOW. Name the date. Name the harm. We will pause a live system when pause is the safe move.

If you are a regulator with a lawful power, cite it.

If you are a journalist, still write. We may not share a client's file.

Governing law

Federal Republic of Nigeria. Courts in Ibadan, Oyo State, unless a signed SOW already names another Nigerian forum. We do not assume a foreign court because an invoice is in USD.

Changes to this page

When the company changes a fact, this page should change. When a letter arrives, a chip on the hub may get more precise. When a sentence over-claims, we cut it.

There is no last-updated stamp under the title. The live page is the current page. If you need a dated PDF, ask for the pack and we will date that file.

What this page does not do

It does not replace Privacy. It does not replace Terms. It does not replace the SOW. It does not certify ISO. It does not grant a sector licence. It does not turn outbound on. It does not sell the $250 audit.

Worked examples for procurement forms

Form asks: legal name. Answer: Patrick Enwerem Limited.

Form asks: trading name. Answer: PEL.

Form asks: registration. Answer: RC 9180331.

Form asks: address. Answer: Bodija, Ibadan, Oyo State, Nigeria.

Form asks: tax. Answer: Nigerian company. VAT 7.5 percent on invoices. USD billing. WHT only when withheld.

Form asks: DPO name. Answer: write info@penwerem.com. The function is appointed. A private person's name is not a public field on this site.

Form asks: ISO 27001 certificate number. Answer: none. Target only.

Form asks: insurance certificate numbers. Answer: ask in the SOW process. This page does not invent policy numbers.

Form asks: parent company in the US or UK. Answer: none.

Form asks: beneficial owner theatre for a listed multinational. Answer: this is a Nigerian private company. Ask counsel for the CAC extract.

How we treat a request that we cannot meet

We say no. We do not quietly accept and hope. We do not accept a clause that requires a 100 percent result. We do not accept a clause that requires us to break NDPA. We do not accept a clause that requires us to put client data into a public model. We do not accept a clause that requires a bribe.

If we can meet the request with a change to scope or fee, we say that.

Language and accessibility of the policy

This page is in English. That is the language of our contracts unless a SOW says otherwise. If you need a Nigerian language summary for a board that does not work in English, ask. A summary is not a second contract.

The page is meant to be read on a phone. Titles follow the Trust look: a cream line and a gold line, centred. Body is centred. There is no frost panel. There is no dump of RC and a date under the title.

Relationship to the other two policies

Review, at /governance/ai-ethics, is how live systems are watched. Read it if your job will send messages, score people, or produce a voice script.

Security, at /governance/information-security, is what is in place and what is still being written. Read it if your job will hold data.

This page is the company. Read it first.

A note on competitors and how we differ without theatre

Large firms publish fifty-page PDFs with framework maps. Those PDFs often claim global coverage, a certificate wall, and a methodology name. We are not those firms. We will not copy their methodology name and swap in PEL. We will not publish a fake wall.

What you get instead is a company you can find at CAC, an office in Ibadan, invoices that match the legal name, a data notice, a review rule that a human can stop, and a security page that admits the unfinished part.

If you need the fifty-page PDF because your score sheet has a page-count row, ask for the pack. We will not pad this public page with empty adjectives to win that row.

A note on staff conduct in client buildings

If we are on your site, we follow your visitor rules. We do not photograph badges. We do not plug an unknown drive into your network. We do not ask your receptionist to skip the book. We do not take a bag of paper home because it was late.

If your site requires a police report or a drug test that the law allows, say so before travel.

A note on subcontracting

We may use a specialist. We remain the party on the SOW unless we novate in writing. A specialist does not become your unnamed second vendor. If a specialist will see personal data, they go on the processor list for that job.

A note on exit

When a SOW ends, we stop the live system that the SOW started, unless a retainer says keep it. We return or delete client data as the SOW and the law require. We do not keep a shadow copy for our demo reel. We may keep invoices and legal records.

If you need an exit certificate, ask. We will write what we did, not a poem.

Closing

This is the regulatory policy of Patrick Enwerem Limited. It is long because buyers asked for pages that do not dodge. It is plain because a dodgy sentence is how a bid dies in legal review.

Write to info@penwerem.com if a line is wrong. Bring a SOW conversation if the work is real. Do not bring a request for a guaranteed outcome.

Back to the Trust hub when you are done.

Invoice anatomy

A proper invoice from us should show Patrick Enwerem Limited, RC 9180331, the client legal name, the SOW reference, the USD amount, VAT at 7.5 percent, and the due date. It should go to the email finance named. It should not go to a personal Gmail because someone forwarded a thread.

If a line is wrong, write before you pay. If you pay the wrong entity, we still have to unwind it. That wastes both clocks.

Purchase orders

Put the legal name in the supplier field. Put PELPortal or SalesLever in the description if you must. Do not put a dead product name. Do not put retired internal names.

If your PO dies after thirty days, tell us. We will not keep working against a dead PO and then argue.

Multi-year work

A retainer is still a SOW. It still has a stop. It still has VAT. It still does not include a close rate. If year two adds a regulator, we write a note. If year two only renews the same path, we can renew in fewer pages.

Public records and FOI

If a Nigerian public body must release a contract, we assume they will. We write the SOW as if they will. We still mark genuine secrets. We do not mark a fee schedule secret if the law says it is not.

Gifts we refuse

Cash. Flights that are not in the SOW. A job for a cousin. A donation to a private account. A phone. A laptop. A "small thing" the night before a score. Refuse. Write.

Gifts that may be fine

A cup of water in your office. A printed agenda. A modest meal that appears on a normal invoice and cannot move a score. If it would look ugly in a newspaper, it is not fine.

Political activity

The company does not fund a party as a way to win a bid. Staff may have private politics. They do not bring them into a SOW. We do not build a voice that endorses a candidate.

Sanctions and restricted parties

If a party is restricted under a law that applies to the job, we stop. We do not need a Hollywood plot. We need you to say who the end client is. A hidden end client is a reason to pause.

Export of tools

Products stay ours unless the SOW sells extra rights. A USB stick with a private build is not a souvenir. If we must leave software with you, the SOW says the licence.

Training your staff

If we train your team, the room is confidential. We do not record faces unless you ask. We do not use your screens in our demo without permission.

Accessibility of delivery

We can write in plain English. We can meet on Zoho. We can send a PDF. We cannot honestly claim a full WCAG audit of every internal screen on this page. If accessibility is a scored row, ask for what we can show, not for a badge we have not bought.

Environment

We do not publish a net-zero theatre number. We do not fly a team around the world to look busy. Most work is remote plus Ibadan. If you need travel, the SOW says who pays.

Insurance again

Ask in the commercial process. This page will not invent policy numbers, limits, or brokers. If we cannot meet a required cover, we say no.

Subpoenas and lawful orders

We follow a lawful order. We tell you if we can. We do not hide a server in a story.

Closing addendum

If you read this far, you are the reader we wrote for. Use the form answers. Use the email. Do not use a rumour about a certificate.

Back to the Trust hub.

How we treat a change of director or address

If the director changes, CAC is the source. If the office moves, CAC and this page should move. Until both move, treat the older public record as the one you verify, then write to us.

How we treat a change of product name

A product can be renamed. The company cannot be renamed by a find-replace on a website. If PELPortal or SalesLever change their public names, the invoice still says Patrick Enwerem Limited. Old SOWs still bind the company.

How we treat a change of tax rule

If FIRS changes VAT, invoices change. This page will follow. We will not keep 7.5 percent out of habit if the law moves. We will not invent a zero rate for a foreign client unless the law and the invoice both say so.

How we treat a change of data law

If NDPA is amended, Privacy and this page should move. We will not wait for a pretty redesign. We will change the sentences that became false.

How we treat a request to backdate

We do not backdate a SOW. We do not backdate an invoice to hide a year. We do not backdate a review yes. If work started too early, we write what actually happened.

How we treat a request to hide a party

If a party must be unnamed, the SOW still names the legal buyer we can sue or be sued by. A nickname is not a party. A wordmark is not a party.

How we treat a request to pay a different person

Fees come to the company. They do not go to a private wallet because a form is slow. They do not go to a cousin. They do not go to cash in a car park.

How we treat a request to work without a SOW

Small talk can happen without a SOW. A live send cannot. A data connection cannot. A voice file of a real assessment cannot. If someone asks us to start while legal is still reading, we wait.

How we treat a request to reuse another client's work

We can reuse our own methods. We cannot reuse another client's data, list, or confidential memo. If two jobs look alike, that is not a licence to copy the first list into the second.

How we treat a request for a reference letter

We can confirm that a signed SOW exists if the client allows it. We will not invent a result. We will not invent a logo wall.

How we treat a request for a site visit

You may visit the Ibadan office by appointment. You will not see another client's screen. You will not receive a badge that implies a data centre. You will receive a conversation and, if useful, a walk through the public pages.

How we treat a request for source code

Source of our products stays ours unless a SOW sells extra rights. A client can receive work product named in the SOW. A client cannot assume they bought PELPortal because they bought a project.

How we treat a request for an escrow

If a public body needs source escrow, that is a special. We will say yes or no in the SOW. We will not imply escrow on this page.

How we treat a request for most-favoured pricing

We do not publish a price list that secretly promises every later buyer a lower fee. A SOW has a fee. Another SOW may have another fee. That is ordinary.

How we treat a request for exclusivity

Exclusivity is a special. It has a fee and a term. It is not the default. The default is that we may work for others so long as we do not use your brief to do it.

Last pass

If you only remember six lines, remember these.

Patrick Enwerem Limited, RC 9180331. USD invoices. VAT 7.5 percent. info@penwerem.com. NDPA is the data baseline. ISO is a target. The SOW is the contract.

Use the three doors for the rest.

One page you can hand to finance tonight

Patrick Enwerem Limited. RC 9180331. Bodija, Ibadan, Oyo State, Nigeria. Invoices from Zoho Books as info@penwerem.com. Currency USD. VAT 7.5 percent. Withholding only when it happens. Paystack trading name PEL. Legal name on the invoice is the company. No US EIN. No UK VAT number. No $250 product on this site. Ask for a SOW before a live path starts.

That is the whole finance card. If a cell on your form still sits empty, write. Do not fill it with a guess.

Hand finance the six lines. Hand counsel the rest of this page.