Advertisement Policy

Social Media, Digital Platform and Commercial Content Policy
Effective date: 6 September 2026
Last updated: 6 September 2026

1. Introduction

PenpenGo is an online digital commercial platform established to facilitate and promote legitimate business activities through electronic and mobile technology.

The platform is designed to support and promote commercial activities involving:

• Keke (commercial motorcycles)
• Penpen (motorcycles)
• Vehicles and connection of transportation services
• Commercial service providers
• Businesses and entrepreneurs
• Product and service advertisements
• Government advertisements and public information
• Other legitimate commercial activities
• Digital and electronic business opportunities
• Commercial promotions and marketing

PenpenGo began its operations in Liberia and will subsequently expand throughout West Africa and other international markets.

Because PenpenGo operates in the digital environment, social media and digital content are important parts of its business operations. The platform must therefore maintain a professional, neutral, safe, transparent, lawful and commercially responsible digital environment.

This Policy establishes the rules governing:

1. Social media use
2. Advertising
3. Commercial content
4. User-generated content
5. Government advertisements
6. Political neutrality
7. Customer communication
8. Privacy and personal information
9. Fraud prevention
10. Cybersecurity
11. Prohibited content
12. Contractor, sub-contractor and independent representative use of social media
13. Influencers and third-party marketers
14. Complaints and enforcement
15. Compliance monitoring
16. International expansion

2. Purpose of the Policy

The purpose of this Policy is to establish clear rules for the responsible use of PenpenGo's digital platforms and social media channels.

The Policy seeks to ensure PenpenGo:

• Operates professionally
• Remains politically neutral
• Protects users and customers
• Promotes legitimate businesses
• Prevents fraudulent activities
• Prevents misleading advertising
• Protects personal information
• Complies with applicable laws in the country of operations
• Maintains the reputation of the company
• Provides equal commercial opportunities
• Prevents abuse of the platform
• Promotes responsible digital communication
• Creates a trusted digital marketplace

3. Scope of Application

This Policy applies to:

• PenpenGo representatives and social media administrators
• International and national management team
• Compliance personnel
• Marketing personnel
• Customer service personnel
• Advertisers
• Commercial partners
• Drivers and riders using the platform
• Businesses using the platform
• Service providers
• Agents
• Contractors
• Influencers
• Digital marketers
• Content creators
• Vendors
• Government institutions advertising through PenpenGo
• All users of PenpenGo's digital platforms

It applies to all official PenpenGo communication channels, including:

• Website
• Mobile application
• Facebook, Instagram, TikTok, X, LinkedIn and YouTube
• WhatsApp and other messaging platforms
• Email and SMS
• Future digital platforms and other official online channels

4. Guiding Principles

All PenpenGo digital activities shall be guided by the following principles:

4.1 Legality

All content and activities must comply with applicable laws and regulations in the country where PenpenGo operates.

4.2 Political Neutrality

PenpenGo shall maintain a politically neutral commercial identity. The company shall not become an advertising platform for political parties or political campaigns.

4.3 Commercial Fairness

PenpenGo shall provide fair and non-discriminatory opportunities for legitimate businesses and service providers.

4.4 Transparency

Advertising and commercial relationships should be presented honestly and transparently.

4.5 Accuracy

Information published through PenpenGo should be accurate, verifiable and not intentionally misleading.

4.6 Privacy

PenpenGo shall respect the privacy and confidentiality of its users and customers.

4.7 Consumer Protection

PenpenGo shall take reasonable measures to protect customers from fraudulent, deceptive or harmful commercial activities.

4.8 Professionalism

All official communications must maintain a professional corporate standard.

4.9 Accountability

Users, advertisers, contractors, sub-contractors, independent representatives and administrators are responsible for content and activities associated with their accounts.

4.10 Respect

The platform shall promote respectful communication and prohibit abusive, threatening or discriminatory behavior.

5. Political Neutrality Policy

Political neutrality is a fundamental principle of PenpenGo. PenpenGo is a digital platform and shall not operate as a political organization, campaign organization or political advocacy platform.

5.1 Political Party Advertising Prohibited

PenpenGo shall not knowingly accept or publish advertisements promoting:

• Political parties or political party candidates
• Political campaigns, fundraising or election campaigns
• Political rallies, slogans, manifestos or endorsements
• Political propaganda or attack advertisements
• Campaign merchandise or political fundraising events
• Any other content primarily intended to promote a political party or political candidate

This restriction applies regardless of the political party's ideology, size, popularity or position.

5.2 Government Advertising Permitted

PenpenGo may accept legitimate advertisements and public information from ministries, government agencies, public corporations, commissions, authorities, local government institutions and other legally recognized government entities.

Government advertisements must be institutional rather than partisan.

5.3 Government in Power Does Not Change the Policy

PenpenGo shall maintain the same policy regardless of which political party or administration is in government.

5.4 Political Content Disguised as Commercial Advertising

Users shall not use commercial advertisements to disguise political messages. Where the primary purpose is political promotion, the content shall be treated as political advertising and rejected.

6. Commercial Advertising Policy

PenpenGo shall provide advertising opportunities for legitimate businesses, products and services. Advertisements may include transportation, automotive and motorcycle services, restaurants, hotels, construction, agriculture, manufacturing, retail, wholesale, financial services, professional services, education, health-related businesses (subject to applicable laws), telecommunications, technology, entertainment, real estate, logistics, tourism, import/export, household services, employment-related commercial services, events, products, mobile services and other lawful commercial activities.

7. Advertising Standards

Every advertisement must:

1. Be truthful
2. Be reasonably verifiable
3. Identify the advertiser where appropriate
4. Not deliberately mislead consumers
5. Not contain fraudulent claims
6. Not promote illegal activities
7. Not infringe intellectual property rights
8. Not contain unlawful discriminatory content
9. Not contain malicious software or harmful links
10. Not impersonate another company or person
11. Not make deceptive financial promises
12. Comply with applicable advertising laws

PenpenGo reserves the right to reject, suspend, modify or remove an advertisement that violates this Policy.

8. Prohibited Commercial Content

PenpenGo shall not knowingly permit advertisements promoting illegal or dangerous activities. Prohibited content may include:

• Fraudulent investment schemes
• Counterfeit products or stolen goods
• Illegal drugs
• Weapons or unlawful firearms sales
• Human trafficking, sexual exploitation or child exploitation
• Money laundering or identity theft
• Fake documents or forged certificates
• Illegal gambling where prohibited
• Criminal or hacking services
• Fake government services
• Fraudulent immigration schemes
• Fake employment opportunities
• False medical claims
• Other unlawful activities

PenpenGo may cooperate with appropriate authorities where legally required.

9. Motorcycle, Keke, Penpen and Vehicle Connection Services

PenpenGo is a digital platform and not a transportation service provider. It establishes connections for riders, drivers and independent operators.

Users advertising and connecting transportation services must provide truthful information regarding type of vehicle, ownership or authorization to operate, service offered, location, contact information, applicable charges, operating conditions, and required permits or licenses where applicable.

PenpenGo may require verification of vehicles, riders, drivers or operators where appropriate.

Users shall not advertise:

• Stolen vehicles
• Unregistered commercial transportation services where registration is legally required
• Fraudulent vehicle documentation or fake vehicle ownership
• Unsafe or illegal transportation services

10. User-Generated Content

Users may create or submit content through PenpenGo's platforms, subject to this Policy. User-generated content may include business advertisements, product and service listings, reviews, comments, photos, videos, business descriptions, customer feedback and other commercial information.

Users are responsible for the content they submit. PenPenGo reserves the right to remove content that violates this Policy.

Users must not upload content that:

• Is false or fraudulent
• Defames or threatens another person
• Encourages violence or promotes illegal activity
• Violates privacy or infringes copyright
• Impersonates another person
• Contains malicious software
• Contains political campaign material where prohibited
• Contains hate speech
• Exploits children
• Violates applicable law

11. Social Media Policy

PenpenGo's official social media accounts shall be used for legitimate corporate purposes, including promoting services and advertisers, customer information, business developments, educational content, commercial opportunities, government institutional advertisements, service updates, customer responses, responsible transportation, entrepreneurship and company announcements.

Official accounts shall not be used for:

• Political campaigning or personal political arguments
• Personal attacks or religious attacks
• Hate speech
• Confidential company information
• Unverified accusations
• Internal disputes or contractor grievances
• Defamatory statements
• Personal business unrelated to PenpenGo

12. Political Comments on PenpenGo Social Media

PenpenGo recognizes that users may have different political opinions. However, the company's official social media platforms are primarily commercial platforms.

Administrators may remove comments that:

• Promote or attack political parties or candidates
• Encourage political violence
• Contain threats or hate speech
• Disrupt commercial discussions
• Harass other users
• Violate this Policy

The objective is not to suppress legitimate personal expression but to maintain PenpenGo's neutral commercial environment.

13. Government Advertisements

PenpenGo may provide advertising services to government institutions.

Government advertising must:

• Clearly identify the government institution
• Provide accurate information
• Serve a legitimate public or institutional purpose
• Comply with applicable laws
• Not promote a political party
• Not promote an individual politician as a political candidate
• Not contain partisan campaign messaging

Examples of acceptable government content include:

• Public health announcements and road safety campaigns
• Tax, business registration and public procurement notices
• Public service announcements and government employment notices
• Public education and agricultural information
• Transportation regulations and public infrastructure announcements
• Government programs

14. Customer Communication Policy

PenpenGo shall communicate with customers respectfully and professionally.

Customer service representatives shall:

• Be polite and listen carefully
• Avoid arguments
• Provide accurate information
• Protect customer information
• Escalate serious complaints
• Avoid political discussions and personal opinions
• Record relevant complaints
• Follow approved response procedures

Contractors, sub-contractors and independent representatives shall not insult, threaten or ridicule customers.

15. Privacy and Personal Information

PenpenGo may collect information necessary to provide its services, which may include name, telephone number, email, business information, vehicle information, location information, transaction information, account information and customer service records.

PenpenGo shall establish appropriate measures to protect personal information. Contractors, sub-contractors, independent representatives and authorized persons must not sell, share improperly, publish, or use customer information for personal purposes, or access information without authorization.

Privacy practices should comply with applicable data protection and privacy laws in each country where PenpenGo operates.

16. Fraud Prevention

PenpenGo shall maintain measures to identify and prevent fraudulent activities. Potential indicators include false identities, fake business registration, suspicious advertisements, unrealistic prices, fake investment opportunities, requests for unusual payments, fake government representation, repeated customer complaints, multiple fraudulent accounts, suspicious transactions and misleading product descriptions.

PenpenGo may suspend or terminate accounts where there are reasonable grounds to suspect fraud, subject to applicable law and internal procedures.

17. Cybersecurity

All users and contractors, sub-contractors and independent representatives must take reasonable measures to protect their accounts.

Users should:

• Protect passwords and avoid sharing login credentials
• Use secure passwords
• Report suspicious activity
• Avoid suspicious links
• Keep devices secure

Those with administrative access shall use enhanced security controls, including strong passwords, multi-factor authentication where available, controlled access, access logs, regular security reviews, and prompt removal of former access.

18. Intellectual Property

Users must have the legal right to use content they upload. Users must not upload:

• Copyrighted material without permission
• Trademarks without authorization
• Private photographs without appropriate permission
• Proprietary business materials belonging to another party
• Pirated materials

PenpenGo may remove content where there is a credible intellectual property complaint.

19. Defamation, Harassment and Abuse

PenpenGo shall not be used to harass or attack individuals or organizations. Prohibited behavior includes threats, bullying, intimidation, repeated harassment, personal attacks, false accusations presented as facts, publishing private information, blackmail, extortion and hate speech.

Legitimate customer complaints should be handled through appropriate complaint and dispute-resolution mechanisms.

20. Content Moderation

PenpenGo shall establish a content moderation system. Content may be:

• Approved — content meets all applicable requirements
• Flagged — content requires further review
• Rejected — content violates the Policy
• Removed — previously published content is removed because of a violation
• Suspended — an account or advertisement is temporarily restricted while an investigation occurs
• Terminated — an account may be permanently closed for serious or repeated violations

21. Content Review Process

Where practical, advertisements should pass through the following process:

Submission → Initial Review → Compliance Review → Approval/Rejection → Publication → Monitoring

High-risk advertisements may require additional verification, including financial services, health services, government advertising, high-value goods, transportation businesses, employment services, investment opportunities and regulated industries.

22. Advertiser Verification

PenpenGo may require advertisers to provide information necessary to verify their identity or business, including business name, contact information, business registration, physical/business location, relevant license, authorized representative and product/service information.

The level of verification should be proportionate to the risk associated with the advertisement.

23. Employee Social Media Use

Contractors, sub-contractors and independent representatives have personal social media accounts and remain responsible for their personal activities. However, they must not:

• Present personal opinions as official PenpenGo positions
• Disclose confidential company information
• Publish customer information
• Use company accounts for personal political activity
• Make unauthorized statements on behalf of PenpenGo
• Damage the company's reputation intentionally
• Disclose passwords or security information

Only authorized persons may issue official corporate statements.

24. Official PenpenGo Spokespersons

PenpenGo shall designate authorised persons to speak publicly on behalf of the company. These may include the Chief Executive Officer and/or the Chief Information Security Officer (CISO), Managing Director, Communications/Marketing Director, authorized spokesperson, Compliance Officer on compliance matters, and other persons formally authorised by management.

Contractors, sub-contractors and independent representatives must refer media inquiries to the appropriate authorized spokesperson.

25. Influencers and Digital Marketers

PenpenGo may engage influencers and digital marketers. Such persons must:

• Follow this Policy
• Represent PenpenGo accurately
• Avoid political campaigning
• Avoid misleading advertising
• Disclose commercial relationships where required
• Avoid fraudulent claims
• Protect PenpenGo's reputation

PenpenGo may terminate relationships with influencers who violate these requirements.

26. Government and Corporate Partnerships

PenpenGo may enter into advertising or commercial arrangements with government institutions, private companies, NGOs, development organizations, international organizations, financial institutions, telecommunications companies, transport operators, manufacturers, retailers and service providers.

Such arrangements must not compromise PenpenGo's political neutrality.

27. Conflict of Interest

Contractors, sub-contractors, independent representatives, directors and representatives must disclose actual or potential conflicts of interest.

For example, a contractor should not secretly approve advertisements for a business owned by a close associate while personally benefiting from the transaction. Conflict-of-interest concerns shall be reported to management or the Compliance Department.

28. Bribery and Improper Payments

PenpenGo prohibits bribery and improper payments in connection with advertising, account approval, content moderation or other business activities.

Contractors, sub-contractors and independent representatives must not accept money or benefits in exchange for approving prohibited advertisements, removing legitimate complaints, giving preferential treatment, providing confidential information, approving fraudulent accounts, or manipulating platform decisions.

29. Child and Vulnerable Person Protection

PenpenGo shall not knowingly permit content involving child exploitation, sexual exploitation of children, trafficking, abuse, dangerous exploitation, or other unlawful activities involving vulnerable persons.

Where legally required, serious matters may be reported to appropriate authorities.

30. Advertising of Regulated Services

Certain sectors may require additional regulatory review, including banking, insurance, investment, telecommunications, health services, pharmaceuticals, education, transportation, real estate, employment agencies, security services and financial technology.

PenpenGo may require evidence of appropriate authorization before publishing certain advertisements.

31. False Reviews and Manipulation

Users must not create fake reviews or manipulate ratings. Prohibited conduct includes:

• Paying for fake reviews
• Creating fake customer accounts
• Posting reviews for one's own business
• Artificially lowering competitors' ratings
• Coordinated fake complaints
• Creating multiple accounts to manipulate rankings

PenpenGo may remove fraudulent reviews and take action against responsible accounts.

32. Competition and Fair Business Practices

PenpenGo should maintain a commercially fair environment. Advertisers must not use the platform to make knowingly false claims about competitors, steal another company's identity, misrepresent products, conduct deceptive price comparisons, or coordinate illegal anti-competitive activities.

33. Spam and Unauthorized Communication

Users must not use PenpenGo to distribute excessive or unauthorized messages. Prohibited activities may include mass unsolicited advertising, spam, automated abusive messaging, phishing, repeated unwanted commercial communications and malicious links.

34. Account Security and Account Ownership

Users are responsible for activities conducted through their accounts unless unauthorized access is demonstrated. Users must immediately report hacking, account theft, unauthorized access, fraud and suspicious transactions.

PenpenGo may temporarily restrict accounts for security reasons.

35. Complaints and Dispute Resolution

PenpenGo shall establish a formal complaint mechanism. Complaints may concern fraud, advertising, service quality, privacy, harassment, account suspension, payment issues, content, misrepresentation and business conduct.

Complaints should be:

1. Received
2. Recorded
3. Assessed
4. Investigated where necessary
5. Resolved or escalated
6. Documented

36. Appeals

Where an account or advertisement is suspended or removed, PenpenGo may provide an appeal mechanism. An appeal should identify the account/user, advertisement/content, reason for appeal and supporting information.

PenpenGo may review the decision and either:

• Confirm the decision
• Restore the content/account
• Modify the restriction
• Request additional information

37. Enforcement

Violations may result in:

Penalties should be proportionate to the seriousness and frequency of the violation.

38. Serious Violations

PenpenGo may immediately suspend an account for serious activities including fraud, threats, cybercrime, child exploitation, human trafficking, money laundering, terrorist-related activities, sale of illegal weapons, serious identity theft, major financial scams and repeated serious violations.

39. Compliance Officer

The Compliance Officer shall help ensure that PenpenGo's digital operations comply with this Policy and applicable requirements. Responsibilities may include monitoring compliance, reviewing high-risk advertisements, developing compliance procedures, conducting assessments, investigating violations, maintaining records, advising management, training personnel, monitoring regulatory developments, coordinating with regulators where appropriate, and preparing compliance reports.

The Compliance Officer should have appropriate independence to raise compliance concerns without improper interference.

40. Social Media Administrator

The Social Media Administrator shall:

• Manage official accounts
• Publish approved content
• Monitor comments
• Escalate violations
• Respond professionally
• Protect account credentials
• Maintain publication records
• Follow the political neutrality requirement

The Social Media Administrator shall not independently publish controversial or high-risk content without authorization.

41. Marketing Department

The Marketing Department shall:

• Develop advertising campaigns
• Ensure advertising complies with this Policy
• Coordinate with Compliance
• Maintain advertiser information
• Avoid misleading claims
• Ensure proper authorization of promotional content

42. Compliance Review Matrix

PenpenGo should classify content according to risk:

43. Political Neutrality Test

Before approving potentially sensitive content, the reviewer should ask:

1. Is this content promoting a political party?
2. Is it promoting a political candidate?
3. Is it asking people to vote for or against someone?
4. Is it fundraising for political purposes?
5. Is it attacking a political party or candidate?
6. Is the political message disguised as a commercial advertisement?
7. Is the content genuinely institutional government information?

44. Record Keeping

PenpenGo should maintain appropriate records of advertisers, advertisements, approvals, rejections, complaints, suspensions, appeals, government advertisements, compliance reviews, fraud investigations and regulatory communications.

Records should be retained according to the company's records-management requirements and applicable law.

45. Monitoring and Reporting

The Compliance Department should periodically review the platform. A monthly or quarterly compliance report may include numbers of advertisements reviewed, approved, rejected and suspended; complaints; fraud cases; political advertisements rejected; government advertisements approved; privacy incidents; cybersecurity incidents; regulatory issues; and corrective actions.

46. Key Performance Indicators

PenpenGo may monitor advertisement approval time, complaint resolution time, fraud detection rate, number of policy violations, number of repeat offenders, customer satisfaction, account verification rate, content removal rate, privacy incidents, cybersecurity incidents and appeal outcomes.

47. International Expansion

As PenpenGo expands beyond Liberia, the company shall establish country-specific compliance requirements. The core principles of this Policy shall remain applicable globally, but local procedures may be developed to comply with data protection, consumer protection, advertising, transportation, e-commerce, cybersecurity, tax, business registration, financial and telecommunications requirements, and other applicable national laws.

Where local law imposes stricter requirements than this Policy, PenpenGo shall comply with the applicable legal requirement.

48. West African Operations

Before launching in another West African country, PenpenGo should conduct a country compliance assessment covering:

1. Business registration
2. Digital platform requirements
3. Data protection
4. Consumer protection
5. Advertising rules
6. Transportation regulations
7. Tax obligations
8. Payment regulations
9. Cybersecurity
10. E-commerce requirements
11. Content restrictions
12. Government advertising requirements

A country-specific compliance annex should be developed before launch.

49. Platform Terms and Conditions

This Policy should be supported by separate:

• Terms and Conditions
• Privacy Policy
• Cookie Policy
• Advertising Policy
• User Agreement
• Driver/Rider Terms
• Business/Advertiser Agreement
• Complaints Procedure
• Data Protection Procedure
• Cybersecurity Policy
• Content Moderation Procedure

The Social Media and Digital Platform Policy should not be treated as a substitute for these documents.

50. Employee Training

All contractors, sub-contractors and independent representatives whose duties involve digital platforms should receive training on social media use, customer communication, privacy, data protection, cybersecurity, fraud detection, advertising standards, political neutrality, content moderation, complaints management and professional ethics.

Training should occur during onboarding and periodically thereafter.

51. Management Responsibility

Management is responsible for ensuring that adequate resources are available to implement this Policy, including appropriate technology, qualified personnel, compliance resources, cybersecurity controls, training, monitoring systems, complaint mechanisms and appropriate legal advice where necessary.

52. Policy Review

This Policy should be reviewed at least annually or whenever there are significant changes in business operations, technology, applicable laws, digital-platform risks, advertising practices, data protection requirements or country expansion.

The Compliance Officer should coordinate the review and submit proposed amendments to management for approval.

53. PenpenGo's Political Neutrality Statement

54. User Acceptance

By using PenpenGo's digital platforms, users acknowledge that they are expected to comply with this Policy, PenpenGo's Terms and Conditions, Privacy Policy, Advertising Policy, and applicable laws and regulations.

Failure to comply may result in removal of content, suspension or termination of an account, or other appropriate action.

55. Policy Approval

The authorised management of PenpenGo approves this Policy.

56. Conclusion

PenpenGo Liberia recognises that a successful digital platform depends not only on technology but also on trust.

The company therefore commits itself to developing a platform that is professional, neutral, transparent, secure, responsible, inclusive, commercially fair and customer-focused.

PenpenGo's digital environment shall be designed to promote legitimate commerce while protecting users, advertisers, government institutions and the reputation of the company. The company shall maintain its political neutrality while remaining open to legitimate commercial and institutional advertising.

As PenpenGo expands from Liberia to West Africa and eventually the global market, this Policy shall serve as the foundation for responsible digital-platform governance and compliance.