1. INTRODUCTION

The Rules of the Securities and Exchange Commission relating to the complaints management framework, dated February 12, 2015, titled “Rules Relating to Complaints Management Framework of the Nigerian Capital Market” (as amended or supplemented from time to time), together with the extant Investments and Securities Act 2025 (“ISA 2025”) and Rule 13.4 of the Rulebook of the Nigerian Exchange Limited (NGX), mandate all Capital Market Operators in Nigeria, including Trading License Holders of the NGX to establish a clearly defined Complaints Management Policy (the “Policy”) to handle and resolve complaints.

2. SCOPE

The Policy shall focus on a wide spectrum of complaints with special attention to complaints from clients (Corporate and Individual) and the Regulators. There is no such thing as a minor complaint as any complaint has the possibility of causing immense, irreparable damage to the Company.

3. OBJECTIVES

The Policy aims to accomplish the following:

3.1. Development of a mechanism for prompt and effective resolution of complaints.

3.2. Creation of database of complaints which may be useful for research purposes.

3.3. Effective and proper management of complaints within Regulatory timeline.

3.4. Minimize the risk exposure of the Company.

3.5. Forestall a crystallization of risk with potential that could lead to reputational damage for the Company.

3.6. Ensure timely acknowledgement of and response to complaints and client correspondence generally, in line with Executive Management’s directive on staff response timelines.

4. DEFINITIONS

4.1. “Competent Authority” means Self-Regulatory Organizations (SRO) like the Nigerian Exchange Limited (NGX), NASD OTC Securities Exchange (NASD) and recognized Capital Market trade associations.

4.2. “Regulator” means Securities & Exchange Commission (SEC).

4.3. “Complaints” means any written statement of a client (personal and/or corporate) alleging a grievance involving the conduct of business or affairs of his investments under the management of the Company. Complaints may also be against an employee, Representative, officer, director or advisor of the firm.

4.4. “RCC” means Risk Management, Control and Compliance.

4.5. “CMP” means Complaint Management Policy.

4.6. “Working Hours” means the Company’s official hours of business (8am - 5pm)

4.7. “Holding Reply” means an interim written response issued to a complainant acknowledging receipt of a complaint, confirming that it is being investigated and indicating a timeline for substantive response, pending full resolution of the complaint.

5. TYPES OF COMPLAINTS

Below is an inexhaustive list of complaints that the company is exposed to:

5.1. Complaints from Clients (Individuals and Corporate)

5.2. Complaints from Capital Market Operators

5.3. Complaints from Regulators

6. MODE OF LODGING COMPLAINTS AND ACKNOWLEDGEMENT

6.1. All complaints must be submitted and expressed in writing. Written complaints should contain the following information:

a. Name of the complainant

b. Full address

c. Telephone number

d. E-mail address

e. Signature of the complainant and date

6.2. Complaints may be submitted to the Company via the following:

a. E-mail - complaints received by e-mail must be acknowledged within one (1) hour of receipt during Working Hours. Complaints received outside Working Hours must be acknowledged by 9:00 a.m. of the following working day, in line with Executive Management’s directive on staff response times.

b. By post - acknowledged in accordance with section 6.3 below.

c. In person - acknowledged immediately upon receipt.

d. By telephone conversation - a complaint made by telephone must be reduced into writing. Staff receiving such a complaint shall (i) make a written record of the complaint immediately (ii)inform the complainant that the complaint must be confirmed in writing and (iii) request the complainant to submit a written follow-up by e-mail or any other written medium within a reasonable time.

e. The complaint shall proceed to resolution only upon receipt of the written follow-up where a complainant is unable to provide same within a reasonable time, the staff member shall escalate the matter to RCC for guidance.

6.3. Where complaints are received by post, the Company shall ensure that a letter of acknowledgment is sent to the Complainant within Two (2) working days from the date of receipt of the complaint. A copy of the l letter of acknowledgment should be immediately sent to the Regulator if the Regulator is copied in the letter of complaint.

6.4. All complaints shall be resolved within ten (10) working days from the date the complaint was received n or in the case of a telephone complaint, from the date the written follow-up referred to in Rule 6.2(d) is received. The Competent Authority shall be notified of the resolution of the complaint within two (2) working days.

6.5. Holding Reply- Where a complaint cannot be conclusively resolved within the acknowledgment period specified in Rule 6.2, the responsible staff member or business unit shall, in addition to the acknowledgment, issue a Holding Reply to the complainant, without prejudice to the ten (10) working day resolution timeline under Rule

7. COMPLAINT MANAGEMENT FRAMEWORK

7.1. Complaints will be registered on the Company’s register and sent to the Regulator on quarterly basis. This data shall contain the number and nature of complaints received and should be differentiated according to the types of Complaints.

7.2. The Policy should be made available to clients and the public, by hoisting on the company website.

7.3. All complaints should be addressed to the Chief Executive Officer of the Company who is responsible for overseeing the implementation of the Policy.

7.4. RCC shall manage all complaints and ensure its daily implementation across the Company with the support of other business units of the Company.

7.5. An effective resolution at the earliest opportunity will enhance the complainant’s view of the organisation and allow prompt improvement to practices.

7.6. Complaints shall be handled by staff of the Company who have the appropriate expertise and authority to resolve or investigate complaints and where appropriate, provide remedies and identify improved practices.

7.7. Where business units are unable to resolve complaints, the matter should immediately be referred to the Head of RCC for investigation and resolution.

8. COMPLAINT MANAGEMENT PROCESS FLOW Complaints should be dealt with promptly in accordance with SEC rules & regulation. The essential steps in the resolution of complaints are as follows:

8.1. Acknowledge: every complaint, however received, must be promptly acknowledged in accordance with the timelines set out in Section 6 above and a Holding Reply issued where applicable pursuant to Section

8.2. Assess the Issue: in the resolution of complaints, the issue raised by the complainant should be identified. This is critical in determining the next course of action.

8.3. Determine the most appropriate course of action that leads to a resolution of the matter. This may i include the involvement of other business units.

8.4. Investigation: the issues raised should be investigated to determine the veracity of the claims and/or issues raised by the complainant.

8.5. The outcome of the investigation should be reported to the complainant and the Regulator where applicable.

8.6. All complaints must be given the required attention and must be resolved as amicably as possible before it crystallizes.

8.7. All complaints must be resolved in accordance with the directives contained in a letter of complaint, subject to relevant SEC rules.

8.8. All letters of response to complaints must either be drafted by RCC or should be forwarded to RCC for approval before being sent to the Regulators.

9. Complaints between Capital Market Operators and complaints against a relevant Competent Authority may be lodged, at first instance, with the relevant Competent Authority respectively.

9.1. All complaints lodged at first instance with a relevant Competent Authority shall be resolved within twenty (20) working days.

9.2. Further to Section 9.1 above, all unresolved complaints must be forwarded to SEC within five (5) working days.

9.3. Complaints referred by the Company to relevant Competent Authorities shall be resolved within twenty (20) working days of receipt of the complaint.

9.4. The letter of referral shall be accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents, within two (2) working days.

9.5. Failure to forward a summary of proceedings within the specified timeframe shall attract a sanction in line with the rules and regulations of SEC.

9.6. Where the complainant is not satisfied with the decision of the relevant Competent Authority, the matter shall be referred by the complainant to SEC within two (2) working days.

10. COMPLAINT REGISTER

10.1. All complaints must immediately be reported to RCC, and all complaints should be recorded in the Complaint Register.

10.2. The Complaints Register shall be updated monthly and forwarded to SEC quarterly.

10.3. The Complaints Register shall contain the following:

10.3.1. Name of complainant

10.3.2. Date of complaint

10.3.3. Nature of complaint

10.3.4. Complaint details in brief

10.3.5. Remarks / comments

11. KEY STAFF & THEIR ROLES

11.1. Chief Executive Officer / Managing Director (MD/CEO): Responsible for overseeing the proper management and implementation of the Policy.

11.1.1. The MD shall assist the RCC team in its mandates to effectively manage the Policy.

11.1.2. The MD shall lead the full implementation of the Policy.

11.1.3. The MD shall establish adequate operational planning and financial control systems.

11.1.4. The MD ensures appropriate internal control measures are in place.

11.2. Chief Compliance Officer (CCO) The CCO is saddled with the following responsibilities:

11.2.1. The CCO implements the execution of the CMP daily.

11.2.2. The CCO reviews, investigates and monitors complaints and ensures proper and timely resolution of complaints.

11.2.3. The CCO acts as an interface between the Company and the Complainant and/or the Company and the Regulators.

11.2.4. The CCO shall monitor staff compliance with the acknowledgment, Holding Reply and resolution timelines under this Policy and report material breaches to Executive Management.

11.3. All Staff

11.3.1. All staff members shall respond to e-mails, including complaints, within same business day of receipt during Working Hours and by 9:00 a.m. of the following working day where the e-mail is received outside Working Hours.

11.3.2. Any staff who receives a complaint by telephone shall comply with Section 6.2(d) regarding written follow-up.

11.3.3. Failure to comply with Section

11.3.1 or

11.3.2 shall constitute a breach of this Policy and shall attract disciplinary action as may be determined by Executive Management, in line with the Staff Disciplinary Committee’s mandate.

12. CONFIDENTIALITY / NON-DISCLOSURE Information on complaints received by the Company shall not be disclosed to third parties without appropriate authorization by RCC.

12.1. All complaints received by the Company shall be resolved by RCC and business units/staff that may be connected to the complaints. Under no circumstances should information on a complaint be disclosed to staff that is not involved in the resolution process.

12.2. Unauthorized use of information from complaints shall receive appropriate sanctions from the Executive Management of the Company.

12.3. Employees shall endeavour to keep all information from complaints confidential both during and after employment.