We take complaints seriously and have established a structured framework to ensure that all complaints are handled promptly, fairly, and independently.

1. What Is a Complaint

A complaint is any expression of dissatisfaction by a client or investor relating to our products, services, investment decisions, disclosures, fees, conduct of staff, or Shariah compliance, whether made verbally or in writing.

2. How to Submit a Complaint

Clients may submit complaints through any of the following channels:

• Email: info@ethicacapitalltd.com
• Physical Address: Suite 413, NAWA Complex, Plot 106/107 Ahmadu Bello Way, Kado, Abuja
• Online: [Link to complaint form, if applicable]

To enable prompt investigation, complaints should include:

• Client’s full name and contact details
• Account or portfolio reference (if applicable)
• Clear description of the complaint
• Relevant supporting documents (if any)

3. Complaint Handling Process

All complaints are handled by the Compliance function to ensure independence and objectivity. Our process includes:

• Acknowledgment of receipt within 2–5 business days
• Review and investigation of the complaint
• Engagement with relevant internal teams where necessary
• Written communication of findings and resolution

Where a complaint requires additional time due to its complexity, the client will be informed accordingly.

4. Resolution Timelines

We aim to resolve complaints within 10–30 business days, depending on the nature and complexity of the issue. Clients will be kept informed throughout the process.

5. Escalation and Regulatory Recourse

If a client is dissatisfied with the outcome of a complaint, they may request an internal escalation. Where the complaint remains unresolved, the client has the right to refer the matter to the Securities and Exchange Commission (SEC) Nigeria through its complaints management channels.

SEC Nigeria
Website: www.sec.gov.ng

6. Shariah-Related Complaints

Complaints relating specifically to Shariah compliance are escalated to our Shariah governance process and reviewed in line with guidance from our Shariah Supervisory Board, where applicable.

7. Fairness and Non-Retaliation

Clients will not suffer any disadvantage, discrimination, or retaliation for submitting a complaint. All complaints are handled objectively, fairly, and in good faith.

8. Confidentiality and Data Protection

All complaints and related information are treated as confidential and handled in accordance with applicable data protection laws. Information is disclosed only where required by law or regulatory authorities.

9. Cost

There is no charge for submitting or investigating a complaint.

10. Continuous Improvement

Complaints are reviewed periodically to identify trends, strengthen internal controls, enhance service quality, and reinforce investor protection in line with regulatory and Shariah best practices.

Ethica Capital Ltd is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in the Nigerian capital market. Our Whistleblowing Policy provides a secure framework for employees, clients, investors, and stakeholders to confidentially report concerns about suspected misconduct, regulatory violations, or unethical behavior without fear of retaliation.

Your commitment to integrity is essential in maintaining the integrity of financial markets. Whistleblowers play a crucial role in helping us detect and prevent securities law violations, protect investors, and maintain fair and transparent markets.

1. What is Whistleblowing?

Whistleblowing is the act of reporting potential securities law violations, corporate fraud, or other illicit activities within the financial industry. This policy encourages the reporting of genuine concerns relating to illegal, unethical, or improper conduct that may expose the Company, its clients, or the financial system to risk. All disclosures are handled confidentially, independently, and in accordance with Nigerian laws, SEC regulations, Shariah principles, and international best practices.

2. Why Whistleblowing Matters

Your reports contribute to:

• Protecting Investors: Helping identify and halt activities that could harm investors and erode market trust
• Maintaining Market Integrity: Contributing to the integrity and fairness of Nigeria's financial markets
• Holding Wrongdoers Accountable: Enabling enforcement actions against individuals and entities engaging in illegal activities
• Upholding Shariah Principles: Ensuring compliance with Islamic ethical standards and protecting the religious validity of investments

3. Who Can Report

This policy applies to and may be invoked by:

• All employees, directors, and officers
• Members of the Shariah Supervisory Board
• Contractors, consultants, and service providers
• Clients, investors, and fund participants
• Suppliers, vendors, and business partners
• Former employees and stakeholders

4. What Can Be Reported?

You can report various types of misconduct and securities law violations, including but not limited to:

• Insider trading: Misuse of material non-public information for trading advantage
• Financial fraud or accounting irregularities: Fraud, embezzlement, falsification of records, or theft of company/client assets
• Market manipulation: Artificial price manipulation or deceptive trading practices
• Ponzi schemes: Participation in, promotion of, or facilitation of illegal investment schemes (criminal offences under ISA 2025)
• Bribery or corruption: Improper payments, facilitation payments, or inducements
• False statements or omissions in disclosure documents: Misleading or incomplete regulatory filings
• Foreign Corrupt Practices Act (FCPA) violations: International corruption or bribery
• Shariah non-compliance: Investment in prohibited activities, engagement in riba (interest), gharar (uncertainty), maysir (gambling), or misrepresentation of Shariah compliance
• Regulatory violations: Breaches of SEC rules, ISA 2025, anti-money laundering obligations, KYC failures, or data protection violations
• Corporate governance failures: Breach of fiduciary duties, conflicts of interest, or misuse of company assets
• Workplace misconduct: Discrimination, harassment, health and safety violations, or retaliation against whistleblowers
• Criminal activity or obstruction of justice

Good Faith Reporting: You are encouraged to report concerns even if you are unsure whether they fall within these categories. Unsubstantiated reports made in good faith will not result in any adverse action against the whistleblower.

5. How to Report

Internal Reporting Channels

• Chief Compliance Officer: Okwilague Simbiat Abubakar — simbiat.abubakar@ethicacapitalltd.com
• Head of Internal Audit: audit@ethicacapitalltd.com
• Anonymous Hotline: 07014661477 — info@ethicacapitalltd.com

External Reporting

If internal channels are compromised or the matter has not been adequately addressed, you may report directly to:

• SEC Nigeria Whistleblowing Portal: sec.gov.ng/for-investors/whistleblowing
• Email: whistleblowing@sec.gov.ng
• General Email: complaint@sec.gov.ng

Other Regulatory and Law Enforcement Agencies

• EFCC: info@efccnigeria.org | +234-9-4618765
• ICPC: complaints@icpc.gov.ng | +234-9-6707013
• Federal Ministry of Finance Whistleblowing Portal: whistle@yourwhistle.com | fmf.gov.ng
• ReportGov.Ng: reportgov.ng - Submit complaints about government services and regulatory issues

6. Protection for Whistleblowers

The SEC and Ethica Capital take the confidentiality and protection of whistleblowers seriously. We are committed to providing safeguards to those who come forward in good faith, including:

• Anonymous Reporting: You can choose to remain anonymous while submitting information
• Anti-Retaliation Protections: You are protected from retaliation by your employer for reporting wrongdoing
• Financial Rewards: Eligible whistleblowers may receive monetary awards if their information leads to successful enforcement actions

Zero Tolerance for Retaliation: Ethica Capital strictly prohibits any form of retaliation, intimidation, harassment, or adverse treatment against whistleblowers who report concerns in good faith. Victimization of a whistleblower is treated as gross misconduct and may result in termination.

Additional protection measures include:

• Strict confidentiality of your identity and information disclosed
• Active monitoring for signs of retaliation
• Disciplinary consequences for those who victimize whistleblowers
• Support measures including counselling where appropriate
• Protective adjustments such as temporary reassignment if needed

Financial Rewards: The Board may approve financial or non-financial recognition for significant disclosures. Additionally, reports made through the Federal Ministry of Finance Whistleblowing Programme may qualify for rewards of 2.5% to 5% of recovered funds under the Federal Government Whistleblowing Policy 2016. The SEC may also provide monetary awards to eligible whistleblowers whose information leads to successful enforcement actions.

7. Investigation Process

All reports are handled promptly and objectively:

• Acknowledgment: Receipt confirmed within 3 business days
• Initial Assessment: Conducted within 5 business days
• Full Investigation: Completed within 30–60 days (may be extended for complex matters)
• Outcomes: May include warnings, suspension, termination, asset recovery, or referral to law enforcement or SEC

8. Confidentiality & Data Protection

All whistleblowing information is handled in strict compliance with the Nigeria Data Protection Act 2023. Your identity will not be disclosed without your consent except where required by law, necessary for investigation, or essential for legal proceedings. Anonymous reporting is fully supported.

9. False Reports

This policy protects only good-faith reporting. Knowingly false, malicious, or frivolous reports may result in disciplinary action, civil proceedings, or criminal referral. However, unsubstantiated reports made in good faith will not result in any adverse action against the whistleblower.

10. Regulatory Compliance

This policy complies with:

• Investments and Securities Act 2025
• Companies and Allied Matters Act 2020
• Nigeria Data Protection Act 2023
• Nigerian Code of Corporate Governance 2018
• SEC Rules and Guidelines
• Shariah governance principles