Whistleblowing Policy

This Policy is open to employees, directors, clients, vendors, consultants, and any other person who has a genuine concern relating to the Firm's business or conduct.

You are encouraged to report any genuine concern about suspected misconduct, including, but not limited to:

• Fraud, theft, bribery, or corruption.
• Money laundering or terrorist financing, or a failure to comply with applicable AML/CFT requirements.
• Breach of applicable law, regulation, or regulatory requirements, including those of the SEC or CBN.
• Misuse or mismanagement of client funds or assets.
• Unauthorized disclosure or misuse of confidential or personal data.
• Conflicts of interest that have not been properly disclosed or managed.
• Conduct that endangers the health or safety of any individual or damages the environment.
• Any attempt to conceal any of the above.

Concerns should be reported as soon as reasonably possible, in writing, using the contact details on our website marked for the attention of the Compliance Officer or Data Protection Officer.

Where you are able to do so, please provide as much detail as possible, including relevant dates, individuals involved, and any supporting documentation, to help us investigate effectively.

Reports may be made on a named basis, or anonymously where you prefer not to disclose your identity, although providing your identity may assist us in investigating your concern more effectively.

We will treat all reports as confidential and will only disclose your identity, or information likely to reveal your identity, on a need-to-know basis, to the extent necessary to investigate the concern properly, or where required by applicable law or a regulator.

The Firm will not tolerate any form of retaliation, victimization, or detrimental treatment against any person who raises a genuine concern in good faith under this Policy, whether or not that concern is ultimately substantiated. Any employee found to have retaliated against a person who has made a report in good faith will be subject to disciplinary action. This protection does not extend to any person who makes a report that they know to be false or made in bad faith.

All reports will be reviewed promptly by the Compliance Officer, or another appropriate senior individual independent of the matter reported, who will assess the concern and determine the next appropriate steps, which may include a formal investigation. Where appropriate, and subject to confidentiality and legal constraints, we will endeavor to keep you informed of the outcome of any investigation arising from your report.

Where a report indicates a suspected breach of AML/CFT requirements, securities law, or other serious regulatory or legal obligations, we are required, and reserve the right, to escalate and report the matter to the relevant regulatory or law enforcement authority, which may include the Securities and Exchange Commission (SEC), the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), or the Nigeria Data Protection Commission (NDPC), as applicable, in accordance with applicable law. This may occur whether or not an internal investigation has concluded.

Records of reports made under this Policy, and of any related investigation, are retained confidentially and securely, with access restricted to the Compliance Officer and other individuals with a legitimate need to know in order to investigate or act on the report. Records are retained for as long as necessary to fulfil the purposes described in this Policy, including any applicable legal, regulatory, or investigatory requirements, consistent with our Privacy Policy.

This Policy must not be used to raise malicious, frivolous, or knowingly false allegations. Any person found to have knowingly made a false report may be subject to disciplinary or other appropriate action.