The following Policy applies to current and former individual and corporate clients who have or had a brokerage account with Apel Asset Limited. This Policy is applicable to individuals and clients who select us to be a custodian of securities or assets accounts.

Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.

WE RESPECT YOUR PRIVACY

We appreciate that you have provided us with your personal financial information. We strive to maintain the privacy of such information while we help you achieve your financial objectives.

This Policy describes what non-public personal information we collect about you, why we collect it, and when we may share it with others.

It also discusses the steps you may take to limit our sharing of information about you with affiliated Apel Asset Limited companies, including but not limited to our local and international financial services affiliates that are part of our integrated securities and investment management business, We hope this Policy will help you understand how we collect and share non-public personal information that we gather about you. Throughout this Policy, we refer to the non-public information that personally identifies you or your accounts as “Personal Information.”

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

To serve you better and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies, from our web sites and from third parties and other sources.

For example: We collect information such as your name, address, e-mail address, telephone/fax numbers, assets, income and investment objectives through applications and other forms you submit to us. We may obtain information about account balances, your use of account(s) and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources. We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.

If you interact with us through our public and private web sites (including my Clients Login and Research), we may collect information that you provide directly through online communications (such as an e-mail address). We may also collect information about your internet service provider, your domain name, your computer’s operating system and web browser, your use of our web sites and your product and service preferences, through the use of “cookies.” “Cookies” recognize your computer each time you return to one of our sites, and help to improve our sites’ content and personalize your experience on our sites by, for example, suggesting offerings that may interest you. Please consult the Terms of Use of these sites for more details on our use of cookies.

2. WHEN DO WE DISCLOSE PERSONAL INFORMATION WE COLLECT ABOUT YOU?

To provide you with the products and services you request, to serve you better and to manage our business, we may disclose personal information we collect about you to other Apel Asset Limited companies and to non-affiliated third parties as required or permitted by law.

-Information we disclose to other Apel Asset Limited companies

In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and other Apel Asset Limited companies, and as otherwise required or permitted by law, we may disclose personal information to other Apel Asset Limited companies. Offers for products and services from other Plc Apel Asset Limited companies are developed under conditions designed to safeguard your personal information.

-Information we disclose to third parties

We do not disclose personal information that we collect about you to non-affiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, or as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with these companies, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfil that limited purpose.

3. HOW DO WE PROTECT THE SECURITY AND CONFIDENTIALITY OF PERSONAL INFORMATION WE COLLECT ABOUT YOU?

We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.

APPLICABLE LAW

This Website is created, hosted, maintained and controlled in the Federal Republic of Nigeria and as such you agree that the laws of the Federal Republic of Nigeria and the jurisdiction of the Nigerian courts govern the Privacy Policy, any disclaimers, copyright and use statements contained in the Website, and any legal matter resulting from the use or inability to use this Website, without giving effect to any principle of conflict of laws. Notwithstanding the foregoing, Apel Asset Limited may seek recourse in any jurisdiction worldwide in order to restrain the unlawful use of any of the material contained in the Website.

LEGAL AND REGULATORY

Please read these terms and conditions carefully. By accessing this Web site and any pages hereof, you are indicating that you have read, acknowledged and assent to be bound by these terms and conditions. If you do not agree to these terms and conditions, do not access this Web site. Apel Asset Limited reserves the right to change these terms and conditions and you are responsible for regularly reviewing these terms and conditions. Your continued use of this Web site constitutes your agreement to all such terms and conditions. As used herein, Apel Asset Limited means Apel Asset Limited and its affiliates.

-General information

This Web site comprises various Web site and pages operated by Apel Asset Limited (collectively, the “Web site”). Certain sections of or pages on this Web site may contain separate terms and conditions, which are in addition to these terms and conditions. You should read those additional terms and conditions carefully. By accessing such sections or pages, you agree to be bound by those additional terms and conditions. In the event of a conflict, those additional terms and conditions will govern for your use of those sections or pages. Unauthorized use of Apel Asset Limited‘s Web site and systems, including, but not limited to, unauthorized entry into Apel Asset Limited‘s systems, misuse of passwords or misuse of any other information, is strictly prohibited. You may not use this Web site in any manner that could damage, disable, overburden, or impair any Apel Asset Limited site or service or interfere with any other party’s use and enjoyment of any Apel Asset Limited site or service. You may not attempt to gain unauthorized access to any Apel Asset Limited site or service, computer systems or networks connected to any Apel Asset Limited site or service, through hacking, password mining or any other means. You agree that you will not engage in any activities related to this Web site that are contrary to applicable laws or regulations. The information and materials on this Web site may contain typographical errors or inaccuracies. Apel Asset Limited reserves the right, in its sole discretion, without any obligation and without any notice requirement, to change, improve or correct the information, materials and descriptions on this Web site and to suspend and/or deny access to this Web site for scheduled or unscheduled maintenance, upgrades, improvements or corrections. Any dated information is published as of its date only, and Apel Asset Limited does not undertake any obligation or responsibility to update or amend any such information. Apel Asset Limited may discontinue or change any product or service described in or offered on this Web site at any time.

-Disclaimer of warranty and limitation of liability

The information, products, and services on this Web site are provided on an “AS IS,” “WHERE IS” and “WHERE AVAILABLE” basis. Apel Asset Limited does not warrant the information or services provided herein or your use of this Web site generally, either expressly or impliedly, for any particular purpose and expressly disclaims any implied warranties, including but not limited to, warranties of title, non-infringement, merchantability or fitness for a particular purpose. Apel Asset Limited will not be responsible for any loss or damage that could result from interception by third parties of any information or services made available to you via this Web site. Although the information provided to you on this Web site is obtained or compiled from sources we believe to be reliable, Apel Asset Limited cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither Apel Asset Limited, nor any of its affiliates, directors, officers or employees, nor any third-party vendor, will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this Web site, or resulting from the act or omission of any other party involved in making this Web site, the data contained herein or the products or services offered on this Web site available to you, or from any other cause relating to your access to, inability to access, or use of the Web site or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Apel Asset Limited or of any vendor providing software or services. In no event will Apel Asset Limited or any such parties be liable to you for any direct, special, indirect, consequential or incidental damages or any other damages of any kind even if Apel Asset Limited or any other such party has been advised of the possibility thereof. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (e.g., you cannot access your Internet service provider), unauthorized access, theft, operator errors, strikes or other labor problems or any force majeure. Apel Asset Limited cannot and does not guarantee continuous, uninterrupted or secure access to the Web site.

-Proprietary rights

All right, title and interest in this Web site and any content contained herein is the exclusive property of Apel Asset Limited, except as otherwise stated. Unless otherwise specified, this Web site is for your personal and non-commercial use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, frame, create derivative works from, transfer, or otherwise use in whole or in part any information, software, products or services obtained from this Web site, except for the purposes expressly provided herein, without Apel Asset Limited ‘s prior written approval. If you download any information or software from this Web site, you agree that you will not remove or obscure any copyright or other notices or legends contained in any such information.

Apel Asset Limited, the Apel Asset Limited logo and other Apel Asset Limited trademarks and service marks referenced herein are trademarks and service marks of Apel Asset Limited. The names of other actual companies and third-party products or services mentioned herein may be the trademarks or service marks of their respective owners. You are prohibited from using any marks for any purpose including, but not limited to use as metatags on other pages or sites on the World Wide Web without the written permission of Apel Asset Limited or such third party which may own the marks.

-Use of links

This Web site may contain links to and be linked from third-party Web site. These links are provided only as a convenience. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification or monitoring by Apel Asset Limited of any information contained in any third-party Web site. In no event shall we be responsible for the information contained on that site or your use of or inability to use such site. You should also be aware that the terms and conditions of such site and the site’s privacy policy may be different from those applicable to your use of this Web site.

-Securities products

None of the information contained in this Web site constitutes a solicitation or offer by Apel Asset Limited or its affiliates to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service. Prior to the execution of any transaction by you involving information you received from this Web site, you should consult your business advisor, attorney, and tax and accounting advisors with respect to the price, suitability, value or other aspects of any stock, mutual fund, security or other investment. Pricing and other information generated through the use of data or services made available herein may not reflect actual prices or values that would be available in the market at the time provided or at the time that the user may want to purchase or sell a particular security or other instruments. The information and services provided on this Web site are not provided to and may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory or self-regulatory organization or clearing organization or where Apel Asset Limited is not authorized to provide such information or services. Some products and services described in this Web site may not be available in all jurisdictions or to all clients.