Complaints Management Policy

Document Title: Complaints Management Policy

Company: Network Capital Limited

Version: v2

Approved Date: December 16, 2025

Review Frequency: Annually or upon regulatory change

1. Purpose

Network Capital Limited (NETCAP) is committed to providing excellent service to all clients, prospective clients, and stakeholders. This Complaint Management Policy has been developed in alignment with BS ISO 10002:2018 (Customer Satisfaction — Guidelines for Complaints Handling) and the applicable requirements of the Securities and Exchange Commission (SEC) of Nigeria and the Nigerian Exchange Limited (NGX).

Network Capital Limited is committed to handling complaints fairly, promptly, transparently and in line with applicable capital market rules, data protection requirements and internal governance standards. Complaints are treated as an opportunity to improve service quality, strengthen controls and protect clients, investors and market integrity.

We view every complaint as an opportunity to improve. This policy establishes clear, consistent, and transparent procedures for receiving, investigating, and resolving complaints — and for escalating them appropriately where regulatory involvement is required.

2. Scope

This policy applies to complaints relating to Network Capital Limited’s stockbroking, account opening, trading, settlement, portfolio, client service, website, data protection, cybersecurity, employee conduct, vendor and other regulated capital market activities. It applies to employees, directors, officers, agents, service providers and any person handling complaints on behalf of the Company.

3. Definition of Complaint

A complaint is an expression of dissatisfaction made to Network Capital Limited or about Network Capital Limited, relating to its services, products, staff, processes, market conduct, data handling or complaint-handling process, where a response, explanation, remedy or resolution is explicitly or implicitly expected.

4. Policy Objectives

• Make clients, investors and stakeholders aware of how to lodge complaints.
• Ensure complaints are logged, acknowledged, classified, investigated and resolved objectively.
• Protect complainants from unfair treatment or retaliation.
• Resolve operational complaints quickly and escalate material issues without delay.
• Ensure regulatory complaints are handled in line with applicable SEC, NGX, CSCS, NASD, CIS, NDPA and other relevant requirements.
• Identify root causes, implement corrective action and report complaint trends to management and the Board.

5. Who May Complain

• Clients
• Prospective clients
• Shareholders
• Investors
• Regulators
• Employees
• Counterparties
• Vendors and service providers
• Members of the investing public
• Beneficiaries, estate representatives or authorised representatives
• Other stakeholders interacting with the Company

6. Complaint Categories

6.1 Operational and Administrative Complaints

These are complaints that can usually be resolved internally by Client Services, Operations and Compliance without immediate regulatory escalation, provided they do not involve fraud, unauthorised trading, client asset abuse, market infraction or material breach.

• Rudeness or unprofessional conduct by staff
• Poor customer service or delayed response to enquiries
• Delay in account opening, mandate processing or document issuance
• Delay in issuance of contract notes or statements
• Errors in account statements or administrative records
• Communication lapses
• Delay in CSCS account processing
• Technical or system access issues
• Relationship management concerns
• Minor operational errors capable of prompt correction

6.2 Trading, Settlement and Client Asset Complaints

These complaints involve securities transactions, client assets, mandates, trade execution, settlement, CSCS records or client funds. They require immediate Compliance review and may require escalation to Senior Management, the Board, NGX, CSCS, NASD, SEC or another competent authority depending on the facts.

• Unauthorised sale or purchase of securities
• Execution outside client mandate or price instruction
• Delayed or failed settlement
• Misappropriation or diversion of client funds or sale proceeds
• Fraudulent or unauthorised transfer of securities
• Unauthorised discretionary trading
• Diversion of dividends or other entitlements
• Falsification of trade or account records

6.3 Regulatory, Market Conduct and Board-Level Complaints

These are serious matters involving possible breaches of law, market rules, professional standards, governance requirements or regulatory obligations.

• Insider trading
• Front-running of client orders
• Market manipulation
• Breach of SEC, NGX, NASD or CSCS rules
• Conflict of interest violations
• Forgery or falsification of documents
• Fraud or attempted fraud
• Repeated unresolved operational failures
• Any complaint that may materially affect clients, the Company, regulators or market integrity

6.4 Data Protection and Cybersecurity Complaints

These complaints involve personal data, website security, unauthorised access, cyber incidents or suspected misuse of personal information. They must be escalated to the Data Protection Officer, Compliance and IT immediately.

• Unauthorised disclosure of personal data
• Loss or misuse of KYC documents
• Suspected data breach or cyber incident
• Unauthorised access to client account or portal
• Website form submission or upload security complaint
• Failure to respond to a data subject request

7. Complaint Submission Channels

Complaints may be submitted through any of the following official channels:

Complaints received through unofficial channels should be redirected to an official channel and logged once received by the Company.

8. Information Required When Making a Complaint

• Name and contact details of the complainant
• Client account number, CSCS number or CHN, where applicable
• Description of the issue, including date, time, transaction details and persons involved
• Relevant documents, screenshots, contract notes, statements, mandates, emails or messages
• Preferred contact channel for updates
• Where the complaint is made by a representative, evidence of authority to act

9. Complaint Logging and Acknowledgement

All complaints shall be recorded in the Complaints Register immediately upon receipt. Each complaint shall receive a unique complaint reference number. The register shall capture the complainant, date received, category, summary, owner, action taken, status, resolution date, escalation history and root-cause/corrective action where applicable.

Email complaints should be acknowledged within two working days. Postal complaints should be acknowledged within five working days. The acknowledgement should include the complaint reference number, responsible unit and expected next steps.

10. Complaint Escalation Hierarchy

11. Investigation and Resolution Process

1. Receive and log the complaint.
2. Acknowledge the complaint and provide a reference number.
3. Classify the complaint by type, severity and regulatory impact.
4. Assign a complaint owner. Compliance shall own material, regulatory, trading, settlement, data protection and client-asset complaints.
5. Gather evidence, including mandates, emails, call logs, trading records, CSCS records, system logs, staff statements and relevant documents.
6. Identify whether immediate containment is required, such as suspending a transaction, preserving records, restricting access or notifying management.
7. Prepare findings and proposed resolution.
8. Communicate the decision and corrective action to the complainant in writing.
9. Implement corrective action and update the Complaints Register.
10. Close the complaint only when resolved, withdrawn, escalated externally or all reasonable internal options have been exhausted.

12. Resolution Timelines

The Company shall aim to resolve complaints within the regulatory timelines applicable to capital market operators and shall notify the complainant where a matter is complex and requires more time. As a standard internal service target:

13. Possible Remedies and Corrective Actions

• Apology and explanation
• Service correction or reprocessing
• Correction of records or statements
• Staff counselling, retraining or disciplinary action where appropriate
• Operational rectification and control improvement
• Escalation to senior management, Board or regulator
• Restitution or other remedy where legally and contractually appropriate
• Cybersecurity containment, password reset, access review or incident response action

14. Communication and Feedback

The complainant shall be kept informed at reasonable intervals, especially where resolution will take longer than expected. The final response shall state the issue reviewed, the findings, the decision, any corrective action, and available escalation options where applicable.

If the complainant accepts the proposed decision or action, the resolution shall be implemented and recorded. If the complainant rejects the proposed decision or action, the complaint shall remain open or be escalated until all reasonable internal and external redress options have been exhausted or the matter is otherwise concluded.

15. External Escalation

Where a complaint cannot be resolved internally, where the complainant is dissatisfied with the final response, or where the nature of the matter requires regulatory attention, the complaint may be escalated to the appropriate authority depending on the subject matter:

• Nigerian Exchange Limited (NGX) for exchange-traded securities, dealing-member conduct and exchange-related matters.
• CSCS for depository, settlement, account holding, securities transfer and portfolio record issues.
• NASD OTC Securities Exchange for NASD OTC market matters.
• Securities and Exchange Commission for capital market regulatory complaints and unresolved complaints.
• Nigeria Data Protection Commission for unresolved data protection complaints or qualifying personal data breach matters.
• Chartered Institute of Stockbrokers or other professional body for professional conduct issues where applicable.

16. Reporting, Monitoring and Recordkeeping

The Compliance Department shall maintain the Complaints Register and submit periodic reports to Senior Management and the Board. Reports should include the number of complaints, categories, ageing, unresolved matters, root causes, corrective actions, repeated issues, and regulatory escalations. Complaint records shall be retained in line with legal, regulatory and internal record-retention requirements.

Approved and Authorised