NetCapTrader Acceptable Use Policy

1.  Parties and Definitions

2.  Acceptance of These Terms

You are deemed to have accepted these Terms upon registering for, logging into, or otherwise using the Netcap Trader Platform. These Terms apply in addition to NETCAP’s general Terms of Use and Privacy Policy published at www.networkcapitalltd.com.

NETCAP reserves the right to amend these Terms at any time. Any variations will be communicated through the Platform and/or by email to your registered address. Your continued use of the Platform after notification of a change constitutes your acceptance of the revised Terms. If you do not accept any change, you must immediately discontinue use of the Platform and notify us in writing.

3.  Eligibility and Registration

To access and use Netcap Trader, you must:

• Be at least 18 years of age.
• Hold a valid, approved Network Capital Limited brokerage account and an active CSCS account.
• Have completed NETCAP’s KYC process in full and received account activation confirmation.
• Be the named account holder — Netcap Trader access is personal to the account holder and may not be shared.

Corporate and institutional accounts may designate authorised signatories. Each authorised signatory must complete individual registration and maintain their own login credentials.

4.  Minimum Platform Balance

The minimum funded balance required to activate and maintain an active Netcap Trader account is:

NETCAP reserves the right to review or amend the minimum balance requirement from time to time. Clients will be notified in advance of any changes through the Platform.

5.  Charges and Transaction Fees

By using Netcap Trader, you agree to pay the applicable charges on each Transaction as set out below. All charges are deducted from your Account automatically upon conclusion of each Transaction. A contract note detailing the full breakdown of charges will be sent to your registered email address after each Transaction.

⚠ Important: The rates above reflect the current published schedule and are subject to change in accordance with NGX, SEC, and CSCS regulations. Clients with pre-negotiated rate agreements are subject to the terms of those agreements. Use the Transaction Fee Calculator at www.networkcapitalltd.com/tools/fee-calculator for an exact cost breakdown before placing a trade.

VAT is charged at 7.5% on the brokerage commission, the regulatory fee (SEC on buys, NGX on sells), and the CSCS settlement fee. Stamp duty and the CSCS Trade Alert are not subject to VAT. The full breakdown appears on every contract note.

All charges are deducted without further reference to you. Contract notes in hard copy are available on request and may attract an administrative charge. Electronic contract notes are provided free of charge.

6.  Trading and Transactions

6.1  How Mandates Work

You may submit buy and sell Mandates through the Netcap Trader Platform. Mandates are transmitted directly to the NGX Central Limit Order Book (CLOB) for execution in accordance with NETCAP’s Best Execution Policy, which is published at www.networkcapitalltd.com.

Mandates received before 8:00 AM on a trading day are eligible for same-day execution. Mandates received after that deadline will be executed on the next business day, subject to market conditions.

6.2  Transaction Confirmation

Netcap Trader will notify you of all Transactions executed on your Account by email and in-app notification. Please note that notification may attract a CSCS Trade Alert fee as listed in the charges table above.

Transaction records held by Netcap Trader are taken as correct unless the contrary is proved. If you have not received a notification or wish to dispute a Transaction, contact us within 24 hours of the Transaction date at info@networkcapitalltd.com or on 0706 200 2333.

If no notification of dispute is received from you within 24 hours of a transaction confirmation being sent, the Transaction will be deemed confirmed and accepted by you.

6.3  Insufficient Funds

You will not be permitted to place a buy Mandate if you do not have sufficient cash balance in your Account to meet the value of the Transaction plus all applicable charges. NETCAP is not required to extend credit or complete partial buy orders.

6.4  Internet Connectivity

Access to Netcap Trader requires broadband or mobile internet connectivity. NETCAP is not responsible for the provision, quality, or availability of internet connectivity. You agree that NETCAP shall not be liable for any loss or damage arising from poor internet connectivity, failure of your device, or any circumstances outside NETCAP’s reasonable control.

You acknowledge that Mandates and instructions transmitted through Netcap Trader travel over the public internet. While NETCAP takes all reasonable technical precautions, we cannot guarantee that transmissions will be entirely free from interception, corruption, non-delivery, or mis-delivery.

6.5  Cancellation and Modification of Mandates

You may cancel or modify a Mandate at any time before it executes on the trading floor. Once a Transaction has executed, it cannot be reversed — this is a fundamental rule of NGX market operations. Cancellation requests must be submitted through the Platform or by direct contact with your Relationship Officer.

7.  Account Security

7.1  Your Responsibilities

You are solely responsible for keeping your PIN/Password and all login credentials strictly confidential. You must:

• Select a strong, unique PIN/Password during registration that is not used for any other service.
• Never share your PIN/Password with any other person, including NETCAP staff. NETCAP will never ask for your password.
• Log out of the Platform after each session, particularly on shared or public devices.
• Enable the two-factor authentication (2FA) option — this is strongly recommended.

7.2  Failed Login Attempts

You have three (3) attempts to enter the correct PIN/Password. If the correct credentials are not entered on the third attempt, your Account will be temporarily disabled. To reactivate your Account, follow the account recovery procedure within the Platform or contact NETCAP directly.

7.3  Compromised Credentials

If you discover or reasonably suspect that your PIN/Password has been compromised or become known to a third party:

1. Log in to Netcap Trader immediately and change your PIN/Password.
2. Contact the NETCAP Help Desk at info@networkcapitalltd.com or 0706 200 2333 to report the compromise and, if required, to request an account lock.

NETCAP is entitled to rely on the use of your PIN/Password as conclusive evidence that a Mandate or Transaction was authorised by you, unless and until NETCAP has received written notice that your credentials are no longer secure. NETCAP shall not be responsible for any fraudulent, duplicate, or erroneous instructions submitted using your PIN/Password prior to such notification.

You authorise NETCAP to execute any Mandate authenticated using your PIN/Password. NETCAP is not required to seek additional written confirmation of Transactions confirmed by PIN/Password entry.

⚠  Security reminder: NETCAP will NEVER ask for your PIN, password, BVN, OTP, or CSCS Number via phone, email, or WhatsApp. Any communication requesting these details is not from NETCAP. Call 0706 200 2333 immediately to report it.

8.  Acceptable Use

You agree to use Netcap Trader only for lawful purposes and in accordance with these Terms. You must not:

• Use the Platform for any purpose that is unlawful, fraudulent, harmful, or prohibited by Applicable Laws, including the Cybercrimes (Prohibition, Prevention, etc.) Act 2015.
• Attempt to gain unauthorised access to the Platform, any associated system, CSCS records, or another user’s account.
• Introduce viruses, malware, spyware, or any other harmful code to the Platform.
• Interfere with, disrupt, or place an unreasonable load on the Platform’s infrastructure.
• Reverse engineer, decompile, or attempt to extract the source code of the Platform.
• Use the Platform to transmit unsolicited commercial communications (spam).
• Use another person’s login credentials or impersonate another user.
• Submit Mandates on behalf of another person without documented written authorisation and compliance with all KYC requirements for that person.
• Use the Platform for market manipulation, insider trading, front-running, or any other activity that violates NGX Trading Rules or SEC regulations.
• Use automated bots, scripts, or other non-human means to interact with the Platform, unless explicitly authorised by NETCAP in writing.

9.  Platform Content and Third-Party Information

Netcap Trader may display financial market data, stock prices, indices, charts, research reports, news, analyst opinions, currency rates, and other content sourced from third-party providers (“Content”). NETCAP does not endorse, approve, or guarantee the accuracy, completeness, timeliness, or reliability of any third-party Content.

All Content on the Platform is provided for informational purposes only. Nothing on the Platform constitutes investment advice, a personal recommendation, or an offer to buy or sell any financial instrument. You bear sole responsibility for evaluating the merits and risks of any investment decision made using information on the Platform.

The Platform may contain links to, or embed content from, third-party websites and services. NETCAP does not control such third-party sites and is not responsible for their content, accuracy, or availability. Accessing any third-party site is at your own risk.

NETCAP operates as an execution-only stockbroker. We execute your Mandates on the NGX but do not provide personalised investment advice. If you need investment guidance, speak with your Relationship Officer about our Portfolio Management service.

10.  No Recommendations

NETCAP provides the Platform and its Content for informational, educational, and execution purposes. Any data, research, market commentary, or analytical output available on the Platform should not be construed as investment, financial, tax, or legal advice. You are solely responsible for evaluating the merits and risks of any decision you make based on Content available through the Platform.

In exchange for access to the Platform and its Content, you agree not to hold NETCAP or its third-party content providers liable for any claim for damages arising from any investment decision you make based on information made available through Netcap Trader.

11.  Intellectual Property

All intellectual property rights in the Netcap Trader Platform, including but not limited to the software, design, layout, user interface, trademarks, logos, and all original Content created by NETCAP, are owned by or licensed to Network Capital Limited. All rights are reserved.

You may access and use the Platform solely for the purpose of managing your investment account with NETCAP. You must not:

• Reproduce, copy, redistribute, or exploit any part of the Platform or its proprietary Content for commercial purposes without NETCAP’s prior written consent.
• Remove or obscure any copyright, trademark, or proprietary notice on the Platform.

12.  Account Statements

You may access your account statements, transaction history, and portfolio summary directly through the Platform at any time, at no additional charge. Statements may also be requested by email from your Relationship Officer.

13.  Your Indemnity to NETCAP

You agree to indemnify Network Capital Limited, its directors, officers, employees, and agents, and to keep them fully indemnified against all claims, liabilities, losses, damages, costs, and expenses (including reasonable legal fees) of any kind arising out of or connected to:

• Your use of or access to the Platform, including any Transaction executed through your Account.
• Your breach of these Terms or any Applicable Laws.
• Any Mandate submitted through your Account, whether or not actually authorised by you, where NETCAP had no actual notice of a compromise of your credentials at the time of execution.
• Any false, inaccurate, or misleading information you provide to NETCAP.

14.  Disclaimer and Limitation of Liability

The Platform and all Content are provided on an “as is” and “as available” basis. To the maximum extent permitted by Nigerian law, NETCAP disclaims all representations and warranties, whether express or implied, regarding:

• The availability, continuity, or uninterrupted operation of the Platform at all times.
• The accuracy, completeness, timeliness, or fitness for purpose of any Content.
• The Platform being free from viruses, malicious code, or other harmful components.

To the maximum extent permissible by law, NETCAP shall not be liable for any direct, indirect, incidental, consequential, or special loss or damage arising from:

• Any interruption, suspension, or unavailability of the Platform.
• Any failure, malfunction, or delay in any mobile network, internet service provider, or device used to access the Platform.
• Any unauthorised access to your Account prior to notification of a credential compromise.
• Any decision made in reliance on Content displayed on the Platform.
• Acts of God, force majeure, or other circumstances outside NETCAP’s reasonable control.

Nothing in these Terms limits or excludes liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

15.  Suspension and Closure of Account

NETCAP may suspend, restrict, or terminate your access to the Platform and/or close your Account, with or without prior notice, in any of the following circumstances:

• We have reason to believe your Account is being used in an unauthorised, unlawful, fraudulent, or improper manner.
• You have failed to comply with any of these Terms or any Applicable Laws.
• You have failed to notify us of a credential compromise in a timely manner.
• We are required to do so by a regulatory authority, court order, or Applicable Law.
• Your Account balance falls and remains below the minimum required balance.
• You request closure of your Account.

Where closure or suspension is initiated by NETCAP for regulatory or fraud-related reasons, we are not required to notify you in advance. Where closure is due to an administrative or contractual matter, we will provide reasonable notice where practicable.

16.  Failure or Malfunction of Equipment and Services

NETCAP shall not be liable for any loss arising from any failure, malfunction, or delay in any POS terminal, mobile device, mobile network, internet service provider, server, or other technology used to access the Platform where such failure results from circumstances outside NETCAP’s reasonable control, including planned maintenance, network outages, natural disasters, or third-party system failures.

We will endeavour to notify users of planned maintenance periods through the Platform and by email in advance where reasonably practicable.

17.  Privacy and Data Protection

Network Capital Limited takes the protection of your personal data seriously. This section summarises how we collect and use your data on the Platform. Full details are in NETCAP’s Privacy Policy, which is published at www.networkcapitalltd.com/privacy-policy and is incorporated into these Terms by reference.

By using the Platform, you acknowledge and consent to the following:

• NETCAP collects your personal and financial information to administer your account, execute your Mandates, maintain Netcap Trader, and comply with its regulatory obligations under Applicable Laws.
• Your data may be shared with the Central Securities Clearing System (CSCS), the Securities and Exchange Commission (SEC), the Nigerian Exchange Limited (NGX), the Nigerian Financial Intelligence Unit (NFIU), and other regulatory bodies as required by law.
• NETCAP will not sell or share your personal data with third parties for their own marketing purposes.
• NETCAP may monitor your Account usage and may disclose relevant information to law enforcement, regulatory, or fraud prevention agencies where required to do so by law or where we have reasonable cause to suspect fraudulent or criminal activity.

NETCAP complies with the Nigeria Data Protection Act 2023 (NDPA). You have the right to access, correct, and in certain circumstances, request deletion of your personal data. Contact our Data Protection Officer at dpo@networkcapitalltd.com.

⚠  Data security note: NETCAP uses TLS encryption, Cloudflare security, and two-factor authentication to protect your data. However, no internet transmission can be guaranteed as 100% secure. You use the Platform at your own risk in this regard and are responsible for maintaining the confidentiality of your login credentials.

18.  Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity, or termination, shall first be referred to NETCAP’s internal complaints process as described in NETCAP’s Complaint Management Policy published at www.networkcapitalltd.com.

If the dispute is not resolved through the internal process within the timeframes set out in the Complaint Management Policy, either party may refer the matter to arbitration in accordance with the provisions of the Arbitration and Mediation Act 2023. The seat of arbitration shall be Lagos, Nigeria.

Nothing in this clause prevents either party from seeking urgent injunctive or other interim relief from a court of competent jurisdiction.

19.  Contact Information

Electronic Acceptance

By clicking “I Agree”, registering for an account, or logging in to Netcap Trader, you confirm that:

• You have read and understood these Terms of Use and Acceptable Use Policy in full.
• You agree to be bound by these Terms and any future amendments notified to you.
• You are at least 18 years of age and have the legal capacity to enter into a binding agreement.
• You have also read and accepted NETCAP’s Privacy Policy, Cookie Policy, and Disclaimer published at www.networkcapitalltd.com.

These Terms take effect from the date you first register for or use the Netcap Trader Platform and remain in effect for the duration of your account relationship with Network Capital Limited.

Approved and Authorised