Complaints Management Policy

1. Preamble

This policy is established to ensure that:

  1. Complaints about management function are investigated fairly and possible conflicts of interest are identified and mitigated.
  2. Shareholders of the company are provided an avenue to express their reservations about the direction of the company on any matter.
  3. Companies/firms shall post their Complaint Management Policies on their website.
  4. Complaints are dealt with under a uniform body of rules and regulations and in an appropriate manner.
  5. Information on complaints on complaints and complaints-handling to the relevant Competent Authority on a quarterly basis as directed by Securities and Exchange Commission.

2. The under listed complaints shall not be handled under the Complaint Management Framework of the Nigerian Capital Market:

  1. Complaints against private wound up and liquidated companies.
  2. Complaints on matters that are sub-judice or in arbitration.
  3. Complaints falling outside the purview of the Securities and Exchange Commission.

3. Procedure for making complaints

  1. Every complaint received by email shall be acknowledged within two (2) working days.  Where complaints are received by post, the company shall respond in writing within five (5) working days of the receipt of the complaint. Copies of the complaint and the acknowledgement letter shall be forwarded to SEC.
  2. All complaints shall be resolved by the company within ten (10) working days from the date the complaint was received. The Competent Authority shall be notified of the resolution of the complaint within two (2) working days.
  3. Where the complaint is not resolved within the given timeframe, the complainant or company shall refer the complaint to SEC within two (2) working days. The letter of referral shall be accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents.
  4. All complaints shall be referred to the SEC within two (2) working days. The letter of referral shall be accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents.

4. Complaints lodged at first Instance

  1. Complaints against the company may be lodged at first instance with the company.
  2. All complaints lodged at first instance shall be resolved within twenty (20) working days.
  3. For all complaints that are not resolved thereafter, the outcome shall be referred to SEC within five (5) working days.

5. Complaints Referred to SEC

  1. Where the complainant is not satisfied with the decision of the company, the matter shall be referred by the complainant to the SEC within two working days.
  2. Complaints referred by the company to SEC shall be resolved within twenty (20) working days of receipt of the complaint.
  3. The letter of referral shall be accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents, within two (2) working days.
  4. Failure to forward a summary of proceeding within the specified timeframe shall attract a sanction in line with the rules and regulations of the Commission.

6.Complaints Lodged at first Instance with the SEC

  1. The following complaints may be lodged at first instance with the SEC:
    1. Complaints against operators by SEC.
    2. Trade manipulation, accounting frauds, Ponzi schemes and such other complaints as may be determined by the SEC from time to time.
  2. In the case of (a) the SEC shall acknowledge receipt of complaints received from complainants by email, within five (5) working days.
  3. In the case of (b), once a complaint is lodged at the SEC, the SEC shall;
    1. Assess the complaint and decide whether the subject matter falls under the purview of SEC or whether it needs to be referred to another entity. The SEC shall assess the complaint within ten (10) working days.
    2. After the assessment and where the SEC has ascertained that a complaint is within its purview, it shall launch an investigation to verify the assertions made in the complaint.
    3. investigation shall be concluded within thirty (30) working days or for an extended time as the SEC deems fit.
  4. Where it is determined by investigation that there is a prima facie case to be answered, the matter may be referred to the Administrative Proceedings Committee of SEC or where it is determined that a crime has been committed the matter shall be referred to the appropriate criminal agency for prosecution.

7. Complaints Referred to the SEC from relevant Competent Authorities

In cases where complaints are referred to the SEC from relevant Competent Authorities, the SEC shall:

  1. Review the complaint and decide whether the subject matter falls under the purview of SEC or whether it needs to be referred to another entity. The SEC shall review the complaint within five (5) working days.
  2. Where SEC determines that it falls within its purview, it shall resolve the   complaint within twenty (20) working days or for an extended time as the SEC deems fit.
  3. Complainants not satisfied with resolutions /decisions reached by SEC reserve the right to proceed to the Investments and Securities Tribunal (IST).

8. Register of Complaints:

  1. The company shall maintain an electronic Complaints Register.
  2. The Complaints Register shall contain the following details:
    1. Name of the complainant
    2. Date of the complaint
    3. Nature of complaint
    4. Complaints details in brief
    5. Remarks/comments
  3. The Complaints Register shall be up dated monthly.
  4. Status reports of complaints filed with the entities shall be forwarded to the SEC quarterly.
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