Online Trading Compliance,
Terms of Use & Indemnity

All dealings on the Portal shall be in strict compliance with the rules, regulations, codes of conduct, and ethics of the Nigerian Exchange Group ("NGX Rules"), the Securities and Exchange Commission ("SEC"), the Central Bank of Nigeria AML/CFT Regulations, CSCS Rules, and the Investments and Securities Act. You are advised to familiarise yourself with these rules and regulations at all times.

These Terms are subject to amendment, modification, or substitution by the Company at any time. Your continued use of the Portal after any such change shall constitute your acceptance of the revised terms. You are encouraged to review this document periodically for updates.

If any provision herein is found by a court or administrative body of competent jurisdiction to be invalid, unenforceable, or illegal, the remaining provisions shall continue in full force and effect, modified as necessary to give effect to the commercial intention of the parties.

Access to the Portal is granted solely for lawful securities transactions and is at your own risk. The following conditions apply:

• You are not permitted to link any external website to the Portal without prior written consent from the Company.
• The Company does not warrant that use of the Portal or any material downloaded from it will not cause damage to property, including loss of data or computer virus infection.
• The Company shall not be responsible for any loss or damage arising from IT or network downtime, internet failure, third-party disruptions, or cyber incidents not attributable to the Company's own negligence.
• The Company will make all reasonable efforts to ensure the Portal is fully operational and that its servers are secure; however, it does not guarantee freedom from unauthorized access or hacking.
• Under no circumstances shall the Company be liable for special, punitive, or consequential damages arising from your use of or inability to use the Portal. If you are dissatisfied with the Portal or these Terms, your sole remedy is to discontinue use.
• Unless provided on a complimentary basis, the online trading service carries a fee of ₦10,000 per year.

By enrolling for online trading, you acknowledge and accept the following:

• All online trades executed using your credentials are considered duly authorised, whether or not they bear your handwritten signature.
• You are solely responsible for the security of your passwords, PINs, devices, and all authentication tools at all times.
• Any transaction executed on your account prior to the Company being notified of a security compromise shall be binding on you.
• The Company may freeze, suspend, or report any suspicious account or transaction to the relevant regulatory authority without prior notice.
• The Company is not liable for losses caused by your own negligence, compromised devices, weak passwords, internet or network failure, third-party disruptions, or cyber incidents attributable to you.

You agree to observe the following responsibilities as a condition of using the Portal:

• Keep all login credentials, passwords, usernames, and other electronic channel details strictly confidential and secure at all times.
• Ensure that sufficient cleared funds are available in your account before placing any order.
• Use the Portal exclusively for lawful securities transactions in accordance with applicable Nigerian capital markets regulations.
• Monitor your account regularly and report any suspicious, unauthorized, or potentially compromised activity to the Company immediately at investment@transworldltd.com.ng.
• Notify the Company of any suspicious email, message, or notification concerning your account before taking any action in response to it.
• Maintain secure devices that are free from viruses, malware, spyware, or any form of unauthorized access.
• Confirm that any mandate you have submitted has been successfully recorded on the Company's database and reflected on your account.

In consideration of the Company acting on mandates given via email, the brokerage account, and all other electronic channels in connection with your stockbroking account, you confirm and accept the following:

• The Company is authorised to act on your mandates transmitted through any electronic channel registered under your name without bearing your handwritten signature, and is under no obligation to verify the identity of the individual sending the mandate.
• Any transaction made pursuant to such a mandate shall be binding upon you regardless of subsequent attempts to revoke it, unless the Company has received and acted upon a valid revocation instruction before execution.
• You are bound by every mandate sent through registered electronic channels that has been acted upon by the Company, whether or not a subsequent mandate to revoke the previous one has been received.

The Company reserves the right to refuse, suspend, or discontinue online trading service to any client at its sole discretion. The Company may deny access to all or part of the Portal without prior notice if you engage in conduct or activities that, in the Company's reasonable judgement, violate any of these Terms. The Company shall have no liability for any consequences arising from such discontinuance.

The Company also reserves the right to monitor use of the Portal from time to time and to disclose information as necessary to satisfy any applicable law, regulatory requirement, or to protect its own interests. The Company may cooperate with any government, regulatory, or legal investigation regarding your use of the Portal.

The Company may also modify or discontinue any or all of its services at any time and for any reason, including but not limited to required maintenance, telecommunications interruptions, or other operational exigencies.

You agree to fully indemnify, defend, and hold harmless Transworld Investment & Securities Limited, its directors, officers, employees, agents, and all associated entities against all losses, liabilities, damages, penalties, claims, enforcement actions, and costs (including legal fees) arising from or connected to:

• Any form of fraud, forgery, misrepresentation, insider trading, market manipulation, corruption, or other unlawful activity by you in connection with your use of the Portal.
• Money laundering, terrorist financing, or any breach of Nigerian AML/CFT laws, NFIU Guidelines, or applicable international financial crime regulations.
• The submission of false, misleading, or unverifiable documents or KYC information to the Company.
• Unauthorized or illegal use of your online trading account for the purchase or sale of securities.
• Any breach of SEC Rules, CBN AML/CFT Regulations, NGX Rules, CSCS Rules, or the Investments and Securities Act arising from your conduct on the Portal.
• Any loss or damage resulting directly or indirectly from your use of or inability to use the Portal, including losses arising from your reliance on information or services provided through the Portal.

The following procedures apply to the resolution of trade-related disputes and complaints:

• All trade-related complaints must be reported to the Company within 24 hours of the disputed transaction.
• The Company will rely on platform logs, timestamps, and system records when determining the outcome of any dispute.
• All dispute information received under this policy will be reviewed and addressed within 7 working days.
• Where matters cannot be resolved at the Company level, they may be escalated to the SEC, NGX, or CSCS in accordance with applicable regulatory procedures.

By proceeding to enrol for and activate online trading access, you confirm that:

• You have read this document in its entirety and understand all provisions contained herein.
• You agree to be unconditionally bound by these Terms and all applicable regulatory requirements.
• All buy and sell transactions on stock, shares, and bonds in your CSCS account domiciled with Transworld Investment & Securities Limited shall be executed in accordance with the requirements set out above.
• You understand that the Company's electronic systems constitute the authoritative record of all transactions and account activity.