Legal

Complaints policy

Effective 11 August 2026. How to complain to Starfetch Investment Limited, what we will do, how long it will take, and how to escalate to the Securities and Exchange Commission if you are not satisfied. Published in line with the SEC Rules on the Complaints Management Framework of the Nigerian Capital Market.

1. Our commitment

If something we have done falls short, we want to hear about it directly and fix it. A complaint is not a nuisance to us — it is the fastest information we get about where our service is failing. Every complaint is investigated fairly, by someone not responsible for the matter complained about wherever that is possible, and no client is disadvantaged for having complained.

2. What counts as a complaint

Any expression of dissatisfaction with our services, our people or our handling of your money or your instructions — whether about delays, errors, charges, communication, conduct, or the way a previous complaint was handled. You do not need to use the word "complaint" or any particular form of words.

3. How to make a complaint

By email: info@starfetchinvestltd.com.ng, with "Complaint" in the subject line. This is the fastest route and the one we recommend.

By letter: The Compliance Officer, Starfetch Investment Limited, The Bloc (2nd Floor), 70 Kusenla Road, Off Lekki–Epe Expressway, Ikate-Elegushi, Lekki, Lagos, Nigeria.

In person: at the office address above, during business hours (Monday to Friday, 8:30am–5:30pm WAT).

Through this website: using the contact form or the "Leave a message" widget on any page.

4. What to tell us

So that we can investigate without going back and forth, please include where you can: your name and the account or reference the complaint relates to; what happened and when; who you dealt with; what you would like us to do to put it right; and copies of anything relevant. If you are complaining on behalf of someone else, please tell us your authority to do so.

5. What we will do, and how quickly

Acknowledgement. We will acknowledge your complaint in writing within two (2) working days of receiving it by email or through this website, and within five (5) working days where you write to us by post. The acknowledgement will tell you who is handling the matter and how to reach them.

Investigation and resolution. We aim to resolve your complaint and give you our written response within ten (10) working days of receipt. If we need longer — for example because we must obtain records from a third party such as our custodian or bank — we will tell you why and give you a revised date.

If we cannot resolve it in time. Where a complaint is not resolved within ten working days, we will notify the Securities and Exchange Commission within two (2) working days of that deadline passing, setting out the action taken to date and providing the supporting documents, as the Commission's rules require.

6. If you are not satisfied with our response

First, come back to us. Ask for the matter to be reviewed by our Compliance Officer, and then by the Managing Director. Say what part of our response you disagree with — a second look by a more senior person resolves most matters.

Then, the Commission. You may refer your complaint to the Securities and Exchange Commission, Nigeria, which operates a complaints management framework for the capital market. Details are available at sec.gov.ng. You do not need our permission to do this and we will not treat you differently for doing it.

Finally, the Tribunal. Where a matter remains unresolved, it may be referred to the Investments and Securities Tribunal.

7. Our complaints register

We maintain an electronic complaints register recording, for every complaint: a unique complaint number, the date received, the complainant, the nature and details of the complaint, the action taken, the date of resolution and the outcome. The register is reviewed by management, and we file the periodic returns on complaints that the Commission requires.

8. Confidentiality

We handle your complaint confidentially. Information is shared only with those who need it to investigate and resolve the matter, or where we are required to disclose it to a regulator. Personal data is handled in line with our Privacy Policy and the Nigeria Data Protection Act 2023.

9. Ownership and review

This policy is owned by the Compliance Officer of Starfetch Investment Limited and is reviewed at least annually, and whenever the applicable rules change. Complaints data is reported to the Board, because patterns in complaints are a governance matter, not only an operational one.

Version 2026-08-11.v1 · Effective 11 August 2026 · Owner: Compliance Officer · Next scheduled review: August 2027

Market digest

Stay ahead of the Nigerian market

Rates, market notes and plain-language investing guidance — sent periodically, no noise.