SEC NIGERIA

SECURITIES AND EXCHANGE COMMISSION, NIGERIA

NEW RULE AND SUNDRY AMENDMENTS TO THE RULES AND REGULATIONS OF THE COMMISSION

LEGEND: Additions are underlined; Deletions are struck through.

New Rule A. Rule on Warehousing and Collateral Management

Major Amendment B. Amendment to Rule 19- Renewal of Registration (Reinstatement of Rule 19)

Sundry Amendment C. Amendment to Quarterly Returns Forms for Unit Trust Schemes

NEW RULE A. RULE ON WAREHOUSING AND COLLATERAL MANAGEMENT

1. DEFINITION OF TERMS In this Rule, unless the context otherwise requires:

“Assayer” is an entity (person/institution) recognized by the relevant professional body that certifies and grades the commodities that are delivered in registered warehouses.

"Collateral Management Company” or “CMC” means a Company registered by the Commission to provide collateral management services;

"Collateral Management Services” means the activity of managing commodities as collateral, including but not limited to the following-

I. Providing enabling arrangements for collateral commodity financing; II. Issuance of credible Warehouse receipts and other necessary arrangements for agricultural commodity financing; III. provision of quality warehousing services involving storage and preservation of commodities; and IV. Stock audit, evaluation and verification services.

Collateral Manager means a company registered by the Commission to act as a third party holder of commodities, deposited by a depositor who is financed by a lending

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA institution or for commodities to be traded on a recognized Exchange, in a warehouse owned or effectively controlled by the Collateral Management Company;

"Commission” means the Securities and Exchange Commission established under the Investment and Securities Act, 2007.

"Commodity" I. Means raw material or primary agricultural product that can be bought and sold such as grains, livestock and its derivative products, extractive minerals and all other goods and articles, except all services, rights and interests in which contracts for future delivery are presently or in the future dealt in; or II. Any product resulting from any of the above activities, including by- products of such products; and III. Any product which is intended to increase the production of anything referred to in I above sub-clauses or improve the quality thereof;

“Depositor” means a person who delivers Commodities to the Warehouse Operator for storage or transfer of ownership;

"Electronic Warehouse Receipt” or “EWR” means an electronically issued negotiable and transferable receipt issued by a Collateral Management Company, as evidence that specified commodities of stated quantity and quality have been deposited in the Warehouse by the holder of the receipt;

"Financial Institution” means any entity licensed by the Central Bank of Nigeria to amongst other things provide financing using securities including Warehouse Receipts";

“Exchange” means a Commodities Exchange duly registered by the Commission for the trading of commodities;

"Goods Received Note” means a temporary non-negotiable and non-transferable note issued by a Warehouse Operator for a maximum period of two days to a Depositor upon depositing commodity in the Warehouse, for the purpose of acknowledging the deposit until the issuance of the Electronic Warehouse Receipt to the Depositor;

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA "Standard Operating Procedure (SOP)” means a document describing processes, actions and responsibilities relevant to the operations of a registered and accredited warehouse;

"Warehouse” means any premises registered by the Commission to be used for the storage of commodities deposited by a depositor;

"Warehousing Guidelines” means the guidelines issued by an Exchange/ Collateral Management Company, with the approval of the Commission, for compliance by all registered and accredited Warehouses in relation to storage, warehousing management and supply chain/inventory maintenance and distribution standards;

"Warehouse Operator” means any person responsible for managing registered Warehouses;

"Warehouse receipts” means a document of title issued as evidence that a specified commodity of stated quantity and quality has been deposited at a particular warehouse location by a named depositor. It allows the depositor to confer a security interest in the stored commodity to another party without requiring physical delivery.

"Weight or Quantity” in relation to a specific Commodity means such weight or quantity which is duly adjusted for the specified commodity in accordance with standards approved by the relevant standard-setting bodies.

2. REGISTRATION OF COLLATERAL MANAGEMENT COMPANY

Conditions applicable to a CMC:

a) No person shall provide collateral management services unless registered by the Commission. b) A Warehouse Collateral Management Companies shall not undertake, without the approval of the Commission, any other form of business except for collateral management services and any other incidental services as determined by the Commission from time to time.

3. REGISTRATION REQUIREMENTS An application for registration as Collateral Manager shall be filed on the appropriate S.E.C Form and shall be accompanied by:

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA a) Two sets of completed appropriate S.E.C Forms to be filed by the sponsored individuals; b) A copy of the Certificate of Incorporation certified by the Corporate Affairs Commission where a copy not certified is filed, the applicant shall present the original for sighting by an authorized officer of the Commission; c) A copy of the Memorandum and Articles of Association certified by the Corporate Affairs Commission, which shall among others, include power to act as a Collateral Manager d) A copy of the appropriate CAC Form containing particulars of the directors certified by the Corporate Affairs Commission; e) Copy of latest audited accounts or audited statement of affairs for companies in operation for less than one (1) year; f) Fidelity Bond representing 20% of paid-up capital; g) Sworn undertaking to keep proper records and render returns; h) Evidence of minimum paid-up capital of N50 million. i) Application for registration of a minimum of two sponsored individuals one of whom shall be the chief executive officer. The two principal officers of the Collateral Management Company who shall be registered as sponsored officers must have a minimum of a university degree or its equivalent with not less than ten (10) years relevant post-qualification experience; j) A list of key officers and technical experts engaged and details of their qualifications, which should capture evidence of financial, technical capabilities to carry out the functions of a Collateral Manager. k) A list of relevant technology systems in place as required by collateral management services;

1. Information relating to the relevant Commodities Management Facilities including: Assaying facilities, Warehousing, Aggregation, Computerization and Telephone systems and a well finalized Business Plan; m) Two copies of existing or proposed by-laws or rules, Code of Conduct, Warehousing Guidelines etc., n) Instruction and inspection manuals of warehouse activities; o) Detailed information about the promoters and principal officers of the Collateral Management Company; p) Two copies of Warehouse Accreditation requirements of the Collateral Management Company; q) Detailed information about the Technology system to be adopted; r) An Undertaking by the CMC to always forward copies of amendments of its Guidelines for approval by the Commission;

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 4) MINIMUM PAID-UP CAPITAL AND FIDELITY INSURANCE BOND

1. Evidence of required Minimum Paid-up Capital – N50, 000,000 (Fifty Million Naira).

2. Maintain a Fidelity Insurance Bond covering 20% of the minimum paid-up capital as stipulated by the Commission's Rules and Regulations;

5. MAINTENANCE OF RECORD BY A COLLATERAL MANAGER

(1) Every CMC is required to properly maintain the following: - (a) All the records relating to the depositors and complaints, if any; (b) Such other record as may be required by the Commission.

(2) Every CMC shall ensure that the record referred to in (1) above is maintained and preserved in good condition for a period of at least 7 (seven years).

(3) Every CMC shall- (a) Ensure that the record is kept at such a place and maintained in such a manner that it is easily accessible; and (b) Establish a record-retention-policy, which shall ensure that all relevant legal and regulatory requirements are complied with.

6. DUTIES AND RESPONSIBILITIES OF A COLLATERAL MANAGEMENT COMPANY

The Collateral Management Company shall:

1. Ensure that its Board of directors and the chief executive are appointed with prior approval of the Commission;
2. Ensure that key officers fulfill the fit and proper criteria as provided in these regulations;
3. Maintain the eligibility criteria provided by the Commission and notify the Commission immediately if it ceases to fulfill any of the conditions provided in these rules;
4. Maintain high standard of integrity and fairness in discharging its functions and its dealing with other persons with whom it has agreed in writing to render services as CMC;
5. Fulfill its obligations in a fair, efficient, transparent and ethical manner;
6. Act with due skill, care and diligence in performing all its functions and discharging all its obligations and responsibilities;

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 7. Upon Registration, display such license, in a conspicuous place, in the principal place of its business; 8. Establish the procedure for pledging, in favor of a financial institution, the Depositor's commodities held with the Warehouse against which Electronic Warehouse Receipt has been issued; 9. Certify a Warehouse.

7. WAREHOUSING

A. Registration of Warehouses:

1. Every warehouse that stores commodities to be traded on a registered Exchange shall apply to be registered by the Commission.

2. The Commission shall maintain a Register of all registered warehouses which shall be published on its website.

3. A warehouse applying for registration shall: i. Submit proof of ownership or registered-lease deed or rent agreement, along with disclaimer from the owner of the Warehouse/property providing waiver of ownership regarding Commodities stored in such Warehouse, in case of leased or rented Warehouse; ii. Present evidence of construction in compliance with the National Building Code, iii. Present evidence of compliance with relevant Federal and State regulation relating to the operation of warehouses, iv. Have facility(ies) appropriate for storage of commodities, v. Have appropriate security arrangements in place, vi. Have adequate trained staff with expertise and knowledge of scientific storage of commodities, vii. Have requisite equipment for weighing and quality measures of commodities, viii. Have comprehensive insurance cover for the building, equipment, stock and other items as may be necessary, ix. Be located in a place with access to infrastructure to support its operations and have sufficient space for parking and movement of large vehicles, Χ. Have an efficient system for loading/unloading of Commodity including proper mechanism for segregation of different kinds/quality of Commodity; xi. Submit a Standard Operating Procedure (SOP) which shall cover the following among others: a. Procedures for acceptance of commodities to be deposited and delivery of commodities; b. Procedures for weighing, sampling of goods to be deposited in compliance with industry standards,

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA c. Procedure for verification of commodities and communication to depositors, d. Procedure for maintaining the quality of the goods stored in line with relevant specifications, e. Procedure for Know your depositor, f. Security policy for ensuring the safety of the goods, g. Procedure for the use of modern techniques for storage of goods, h. Procedure for determining and addressing losses due to theft, fire, burglary, fraud, negligence and force majeure events, i. Procedure for internal verification of stock, j. Procedure for maintenance of warehouse and preservations of Stock, k. Organizational structure, l. Job description for every staff

B. Exchange Accreditation of Collateral Management Companies/Warehouses/Assayers

1. A registered Collateral Management Company, registered warehouse and Assayer shall be accredited with an Exchange in order to handle commodities linked to the Exchange.

2. The Exchange shall make an initial assessment at the time of accrediting a Warehouse as well as annual assessment in relation to each Warehouse accredited, and maintain a copy of the report for a minimum period of 7 years.

3. Exchanges shall periodically submit details of Warehouses accredited and inspections carried out to the Commission as may be prescribed.

4. A Collateral Management Company may be accredited by more than one Exchange.

5. In addition to the provisions of these Rules, the Exchanges may prescribe additional guidelines for compliance by their accredited Collateral Management Companies, warehouses and Assayers.

C. Certification of Warehouses by Collateral Management Companies

1. Every registered warehouse seeking to issue Electronic Warehouse Receipts to be traded on a registered Commodity Exchange/used for collateral management purposes shall be certified by the Collateral Management Company to which it is linked subject to the following conditions:

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA a. The Warehouse is suitable with respect to the types of Commodities being stored; b. The Warehouse is equipped with all the necessary equipment and apparatus including but not limited to drying, weighing, handling, firefighting, circulation of stock, alternative power source, and insect/pest management; c. The Warehouse is comprehensively insured for incidents including but not limited to natural disaster, fire, and theft; d. The Warehouse Operator is of a good repute, has no criminal convictions, has not defaulted on his financial obligations, is competent and has control over the operations of the Warehouse; e. The Warehouse Operator has submitted an affidavit that he is responsible for ensuring maintenance of quantity, weight and quality of Commodity that is stored for the Depositor; f. The Warehouse is electronically connected with the CMC, which in turn has a link to the Commodity Exchange(s); g. Maintain an efficient electronic inventory management system; h. Establish effective complaints management procedures; and

2. Upon certifying a Warehouse, the CMC shall inform the Commission, indicating the location, capacity, types of Commodities the Warehouse is suitable for storing, and other relevant information;
3. Maintain records and documents in respect of certified Warehouses;
4. Maintain a register of certified Warehouses and publish the list on its website;
5. Submit a monthly report to the Commission about details of Warehouses accredited and inspections carried out.

D. Insurance:

A Warehouse Operator shall ensure at all times that the value of commodities stored at registered warehouses is under insurance. The value of the commodities to be insured should be re-evaluated periodically.

E. Know Your Depositor: A Warehouse Operator shall at all times be able to identify the depositor of the commodities deposited in registered warehouses, the owner of the deposited goods (in case the depositor is an agent of the actual owner), and the actual beneficiary (in case the depositor and the beneficiary are different) of the stored commodities.

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA F. Every depositor shall be issued a Goods Received Note against commodity deposited in a warehouse. The Goods Received Note shall be replaced within two days with an Electronic Warehouse Receipt issued by the Collateral Management Company.

G. The Collateral Management Company/Warehouse Operator shall not issue a warehouse receipt without actually receiving the commodities.

H. The Collateral Management Company/Warehouse Operator shall not issue more than one receipt for the same commodities deposited by a depositor provided that in case of a loss or destruction, a duplicate receipt may be issued in compliance with the specified process.

8. STANDARDIZATION AND ISSUANCE OF ELECTRONIC WAREHOUSE RECEIPTS

1. Electronic Warehouse Receipts shall only be issued by Collateral Management Companies;

2. The Collateral Management Company shall control and maintain records of Electronic Warehouse Receipts issued by it.

3. The Collateral Management Company shall prescribe particulars to be contained in the Electronic Warehouse Receipt subject to the approval of the Commission which shall include the following:

i. Auto-generated unique receipt number by the Electronic Warehouse Receipt System/Collateral Management System; ii. Warehouse Registration number, name of the Warehouse and its complete address; iii. Name and address of the person by whom or on whose behalf the commodity is deposited; iv. Date of issuance of the Electronic Warehouse Receipt; v. Storage charges and handling charges; vi. Description of the Commodity and the packages containing them (if any) with particulars of quantity and quality or grade; vii. Market value of the Commodity at the time of deposit; viii. Declared shelf-life of the Commodity as determined by the Assayer;

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA ix. Validity of the Electronic Warehouse Receipt which shall be for a maximum period of the declared shelf-life of the Commodity as determined by the Assayer; x. Name of the insurance company, policy and policy number of the insurance cover for indemnifying the Electronic Warehouse Receipt holder for any loss that may be caused to such person by the wrongful act, negligence, natural catastrophe, or other act of the Warehouse causing loss or depreciation of value to the commodity based on the criteria predetermined by the Collateral Management Company; xi. Statement that the Commodity received shall be delivered to the holder thereof, or that the Commodity shall be delivered to the order of a named person;

4. Each Electronic Warehouse Receipt shall be assigned a serial number, and shall maintain the same serial number.

5. The Collateral Management Company shall ensure that its Electronic Warehouse Receipt System/Collateral Management System is electronically linked to its certified warehouses and the Exchange where the Electronic receipt is to be traded.

6.Tradability of Electronic Warehouse Receipts

a. Electronic Warehouse Receipts shall be tradable on an Exchange,

b. For the purpose of settlement of Electronic Warehouse Receipt, the Electronic Warehouse Receipt System of the Collateral Management Company shall be linked to the Exchange and its Depository.

7. Maintenance of Records of Electronic Warehouse Receipts

The Collateral Management Company shall maintain the following records:

(a) All Electronic Warehouse Receipts issued;

(b) Date of issuance of the Electronic Warehouse Receipts;

(c) Date of expiry of the Electronic Warehouse Receipts;

(d) The commodity for which the Electronic Warehouse Receipt has been issued;

(e) Quality and quantity of the commodity as specified in the Electronic Warehouse Receipt;

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA (f) Any Electronic Warehouse Receipt that has been cancelled by the Collateral Management Company;

(g) Any transaction that has been carried out on the Electronic Warehouse Receipt as provided by the Commodities Exchange; and

(h) Any other information as may be required by the Commission.

8. The Collateral Management Company shall submit a summary of all Electronic Warehouse Receipts issued, along with the total value of the relevant Commodity, on a monthly basis to the Commission.

9. The Collateral Management Company shall inform the Commission immediately of any loss, damage or destruction of any record or report in relation to the Electronic Warehouse Receipt.

10. DELIVERY AND WITHDRAWAL OF COMMODITIES

11. Delivery of Commodities shall be made after due charges are paid. The Collateral Management Company/Warehouse Operator shall deliver the Commodity to the depositor or endorsee subject to payment of all dues to the warehouse and cancellation of the Electronic Warehouse Receipt.

12. Commodities deposited in the Warehouse by the Depositor on the basis of which Electronic Warehouse Receipt has been issued by the Collateral Management Company may be withdrawn in the manner prescribed by the Collateral Management Company/Warehouse Operator.

13. PLEDGING AGAINST ELECTRONIC WAREHOUSE RECEIPT IN RESPECT OF COMMODITIES

14. The Collateral Management Company shall make necessary arrangements for provision of pledging against the Electronic Warehouse Receipt, issued in respect of the Commodity, including the matters concerning the collateral management of such financing and matters connected therewith.

15. The Collateral Management Company shall provide a Financial Institution necessary access to the data for verification of Electronic Warehouse Receipt.

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 3. The Depositor of Commodities or other person holding an Electronic Warehouse Receipt may create a Pledge in favor of a Financial Institution, by instruction to the Collateral Management Company, against the Commodity represented in such Electronic Warehouse Receipt in the manner prescribed by the Collateral Management Company.

4. Information to be provided for the purpose of creation of Pledge on an Electronic Warehouse Receipt by the Collateral Management Company, Pledgor and the financial institution shall be in the manner prescribed by the Collateral Management Company.

5. The Collateral Management Company shall give effect to the Pledge transaction in favor of the financial institution upon the instructions of the Depositor of the Commodity or such other person in whose favor Electronic Warehouse Receipt has been issued, in the manner prescribed by it.

6. The financial institution shall have a lien on the Commodity represented through the Electronic Warehouse Receipt and the Collateral Management Company shall not release the Commodity from the warehouse if a pledge exists on the Electronic Warehouse Receipt issued against the Commodity.

7. The financial institution, upon satisfaction, may release the Pledge as prescribed.

8. Upon release of the Pledge by the financial institution, such Commodity shall be available to the Depositor of the Commodity or other person holding the Electronic Warehouse Receipt.

9. INSPECTION

The Commission shall conduct inspection of registered warehouses and Collateral Management Companies.

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA MAJOR AMENDMENT B. RENEWAL OF REGISTRATION (REINSTATEMENT OF RULE 19)

(1) (a) All Capital Market Operators shall file applications for renewal of their registration every year. (b) Every Capital Market Operator shall renew its registration by filing the appropriate SEC form as contained in the Schedules to these Rules and Regulations.

(2) Every Capital Market Operator shall file an application for renewal of registration not later than 31st January of every year.

(3) The application for renewal shall be accompanied by a renewal fee as provided in the Schedule to this Rule as well as evidence of the following:

(a) renewal of valid fidelity bond/professional indemnity insurance (where applicable); (b) proof of compliance with minimum paid-up capital requirement; (c) details of current minimum number of sponsored individuals as prescribed by the Commission from time to time; (d) Attendance by all sponsored individuals, of at least one course organized by the Commission or institutions recognized by the Commission prior to the renewal date; (e) latest quarterly returns of the applicant.

(4) Any Capital Market Operator who fails to comply with the provisions of this Rule shall be liable to a late filing fee as specified in the Schedule to these Rules and Regulations and/or any other sanction as may be deemed appropriate by the Commission.

(5) Where a Capital Market Operator fails to meet the requirements for renewal of registration, the Commission shall give written notification of its intention to deny or refuse renewal of registration and such Capital Market Operator shall be given an opportunity to be heard.

(6)(a) Any Capital Market Operator subject to this Rule shall within 5 working days upon receipt of the notice required under sub-rule (5) above, file a sworn statement including any document that may be necessary, showing reasons why it should not be suspended.

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA (b) Upon receipt of the sworn statement and any accompanying document the Commission shall within 5 working days communicate its decision to the Capital Market Operator concerned.

(7) Where the certificate of registration of a Capital Market Operator is suspended or withdrawn, the Commission shall publish such suspension in two national daily newspapers and the Commission's website.

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA SCHEDULE I

Registration Fees, Renewal Fees Minimum Capital Requirements, Securities and others

PART A Registration Fees and Renewal Fees

A1. Capital Market Operators Registration fees | Renewal Fees

N k

1. Application Form 50,000.00 二
2. Broker/Dealer 500,000.00 125,000.00
3. Broker 500,000.00 125,000.00
4. Dealer 500,000.00 125,000.00
5. Sub-broker 200,000.00 50,000.00
6. Inter-Dealer Broker 500,000 125,000.00
7. Corporate Sub-Broker 200,000.00 50,000.00
8. Underwriter 200,000.00 50,000.00
9. Issuing House 500,000.00 125,000.00
10. Registrar 500,000.00 125,000.00
11. Fund/Portfolio Manager 500,000.00 125,000.00
12. Corporate Investment Adviser 300,000.00 75,000.00
13. Individual Investment Adviser 100,000.00 25,000.00
14. Commodity Broker Dealer 300,000.00 75,000.00
15. Commodity Broker 50,000.00 12,500.00

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 16. Commodity Dealer 50,000.00 12,500.00 17. Receiving Banker 1,000,000.00 250,000.00 18. Trustee 500,000.00 125,000.00 19. Rating Agency 1,000,000.00 250,000.00 20. Capital Market Consultant (Corporate) 300,000.00 75,000.00 21. Capital Market Consultant (Partnership) 100,000.00 25,000.00 22. Capital Market Consultant (Individual) 100,000.00 25, 000.00 23. Venture Capital Company 300,000.00 75,000.00 24. Market Maker 200,000.00 50,000.00 25. Custodian of Securities 200,000.00 50,000.00 26. Nominee 300,000.00 75,000.00 27. Crowdfunding Platform 1,000,000.00 250,000.00 28. Dealing Member Banks 500,000.00 125,000.00 29. Securities Exchange 1,000,000.00 250,000.00 30. Central Counter-Party(CCP)/Central 500,000.00 125,000.00 Securities Depository(CSD)/Securities Clearing and Settlement Company 31 Self-Regulatory Organizations(S.R.O) 100,000.00 25,000.00 and Trade Associations

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA SUNDRY AMENDMENT

C. AMENDMENT TO QUARTERLY RETURNS FORMS FOR UNIT TRUST SCHEMES

SEC FORM QR6 SECURITIES AND EXCHANGE COMMISSION QUARTERLY RETURNS FROM UNIT TRUST SCHEME FUND MANAGERS AS AT (This return must be made, latest by the end of the first month of the succeeding quarter. Late returns would attract statutory penalty) 1 Details of the Fund a. Name of Scheme:____________________________________________________________ b. Change of Name of Scheme (if applicable):_________________________________________ C. Date of Commencement:_____________________________________________________ d. Fund's financial year end __________________________________________________ 2. Name of Custodian:-_________________________________________________________ Current Address:___________________________________________________________ Old Address (if any).________________________________________________________ Telephone:___________________________ E-mail:_____________________________ 3. Name of Trustees:_________________________________________________________ Current Address:___________________________________________________________ Old Address (if any) ________________________________________________________ Telephone:___________________________ E-mail _____________________________ 4. Name of Registrar:__________________________________________________________ Current Address__________________________________________________________ Old Address (If any) ________________________________________________________ Telephone:___________________________ E-mail_____________________________ 5. Name of Compliance officer:__________________________________________________ Registration Status with the Commission:_______. Telephone:_________________________ E-mail: 6. Status of Fidelity Bond: (a) Valid/Expired:________________________________________________________ (b) Expiry Date of Fidelity Bond ________________________________________________

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 7. INVESTMENT PORTFOLIO ALLOCATION AND PERFORMANCE REPORT SA: Asset B: C: % D: Mkt E: % Mkt F: % G: H: I: % J: / Class/T Origin Trust Value Value of Weighted Income Unrealis Weight of Applicab Nype al Deed as at Aggregate Holding received ed Unrealised le Amou Alloc date of Portfolio period : Capital Cap Benchm nt ation reporti Value(over return(yiel Dividen Appreci Appreciati ark and Invest ng period d) to d ation/(Lon/Loss to its ed N'000 covered/b Aggregate Income, oss) Aggr Return( being Portfolio Interest N'000 Portfolio Yield) reported) return(yiel , etc Val d) A Equities i Listed Equity ii Unlisted( Traded iii Others(S pecify) Total B Fixed Income I Fed Govt Bond Ii State Bond Ii Corporat i e I Supra V Nat'l V Sukuk V Green i Bond V Others(S ii pecify) Total

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA C Money i Mkt T Bills ii Discount Notes iii Com Papers i Bank V Accptce V Call Deposits V Fixed i Deposit V Others(S ii pecify) D Real Estate Investme i nt Propertie S ii Real Estate Related(S pecify) iii Authorise d REITS Fund i Others(S V pecify) Total E Other Asset

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA Classes( Specify) I Specify Ii Specify iii Specify Total F Cash I Cash in Hand Ii Cash at Bank Total GAGGREG ATE VALUE NB: Please attach Valuation methods and analysis of valuation for all investments MANAGEMENT FEE EXPENSE REPORT 8. Description Q1 Amount % Q2 Amount( % Q3 Amount( % Q4 Amount % TOTAL (N'000) Wei (N'000) Weig N'000) Weig (N'000) Wei ght ht to ht to ht to ht to NAV NAV NAV NAV A Professiona I Fees i Mgt. Fee ii Incentive Fee iii Trustee Fee iv Custodian V Registrar vi Auditor Fees vii Rating Fee viii Other(specify 20

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA Total B Operating Expenses I Securities Transaction Cost I-i Equities I-ii Bonds I-iii Money Mkt I-iv Real Estate Asset Acquisition Cost Total C Other Expenses(S pecify) i Specify ii Specify iii Specify iv Specify V Specify D TOTAL EXPENSES 9. Net Income/Loss # 10. MUST BE COMPLETED Development & Level of work done in adoption of IFRS: 11. Premium Earned on Net Subscription_ 12. Total Number of Trade in Equities (Purchase and sales executed): 21

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SECURITIES AND EXCHANGE COMMISSION, NIGERIA 13. Latest Offer Price/Date:______________________________________________________ 14. Latest Bid Price/Date:________________________________________________________ 15. Income Distributed/Date:_____________________________________________________ 16. Total value of Unclaimed Dividends:_____________________________________________ 17. Gross Asset Value:_________________________________________________________ Current Asset:_______________________________________________________________ Non-current Asset:____________________________________________________________ 18. Total Liability to Date:_______________________________________________________ Current Liabilities:_____________________________________________________________

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Others (with notes)___________________________________________________________ Non-Current Liabilities:________________________________________________________ 19. Net Asset Value____________________________________________________________ 20 Summary of Units: Authorised at Opening Additional Redemptions Net Transaction Reserve Inception Number of Subscriptions Units Balance of Units Units 21. Date of Last AGM held:______________________________________________________ 22. Indicate submission of Monthly Returns:_________________________________________ 23. Analysis of Unit Holding/Distribution A) Retail Investor Type and Unit Holding/Distribution (Domestic)

1. Numb Aggregat Aggregate Aggregate Percentag Aggregat Aggregat Net NSRV er of e Units Proportion of Value of e of Value e e Sub/Rede to Invest Held Units to Total Units Held to Total Subscripti