Complaint Management Policy

1. 1.1.Kudy Financials Limited (“the Company”, or “Kudy”) is committed to providing the highest standard of services to its Stakeholders.
2. 1.2.Kudy acknowledges that complaints are a common occurrence in all Stakeholders' business engagement. Kudy further recognizes the right of any person covered under this compliant management policy (“Policy”) to raise an issue or make a complaint in the course of their dealing with Kudy and shall ensure that their complaints are dealt with in an efficient, responsive, impartial and courteous manner.
3. 1.3.A complaint is a written expression of dissatisfaction (justified or not) made about the standard of services, act or omission of Kudy affecting an individual client or group of clients covered by the Investment and Securities Act, 2007 (ISA) and the Securities and Exchange Commission (“SEC”) Rules relating to Complaint Management Framework of the Nigerian Capital Market (and other relevant Rules and Regulations issued by the SEC) (“SEC Rules”).
4. 1.4.For the avoidance of doubt, the following shall not constitute a complaint under this Policy:
   • A request for information, clarification of services offered or provided
   • Complaints whose subject matter is being investigated by Competent Persons/Authorities or have been or are currently the subject of legal proceedings or arbitration, including an employee-related dispute
   • Complaints that are not covered within the ISA and SEC Rules and/or within the purview of other regulatory agencies.

1. 2.1.This Policy is issued in compliance with the provisions of:
   • The Investment and Securities Act, 2007 (ISA) and
   • The Securities and Exchange Commission (“SEC”) Rules and Regulation, 2013 (and other relevant Rules and Regulations issued by the SEC)

1. 3.1.The key objective of this Policy is to provide information about the framework for handling complaint relating to Kudy. The Policy will:
   • Provide a fair complaint procedure which is clear and easy to follow by any Complaint wishing to make a complaint
   • Document and publicize the existence of Kudy's complaint procedure so that Stakeholders know what to do when they have a complaint.
   • Make sure that all complaints are investigated fairly and promptly
   • Make sure that all complaints are, wherever possible, resolved and relationships are appropriately managed.
2. 3.2.Stakeholders referenced in this Policy include the following:
   • Employees of the Company
   • All clients/customers both internal and external
   • Third parties working in association, partnership or contractual agreement with Kudy
   • Third-party auditors and service providers
   • External organizations providing customer representation such as advocacy and complaint services
   • Regulators and
   • Other stakeholders that are not listed above.

1. 4.1.The Chief Compliance Officer (“CCO”) shall be responsible for handling all complaints received by Kudy. In this context, Complaints should be in writing and addressed to any of the following:
   
   
   1. The Chief Compliance Officer
      Kudy Financials Limited
      8 Lake Chad Crescent
      Maitama, Abuja
   
   
   2. Head, Corporate Communication
      Kudy Financials Limited
      8 Lake Chad Crescent
      Maitama, Abuja
   
   

   Email: compliance@kudy.ng

2. 4.2.The CCO shall be responsible for ensuring that the proper process for managing complaints is followed and for monitoring compliance
3. 4.3.The CCO shall designate an Officer to assist him/her in the discharge of these responsibilities
4. 4.4.A copy of this Policy shall be made freely available on Kudy's Website.

1. 5.1.Receipt and Acknowledgement
   • 5.1.1.Upon receipt of a Complaint, the Complaint will be recorded in the Complaint Register by the Compliance Officer
   • 5.1.2.Receipt of an electronic Complaint via email shall be acknowledged as soon as possible (not exceeding 3 (three) working days from the date of receipt), whilst a Complaint received by post shall be acknowledged within 5 (five) working days from the date of receipt.
   • 5.1.3.Where a Complaint is resolved within the time frame for acknowledging complaints as set out in clause 5.1.2 above, and the response containing the decision regarding the Complaint sent to the Complainant (this means a person, organization or their legal representative who makes the complaint), this will be deemed to be sufficient acknowledgement and resolution of the Complaint.
   • 5.1.4.Sufficient records of Complaints received by email and the respective email acknowledging and records of complaints received and resolved via physical or post office box address shall be available to the SEC when required. Evidence of posting a response to the shall be deemed sufficient proof that the Complaint received attention from Kudy.
2. 5.2.Resolving a Complaint
   • 5.2.1.The CCO shall have the capacity to investigate and take all reasonable steps to resolve complaints and to implement appropriate remedies as may be deemed required.
   • 5.2.2.Upon resolution of a complaint, the outcome shall be communicated to the Complainant and the Compliance Officer shall record the decision into the Complaint Register.
   • 5.2.3.Where a Complainant is dissatisfied with the decision reached by Kudy, the Complainant, may, if he/she so wishes, refer the complaint to a Competent Authority (means Self-Regulatory Organization (“SRO”) and/or Capital Market Trade Association).
3. 5.3.Timing of Complaint Resolution
   • 5.3.1.All complaints received shall be resolved and a final response sent to the Complainant within 10 (ten) business days of it being received by Kudy.
   • 5.3.2.Where Kudy is unable to resolve a particular complaint within the stipulated timeline above, the Complainant shall have a right to refer the Complaint to a Competent Authority.
   • 5.3.3.You as Kudy’s client shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slow due to, among other things, an overload of system capacities.

1. 6.1.Kudy shall maintain a Complaint Register which shall be in an electronic form. The Complaint Register shall contain the following:
   
   
   1. Name of the Complainant
   2. Date the complaint was received
   3. Nature and description of the complaint
   4. Summary of the complaint
   5. Supporting documents, if any
   6. Decision/resolution made
2. 6.2.Copies of letters, and memos sent including any update letters, acknowledgement letters, and response/resolution documents shall form part of the complaint management record that shall be kept in accordance with Kudy Document Management Policy.

Any improper use of the Complaint process by way of malicious accusations shall not be tolerated and appropriate actions shall be taken within the confines of the law.

The identity of Complainants shall be kept strictly confidential except where the concern raised is of a criminal nature and requires legal proceedings. However, Kudy will to the best of its ability ensure that the Complainant is protected from any form of retaliation, victimization or retribution.

The CCO shall monitor the resolution status of all complaints and provide a quarterly report of complaints received and their status, independently verified by the Internal Audit, to Kudy’s Management Committee. The report shall serve as a monitoring tool which shall enable the Management Committee to monitor the effectiveness of Kudy’s complaint-handling procedure, other related policies and/or procedures and identify relevant trends (if any) which could indicate areas for future focus or improved performance.

This Policy shall be published on Kudy’s Website together with the details of the contact person(s) mentioned in clause 4 above and procedures described in clause 5 above.