Introduction

This Privacy Policy ("Privacy Policy") applies to Wahed Limited NGA ("Wahed") website at www.wahed.com/nga (the "Website") or the mobile digital application through which the service is delivered (the “Mobile App”). This Privacy Policy covers the collection, processing and other use and disclosure of personal data under the Nigeria Data Protection Act 2023 ("NDPA") and the General Data Protection Regulation ("GDPR"). For the purpose of the NDPA and GDPR we are the data controller/user and any enquiry regarding the collection or processing of your data should be sent to our email: nigeriasupport@wahed.com. For the purpose of this Privacy Policy, the terms "we", "us" and "our" refer to Wahed. "You" refers to you as the user of the Website or the Mobile App. This Privacy Policy has been developed as an extension of our commitment to combine the highest-quality services with the highest level of integrity in dealing with all users of the Website or Mobile App. It is designed to assist you in understanding how we collect, use and safeguard personal information you provide to us and to assist you to make informed decisions. We will treat personal data that you provide through the Website according to this Privacy Policy, the NDPA and the GDPR. This statement will be continuously assessed and updated against new technologies, business practices and our customers' needs. 

Please Review this Privacy Policy Carefully. 

By visiting and/or submitting information to or through this Website or the Mobile App, you agree to be bound by the terms and consent to the collection, use, disclosure, retention and processing of your information as described in this Privacy Policy, the NDPA and the GDPR.

Exclusion

You might find links to third party websites on our website. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Amendments to the Privacy Policy

This Privacy Policy will come into effect on 22nd of September, 2025 (the "Effective Date"). Although most changes are likely to be minor, we may change our Privacy Policy from time to time, to reflect changes to the Website, customer feedback and applicable law and at our sole discretion. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We will at all times notify you of any changes or updates. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Website and/or the Wahed mobile application after any change in this Privacy Policy will constitute your acceptance of the amended Privacy Policy.

This policy is intended to establish prudent and effective guidelines on the ways in which Wahed Limited collects, uses and protects personal information of its users under the Nigeria Data Protection Act. 2023 (NDPA) and General Data Protection Regulation (GDPR). We are committed to protecting your personal information and right to privacy.

Overview

Wahed designed this Privacy Policy to treat your personal information as private and confidential. This policy describes how we collect, use, process, disclose and protect your personal data (Personal Data).

This privacy policy sets out how Wahed treats personal data we collect from you, provided to us, and it will be processed by us. Kindly review this Privacy Policy carefully to understand our approach and praxis concerning your personal data and how we treat it. By assessing or using our services, Mobile app or Website, you agree to this Privacy Policy and our Terms of Use.

Consent

Wahed requires your explicit consent to collect and process your Personal Data where consent is the lawful basis for processing under the Nigeria Data Protection Act, 2023 (NDPA) and, where applicable, the General Data Protection Regulation (GDPR). By consenting to this Privacy Policy, you acknowledge and agree to the collection, use, disclosure, retention, and processing of your Personal Data as described herein.

If we request Sensitive Personal Data (such as biometric information), you will be notified of the purpose and manner of use at the time of collection, and your explicit consent will be obtained before such processing takes place.

You may withdraw your consent at any time by contacting our Data Protection Officer at nigeriasupport@wahed.com. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal. For further details, please refer to the Withdrawal of Consent section of this Policy.

Conditions for Processing or Collecting Personal Data

Wahed or any third party acting on its behalf shall only process your Personal Data if at least one of these conditions are met:

• Consent: this refers to any freely given, specific, informed, and unambiguous indication through a statement or a clear affirmative action that signifies your agreement to the processing of your Personal Data by Wahed. Wahed does not intend to seek consent that may engender direct or indirect propagation of atrocities, hate, criminal acts, and anti-social conducts.
• Contract: processing is necessary for the performance of a contract or entering into a contract at your request.
• Legal obligation: processing is necessary for compliance with a legal obligation to which Wahed is subject.
• Vital interest: processing is necessary to protect your vital interests or those of another natural person.
• Public interest: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Wahed.
  

Personal Data We Collect

We collect and process personal data that you provide directly to us, data generated by your use of our Mobile Application or Website visits, and information obtained from authorised third parties. This includes:

• Identification Data: full name(s), date of birth, government-issued identification numbers (including Bank Verification Number (BVN) and National identification number (NIN)), and copies of official documents such as a passport, government-issued identity card, driver’s licence, voter’s ID or national ID card.
• Biometric Data:
  
  • Device-native biometrics (fingerprint or face recognition): used solely for secure login. This data is stored only on your device within its secure hardware. Wahed does not collect, store, or transmit this data.
  • Facial orientation and expression data: captured during liveness checks, confirming that the user is a real person. This data is used exclusively for real-time analysis during the verification process. It is transmitted securely to our authorised identity verification provider to carry out these checks.
  • Selfie images for identity verification (KYC): transmitted securely to our authorised identity verification provider for compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations. The face image is securely stored by our authorised identity verification provider on their servers for a period of ninety (90) days. This period is set by default for audit purposes.
• Contact Data: residential and postal address, e-mail address, and mobile number.
• Financial Data: bank account details, debit or credit card numbers, transaction history, transaction time, account name, and payment information, value of the transaction in Naira, photos and other information you attach to your transaction.
• Demographic Data: gender, date of birth, zip code, and related attributes.
• Technical and Device Data: IP address, browser type, operating system, device identifiers, and geolocation derived from GPS or Wi-Fi.
• And we record your discussion with us if you contact us or we contact you.

Certain personal Information such as genetic and biometric, race or ethnic origin, religion or similar beliefs, health status, sex life, political opinions or affiliations, trade union memberships or other information prescribed by the commission is characterized as sensitive (“Sensitive Personal Data”) and subject to stricter regulation than other personal information. Before providing it to us, we urge you to carefully consider whether to disclose your Sensitive Personal Data to us. If you do provide Sensitive Personal Data to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy.

Use of Facial Data

When you use our identity verification feature, the Wahed Mobile App captures your facial orientation and expression data (for liveness) and your facial image (or selfie) through your device’s camera systems via the SDKs provided by our authorised identity verification provider.

Liveness Data:

• What is collected: face 3D spatial orientation and facial expressions.
• Purpose of collection: this is exclusively used for real-time analysis during the verification process to confirm that the selfie being taken is of a live user, for the purposes of authentication and fraud reduction and it is not stored. Its usage is strictly limited to the liveness detection function.
• Storage and sharing: it is transmitted securely to our authorised identity verification provider to carry out these checks. The spatial orientation/facial expression data is not submitted by our authorised identity verification provider to any third or first parties.

Once liveness is verified, the user’s face image (or selfie) is captured.

Selfie Data: 

• What is collected: a face image (selfie).
• Purpose of collection: the user’s face image is captured to authenticate the identity of the user.
• Storage and sharing: The face image is retained by our authorised identity verification provider, which is securely stored on their servers for a period of ninety (90) days. This period is set by default for audit purposes.

Use of True Depth API

Our authorised identity provider’s SDK utilizes the TrueDepth API to detect faces on the device for liveness detection, confirming that the user is a real person. The TrueDepth data is used exclusively for real-time analysis during the verification process and is not stored. Once liveness is verified, we proceed to capture the user’s facial image. Importantly, TrueDepth data is never persistently stored on the user’s device nor transmitted outside the device. Its usage is strictly limited to the liveness detection function.

Non-Personal and Technical Information

In addition to the Personal Data described above, we collect certain non-personal or technical information when you access or use our mobile application or website. This may include:

• Technical Data: browser type, internet service provider, IP address, operating system, and web pages visited.
• Usage Data: information about what you have searched for and viewed while using the Services.
• Marketing Preferences: records of your decision to subscribe to or withdraw from receiving marketing communications.
• Metadata: information related to items you upload or share, such as the date, time, or location where a photograph or video was taken.
• Location Data: derived from GPS, Wi-Fi, or other device signals, to support compliance requirements and tailor onboarding flows regionally.
• Other Derived Information: information made available by you or others that may indicate the current or prior location of a user.

This information is collected automatically through cookies, device identifiers, SDKs, and similar technologies, and is used to:

• Ensure secure onboarding and compliance with applicable KYC/AML obligations;
• Strengthen authentication and fraud-prevention measures;
• Improve the design, functionality, and performance of our Services; and
• Enhance the overall user experience.

How We Collect Information

The types of information we collect and how we process it depend on how you use and access our Services. Information may be collected in the following ways:

1. Directly from You
   
   1. When you create an account to use our Services, complete onboarding, submit identity documentation, or contact us for help or information.
   2. When you voluntarily provide Personal Data through our mobile application or website.
2. Automatically through Use of Our Services
   
   1. Certain technical and usage data are automatically collected when you interact with our website or mobile application, including IP address, device type, operating system, browser type, geolocation, page views, clicks, and navigation history.
   2. This information may be gathered using cookies, server logs, SDKs, and similar data collection tools, as described further below.
3. From Social Media (Optional)
   
   1. If you choose to connect your Wahed account through a social media platform (such as Facebook Connect), we may receive information from that platform in line with your privacy settings.
4. From Business Partners and Service Providers
   
   1. Trusted third parties engaged to support our business operations — such as identity verification providers, KYC/AML service providers, cloud hosting partners, authentication providers, SMS gateways, and payment processors — may collect Personal Data about you through our Services and share it with us under strict confidentiality and security obligations, unless mentioned otherwise in this Policy.

We may combine the information collected from these sources and use the combined data as described in the How We Use Your Data section of this Policy.

Cookies And Data Collection Tools

Our Services use cookies and other similar tools to enable secure functionality, improve performance, and analyse usage.

Categories of Cookies:

1. Essential Cookies: Necessary for login, navigation, and core security. These cannot be disabled.
2. Analytics Cookies: Help us understand how users interact with our Services by collecting anonymous usage data.
3. Marketing Cookies: Track browsing behaviour to deliver tailored content and advertising. You may opt out of these.

User Consent and Management:
By using our Services, you consent to the use of cookies as described. You may:

• Accept All Cookies (enable all categories).
• Reject Non-Essential Cookies (allow only essential cookies).

Other Data Collection Tools:
In addition to cookies, we may use tools such as web beacons and server logs to help improve your experience. These tools may capture details about the device used to access the Services, including operating system type, browser type, domain, country, and time zone.

Such information does not ordinarily identify you personally and is primarily used for statistical analysis, fraud detection, security monitoring, and performance improvement.

How We Use Your Data

We may process the information we collect/you provide to us in accordance with the Nigeria Data Protection Act, 2023 (NDPA) and GeneralData Protection Regulation (GDPR). This information is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purpose(s): 

• Verifying your identity and carrying out Know-Your-Customer (KYC) and anti-money laundering checks;
• Providing, managing, and improving our Services;
• Securing accounts through authentication, liveness detection, fraud prevention measures and to detect illegal activities; or for archival and backup purposes in connection with the provision of services;
• Processing transactions and maintaining accurate records;
• Complying with legal, regulatory, and tax obligations;
• To operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• To communicate with you and notify you about any changes to our website or Mobile Application, such as improvements or service/product changes, that may affect our services; 
• Communicating with you about your account and updates to our Services;
• To better understand how users access and use the Website and Mobile application, for the purposes of trying to improve our services and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users’ usage of the Website or the App;
• To help us develop our new products and services and improve our existing products and services;
• To provide users with advertising and direct marketing that is more relevant to you;
• To enforce any other applicable policies; and
• To assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Website or the App.

Without your personal data, we may not be able to provide or continue to provide the Services you require.

Automated Decision-Making and Profiling

We may use your Personal Data as part of automated processing activities designed to provide, improve, and tailor our Services. These activities may include:

• Real-time onboarding and identity verification (KYC/AML);
• Risk and suitability analysis through questionnaires that take into account your financial objectives, and risk tolerance;
• Portfolio recommendations and product eligibility assessments; and
• Client segmentation and some fraud prevention checks.

These processes may result in decisions about you that affect the services we provide, including the type of portfolio or product we recommend, or the terms under which they are offered. However, these recommendations are not binding. You remain free to override the suitability profile and select a different investment option where permitted.

You have the right not to be subject solely to automated decision-making that significantly affects you. You may object to, or request human intervention in, such decisions at any time by contacting us using the details in the Contact Information section of this Policy. Please note that if you withdraw consent to certain automated processes, this may limit or prevent our ability to provide Services to you.

Sharing and Disclosure of Personal Data

We may disclose or share your Personal Data with third parties which include our affiliates, employees, officers, service providers, agents, and partners, only as permitted by law and as may be reasonably necessary for the purposes set out in this policy. Wahed may disclose Personal Data to or share it  with the following parties:

• Wahed may disclose Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries in order to perform services requested or functions initiated by users. In addition, we may disclose Personal Data in order to identify a user in connection with communications sent through the Website. 
• With third-party service providers performing services on our behalf; these third party service providers may include: cloud service providers, technology providers, identity verification providers, broker dealer/custodians and other third parties that may be required for the provisions of our services as might be deemed necessary for our function. These services may include but are not limited to identity verification, liveness detection, authentication, SMS delivery, cloud hosting, and payment processing. These providers act strictly as data processors under Wahed’s instructions and are bound by confidentiality and security obligations.
• We share information, including Personal Data, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.
• With professional advisers, auditors, or contractors under confidentiality obligations where required for legitimate business purposes.
• We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Data as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Data as required to pursue available remedies or limit damages we may sustain.
• We may share Personal Data about you in an aggregated form, that is, in a statistical or summary form that does not include any personal identifiers, with third parties in order to discover and reveal trends about how users like you interact with our services.
• We may transfer information, including your Personal Data, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company {in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

Wahed may share Personal Data with third parties if you have given us your consent to do so or:

• in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or in order to enforce or apply our Website Terms and other agreements, but we will endeavor to minimise such disclosure to only that reasonably necessary and, where possible, to provide you with notice of such disclosure; and/or
• to protect the rights, property, or safety of Wahed, the Website, our users and any third party we interact with to provide the Website.

Wahed does not sell personal data to any third party.

Transfer of Personal Data Abroad

Any transfer of personal data outside Nigeria shall be conducted in accordance with the NDPA and subject to adequate safeguards. Such transfers may occur where:

• The receiving country or organisation ensures an adequate level of data protection.
• You have explicitly consented to the transfer after being informed of potential risks.
• The transfer is necessary for performance of a contract with you, or to take steps at your request.
• The transfer is required for the conclusion or performance of a contract in your interest.
• The transfer is necessary for important public interest, legal claims, or vital interests.

In all cases, Wahed ensures that contractual and technical measures are in place to maintain the confidentiality and security of your data.

Data Retention, Storage, and Security

We retain your data for a period of seven (7) years. We also retain Personal Data from closed accounts to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation and other actions permitted by law.

The security of your Personal Data is important to us. We shall take all appropriate security and organizational measures to prevent unauthorized access to, alteration of, disclosure of, accidental loss, and destruction of personal data under our control.

However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Website are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password-protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the services is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Your Rights

Under the NDPA, you have the following rights in relation to your Personal Data. You may exercise these rights at any time by contacting our Data Protection Officer using the details in the Contact Information section.

1. Right to be Informed
   You are entitled to clear, transparent information about how and why we process your Personal Data, the categories of data involved, our lawful bases, recipients or categories of recipients, retention periods, and any transfers to third countries together with the corresponding safeguards.
   ‍
2. Right of Access
   You may obtain confirmation as to whether we process your Personal Data and receive a copy of such data, together with the information required by NDPA, without unreasonable delay. Requests may be made via email to nigeriasupport@wahed.com or by calling +17652123831.
   ‍
3. Right to Rectification
   You may require us to correct inaccurate Personal Data and to complete incomplete data without undue delay.
   ‍
4. Right to Erasure (“Right to be Forgotten”)
   You may request the deletion of your Personal Data where, for example, the data are no longer necessary for the purposes collected, you have withdrawn consent and there is no other lawful basis, or the data have been unlawfully processed. We may continue to retain certain data where retention is required for legal, regulatory, tax, or compliance purposes, or for the establishment, exercise, or defence of legal claims.
   ‍
5. Right to Restrict Processing
   You may request that we restrict processing of your Personal Data in specific circumstances (for example, while we verify accuracy or where processing is unlawful and you request restriction rather than erasure). During restriction, we will store your data but not otherwise process it except for legal claims or with your consent.
   ‍
6. Right to Object
   You may object at any time to processing based on legitimate interests, including profiling on that basis, and we will cease such processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is required for legal claims. You may object at any time to processing for direct marketing, and we will stop such processing immediately.
   ‍
7. Right to Data Portability
   Where processing is based on consent or on a contract and carried out by automated means, you may request to receive your Personal Data in a commonly used, machine-readable format and/or request that we transmit those data to another data controller where technically feasible.
   ‍
8. Right to Withdraw Consent
   Where we rely on your consent, you may withdraw it at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal, and we may continue processing where another lawful basis applies. Please refer to the Withdrawal of Consent section for more information.
   ‍
9. Rights in Relation to Automated Decision-Making (including Profiling)
   You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Where such processing is used, you may request human intervention, express your point of view, and contest the decision.
   ‍
10. Right to Lodge a Complaint
    You may lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe our processing violates NDPA. We encourage you to contact us first so we can address your concerns promptly.

How to Exercise Your Right

To exercise any of your rights, you may contact our Data Protection Officer using the details provided in the Contact Information section of this Policy. For security, we may ask you to verify your identity before fulfilling your request, for example by confirming the email address associated with your Wahed account or other reasonable means. When submitting a request, please provide:

1. Your full name; and
2. A clear description of the right you wish to exercise.

If we decline a request, we will provide a clear explanation of our reasons and inform you of your options to escalate the matter, including to NDPC.

Withdrawal Of Consent

You are not obliged to permit us to process your personal data. If you do not wish us to do so, you may withhold your consent by writing to us at nigeriasupport@wahed.com. If you have previously given your consent for us to process your data for a specific purpose, you may withdraw or amend that consent at any time by providing a written notice to us. Such withdrawal or variation will not affect the lawfulness of processing carried out prior to our receipt of your notice.

Links to Third Party Websites and Services

You may use the Website to link to third party websites. If you use any link, you leave the Website. Your use of any third party website will be subject to that third party's terms and conditions. We do not monitor the content of third party web sites and any links provided are for your convenience only.

A link to any other website does not mean that we guarantee, approve or endorse the information or products available or the quality or accuracy of information presented on it.

We do not operate or control and have no responsibility for the information, products and/or services found on any external websites, unless expressly stated on such external websites. Nor do such links represent or endorse the accuracy or reliability of any information, products and/or services provided on or through any external websites, including, without limitation, warranties of any kind, either express or implied, warranties of title or non-infringement or implied warranties of merchantability or fitness for a particular purpose. You assume complete responsibility and risk in your use of any external sites.

If you decide to visit a third party website, you are subject to its privacy policy and practices, not this privacy policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

Privacy of Children

Wahed respects the privacy of children. We do not knowingly collect names, email addresses or any other personally identifiable information from children. We do not knowingly market to children nor do we allow children under 18 to open online accounts. 

The Wahed app will only allow users that are aged 18 or above to register as mentioned on this document. If false information is entered by the client, this will be checked by our authorised identity verification provider as well as our internal KYC teams and the account will be blocked from signing up further.

Consequently, Wahed shall not be liable for any use or processing of Personal Data of persons under the age of 18.

If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

Governing Law

This Policy is made pursuant to the Nigeria Data Protection Act 2023 (NDPA), Global Data Protection Regulation (GDPR) and other relevant Nigeria laws and regulations. Where any provisions of this Policy is deemed inconsistent with a law or regulations, such provisions shall be subject to the overriding law or regulations.

Amendments to the Privacy Policy

We may update our privacy policy from time to time, to reflect changes to the mobile Application or Website, customer feedback and applicable rules and regulations. We will at all times notify you of any changes or updates.

Contact Information

We welcome any queries, comments, or concerns about this Privacy Policy or our data protection practices. You may contact our Data Protection Officer at:

• Email: nigeriasupport@wahed.com
• Telephone: +17652123831

If you are dissatisfied with how we collect or process your Personal Data, you also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), the competent supervisory authority for data protection in Nigeria:

• Email: info@ndpc.gov.ng or dpo@ndpc.gov.ng 

This Privacy Policy will be reviewed on an annual basis, or sooner where required to reflect changes in law, regulation, or our business practices.

This website, whose home page is located at URL https://www.wahed.com (the “Website’) and the Wahed App (the “App”), is an online information service provided by us, subject to your compliance with these terms and conditions (“Terms and Conditions”). For the purpose of this user agreement, the terms "we", "us" and "our" refer to Wahed. "You" refers to you as the user of the Website or the Mobile App. These Terms and Conditions apply to the entire content of the Website, Mobile App and to any correspondence by email between you and us. You should read these Terms and Conditions carefully before using the Website or Mobile App. By using the Website or Mobile App, you indicate that you accept these Terms and Conditions. If you do not wish to be bound by these Terms and Conditions, do not access or use the Website or Mobile App.

1. Introduction

These Terms and Conditions are issued by Wahed Limited whose registered office is located at Plot 294, Leventis Close, Central Business district Abuja, Nigeria. When we use "we", “us" or "our"; in these Terms and Conditions we are referring to Wahed Limited and any of our affiliates. When we use “you” or “your”, we are referring to you, the user accessing this Website or App.

You will be bound by these Terms and Conditions where you are an individual or a legal person accessing a page of the Website or “Mobile App”, whether via the homepage or not. Where you are accessing the Website or Mobile App in the course of employment you act as your employer's agent; your acceptance of these Terms and Conditions is deemed acceptance by your employer of these Terms and Conditions and any reference to “you” shall be deemed to include your employer. If you have any questions about this agreement, please contact us via email at “nigeriasupport@wahed.com”

We may modify these Terms and Conditions from time to time, and such modifications shall be effective immediately upon posting on the Website or the Mobile App. You should check these Terms and Conditions periodically so that you are aware of such modifications, as your continued access or use of the Website will demonstrate your acceptance of the Terms and Conditions as modified. If you do not accept any modifications then do not access or use the Website.

You will be able to access material on most areas of the Website without going through a registration process.

2. Statutory Rights

Nothing in these Terms and Conditions will affect your statutory rights.

3. Copyright and Intellectual Property Rights

This website and Mobile App is owned and operated by Wahed Limited. All of the content featured or displayed on this website including, but not limited to, text, graphics, photographs, images, moving images, sound, illustrations and software ("Content") is owned by Wahed Limited. All elements of Wahed website and Mobile App including, but not limited to, the general design and the Content, are protected by copyright, moral rights, trademark and other laws relating to intellectual property rights. This website and Mobile App, Its Content and all related rights shall remain the exclusive property of Wahed Limited or its licensors unless otherwise expressly agreed.

All material contained in this website or Mobile App, provided by Wahed Limited, is only intended for the lawful use by its customers, employees and members of the general public. The material may not be copied, republished, incorporated into another website or reproduced (whether by linking, framing or any other method), transmitted, distributed, uploaded, posted, used to create a derivative work or exploited in any other way without the written consent of Wahed Limited.

4. Access to the Website and Wahed Mobile App

We endeavor to make the Website and Mobile App available uninterrupted and fault free. However, we will not be liable if for any reason the Website or Mobile App is unavailable at any time or for any period. Access to the Website and App  may be suspended temporarily and without notice in the case of system failure with maintenance or repair or for any other reason.

5. Your obligations

You must not violate any applicable national or international law in accessing or using the Website or Mobile App.

You must not manipulate or otherwise display the Website by using framing or similar navigational technology. You may not link to the Website without our prior written consent.

You are responsible for obtaining and maintaining all telephone, computer hardware, software and other equipment needed for access to and use of the Website or Mobile App and for meeting all costs associated with that equipment.

You are prohibited from uploading, posting or transmitting to or from the Website any material:

• a) that is threatening, defamatory, obscene, indecent, seditious, offensive, pornographic, abusive, liable to incite racial hatred, discriminatory, menacing, scandalous, inflammatory, blasphemous, in breach of confidence, in breach of privacy or which may cause annoyance or inconvenience; or
• b) for which you have not obtained all necessary licenses and/or approvals; or
• c) which constitutes or encourages conduct that would be considered a criminal offence, give rise to civil liability, or otherwise be contrary to the law with; or
• d) that infringes our or any other third parties patent, trademark, trade secret, copyright or other proprietary rights, in Nigeria or any other country in the world; or
• e) which is technically harmful (including, without limitation, computer viruses, logic bombs, Trojan horses, worms, corrupted data or other malicious software or harmful data or code).

You may not misuse the Website (including, without limitation, by hacking).

Please note that we shall aim to cooperate fully with any law enforcement authorities or court orders requesting or directing us to disclose the identity or locate anyone posting any material in breach as stated above.

You shall indemnify us, our affiliates, suppliers and employees from and against all losses, expenses, damages and costs (including legal fees) arising as a result of your breach of these Terms and Conditions, your negligence or otherwise as a result of your use of the Website or Mobile App or any of our services.

6. Disclaimers

You assume responsibility and risk for your use of the Website or Mobile App and the Internet generally. It is solely your responsibility to evaluate the accuracy, completeness and usefulness of all opinions, advice, services, merchandise, advertising and other information provided on the Website via a link or on the Internet generally.

You acknowledge that nothing on the Website has been tailored for your particular requirements. We recommend that you always consult an appropriate professional advisor before relying on personal, legal or financial advice provided on the Website. Nothing on the Website or Mobile App constitutes the offering of investment advice.

While we have taken all reasonable steps to ensure the accuracy and completeness of the content on the Website and Mobile App, we disclaim any warranties, undertakings, or representations (express or implied) to the fullest extent permitted by law, including (without limitation) regarding the accuracy, availability, or completeness of any content or materials. Use of the Website or Mobile App from outside Nigeria is at your own risk, and you are responsible for complying with local laws.

We may make changes to the material on the Website and Mobile App, or to the products and services described in it, at any time without notice. The material on the Website may be out of date, and we make no commitment to update such material.

Any opinions, advice, statements, offers, advertising, products or other information expressed or made available by third parties on the Website or Mobile App, or via a link, are those of the third party concerned. We neither endorse nor are responsible for the accuracy or reliability of any third party material.

Some of the information on the Website or Mobile App may contain projections or other forward-looking statements regarding future events or our future financial performance. You acknowledge that these statements are only predictions and that the actual events or results may differ materially.

We do not guarantee or warrant that the Website or Mobile App, or any files associated with their download and installation,  will be free of infection or viruses, worms, Trojan horses or other code that manifest contaminating or destructive properties.  You are responsible for implementing adequate safeguards and procedures to satisfy your specific requirements for data security, and for maintaining external means for the reconstruction of any lost data.

We accept full liability to you for: 

• a) death or personal injury caused by our negligence, or 
• b) any fraud or fraudulent misrepresentation we commit; or
• c) any other liability which cannot be excluded or limited under applicable law.

Nothing in these Terms and Conditions will exclude or limit that liability.

Other than any liability to you under this section, we accept no liability however caused (to the maximum extent permitted by applicable law) arising out of the use of or access to this website and our Mobile App (which includes without limitation) any errors or omissions contained in this website or Mobile App, or if the website or Mobile App is unavailable and we shall not be liable, whether directly or indirectly, for:

• a) any business loss including loss of revenue, profits or anticipated savings (whether such  losses are a direct or indirect result of our default);
• b) loss of goodwill or reputation; or
• c) economic losses (including without limitation loss of revenues, data, profits, contracts, use, opportunity, business or anticipated savings);
• d) any loss which was not reasonably foreseeable to us when you accessed or used the Website or Mobile App (even if it results from our failure to comply with these Terms and Conditions or our negligence);
• e) any other loss or damage whatsoever which you suffer (even if it results from our failure to comply with these Terms and Conditions or our negligence, and even if it was foreseeable to you and us when you accessed or used the Website or Mobile App); arising in connection with your use or inability to use the Website or the Mobile App; any information, or transactions provided on the Website or App; via a link; or due to any delay in the provision of such information or service.

7. Links

You may use the Website or Mobile App to access links to third-party websites. lf you follow any such link, you will leave the Website or Mobile App, and your use of any third-party website will be subject to that third party’s terms and conditions. We do not monitor the content of third-party websites, and any links provided are for your convenience only.

8. Information you provide

We respect and are committed to protecting your privacy. Our Privacy Policy informs you how your personal information is processed and used.  We will use reasonable endeavours to ensure that your personal information is handled in accordance with our Privacy Policy.

Other than your personal information, which is covered by the Privacy Policy, any material you transmit or post to the Website shall be considered non-confidential and non-proprietary. We shall have no obligations with respect to such material. We and our designers shall be free to copy, disclose, distribute, incorporate and otherwise use such material and all data, images, sounds, text and other things for any and all commercial or non-commercial purposes.

9. Governing law

These Terms and Conditions shall be governed by, and construed in accordance with, the laws in Nigeria. Any court proceedings must be brought in the Nigerian courts or pursuant to the terms of your client agreement.

10. Assignment

These Terms and Conditions are personal to you. You shall not assign or transfer to anyone any of your rights or obligations under these Terms and Conditions without our prior written consent.

Nothing in these Terms and Conditions shall be deemed to grant any rights or benefits to any person other than you or us.

11. Waiver

Any waiver by either you or us of any right under these Terms and Conditions will be confined to the circumstance in which it is given. It shall not affect the subsequent enforcement of the same right or the enforcement of any other right.

12. Severability

If any part of these Terms and Conditions is for any reason found by a court or any other authority of competent jurisdiction to be void or otherwise unenforceable, that part shall be deemed omitted from these Terms and Conditions. The remainder of these Terms and Conditions shall remain in full force and effect to the maximum extent permitted by law.

13. Entire agreement

These Terms and Conditions contain all our commitments and constitute the entire agreement between you and us in relation to your use of the Website and the Mobile App. No other statement we make, including statements in any brochure or promotional literature published by us, may be incorporated into this agreement or have any legal effect.

14. Registration Information

In order to avail our services, you will be required to create an account and select a username and password. You may be asked to provide some personal information as well. You agree at all times that all the information you provided to us is accurate and complete, and you will be obliged to regularly update this information as necessary to keep it current.. You further agree not to impersonate any other individual or entity, misrepresent affiliation with any person/entity, or hide any required information from Wahed Limited for legitimate  purposes. We agree to protect the information you provide to us, in accordance with our privacy policy. Failure to comply with these obligations  will constitute a breach of our terms and may lead to the termination of your account.

For security reasons, you must not share your registration details (such as username, password, or screen name) with anyone. You agree to notify us immediately of any unauthorised use of your account. If you do share your login information, we may reasonably assume that any activity carried out using your credentials has been authorised by you.

15. Service Communications and alerts

When you create an account with Wahed, you automatically subscribe for various types of alerts. You can customize or deactivate such alerts by changing your account settings.

16. Termination/Access restriction

You and/or we may terminate these Terms and Conditions at any time, without prior notice, for any reason. All provisions of these Terms and Conditions which grant continuing rights or impose continuing obligations shall survive termination of these Terms and Conditions.

We may, in our sole discretion, terminate your access to the Website or Mobile App at any time, without notice.

17. Internet Communications

To maintain the security of its systems, protect its staff and detect fraud and other crimes, Wahed Limited reserves the right to monitor all internet communications–including web and email traffic–into and out of its domain.Such monitoring may include, without limitation, checks for viruses or other malicious code, unlawful or unauthorised content, criminal activity, and material that may be considered offensive in any form.

18. Contact us

Calls may be recorded for training and security purposes. You may contact us by sending an email to nigeriasupport@wahedinvest.com or by calling 0*****.

Introduction

These are our standard client agreement terms and conditions (“Terms”), and it sets out the basis on which Wahed Ltd. (“Wahed”), a subsidiary of Wahed Inc. with its registered address at 16192 Coastal Highway, Lewes, Delaware 19958, United States of America, provides you with its Robo Advisory services. Wahed Limited is registered in Nigeria with Security and Exchange Commission (SEC), with its registered address at Plot 294, Leventis Close, Central Business District FCT, Abuja

In order to perform the trade execution for and on your behalf, Wahed has appointed a broker. Wahed engage a counterparty to serve as its broker as specified in Schedule 1 hereto or as we may advise you of in writing from time to time. A broker's role is to provide execution facilities for trades made on your Account. Your relationship with a broker is governed by the requirements set out in Section 2 below.

References to “we”, “us”, or “our” are references to Wahed. References to “Services” are to the services provided by us. “Client”, “you” and “your” refer to any person operating or intending to operate an account with us.

Capitalised terms not defined in these Terms shall have the same meaning attributed to them in the relevant Rules of Securities and Exchange Commission (SEC).

These Terms are split into sections, in which Section 1 deals with matters specific to Wahed’s Services to you, Section 2 deals with matters specific to the broker services to you, and Section 3 deals with general matters between you and us.

It is important you read these Terms carefully before making any investments, because we will rely on them in all our dealings with you. You should also print off a hard copy, and then keep it safe for future reference.

These Terms will come into effect on the day an account is opened with Wahed and is ready to receive trading instructions from Wahed based upon the ‘Investment Policy Statement’ recommended by Wahed to you.

Section 1: Wahed Ltd

This section sets out the basis on which Wahed is carrying on robo adviser service for you.

Who regulates us?

Wahed Ltd is registered and regulated by the Securities and Exchange Commission (SEC) and the full SEC Register is available on the SECs website which can be accessed here SEC Capital Market Operator Search

Wahed is authorised and regulated by the Securities and Exchange Commission to carry out the Capital Market Operators Activities in Nigeria as a Robo Advisory to facilitate the following services:

• Shari’a Compliant Regulated Activities;
  
  • Robo Advisory Services;

Accordingly, the Regulated Activities and entire business carried out by Wahed will be conducted in accordance with Shari’a and, as such, all references to the business activities and services provided by Wahed in these Terms shall be deemed to be conducted in accordance with Shari’a principles.

• Wahed has appointed Shari'a Review Bureau W.L.L, licensed by the Central Bank of Bahrain under License No. ANC/008 dated 2 July 2007, as its full time Shari'a advisor and administrator of our Shari'a Supervisory Board. The Shari’a Supervisory Board is made of the recognised members (the “Scholars”). To know more about the current Shari'a Supervisory Board composition please contact on nigeriasupport@wahed.com.

The composition of the Shari’a Supervisory Board and the Scholars serving therein may change from time to time without prior notice.

The Scholars have reviewed and approved our securities, systems, and technologies. The Shari’a Advisor and Scholars also review all our investments annually to ensure that all returns are permissible in accordance with the Shari’a.

Wahed provides a service whereby Wahed will manage your investments through our broker on a discretionary basis (the “Service”). This means that Wahed manages your investment portfolio in accordance with an agreed investment mandate. This mandate will be explained to you in your ‘Investment Policy Statement/Personal Investment report’, made available to you through the Wahed mobile application platform (“the App”) after you sign up.

Wahed delegates the right to hold client funds and the ability to engage in securities transactions on behalf of clients to a broker, but Wahed will remain overall responsible to the client and the subject for any complaints.

Other than specifically provided in these Terms, our SEC license does not restrict us from providing any of the services outlined to you.

Client Classification

Wahed as a duly registered Capital Market Operator under the securities and Exchange Commission (SEC) Nigeria, we are authorised to provide services to all categories of clients, namely: Retails Investors, High Net Worth Investors (HNIs) and Institutional Investors. 

Scope of Services

Wahed Robo advisory platform provides automated management services for all our ‘Client Assets’ (which is inclusive of your funds and securities held for investment purposes) that shall be designated by deposit or transfer into Wahed’s or the broker’s Nominee account held with a local bank in Nigeria, on behalf of Wahed (the “Account”). The deposit into the Nominee account will be made in NGN. You authorise Wahed to perform the Services as indicated in these Terms in accordance with your financial objectives, and risk tolerance as specified through your registration in the App.

You hereby grant Wahed discretionary authority in connection with the Account to be established in broker’s name (Capital Asset Limited) and, in such Account, to purchase or sell securities or other investment products, to sell, manage, and reinvest the amount or type of assets or investments, to instruct the broker (see Schedule 1), trustee, or the Custodian (as applicable) to execute orders and/or to receive, accept and deliver securities or other assets, and to implement any investment decisions for the Account, all without prior consultation with you.

This discretionary authority granted to Wahed includes the authority to hire or retain other investment advisers or brokers to exercise any authority granted to Wahed under these Terms, to remove, terminate or replace any such other investment adviser or broker, and to allocate assets belonging to you and, subject to these Terms, between or among any other such advisers, assets and Accounts that are subject to these Terms. This discretionary authority is subject to such other reasonable limitations that you may request upon written notice to Wahed and which Wahed agrees to.

You may revoke the authority granted to Wahed at any time by submitting a written notice to Wahed at nigeriasupport@wahed.com. Other than specified herein, Wahed shall have no authority under these Terms to take or have possession of any assets in the Accounts nor to direct delivery of any securities or payment of funds to itself or direct disposition of such securities or funds to any person other than you. You acknowledge and understand that the Services to be provided by Wahed under these Terms are limited to the management of the assets in the Accounts.

What is Wahed’s discretion when managing your investments?

Wahed will manage your assets in the Account, on a discretionary basis, in accordance with your investment mandate as specified in the App and these Terms. This means that Wahed will, normally acting as your agent, have discretion in respect of your portfolio to enter into any kind of transaction on your behalf without your consent, in line with your agreed investment mandate, using a broker or agent. Therefore, Wahed's discretionary investment management activities are limited to the parameters contained in the Client's Investment mandate.

Wahed also has the right to change your investments without your consent should circumstances change, for example you withdraw your money so that what is left is not sufficient to justify the strategy being used. Wahed may also exercise this right if the nature of your investments change to the point that they no longer match with the requirements of your investment mandate.

Suitability Assessment

Unless otherwise agreed in writing, Wahed will consider suitability for you before first recommending a financial product or investment arrangement.

We will not consider suitability for you if:

• we have classified you as a Market Counterparty;
• we are merely promoting a financial product or a financial service to you; or
• you instruct us to arrange an execution-only transaction.

Under such circumstances, you understand and agree that we will not have any duty to advise you in respect of either that execution-only transaction or any subsequent investment arrangement acquired under that execution-only transaction and you are responsible for assessing the suitability of that execution-only transaction in the context of your investment objectives.

Using the App, you will be required to provide information, including personal information, so that Wahed can assess whether investing is suitable for you. Based on your responses, Wahed may allow you to proceed with opening an account on the App. You must provide complete and accurate answers to the best of your ability, as Wahed relies on this information to assess suitability.

(a) Risk & Suitability Methodology

Wahed employs a structured framework to evaluate investor suitability and risk tolerance. This ensures a consistent mapping between investor characteristics and recommended portfolios, tailored to the specific constraints and opportunities of the Shariah-compliant investment universe in Nigeria. The investment advice is delivered through a fully automated, rule-based system. All portfolio recommendations are generated directly by Wahed’s app, based on the client’s responses to a structured risk and suitability questionnaire. The system applies fixed scoring logic to determine the client's risk profile and assigns a corresponding Shariah-compliant model portfolio without any human modification to this matching process.

In line with Clause 16 of the SEC Robo Advisory Guidelines, Wahed is exempted from collecting full financial information (such as employment status, income, liabilities, or dependent obligations).

Wahed only asks questions around financial objectives and risk tolerance of the client. You are advised to carefully review the portfolio recommendation and consider seeking additional advice if you have complex financial needs not captured through the automated questionnaire.

(b) Scoring Framework

The Risk and Suitability Questionnaire is designed to capture critical dimensions of your risk appetite and product suitability. These dimensions may include:

• Demographics
• Investment Horizon & Objectives
• Income, Savings, and Income Stability (indicating risk capacity)
• Investment Experience & Knowledge
• Psychological Attitude with Risk & Likely Behaviour in a Downturn (indicating risk willingness)

Each answer is assigned a numerical score, reflecting the client’s ability and willingness to bear risk. Some responses also function as Knock-out Questions (e.g., where the investor indicates insufficient liquidity), which may temporarily restrict access to investment until their circumstances improve or a reassessment is completed.

A client’s risk tolerance (or risk appetite) establishes the amount of risk that a client is willing to take. A client’s risk capacity indicates how much the client can afford to lose before it has a material impact on their standard of living. Risk capacity and risk tolerance (or risk appetite) may not always be aligned. A client may wish to take considerable risk, but it may not be affordable. With this questionnaire Wahed intends to ensure, within limitations, whether a client is able to financially bear any related investment risks consistent with their investment objectives, demographics, investment time horizon, and other information that the client provides via this questionnaire.

The historical standard deviation is used as a measure of volatility or risk. The scores from the questionnaire are used to determine the risk suitability of the client, and hence the volatility bucket that the client might have the capacity to tolerate. Wahed’s obligation to assess the client's suitability for the product cannot be waived. Wahed, thus, makes an automated portfolio recommendation to each client based on the methodology described above. The client nevertheless reserves the right to select a portfolio different from the one suggested by the scoring mechanism, at their own discretion, after being shown a disclaimer warning them of the divergence from Wahed’s recommendation. The Services of Wahed will depend upon the accuracy and completeness of the information that you provide. 

You therefore agree to provide complete and accurate information and documents that Wahed requires, in Wahed’s sole judgment, in order to provide the Services hereunder.

(c) Portfolio Allocations

Each portfolio maps to a standard deviation band, estimated from historical annual returns of the instruments used within each risk profile. These bands serve both as a portfolio design constraint and a monitoring tool during ongoing suitability assessment and portfolio management.

Wahed reserves the right to refine these bands and weightings as more behavioural and investment data becomes available over time. However, the methodology will always retain a conservative bias to safeguard clients from excessive exposure and protect long-term financial stability.

(d) Assumptions, Limitations, and Risks of the Methodology

As a Robo-Adviser, Wahed’s investment suitability methodology involves programmed logic. The following assumptions, limitations, and risks apply:

Assumptions

• The suitability algorithm assumes that all responses provided by the investor in the onboarding questionnaire are truthful, complete, and reflect current circumstances and risk preferences.
• The methodology assumes that investor attitudes toward risk, time horizon, and financial capacity do not change significantly over short periods unless explicitly updated.
• Portfolio allocations are designed based on expected standard deviation and return profiles derived from annual five (5) year historical observations. These may not hold during future periods of market stress.

Limitations

The assessment should be regarded as a point-in-time snapshot rather than a dynamic reflection of the client’s ongoing situation. Subsequent changes in circumstances are not automatically incorporated unless reported to Wahed, and even then are subject to the limitations of this Agreement. Accordingly, the scoring is indicative guidance only and not a guarantee of suitability or performance. Clients who select a portfolio outside the suggested bucket may assume exposures inconsistent with their assessed financial capacity. Even where the assessment is accurate, it cannot shield clients from losses arising from market volatility, systemic shocks, or other unforeseeable events.

Despite the structured and robust nature of the scoring logic, it cannot capture every nuance of investor psychology, individual financial or personal circumstances, or sudden behavioural shifts. Clients may provide supplementary information to Wahed (for example, via email), but such inputs may only be partially reflected. The methodology also does not employ machine learning, adaptive models, or statistical inference engines and therefore does not evolve or “learn” from investor behaviour or market outcomes.

Risks

• If an investor responds overly optimistically, they may be placed in a portfolio riskier than they can emotionally tolerate. Though safeguards (such as inconsistency checks) are in place, these cannot eliminate the risk entirely.
• Manual thresholds and fixed score bands, while transparent, may oversimplify real-world complexity and lead to suboptimal portfolio placement in edge cases.
• Since portfolio rebalancing is triggered manually or at set intervals, there is a risk of drift away from the intended risk profile during periods of high market volatility.

Wahed mitigates these risks through conservative portfolio design choices, human oversight of allocations, and regular portfolio monitoring.

(e) Inconsistency Handling

To understand the risk tolerance or willingness to take risk, two questions are asked: Attitude to Losses and Likely Reaction to Losses. These are central to assessing emotional tolerance to market volatility. To control for inconsistencies:

If the difference of the scores of these two questions exceed a certain threshold, an inconsistency is detected. In such cases, the total contribution from these two questions is reduced by the difference, effectively assigning the lower of the two scores. This conservative approach is intended to ensure that  a client is not mistakenly assigned a high-risk profile based on one overly optimistic response. This mechanism ensures investor protection by prioritising conservative risk estimates when inconsistent responses are detected.

Investment Methodology

While using mean-variance quantitative optimisation algorithms is not practicable, considering the sparse asset environment within the Shariah compliant investment universe in Nigeria, a manual allocation strategy is used to construct portfolios that deliver reasonable risk-return characteristics within the mapped distinct volatility bands. The manual allocation strategy uses five year historical data for the funds eligible within the universe.

The construction adheres to the following principles:

• Diversification across asset classes (e.g., Islamic Fixed Income, Equities)
• Alignment with historical risk-return characteristics
• Priority to funds with reasonable AUM and implementation costs

Portfolios are not optimised using Modern Portfolio Theory (MPT) or Efficient Frontier simulations, as these tend to yield unrealistic allocations in markets with limited instruments.

Portfolio Rebalancing Triggers

While portfolios are regularly monitored, rebalancing is triggered under certain conditions, which may include:

• Significant deviation from the volatility band or equity/fixed income ratio drift
• If specific funds are closed, illiquid, or no longer Shariah-compliant
• Cash inflows/outflows
• Significant macro or market volatility events

Portfolios are manually reviewed every quarter to ascertain the need for rebalancing.

Asset Classes

The asset classes represented within the portfolios consist of Shariah-compliant equities and Islamic fixed-income, made available through fund structures that may invest exclusively in one asset class or in a mix of both.

Asset Class Description

Sukuk (Islamic Bond): Sukuk is a type of Shariah Compliant Collective investment scheme that pools money from multiple investors. Sukuks are structured to avoid interest (riba) and instead generate returns from profit-sharing or lease-based arrangement. Investing in Sukuk Instruments e.g. FGN or corporate sukuk listed on NGX or issued privately are overseen by a Shariah Advisory Board (SRB) to ensure compliance. Sukuks provide stable & relatively predictable income, capital preservation and lower volatility. 

Shariah Compliant Equities: Shariah Compliant Equities allow muslim and ethical investors, particularly those seeking halal and ethical investment options to participate  in the stock market without engaging in prohibited (haram) activities. These equities attract investors to earn  competitive returns on their investments from capital appreciation (share capital growth) and halal dividends after any purification of non-permissible income.  

Shariah Compliant Fixed income (Islamic Fixed Income): These instruments in Nigeria allow muslims and ethical investors to invest in asset-backed financing and risk sharing. Asset-backed securities represent ownership in tangible assets, generating shared profits with investors, e.g. Sukuk, Mutual funds with competitive returns on investment.  

Shariah Compliant Fixed return Contract: Ijarah (leasing) and Murabaha (Cost plus sales): Ijarah is the transfer of the usufruct/benefit of a particular property or asset to another party in exchange for a pre-agreed rental for an agreed period. Murabaha is a contract of sale between financier (Investor) and the client for the sale of goods at a price plus margin for investors. From the above asset description, we have designed portfolios that align with specific risk categories. These are tailored to the clients’ responses from the risk assessment questionnaire and structured to target the projected returns on investment.

Risks & Limitations

Portfolio Design Limitations: Wahed does not employ algorithmic trading or dynamic optimisation models. Portfolios are manually constructed and reviewed periodically, which means they may not respond immediately to macroeconomic events or sudden market shocks. Furthermore, recommendations are drawn solely from the current universe of Shariah-compliant investments in Nigeria. This necessarily constrains diversification opportunities and may result in allocations that differ from those of more broadly defined global portfolios.

All investments carry risk. The likely investment return and the risk of losing money is different for each asset class as different strategies carry different levels of risk depending on the underlying mix of assets. Those assets with potentially the highest long-term return (such as equities) may also have the highest risk of losing money in the shorter term. 

In addition to the limitations and risks outlined in this Agreement, the following significant risks should be considered:

Political Risks: Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world.

General Market Risks: Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason, and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. 

Regulatory Risk: Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. 

Tax Risks Related to Short Term Trading: Clients should note that Wahed may engage in short-term trading transactions. These transactions may result in short term gains or losses for tax purposes, which may be taxed at a higher rate than long term strategies. Wahed endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. 

Risks Related to Investment Terms: If you require us to liquidate your portfolio during a period in which the price of the security is low, you will not realize as much value as you would have had the investment had the opportunity to regain its value, as investments frequently do, or had we been able to reinvest in another security. 

Purchasing Power Risk: Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. 

Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. 

Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. For example, FGN savings bond are highly liquid, while real estate properties are not. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them. 

Financial Risk. Excessive borrowing to finance a business’ operations decreases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.

Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. 

Advisory Risk. There is no guarantee that Wahed’s judgment, models, or investment decisions about particular securities or asset classes will necessarily produce the intended or expected results. Wahed’s judgment may prove to be incorrect, and a client might not achieve the client’s investment objectives. Wahed may also make future changes to the investing algorithms and services that it provides. In addition, it is possible that clients or Wahed itself may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to Wahed’s software-based or web-based service. Wahed and its representatives are not responsible to any client for losses unless caused by Wahed breaching a duty or breaching a contract. 

Fund Risks, including Net Asset Valuations and Tracking Error.

ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because (i) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; (ii) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and (iii) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF or other fund strategies may from time to time include the purchase of fixed income, commodities, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. 

Clients should be aware that to the extent they invest in ETF or other fund securities they will pay multiple levels of compensation – fees charged by Wahed plus any management fees charged by the issuer of the ETF or other fund. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a client purchased the ETF or other fund directly. 

An ETF or other fund typically includes embedded expenses that may reduce the fund's net asset value, and therefore directly affect the fund's performance and indirectly affect a client’s portfolio performance or an index benchmark comparison. Expenses of the fund may include management fees, custodian fees, brokerage commissions, early redemption charges and legal and accounting fees. ETF and other fund expenses may change from time to time at the sole discretion of the issuer. ETF tracking error and expenses may vary. 

Large Investment Risks. Clients may collectively account for a large portion of the assets in certain investments. If many Accounts buy or sell some or all of a particular investment where clients hold a significant portion of that investment may negatively impact the value of that investment. 

The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in investing in Investments. As Wahed’s investment strategies develop and change over time, clients may be subject to additional and different risk factors. No assurance can be made that profits will be achieved or that substantial losses will not be incurred. 

Technology Risk. In using Wahed, Clients acknowledge and accept, given the nature of the Platform that there are unique risks of using the Platform, which include, but are not limited to, the following: 

(a) delays in, unavailability of or unable to access or use the Platform due to any hardware, software, system or connection failure, error, malfunction, omission, interruption, delay in transmission or computer virus; 

(b) loss, or errors in transmission of data or information that may occur including any failure of any of our electrical, electronic, computer, microprocessor, recording or communication system; 

(c) the need to conduct maintenance of the Platform system infrastructure from time to time, and any delay, failure, error or omission which may ensue therefrom; and 

(d) the failure of any electronic security measures including, without limitation, filters, authentication processes and anti-virus software, whether or not for the protection of the integrity of the Platform, the privacy of your information or otherwise, 

and Client agree and hold Wahed harmless from any liability or losses and claims, with respect to the above risks and any losses arising, regardless of whether we had been advised, or were aware of such risks. Wahed shall not assume any cost of all necessary servicing, repair, or correction, including any defect, problem or damage in the computer or Systems.

Wahed Invest does not provide regulated advice

Please note that Wahed does not provide any advice, including financial advice, on investments. If you have any questions regarding your investments, including the risks associated with investing in a particular product or market, you should consider seeking independent advice from a suitably qualified professional advisor. This might include, but may not be limited to, financial advice, investment, legal and tax advice. Wahed cannot give you any investment, legal, taxation or other advice in connection with your investments. Wahed will only assess whether or not you are suitable for Wahed’s Service based on your financial objectives and risk tolerance as specified by you on the risk & suitability questionnaire. As stated in the disclaimer shown to you at your completion of the in-App questionnaire, Wahed’s assessment of your suitability or recommendation does not take into consideration your financial circumstances. If you are unsure or feel that your needs go beyond the scope of the Service, Wahed highly recommends that you seek independent financial advice.

Other than this, the SEC license does not restrict us from providing any of the Services outlined in these Terms to you.

Charts showing Historical Portfolio Performance

We may display the historical performance of model portfolios for your information on our Website or Mobile app. Past performance is not indicative of future results. All such information is provided “as is” and does not constitute professional or investment advice. You should seek independent professional advice before making any investment decisions based on information displayed on our website or mobile app.

Exit

If Wahed finds that investing with us is not suitable for you, Wahed reserves the right to exit you from Wahed’s system. Wahed will explain in writing why this happened and offer you a way to resolve the issue, if the circumstances permit Wahed to do so.

Conflict of Interests

Wahed will always endeavor to act in your best interests as Wahed’s client. However, circumstances can arise where Wahed or one of Wahed’s other clients may have some form of interest in business being transacted for you. If this happens or Wahed becomes aware that Wahed’s interests or those of one of Wahed’s other client’s conflicts with your interests, Wahed will act in accordance with its Conflicts of Interest policy.

Wahed has a compliance department which is responsible for ensuring that Wahed’s control structures and procedures are adequate to ensure compliance with all relevant laws, regulations, codes and practices relating to Wahed’s business activities, which includes identifying, monitoring, and managing actual and potential conflicts of interest. Wahed are committed to operating in the best interests of Wahed’s clients and preventing or managing conflicts of interest fairly, including to ensure that the Robo Advisory Business and Investment Management services are carried out appropriately and in compliance with Shari’a. Where there is a conflict of interests, Wahed will not knowingly deal unless Wahed has taken reasonable steps to ensure fair treatment for its clients such as establishing and maintaining effective information barriers to restrict the communication of relevant information.

On the basis that the arrangements made by Wahed to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a client will be prevented, Wahed will clearly disclose the general nature and/or sources of conflicts of interest to you before undertaking any business for you.

To the extent Wahed is unable to prevent or manage a conflict or potential conflict of interest, Wahed will decline to act for you in such circumstances of conflict.

Voting rights

In providing its discretionary Investment Management Service to you, Wahed may decide at its discretion whether or not to procure the exercise of any voting rights attached to your investments. Unless instructed otherwise, Wahed shall be entitled to exercise such rights at Wahed’s discretion, provided that Wahed is in compliance with Wahed’s conflicts of interest policy, which can be found on the website at wahed.com under Policies.

Wahed’s liability

Wahed is committed to providing you its discretionary management Service with reasonable skill, care and diligence under these Terms. As long as Wahed does this, Wahed cannot and does not accept any liability for loss (or loss of an opportunity to gain) which arises from the exercise of Wahed’s discretionary investment management and other services provided to you under this agreement for and on your behalf.

Please note Wahed does not provide, nor does Wahed accept responsibility for, legal, tax or accounting advice. Wahed also does not accept liability for an action, or failure to act, by the broker, as this is the responsibility of the  broker.

Please note, however, that despite the above, Wahed does not limit or exclude Wahed’s liability for fraud or death or personal injury as a result of Wahed’s negligence or that of Wahed’s employees.

Cancellation Rights

Wahed will always honor your statutory rights. After agreeing to invest with Wahed, you are still entitled to cancel your investment for up to 14 (fourteen) business days after having opened your account (the ‘cancellation period’). This is done by sending Wahed written notice of the cancellation to nigeriasupport@wahed.com. 

If you cancel your investment within the cancellation period, Wahed will sell your investments and return the proceeds generated from any sale to you. Wahed will sell your investments within five (5) T+5 business days (on which the relevant markets are open) of receiving your cancellation instruction, subject to circumstances beyond Wahed’s control.

Please be aware that if the value of your investment(s) has fallen you will not get back the full amount you invested. You will also be liable for any costs Wahed has incurred on your behalf in order to sell the investments.

Termination

You or Wahed may terminate Wahed’s discretionary management Services at any time for whatever reason, without penalty. If you wish to terminate the Services, you must notify Wahed in writing by email to nigeriasupport@wahed.com and termination will take effect from the latter of the date of receipt of the termination notice or the date of liquidation of related securities account.

Please note that if and when Wahed’s Services are terminated, unless Wahed agrees with you otherwise in writing, Wahed will sell your investments and return any proceeds received to your designated bank account as confirmed by you on the App. Subject to circumstances beyond Wahed’s control, Wahed will sell your investments within 5 (Five) business days (on which the relevant markets are open) of receiving your termination notice / Wahed’s decision to exit you from the product.

If the value of your investment(s) has fallen, you acknowledge that you will not get back the full amount you had initially invested. Also, please be aware that Wahed offers no refunds for payment of fees already made to Wahed.

How do you keep track of investments and performance?

A statement showing the composition and initial value of your portfolio is provided in the portfolio section on the App which is determined in accordance with your investment mandate. When you instruct Wahed to start providing Wahed’s discretionary management Service, Wahed will acknowledge the instructions received by you in writing, usually through the App or by email. Wahed will provide you with periodic statements on a monthly basis with valuations of your investments, so that you can see how they are performing.

Section 2: Custodian

Who Handles Your Money and Assets?

Wahed will not maintain physical custody of your funds and securities (“Client Assets”) held in the Client Bank and Nominee Account. While all assets are maintained in nominee accounts, the custody arrangement varies by instrument: 

• Securities listed on the Nigeria Exchanges (NGX), such as ETFs, are domiciled with the Central Securities Clearing System (CSCS). 
• Investment in Mutual funds are domiciled with the respective custodian of funds. 
• Client Assets shall be managed by a Third Party Agent, that being a broker, subject to satisfying the suitability requirements.

Wahed will not act as custodian for the Clients fund, or for the Asset in the Nominee Account. Wahed shall be liable to you for any act, conduct, or omission by the broker or Fund Houses or custodians, in relation to clients Assets. Wahed shall indemnify and hold harmless every client against any loss sustained as a direct consequence of its agreement with such client.

Instructions and Executing transactions

Wahed is authorised to give instructions to the broker with respect to all investment decisions regarding the assets held in the Nominee Account and the broker is hereby authorised and directed to effect transactions, deliver securities, and otherwise take such actions as Wahed shall direct in connection with the performance of Wahed obligations in respect of such assets, including, without limitation, securities brokerage transaction. You will be notified of all transactions executed on your behalf on the App.

Client Money and Accounts

A designated bank account is maintained exclusively for clients' transaction related funds by Third party (broker). The client bank account has been established solely as a transitory account into which clients deposits made via the Wahed app are received. Funds from this account are promptly transferred to relevant Funds managers, NGX for trade purposes. Similarly, funds from divestments received through settlement banks are credited to this account before disbursement to clients. 

All Accounts are established in Capital Assets Limited’s name for the purpose of managing and controlling Client Assets and such Account shall include the words “Client Account” or similar designating language in their title. An email confirmation will be issued to you upon receipt and processing of your deposit.

By using our Services, you agree that Wahed may realise Client Money held on your behalf, and Wahed may close out or liquidate any contracts or positions in respect of the Client Money in order to:

1. pay any fees and charges to Wahed as provided for under these Terms;
2. satisfy any amount owed by you to Wahed as a result of a default by you; or
3. satisfy any sum otherwise due to Wahed by you.

Wahed also maintains a list of all Accounts clearly identifying the individual Client’s ownership to any Client Asset which are kept in the Accounts with the Third Party Agent (i.e. NGX, fund houses custodians ), including in circumstances where such accounts are pooled with the Client Assets of other Clients in the same Account. Such master list includes the following details:

1. the name of the account;
2. the number of clients associated with securities;
3. the number of securities covered by each securities;
4. the date of opening or closure. etc

A record of each Account on the list is documented and maintained for a period of at least five (5) years from the date on which the Account is closed.

As part of the reporting obligations, Wahed will provide clients with a monthly statement of accounts, which will be made accessible via the App. Wahed also undertakes to maintain a system to ensure that accurate reconciliations of the Client Accounts are carried out at least every month.

Section 3: General obligations

What are your obligations?

To enable us to provide you with our Services, you are required to:

1. Agree to and comply with Sections 1–3 of this Agreement. We reserve the right to replace your custodian, broker, or any other service provider at our discretion.
2. Confirm that all information supplied in your suitability questionnaire (whether through the App or otherwise) is complete, accurate, and not misleading.
3. Notify us promptly in writing of any changes to the information you have provided.
4. Provide all information, documentation, or copies of documentation required for us to complete our account-opening procedures.
5. Supply any further information that we may reasonably require in order to fulfil our legal, regulatory, or contractual obligations.
6. Confirm that the investments and cash within your account portfolio are under your sole ownership and are free from any liens, charges, or encumbrances.
7. Not deal, nor permit or authorise any other person to deal, in the investments in your account except through us.
8. Execute and/or provide, within the timeframe we specify, any documents we reasonably require to carry out our duties on your behalf.

We do not offer advice on your tax circumstances; therefore, we strongly recommend that you speak to an independent tax advisor if you are unsure.

The Fee Structure

Wahed’s customers are billed on the basis of the Wrap Fee structure concept. A Wrap Fee is a comprehensive charge levied by Wahed on customers against a bundle of services, including investment advice and research, and brokerage services. As a straightforward fee is charged, the payment process for both advisers and investors is simple.

Wrap Fees

We fully disclose our fees to you in monetary and percentage terms in your Investment Policy Statement. They are also available for review at all times under the portfolio section on the app. We calculate and collect the fees on a monthly basis. The fees are assessed daily, based on the value of the individual portfolios as of each calculation date. The fees charged will be either (i) NGN 130 per month for each of your portfolios that have a value under NGN150,000, or (ii) 0.99% monthly for each of your portfolios that have a value of NGN150,000.00 or above. We will promptly notify you of any increase or decrease in these fees. An increase in the fee will be effective for your Account starting in the next month that begins at least 30 days after we send or post such notice. A reduction in the fee will be effective for the Account starting in the next month following its reduction.

In the event that there is insufficient cash in the Account to cover Wahed’s fees at the time they are assessed and deducted, we reserve the right, at its sole discretion, to liquidate securities in the Account as necessary to cover the outstanding fees.

Please note that it is possible that taxes or costs may exist in addition to those which we pay or impose. This may include bank transfer fees, brokerage fees or other fees that your agents or financial institutions may impose upon you in connection with transferring funds to or receiving funds from Wahed.

Anti-Money Laundering

The anti-money laundering regulations require us to verify your identity, to gather information as to the purpose and nature of the business which we conduct on your behalf, and to ensure that the information we hold is up-to-date. We use electronic identity verification systems, at the beginning and throughout our relationship with you. This means your personal information will be shared with third parties, i.e. the relevant agencies who operate the identity verification systems. In addition, we will verify the validity of your bank account
information and this will involve us sharing your personal and financial information with 3rd party providers. Their services compare your data against the government database, electoral register, relevant public registers (and this includes the bankruptcy and insolvency register and database of disqualified directors), and other publicly available information such as media reports. Please note that we cannot provide our Services to you until you have passed our anti money laundering checks.

How will we communicate?

We will communicate with you in English by email or through the App. You may
communicate with us and provide us with instructions in English through the App or by email, in accordance with procedures notified to you by us (including security procedures and use of passwords).

You accept that we are deemed to have received any email or App correspondence and instructions at the time we access it. You accept that there may be a delay in responding to correspondence received via email or App. You also acknowledge and accept the risks inherent in email, particularly of its unauthorised interception and of its not reaching the intended recipient.

Although we take all reasonable care to ensure all electronic communications and attachments we send to you are free from any known virus or bug, we will not be responsible for any loss or damage resulting from any attack by a third party on our systems, any computer virus or any other malicious or technologically harmful material that may infect your computer equipment, computer programs, data or other material due to your use of our Service.

We will communicate with a third party, who you authorise (“Authorised Person”) [refer to the Authorised Person section], at the address(es) you notify us in writing through the App or by email. As long as we act reasonably, you authorise us to rely on instructions by whatever means transmitted which appear or purport to be sent by you or a third party authorised (i.e. the Authorised Person) by you.

We may record and monitor conversations we have with you, and we will keep a record of all communications and instructions for as long as required by law, which is a minimum of five (5) years, or longer, if we feel a longer period is appropriate.

Authorised Person:

A client may formally appoint an authorised person to act on their behalf in respect of their account. To do so, the client must send the Authorised Person’s details (including full name, contact number, and identification particulars) from the client’s registered email address to nigeriasupport@wahed.com. For security, there might be additional verification steps. Only once verification has been successfully completed will the registration or update be processed. An Authorised Person shall only be able to act within the scope of authority confirmed by the client at the time of registration. All such appointments and confirmations shall be documented and logged by Wahed. The client may revoke or amend the authority of an Authorised Person at any time by notifying Wahed through their registered email, subject to confirmation on the client’s registered phone number.

Communication by someone not signed up to these Terms

If you authorise us to accept the instructions from a person that is not signed up to these Terms, such as your introducer, we will do so until we receive notice to the contrary from you. The same rules (set out under “How will we communicate”, above) apply to instructions received from this Authorised Person as they do to instructions received from you and you must ensure that your Authorised Person complies with these rules.

When may we not act on your instructions?

We reserve the right not to act on your instructions if:

• to do so may involve us or you in a breach of legal and/or regulatory requirements; or
• we believe on reasonable grounds that to do so would be impracticable or against your interests; or
• to do so would run the risk of us suffering financial loss.

We will endeavour to advise you in writing promptly if such circumstances arise.

Complaints

We are committed to providing you with a first-class Service. If anything does go wrong, we aim to put it right quickly and efficiently. If we cannot resolve a problem immediately, we will contact you to tell you what we are doing about it. If you wish to complain about any aspect of our Service, please contact us by emailing nigeriasupport@wahed.com and we will provide you with a copy of our complaints process and procedures free of charge.

How disputes will be resolved

All disputes arising from the use of our Services shall be managed in line with our Complaints Management Policy which can be accessed through our Website or App.

Notably,

• All complaints are acknowledged within 2 working days (or 5 working days if received by post).
• Complaints are resolved within 10 working days of receipt.
• Where unresolved, the matter is referred to the Competent Authority within 2 working days, accompanied by a summary and supporting documents.
• If no Competent Authority exists, the case is referred to the Securities and Exchange Commission (SEC).

Escalation Process

If dissatisfied, the complainant may escalate the complaint to the Competent Authority (e.g., SROs/TA) by sending an email to the info@aiapm.org

If unresolved or if the complaint involves misconduct, fraud, or market manipulation, it may be referred directly to the SEC.

The SEC will acknowledge within 5 days, assess within 5 days, and conclude investigations within 30 days (or 20 days for referred cases). 

Final Appeal

If the complainant is dissatisfied with the SEC’s decision, they may appeal to the Investments and Securities Tribunal (IST).

What are the specific risks of the products you are investing in?

It is very important to us that you understand the risks involved when making an investment. As such, in addition to our general description of the relevant risks we set out in these Terms and Investment Policy Statement, we set out here the risks of investing in the different types of asset we may select for you:

General risks:

In addition to the risks and limitations outlined in this Agreement, the following significant risks should be considered. 

The value of your investments can fall as well as rise and you may not get back the full amount you invested. The price and value of investments may depend on fluctuations in the financial markets, or other economic factors, which are outside our control. Past performance is not necessarily a guide to future performance.

Sukuk and other fixed income investments have the following risks:

• the price of sukuk can go down as well as up, for example the price of sukuk tends to fall when interest rates rise;
• if the proceeds from holding sukuk are reinvested in sukuk, the new sukuk may not provide as large an investment return as the previous sukuk;
• the profit rate provided by sukuk can be fixed, in which case you may receive a return that does not keep up with inflation;
• There is the risk, if selling a sukuk back into the marketplace, that there is
  difficulty finding someone willing to buy it, lowering the value of the sukuk.

Equity (also called shares) has the following specific risks:

• share prices can go down as well as up – this is particularly so for smaller
  companies, as the combination of both less shares and less buyers of those shares means the share price can change more rapidly;
• dividend growth is not guaranteed, nor are companies obliged to pay a dividend to you as an investor;
• companies may go insolvent rendering the shares you hold valueless;
• the market for equity may decline in value;
• the company’s earnings and financial markets generally may be volatile; and
• for smaller companies, shares may not obtain their full value on sale if there is difficulty finding a buyer for those shares.

If any of the risks outlined in this Agreement are unclear or if you would like to discuss the risks you face in further detail, please let us know by sending an email to nigeriasupport@wahed.com.

Data Protection

All of your personal information and financial information (called personal and sensitive data) will be collected, processed, transferred and held in accordance with Nigeria Data Protection Act. 2023 (NDPA) and General Data Protection Regulation (GDPR). We are committed to protecting your personal information and right to privacy. You can access our Privacy Policy through our Website or App.

Amending these Terms

Wahed may, at any time, and its sole discretion make changes to these Terms for, but not limited to the following reasons:

1. Changes to relevant law or regulation, or a decision of the SEC
2. Changes to Wahed’s tax obligations (including the requirement to pay any
   government or regulatory levy), or you and your product are taxed.
3. Changes required by any regulatory or tax authority or industry guidance or codes of practice.
4. Changes in the way investment markets work, including changes in
   investment/securities dealing or administration which may affect your account.
5. If it becomes impossible or impractical, in our reasonable opinion, to carry out any of the Terms as a result of circumstances beyond our reasonable control.
6. To reflect changes to our Services or the manner in which we provide them to you.
7. To reflect changes to the level of charges applicable to your account.
8. To reflect changes to the range of investments we make available to you from time to time.
9. To reflect product improvements to our online service that technological, service or propositional enhancements have allowed us to make.

Changes to these Terms which are due to reasons outside our control (e.g. changes in legislation) or do not impact you directly (e.g. improvements to the Service we are able to offer you) will take effect immediately and we will notify you at the next appropriate opportunity.

We will not be liable to you for any failure or delay in performing our obligations under the Terms if such failure or delay is due to any cause outside our reasonable control. Events outside our reasonable control include, but are not limited to:

1. Acts of God, fire, earthquake, storm or flood.
2. Explosion, nuclear accident or collision.
3. Sabotage, riot, civil disobedience, strikes, terrorism.
4. Epidemic, national emergency (whether in law or fact), or act of war.
5. Any change to the law or regulation of a governmental or regulatory body.
6. Market conditions affecting the execution or settlement of transactions in respect of your account.
7. Any targeted network attack or interruption of the internet or other
   telecommunications service.
8. Loss of supply of essential services including electrical power and third-party services.
9. Any other cause beyond our reasonable control which prevents us administering your account for a given period of time.

Otherwise, we will write and tell you about any material changes at least fourteen (14) days before a change becomes effective and where this is reasonably possible. If it is not, we will write to you at the earliest opportunity after the change has taken place.

You understand and agree that if you object to any of the amendments, or any other part of these Terms, we will have the right to terminate our agreement with you with immediate effect.

Other information?

Transfers

‍Unless we agree specifically in writing otherwise, all transfers into and out of your Account will be by bank transfer only.

Wahed is not a bank, nor depository institution and does not accept cash deposits under any circumstances. You should never attempt to deliver by post or courier any cash or directly deposit cash into the client account.

Any attempt to transfer funds into your Account by depositing cash will be rejected and such deliveries returned to the sender.

Fund Transfers/Payments and Investment Transaction

1. Delays in the allocation of funds to your account may arise if the information provided during the transfer does not correspond with the data we have on record.
2. Wahed is not liable for delays in fund allocation, remittance or investment execution that are caused by local holidays or holidays observed by the relevant stock exchanges that impact the trading and settlement processes of listed securities.
3. Wahed reserves the right to reject any withdrawal requests if your account name does not match the name on your bank account or if the bank information provided is not accurate or complete. Additionally, the Company shall not be held liable for any withdrawal request that is denied at the sole discretion of any of our partner banks, in accordance with their internal policies.
4. Deposits are subject to verification and Wahed reserves the right to reject any deposit requests if your registered account name does not match the name on the bank account from which the funds are transferred. Additionally, the Company shall not be held liable for any deposit request that is denied at the sole discretion of any of our partner banks, in accordance with their internal policies.

If you the client are more than one person

Each of you will be jointly responsible for complying with your obligations, and each of you bear full liability for any breach of these obligations. Any notice given to any of you will be deemed to be given to all of you, and we may act on the instructions of any of you provided that you are an Authorised Person to give such instructions.

In case of death

We will suspend taking instructions in relation to your estate. This means that we will continue to manage your account in accordance with any instructions you have given us so far. Otherwise, we will only take further instructions once we have been presented with a valid letter of administration from a court. Wahed shall not act on requests from a Next of Kin or an Authorised Person after the client’s death unless such requests are supported by the appropriate legal documentation.

Next of Kin

Clients may, at their discretion, provide details of a Next of Kin to be registered on their account. The Next of Kin serves solely as an emergency contact or notification recipient. A registered Next of Kin shall have no authority to access, operate, withdraw from, or otherwise manage the client’s account or investments. In the event of a client’s death, account assets shall be administered strictly in accordance with the client’s will or, where no will exists, under Nigerian probate and succession law. No action will be taken on the account in favour of a Next of Kin unless supported by certified legal documents (such as a death certificate, probate, or letters of administration). Clients may request the registration or update of a Next of Kin by sending a formal request from their registered email address with Wahed to nigeriasupport@wahed.com For security, there might be additional verification steps. Only once verification has been successfully completed will the registration or update be processed. The client’s request and the verification record will be securely logged for audit and compliance purposes.

Assignment is prohibited

You may not assign or transfer any of your rights or responsibilities in relation to your Account with us.

Only parties to this contract may enforce it

Unless and to the extent we agree otherwise in writing, a person who is not a party to this investment management agreement shall have no right to enforce any of its terms

Account Access

Access to the Wahed app via your mobile device allows you to submit trade instructions and initiate withdrawals to an account held in your name, using your login credentials. Transaction instructions received by the system will be processed accordingly. You are required to safeguard your mobile device and login credentials at all times. Permitting third parties to access your device constitutes a security risk. We rely on you to report any compromised access to your mobile phone, login credentials, or registered email, to us without delay. You may do this by emailing us at nigeriasupport@wahed.com.

Unavailability of Services

We reserve the right to suspend or terminate access to our website or mobile app at any time and for any reason, without prior notice or explanation. You acknowledge and accept that access to the website or mobile app may be unavailable from time to time due to circumstances including but not limited to: technical failures of our systems, failures of third-party systems on which our services rely, interruptions in telecommunications or electricity supply, or other events beyond our control. We shall not be liable for any loss or damage arising from such unavailability.

Warranties and Representations

We do not warrant that our website or mobile app will be error-free, uninterrupted, or that it will meet any particular standard of accuracy, completeness, reliability, performance, or quality. All services and information are provided on an “as is” and “as available” basis. We expressly disclaim all implied warranties, including, without limitation, warranties of merchantability, title, fitness for a particular purpose, non-infringement, compatibility, security, and accuracy.

Closing prohibited Comment

These Terms apply to all investments you make with us and provide information about the way in which we provide our Services to you. 

If you have any questions or something doesn’t make sense, please let us know by emailing us at: nigeriasupport@wahed.com. Unless we agree otherwise in writing, these Terms apply to all Services we provide to you and any associated work.

Contact us

Please contact us by emailing nigeriasupport@wahed.com in case of questions about our processing of personal data, or about these Terms generally.

Consent

It is important to us that you understand and are happy with these Terms and your Investment Policy Statement. If you have any questions or something doesn’t make sense, please let us know by emailing nigeriasupport@wahed.com. Unless we agree otherwise in writing, these terms and your Investment Policy Statement apply to all Services we provide to you and any associated work, however note, that we may update the fees, services and related terms in this agreement by notifying you of such change.

If you are happy with both our Investment Policy Statement and these terms, please can you indicate below that you consent to be bound by these Terms. We need this consent before we can provide you with our discretionary management Service.

Please note that by agreeing to these Terms:

• You acknowledge receipt of Terms and that these Terms apply to investments you make with us.
• You acknowledge that you have read these Terms carefully.
• You select not to receive information on every transaction we execute on your behalf, but rather to receive our reports every three months (unless we have agreed otherwise);
• You agree that the information you have provided in the Risk and Suitability questionnaire is accurate, and that your Investment Policy Statement is a fair summary of your responses and portfolio choice.
• You authorise the transfer of information, on a confidential basis, as required under these Terms, between third parties.
• You confirm that you have read, understood and agree to our conflicts of interest policies.
• You specifically consent to being provided information regarding our Service through our website/App.
• You have fully understood the risks inherent in the Wahed investment
  management and have been given the opportunity to ask any questions
  regarding this Service.
• You expressly consent to the collection, use and processing of your personal data by Wahed, in accordance with the Nigeria Data Protection Act and global data protection best practices, for the following specific and legitimate purposes:

• to verify your identity for anti-money laundering (AML), know-your-customer (KYC), and other regulatory compliance checks;
• to assess your risk profile and investment suitability through automated systems;
• to generate and deliver robo-advisory investment recommendations based on your inputs;
• to contact you regarding your account activity, service updates, investment insights, and compliance matters; and
• to fulfil legal obligations, including record-keeping and reporting as required by Nigerian law.
• You warrant to us that you have the required legal capacity to enter into and be bound by this agreement.
  

Schedule 1: Third party brokers and Custodians

• Capital Asset Limited

9th Floor, Bookshop House, 50/52 Broad Street, Lagos, Nigeriabroker and a Custodian.

Wahed Limited (Wahed) is registered and regulated by the Securities and Exchange Commission, Nigeria. Wahed Limited is a subsidiary of Wahed Inc.

All investments involve risks, including the possibility of losing the money you invest, and the track record does not guarantee future performance. The history of returns, expected returns, and probability projections is provided for informational and illustrative purposes, and may not reflect actual future performance. Wahed is not responsible for liability for your trading and investment decisions. It should not be assumed that the methods, techniques, or indicators presented in this product will be profitable, or will not result in losses. The previous results of any trading system published by Wahed, through the Website or otherwise, do not indicate future returns by that system, and do not indicate future returns that will be realized by you. It should not be assumed that the recommendation takes into consideration your financial circumstances.

The website and the content presented, including, without limitation, the indicators, strategies, columns, articles, publications and guides is to be used for informational purposes only. Wahed cannot and does not assess, verify or guarantee the adequacy, accuracy or completeness of any third-party information, the suitability or profitability of any particular investment, or the potential value of any investment or informational source. You are responsible for conducting your own investment research and decisions, and should seek the advice of a qualified securities professional before making any investment, and investigate and fully understand any and all risks before investing. Wahed in no way warrants the solvency, financial condition, or investment advisability of any of the securities mentioned on the Website or any linked site.

The names, products, services and branding cited within the Website and the Content may be trademark or registered trademarks of their respective owners and the owners retain all legal rights. The use of trademarks or service marks by another is not a representation that the other is affiliated with, sponsors, is sponsored by, endorses, or is endorsed by, Wahed.

Broker-dealer Disclosure:

Capital Assets Limited (Capital Assets) is a dealing member of the Nigeria Stock Exchange and is duly registered with Securities and Exchange Commission (SEC) as an issuing house, fund manager and broker/dealer. 

Consent

In accordance with the Nigeria Data Protection Act and global data protection best practices, you hereby give your explicit and informed consent for the collection, use, and processing of your personal data by Wahed, for the following specific, explicit, and legitimate purposes:  

1. To verify your identity for the purposes of AML/KYC checks and regulatory compliance. 
2. To assess your risk profile and investment suitability through automated systems. 
3. To generate and deliver robo-advisory investment recommendations on your inputs. 
4. To contact you regarding your account activity, service updates, investment insights, and compliance matters. 
5. To fulfil legal obligations, such as record-keeping and reporting as required by Nigerian law. 

YOU EXPRESSLY UNDERSTAND AND AGREE THAT:

1. Your data will be processed in a fair, lawful, and transparent manner. 
2. Your data will not be used for purposes other than those explicitly stated above and in the Privacy Policy. 
3. You have the right to withdraw this consent at any time, without affecting the lawfulness of processing carried out before the withdrawal. Link to withdrawal consent form
4. You have been informed of my data protection rights, including the right to access, rectify, erase, and restrict the processing of my personal data.

YOU EXPRESSLY UNDERSTAND AND AGREE THAT:

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