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: nigeriadpo@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 12 December, 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 nigeriadpo@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.

Our Basis for Processing your 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.
• Legitimate interest: we use your personal data when it is necessary for legitimate business interest only
• 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 General Data 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 (AML) 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 Disclosore 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 five (5) 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 can request access to your personal data, including confirmation of whether Wahed is processing your data and access to the data itself. Requests may be made via email to nigeriadpo@wahed.com. 
3. Right to Rectification
   You may request 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 at nigeriadpo@wahed.com so we can address your concerns promptly.

How to Exercise your Rights

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 nigeriadpo@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 writing to our DPO at the above email. 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: nigeriadpo@wahed.com

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*****.

Wahed Limited (“Wahed”) is a Robo Adviser, registered and regulated by Securities and Exchange Commission (SEC)in the Nigeria Capital Market. Wahed Limited is a subsidiary of Wahed Inc.  

Wahed does not provide personalized investment advice; users are expected to seek independent professional advice.

All investments carry risk, including loss of principal. Past performance does not guarantee future results. Wahed disclaims any liability arising from your investment decisions. The content provided is for informational purposes only and does not constitute investment advice.

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 Disclosure:

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

Performance Calculator Disclosure

The performance calculator tool on our website or app calculates hypothetical results based on historical data and user-provided inputs (e.g., initial investment amount, risk level, and time horizon). Investing involves risks, including the loss of principal. Hypothetical performance does not reflect actual trading or the impact of market conditions and is subject to significant limitations.

Performance Calculator, Disclosure & Disclaimer

The result generated by this Performance Calculator represents Hypothetical performance illustration. They do not reflect the actual performance of any client account or portfolio managed by Wahed Limited (“Wahed”) and should not be interpreted as a guarantee of future performance. 

The tool evaluates historical performance for specific Shariah complaint portfolios made available by Wahed to its clients in Nigeria. These portfolios are used purely to illustrate hypothetical outcomes based on the defined assumptions and limitations described below. The calculator does not evaluate all possible investment products available in Nigeria, and other products may perform differently. 

Performance shown is net of management fees, inline with applicable fee schedule. 

Fee details are available in the Client Agreement provided to clients.

Investing involves risk, including the possible loss of capital. Historical performance and hypothetical projections are for illustrative purposes only and should not be relied upon as investment advice, a prediction, or an assurance of future results. Past performance is not a n indication or guarantee of future performance. 

No Advisory Relationship:

Use of this tool does not create an advisory, fiduciary, or discretionary portfolio management relationship with Wahed. Users should consider seeking professional advice tailored to their financial situation, objectives and risk tolerance. 

Tool methodology - Key Assumptions & Limitations

The tool allows users to visualize different risk profiles by inputting a starting investment amount, time horizon, and self-assessed risk tolerance; however, this approach is limited because users' subjective assessments may not accurately capture their true risk capacity or align with their long-term financial goals, potentially leading to portfolio recommendations that may not be optimal for their actual financial situation.

The tool’s historical performance and projections assume:

• For each month the user is invested, the investment is compounded by the prior month's ending amount for his selected strategy; however, this approach does not capture intra-month volatility or any mid-month transactions that could affect actual returns.
• Every month the fee is deducted based on the starting amount for the month and this method does not take into account fluctuations within the month or any additional contributions or withdrawals that would alter the fee base.
  
  • The fee is based on the actual fee schedule. A fee schedule is defined as a document that clearly explains what services or actions will cost you money, how much you’ll be charged, and when those charges will apply. This assumes the fee schedule remains unchanged over time and may not account for future adjustments or variations in the fee calculation.
  • The fee changes if the investment grows from one bracket to the next and vice versa, as per fee tier slabs mentioned in fee section of client agreementThe ending amount is equal to the starting amount plus the return, minus any fees. This simplified formula does not account for the potential compounding impact of fees or other real-world factors like taxes or irregular cash flows.
• The ending amount becomes the starting amount for the next month and so on. This assumes no intra-month activity, which may not reflect actual investment behavior.
• The tool does not account for investments made during the month. Consequently, additional contributions or withdrawals are ignored, potentially resulting in performance outcomes that differ from an investor’s true experience.
• The selected risk profile is the same for the entire period; the tool does not account for allocation adjustments, neither automated nor ad hoc. This static approach may not reflect changes in market conditions or shifts in an investor's risk tolerance over time.

No information derived from the tool or through the use of our app or website should be taken as an investment recommendation, or an offer to buy, sell, or trade a security. 

Wahed does not provide personalized investment advice; users are expected to seek independent professional advice.

Historical Returns Disclaimers:

Past performance is no guarantee of future results. Historical returns, expected returns, and probability projections are provided for informational and illustrative purposes only and are not an indication of future performance. All investing involves risk, including the possible loss of all the money you invest. The past performance does not guarantee future performance. Past results of any trading system published by Wahed Invest Limited, through the website or otherwise, are not indicative of future returns by that system, and are not indicative of future returns which will be realised by you. Wahed Invest Limited assumes no responsibility or liability for your trading and investment results. Please visit www.wahed.com/nga/legal for full terms and conditions.

Disclaimer on Fund Prices

Prices and valuations displayed on our website or mobile application are provided strictly for informational purposes and do not constitute investment advice or an offer to buy or sell any security. While we make every reasonable effort to ensure that the information is accurate and current, data may occasionally be delayed, incomplete, or contain rounding or formatting discrepancies due to reliance on third-party sources, including fund managers and public data providers.

Actual transaction values shall be those confirmed directly by the respective fund managers at the time of execution. We therefore do not warrant the accuracy, timeliness, or completeness of any displayed prices and accept no liability for any loss arising from reliance on such information.

Data Protection and User consent

In compliance with the Nigeria Data Protection Act 2023, you consent to Wahed processing your personal data to:  

1.  Verify your identity for AML/KYC purposes. . 
2. Assess your risk profile and suitability using automated systems.  
3. Provide robo-advisory services to you.
4. Communicate relevant account updates and insights.  
5. Fulfill regulatory obligations . 

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 may withdraw your consent at any time by emailing our DPO at nigeriadpo@wahed.com or by submitting the signed withdrawal consent form to us at the same email.
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:

Wahed makes no warranty that (1) the website or any products, services, content, information or other material obtained through the website will meet your requirements or expectations; (2) the content, data and materials presented or displayed on the website are correct, accurate or reliable; (3) the functions and content contained in or on the website will be without errors; (4) the website will be free of viruses; (5) that the security measures taken by Wahed to protect user contributions will withstand attempts to evade security mechanisms or that there will be no cracks, disablements or other circumvention of such security measures; or (6) that any website defects will be corrected, even if Wahed is aware of them. Wahed shall have no liability for any viruses, damage to your computer, loss of data, financial loss, or any other damages arising from your use of this website. Any and all expenses related to necessary services or repairs for software or hardware, computer viruses, software code, and any losses or damages resulting from usage of the website are the sole responsibility of the user.

Limits of liability

To the fullest extent permitted by applicable law, in no event will Wahed, its affiliates or their respective officers, directors, managers, employees or agents be liable for any damages, including, without limitation, direct, indirect, incidental, special, consequential or punitive damages, whether under contract, tort or any other theory of liability, arising in connection with (1) the use of the website; (2) any failure, error, omission, interruption, defect, delay, computer virus or loss of data; (3) any loss of use related to the website or a linked site; (4) any data or content on the website or a linked site, including without limitation any damages caused by or resulting from reliance by you on any information or content obtained from wahed; or (5) any loss relating to your investments and investment results.

This website uses cookies

Wahed Limited uses cookies to help provide you with a better experience when visiting our Website. “Cookies” are pieces of data that are stored on your computer or mobile device when you visit a website. When you browse our Website again, the information from the cookies can be retrieved to help us understand how our Website is being used. By continuing to use our Website without changing the settings, you are agreeing to our use of cookies. For more information on our cookie policy, please read our Privacy Policy and Cookies Policy.

Cookie policy

Wahed Limited (we, us, or our) use cookies on our website https://www.wahed.com/nga  (the Website). This Cookie Policy provides more information about cookies and the purposes for which we use them.

What are Cookies?

A cookie is a small text file that's stored on your computer, tablet or phone when you visit a website.

Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. Alternatively, you can search the internet for other independent information on cookies.

How we use Cookies

We use cookies (and other similar technologies) to:

Enable security services to prevent DDOS attacks and other cyber security threats;

Ensure your security and privacy when in our secure sites;

Collect statistical data about our users' browsing actions and patterns;

Provide products and services that you request and to provide a secure online environment;

Manage our marketing relationships;

Store login details for our secure sites;

Give you a better online experience and track website performance; and

Help us make our website more relevant to you.

The cookies used by this Website will not contain any personal identifiable information about you.

We use cookies to do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. When you visit our website from any device (mobile, tablet or PC), we collect information about your use of this site, such as information about the device or browser you use to access the site (including device type, operating system, screen resolution etc.), the way you interact with this site, and the IP address your device connects from. You can block or remove cookies at any time by activating the setting on your browser that allows you to refuse and/or remove all or some cookies. However, if you change your browser settings to block or remove all cookies (including essential cookies) you may not be able to access all or parts of the Website and we may not be able to identify you as a user of the Website.

Cookies in emails

In addition to the cookies we use on this website, we also use cookies in some emails and push notifications. These help us to understand whether you have opened the email and how you have interacted with it.

Social media and targeting

On some pages, we also feature embedded 'Share' buttons or widgets that enable you to share content through a number of popular social networking sites, such as Facebook and Twitter.

These third party sites set their own cookies. We do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt out.

Cookie categories

Cookies can be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories: Strictly Necessary, Performance, Functionality & Profile and Targeting.

Strictly Necessary Cookies These cookies are essential, as they ensure your security as well as enabling you to move around a website and use its features. Without these cookies, services you've asked for (such as access to secure areas) can't be provided. These cookies don't gather information about you that could be used for marketing or remembering where you've been on the internet.

Performance Cookies The information collected by these cookies is anonymous and is only used to improve how the website works and to help us to identify issues you may have when using our online services. In limited cases for online banking issues, these cookies enable us to identify specific issues you may have had. These cookies are not used to target you with online advertising. Without these cookies we can't learn how our website is performing and make relevant improvements that could better your browsing experience.

Functionality & Profile Cookies These cookies allow a website to remember choices you make and tailor the website to provide enhanced features and content for you. These cookies may be used to ensure that all our services and communications are relevant to you. The information these cookies collect cannot track your browsing activity on other websites. Without these cookies, a website cannot remember choices you've previously made or personalise your browsing experience.

Targeting Cookies

These cookies and similar technologies gather information about your browsing habits. They remember that you've visited a website and share this information with other organisations, such as advertisers and platforms on which we advertise. They do this to provide you with ads that are more relevant to you and your interests. Although these cookies and similar technologies can track your visits to other websites, they don't usually know who you are

Advertising cookies

You can choose to turn off advertising cookies only, by blocking specific companies. You'll still receive advertising on the internet, but the adverts you see may not be tailored to your likely interests or preferences.

Changes to Our Cookie Policy

This Cookie Policy may be updated from time to time so we recommend that you check it each time you visit our Website. The date of the most recent revisions will appear on this page.

Contact us about this Cookie Policy If you have any questions or comments about this Cookie Policy please contact:

The Chief Compliance Officer Wahed Limited Plot 294, Levetis Close, Central Business District, Abuja, FCT, Nigeria  Email: nigeriasupport@wahed.com

Glossary

In this document, unless the context otherwise requires, the following words, terms and expressions shall have the following meanings:

‍

‍

Wahed Limited (“Wahed”) is a Robo Adviser duly registered and regulated by Securities and Exchange Commission (SEC) to provide Robo advisory services  in the Nigeria Capital Market.

Wahed Limited is a subsidiary of Wahed Inc.

Purpose

This policy outlines the process and procedure for the fair and timely resolution of disputes or complaints involving clients, shareholders, investors, and other Capital Market Operators (CMOs), in compliance with SEC Nigeria’s Complaints Management Framework.

Scope

This policy applies to:

• Clients and investors dealing with the Firm
• Capital Market Operators and associated entities
• Internal staff handling complaints

Lodging Complaints

For the purpose of lodging complaints, clients can send us an email at nigeriasupport@wahed.com. Or mail us through our registered office at plot 294, Leventis Close, CBD, FCT, Abuja. We are committed to addressing all your concerns in a timely and efficient manner.

Complaints Management Framework

1. Internal Complaints Handling
   Wahed shall maintain a clearly defined Complaints Management Policy.

• Client support shall receive complaints lodged by clients via email or postal services. 
• Client Support Agent shall send acknowledgements to clients of complaints received by email within two (2) working days or in writing within five (5) working days where the complaint is received by post and shall log such complaints into the Complaints Register with relevant details (e.g. name of complainant, nature of complaint, date received, resolution status, etc.) for maintenance of records. Copies of the complaint and acknowledgement shall be forwarded to the relevant Competent Authority The format of the Complaints Register/Dispute Resolution Template is given at Annexure 1.
• Client support shall resolve complaints that are general in nature (e.g. general enquiries, onboarding issues, login issues or guidance for changing portfolio, etc.) and implement remedies and confirm completion to the complainant.
• Client support shall classify complaints based on their nature, urgency, and department and shall escalate complaints to the relevant units or departments on a daily basis. 
• In case of complaints received on minor dissatisfaction as a result of a system delay or technical glitches, fund confirmation delay, delay in execution of trade, delay in processing redemption, and other operations or trade related matters, the complaints shall be escalated to the operations department. 
• Complaints regarding potential fraud, suspected trade manipulation, monetary loss, etc. shall be escalated by the Client support to the compliance officers and Data Protection Officer.
• All relevant units or departments shall endeavor to resolve the high priority complaints within 10 working days from the date of receipt, and if resolved, shall notify the Competent Authority (CA) of resolution within 2 working days (from the 10 days of receipt).
• Where the complaint is not resolved within the given timeframe, the Compliance Officer shall refer the complaint to the relevant Competent Authority (CA) within two (2) working days. The letter of referral shall be accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents including a copy of the complaint(s).

2. Resolution Timeline
   Where resolution is not achieved within 10 working days, the complaint may be escalated as detailed in the Escalation Procedure section.

Escalation Procedure

a. Referral to Competent Authority

• If the complainant is dissatisfied with the resolution, they may escalate the complaint to the appropriate Competent Authority, e.g. Self-Regulatory Organizations (SRO) or Trade Groups (TG) after two (2) working days from the tenth (10th) working day. 
• Where there is no SRO or TG, refer to SEC.
• Where the complainant is not satisfied with the decision of the relevant Competent Authority, the matter shall be referred by the complainant to the SEC within two working days.

b. Referral to the SEC

• Where the matter remains unresolved or in cases involving trade manipulation, accounting fraud, Ponzi schemes, or misconduct by Capital Market Operators, the complaint may be lodged directly with the SEC.
• Acknowledge receipt within five (5) days
• Assessment of the complaint within five (5) days for referred cases.
• Conclude investigation within thirty (30) days–twenty (20) days for referred cases–or for an extended time as the SEC deems fit.
• The matter may be referred to an Administrative Committee or Law Enforcement Agency.

c. Right to Appeal

• If dissatisfied with the outcome provided by the SEC, the complainant has the right to appeal the decision by filing a case with the Investments and Securities Tribunal (IST).

Assessment and Monitoring

• All complaints received by the firm shall be assessed to determine the appropriate resolution path.
• Complaints falling outside the firm’s jurisdiction will be referred to the appropriate authority or regulator.
• A regular review of complaint trends and outcomes shall be conducted to improve customer service and risk management processes.

Record-Keeping and Reporting

• The Compliance Officer will be maintaining the electronic complaint register, to ensure timely and effective management of client complaints in line with SEC requirements.
• The Compliance Officer shall forward to the SEC status reports of complaints filed with the entities on a quarterly basis.
• Records of complaints shall be retained by Wahed Limited for a minimum of five (5) years.

Complaints Against the Operators

• Only complaints against the operators (e.g. a complaint against Wahed) may be lodged at first instance, with the relevant Competent Authority (Trade Association).
• Any complaints lodged at first instance with the relevant Competent Authority shall be resolved within twenty (20) working days.
• For all complaints that are not resolved thereafter, the outcome shall be referred to SEC within five (5) working days.

Complaints Against the Relevant Competent Authority

• Only complaints between operators and complaints against the relevant Competent Authority may be lodged at first instance, with the relevant Competent Authority respectively.
• All complaints lodged at first instance with the relevant Competent Authority shall be resolved within twenty (20) working days.
• For all complaints that are not resolved thereafter, the outcome shall be referred to SEC within  five (5) working days.

Training and Awareness

All staff involved in handling complaints shall receive annual training to ensure effective complaint resolution in line with regulatory requirements.

Review of Policy

This policy shall be reviewed annually or upon significant regulatory changes as may be advised by the SEC or relevant authorities.

1. Introduction

Wahed Limited, operating as a fiduciary firm, is entrusted with the duty to uphold care, loyalty, and good faith when serving its client’s best interests. We ensure this commitment by actively preventing and reducing conflicts of interest and transparently disclosing all significant information related to any conflicts that may arise with our clients. This policy applies to Wahed Limited (NGA) (referred to as ‘Wahed’).

According to this conflict of interest policy (“Conflict of Interest Policy”) individuals falling under the term “Covered Person” shall be defined as: 

• Board, directors and officers of the Firm (or other persons occupying a similar status or performing similar functions); 
• employees of the Firm; 
• any other person who provides advice on behalf of the Firm and is subject to the Firm’s supervision and control; and 
• vendors, consultants and independent contractors who are subject to the Firm’s supervision and control.

2. Definition of Conflict of Interest

A conflict of interest occurs where the firm’s interest, or the personal or financial interest of any of its officers, employees, or affiliates, interferes, or appears to interfere with the duty owed to clients, shareholders, or regulators. 

3. Board and Directors

In line with Nigerian corporate governance standards, the following principles shall guide the Board and its members:

• Directors must promptly disclose any real, potential, or perceived conflict of interest regarding any matter that may come before the Board or its committees.
• A director must abstain from discussions and voting on any matter in which the director has, or may have, a conflict of interest.
• If a director is uncertain whether a conflict of interest exists, the director must seek guidance from the Chairman of the Board or the Company Secretary.
• If any question arises before the Board as to the existence of a real or perceived conflict, the Board shall, by simple majority, determine whether a conflict exists. The director(s) concerned shall not participate in such deliberations or voting.
• Directors who become aware of a conflict of interest situation affecting another director have a duty to promptly raise the issue with the concerned director or with the Chairman of the Board.
• All disclosures of conflicts of interest by directors, and all Board decisions regarding the existence of conflicts, must be recorded in the minutes of the relevant meeting.

4. Identifying Conflict of interest

Identifying potential conflicts of interest is very crucial to the Firm because it is crucial to maintain trust and ethical conduct. A conflict of interest which may give rise where either the Firm or any relevant third party could make a financial gain, or avoid a financial loss, at the expense of the client or has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome. 

We have identified potential conflicts of interest in our business in order to put in place measures to monitor, manage and prevent the materialisation of those conflicts. We have identified the following main interests/roles that potentially give rise to conflicts of interest:

The Firm’s

• duties as a Robo advisor
• duties as an independent researcher

The Clients:

• interest as recipient of investment recommendation services 
• interest as investor in financial instruments (e.g. securities/ETFs/mutual funds)
• interest as user of services/facilities provided by the Firm

The Employees:

• interest in performing their roles and responsibilities
• Interest in where market information is misused for personal or corporate gain
• interest in accepting gifts or benefits that impair objectivity by employee or directors
• interest in achieving objectives/targets 
• interest in status, remuneration and bonus 
• interest in where affiliated or related investment products are favored over more suitable client options.
• interest in external businesses/activities

Below is a list of examples, which is not exhaustive, illustrating situation where potential conflicts could emerge: 

• Situations where the Firm promotes its own financial products over others, it may prioritize its interest over the client’s
• Situations where the Firm has affiliate relationships with certain investment firms, influencing product recommendations is possible
• Situations where the firm conducts its own trading, it might execute trades differently based on its interest, potentially affecting client returns. 
• Situations where the Firm favors HNI’s with better investment options or services can create conflicts with smaller investors. 
• Situation where the Firm develops new products or offers (mandate) propositions 
• Situation where the Firm changes, merges or closes (a) fund(s) within its fund ranges 
• Situation where the Firm fails to provide clients with materials that are fair, accurate and not misleading 
• Situation where the Firm trades for its affiliated clients in a security when at the same time it has information about potential future client orders in relation to that security 
• Situation where the Firm employee engages in personal account dealing and the Firm has a client with an interest that potentially conflicts with such dealing 
• Situation where the Firm has information in relation to distressed assets and the Firm trades these assets for one client/group of clients but not others 
• Situation where substantial gifts (including non-monetary gifts) are received that may influence the Firm’s behaviour in any way that conflicts with the interests of the clients of the Firm 
• Situation where the Firm deals with errors within client portfolios or with complaints 

Conflicts among Client Interests

Conflicts of interest may arise where a firm or its representatives have reason to favor the interests of one client over another client (e.g., larger accounts over smaller accounts, accounts in which employees have made material personal investments, or accounts of close friends or relatives of Covered Persons). The Firm specifically prohibits inappropriate favoritism of one client over another client that would constitute a breach of fiduciary duty.

5. Governance and Oversight:

• The Board of Directors has overall responsibility for ensuring compliance with this policy. 
• The compliance Officer shall maintain a conflict of Interest register, documenting identified conflict and mitigate measures. 
• Annual disclosures of potential conflicts of interest shall be made by all directors and employees. 
• The compliance Officer to maintain employee conflict disclosure Form

6. Management of Conflict of Interest

Managing a conflict of interest is the process of reviewing the disclosed conflicts, evaluates the potential impact on the firm, consults with the relevant parties to determine the appropriate action to manage and resolve the conflicts, and the firm has measures to mitigate or avoid (where necessary) situations of conflict of interest. 

The measures adopted by the Firm include: 

• Ensuring that all product inclusion with the portfolio is based strictly on objective, data-driven criteria such as risk profiling, suitability, cost and performance metrics.
• Maintaining an arm’s length relationship in product selection, portfolio construction, ensuring continued suitability and competitiveness. 
• Executing client trades following strict transaction schedules and cut-offs without preference to any client or employee over another. 
• Ensuring that access to investment products is not unfairly restricted based solely on account size, unless objectively justified and disclosed.
• Conducting independent suitability and risk assessment, providing full risk disclosures to the client prior to onboarding and ensuring that product offerings are not solely intended for commercial benefits. 
• Ensure that the act is in the best interest of the affected clients and ensure no unfair disadvantage, 
• Ensuring that all client facing tools/materials are fair, clear, accurate and inline with disclosure standards. 
• Prohibiting employees from trading in securities where they possess non-public information. 
• Ensuring that the allocation of assets across portfolios is based solely on suitability and investment objectives. 
• Prohibiting the acceptance of substantial gifts, requiring stringent disclosures for any gifts received by employees, maintaining a gift register and avoiding any inducements that may influence decision making. 
• Acting promptly to investigate, correct, and resolve any errors.
• Conducting regular training to ensure staff understand their obligations under this policy.

1. Receipt or provision of benefits
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   The Firm has established policies and procedures including, but not limited to, monetary limits, pertaining to any acceptance or giving of gifts or any benefits by the Firm or its Covered Persons as follows:

• Covered Persons should avoid any actions that create a perception that favorable treatment of outside entities by the Firm was sought, received, or given in exchange for personal business courtesies.

• Covered Persons must assure that any offer of business courtesy cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively on the Firm. In addition, a Covered Person may never use personal funds or resources to do something that cannot be done with Firm resources. 

• No Covered Person should offer or provide any gifts to clients, prospective clients, vendors or third parties with whom or with which the Firm or its affiliates conducts, or is considering conducting, business, without the consent of the Compliance Officer. A gift may include any services or merchandise of any kind, or discounts on merchandise or services, and other transfers of cash or items of value. This Conflicts of Interest Policy does not prohibit the provision of occasional or nominal non-cash gift items (without the consent of the Compliance Officer), such as holiday gifts, so long as the amount provided by any employee to any one recipient over a calendar year does not exceed One Hundred and Fifty Thousand Naira (NGN150,000) only (for the avoidance of doubt, if more than one employee provides a gift to the same recipient in a calendar year the gift amounts are aggregated). The following gifts are excluded from the One Hundred and Fifty Thousand Naira (NGN150,000) gift limit: gifts of the minimum value such as pens and notepads; promotional gifts that display the Firm’s logo such as tote bags, shirts, etc., as long as they are valued at Seventy Five Thousand Naira (NGN75,000) only or less; personal gifts that are not paid for or reimbursed by the Firm; and gifts commemorating business transactions such as Lucite tombstones, plaques, etc., as long as they are decorative only.

• Covered Persons should not obtain any material personal benefits or favors because of their position with the Firm. Each Covered Persons’ decisions on behalf of the Firm must be free from undue influence.

• No Covered Persons shall ask for, or accept, any gifts from clients, vendors or third parties with whom, or with which, the Firm, or its affiliates, conducts, or is considering conducting, business without the consent of the Board. A gift may include any services or merchandise of any kind or discounts on merchandise or services and other transfers of cash or items of value. This Conflicts of Interest Policy does not prohibit the receipt of occasional or nominal non-cash gift items (without the consent of the Chief Executive Officer), such as holiday gifts, so long as the amount received by any employee from any one source over a calendar year does not exceed Three Hundred Thousand Naira (NGN300,000) only.
  
  The foregoing is not intended to prohibit the acceptance or provision of normal amenities and entertainment that facilitate the handling of the Firm’s business, such as business luncheons, dinners, or other non-extravagant activities. Thus, normal and customary entertainment (i.e., business meals and entertainment where the person providing the entertainment is present) that is not “lavish” is acceptable. The Firm and its Covered Persons may not provide, or accept, extravagant or excessive entertainment to or from a client or any person or entity that does or seeks to do business with or on behalf of the Firm.

2. Gifts and Entertainment Log.
   
   Any Covered Persons who receive gifts or benefits given by a client shall report to the Compliance Officer who is in charge of maintaining a register of all gifts and entertainment given or received.

APPENDIX A

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Table of Securities Held

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Any Covered Person who breaches this Conflict of Interest Policy shall be subject to disciplinary action as determined by the appropriate authority, having regard to the level of the Covered Person involved.

7. Amendment and review

This Policy shall be reviewed and updated to ensure effectiveness and continued application and relevance to the Company’s business by the Compliance Officer as business circumstances require but not less frequently than annually, and approved by the Board. The Board and the CEO shall approve all recommended and reviewed policies. Staff members will be notified of any updates to this policy.