Customer Complaint Management Framework

Glossary of Terms

In this Framework, unless the context otherwise requires, the following terms apply:

Introduction to Customer Complaint Management

In every service-based industry, some customers are likely to experience a form of dissatisfaction with services provided to them. Any communication of unsatisfactory service by the customer to a representative of Mega Capital Financial Services Ltd is a formal complaint. The Company recognizes that it is necessary to manage customer complaints to prevent loss of business and/or reputational damage. The process of managing complaints is regarded as Customer Complaint Management (“CCM”).

In a bid to ensure uniformity and speed in the management of complaints, a process for the supervision and documentation of complaints has been put in place. This procedure is known as the Customer Complaint Management Framework (“CCMF”).

Mega Capital Financial Services Ltd is a service-based business known in the non-bank financial services industry for its provision of superior customer service. In a bid to sustain this standard of service delivery, good complaint handling is essential. CCM achieves multiple purposes, including:

• Ensuring customers receive the excellent level of service they are entitled to receive from a first-class institution;
• Serving as a valuable source of feedback on quality of service;
• Providing an audit trail and an effective method of early detection of failures in service delivery; and
• Providing an opportunity for the Company to improve its services and sustain its good reputation.

Key Features of the CCMF

The following highlights the key features of the Company's CCMF:

1. A uniform CCMF for Mega Capital Financial Services Ltd;
2. Availability of an electronic complaint reporting process;
3. Proforma templates for initial response to customer complaints;
4. Formulation of a Customer Complaint Resolution Panel;
5. Annual customer complaint management training; and
6. Monthly updates on complaints and resolution reported to the Head of Customer Service / Company Chief Compliance Officer.

Policy Statement

The aim of having an efficient CCM procedure is to ensure proper management of complaints brought to the attention of Mega Capital Financial Services Ltd for fair resolution. It is designed to improve the services offered by helping to detect weakness, remedy unfair situations and improve operating methods within the system.

The Board and Management are highly committed to promoting an effective and efficient complaint handling process, and adequate resources shall be deployed towards achieving this objective. All complaints received shall be acknowledged and analyzed to aid informed and continuous quality improvement initiatives.

The major aims of this Framework are to:

1. Ensure accessibility by all Mega Capital Financial Services Ltd customers to a structure where they can communicate any dissatisfaction with the Company's services;
2. Improve communication links between Mega Capital Financial Services Ltd and its clients;
3. Establish and maintain an effective and transparent procedure for reasonable and prompt management of all customer complaints across Mega Capital Financial Services Ltd;
4. Engrain complaint management into customer service for enhanced customer satisfaction and brand protection;
5. Ensure that all subsidiaries and divisions with a high retail customer base maintain dedicated resources for the prompt management of complaints;
6. Identify areas of weakness to support Company development and improvement;
7. Establish a consistent guideline to be followed when responding to complaints; and
8. Comply with existing regulations on Complaint Management, particularly the SEC and CMO's Customer Complaint Framework.

Categories of Customer Complaints

Mega Capital Financial Services Ltd recognizes that complaints may fall into one or more of the following categories:

• Complaints alleging financial losses;
• Complaints with potential legal/regulatory implications;
• Complaints alleging failure of service delivery; and
• Complaints that increase the risk of reputational damage.

Causes

The issues that might lead to customer complaints vary between Mega Capital Financial Services Ltd's businesses. They however include the following:

• Delay in execution;
• Poor customer service;
• Failure to carry out instructions;
• Negligence, including failure to follow through on promises and failure to carry out instructions;
• Mistakes in the computation of charges/fees;
• System errors; and
• Communication and/or technological failures.

Channels of Complaint

The Company's customers may lodge their complaints through any one or more of the following channels:

Risk Rating of Complaints

Procedure for Customer Complaint Management

The procedure for managing customer complaints is progressive in nature that is, completion of one stage automatically triggers the next until the complaint is resolved. As soon as a resolution is reached, subsequent stages of the CCMF can be discontinued.

(a) Acknowledgement

Upon receipt of a customer's complaint, the immediate recipient should take the following actions depending on the mode of complaint.

In the case of verbal complaints:

• An attempt should be made to calm the offended client while an employee with better knowledge of the situation (preferably the client's account officer) is notified;
• Neither the employee of first contact nor the account officer is to admit liability on behalf of the Company or apportion blame in the presence of the client. The aim is to contain the situation until escalation if required; and
• The client should be informed of the nearest date within which the business will revert on the issues in dispute.

In the case of written complaints:

• The recipient of the letter must send it to Customer Service as soon as it is received;
• Customer Service must send an acknowledgement to the client within 24 hours (email) or 3 working days (post), confirming receipt and a proposed date for communicating findings;
• Within 3 hours of receipt, Customer Service shall notify the Compliance Unit via email and verbally. The Compliance Unit shall keep a Register of Complaints; and
• The Compliance Unit will send copies of the complaint and acknowledgement to the relevant Competent Authority as part of routine regulatory reporting.

(b) Timeline for Resolution of Complaints

The Policy is to resolve all complaints within 10 (ten) working days from the date of receipt. After resolution, the Company shall notify the relevant Competent Authority within 2 (two) working days.

(c) Escalation of Complaints to the Competent Authority

• Complaints not resolved within 10 working days shall be referred to the relevant Competent Authority within 3 working days, by either Customer Service or the Complainant;
• A letter and a summary of the proceedings, along with copies of relevant supporting documents, shall be sent to the Competent Authority. Sanctions may be imposed by the SEC for failure to forward this summary within the stated timeline; and
• If the customer is not satisfied with the decision of the Competent Authority, the Complainant shall have the right to refer the Complaint to the SEC within 2 (two) working days where he/she is not satisfied with the decision of the Competent.

(d) Competent Authority

• Complaints referred by Customer Service to the relevant Competent Authority shall be resolved within 20 (twenty) working days of receipt of the Complaint.
• Where there is no relevant Competent Authority, the Complaint shall be referred to the SEC within 3 (three) working days either by the Company or the Complainant. The summary of the proceedings of events leading to the referral and copies of relevant supporting documents shall be attached to the letter the SEC.

Register of Complaints

1. All complaints must immediately be reported to the Head, Customer Service.
2. All complaints must be recorded in the Complaint Log, which must at least include:
   1. Date of complaint;
   2. Complainant's name;
   3. Nature of the complaint and the circumstances;
   4. Name of the person who is the subject of the complaint;
   5. The product or service which is subject of the complaint; and
   6. The date and summary of the decision reached.

Scope of Complaints to the Competent Authority and SEC in the First Instance

• Customers must not lodge a complaint with the relevant Competent Authority or the SEC in the first instance;
• Only complaints between Capital Market Operators, and complaints against the Relevant Authority, may be lodged at first instance with the NGX or the SEC; and
• Only complaints (i) against Capital Market Operators by Regulators and/or Self-Regulatory Organizations, and (ii) trade manipulation, accounting frauds, Ponzi schemes and similar matters may be lodged with the SEC in the first instance.

Escalated Complaints

In cases where the customer had already escalated the complaint to the SEC and the Company is aware, the Company will write the Regulator within 2 (two) working days stating that the CCM process has commenced. The Customer will be notified of this and the Company will continue with the CCM process except instructed otherwise by the Regulator.

(a) Investigation

Where complaints cannot be resolved immediately at the point they are made, they will be thoroughly investigated. The head of the relevant Unit or business against whom the complaint is levied shall be notified via email by the Customer Service Officer on the same day the complaint is received.

In all cases, the occurrence of the complaint must be recorded in the Complaint Register by the responsible Customer Service Officer within 24 hours of receipt. The issues complained about must be clearly defined and recorded. Steps taken to ensure the resolution of the complaint as well as the resolution must also be stated as soon as it occurs.

Investigations of complaints received after 4:00pm WAT must be initiated latest 8:00am WAT on the next business day. The head of the Unit or business manager against whom the complaint is lodged shall investigate the true state of affairs leading to the complaint. Investigation must be concluded within 24 hours of receipt of the email notifying the Unit head or business manager of the existence of the Complaint. If a suitable resolution is reached at this stage, it must be communicated to the following officers before the client is informed of the decision:

• Business Manager of the affected business;
• Company Head, Compliance;
• Head, Legal;
• Company Head, Risk Management & Internal Audit; and
• Head, Internal Control.

This communication ensures the Company collectively owns the decision communicated to the client. A member of each of these Units must be appointed to the CCRP.

(b) Escalation

Any unresolved complaints, as well as all complaints brought to the Company's notice by any Regulator, must be escalated to the CCRP. The Panel is expected to:

1. Approve the decision communicated as the appropriate resolution. Approval may be done by circular; or
2. Further investigate all unresolved cases and decide on the best solution.

If a resolution cannot be reached immediately, the head of the affected Unit or business manager is to verbally communicate with the offended client until resolution is reached within the stated timeline. All verbal communications must be transcribed and circulated among CCRP members.

(c) Communication of Decision

All resolutions reached must be promptly communicated to the complainant. Both the Legal Unit and Compliance Unit must be involved in drafting response letters to avoid unsavory legal or compliance issues. Contents of the letter must be stated in words that show the Company’s reconciliatory intentions. In cases where any Regulator had been informed about the situation, such Regulator must be copied on all written correspondences to the complainant.

Dispute Resolution

Mega Capital Financial Services Ltd must seek ways to resolve clients' complaints amicably. The Company encourages the use of alternative dispute resolution techniques to avert public court cases that may create acrimony between the Company and its clients. This approach should be adopted where all available measures to resolve an issue have proven unsuccessful.

It is the responsibility of Senior Management to choose an appropriate and independent negotiator, mediator or arbitrator to mediate. Such person must be independent and shall not:

1. Be a former employee of the Company;
2. Perform other functions that could affect independence; and
3. Be subject to receiving instructions or be influenced by the Company.

Record Keeping and Retention — Client Complaint Log

When a complaint has been resolved, the complaint record (including details of how it was resolved) and associated correspondence must be retained for at least 7 (seven) years from the date the complaint was received, whether or not the complaint has been resolved. The date on which the complaint was resolved must be recorded, along with information on the measures taken to resolve issues logged by customers.

Framework Review

This Framework is subject to review annually, or as recommended by the SEC or NGX. The review responsibility shall be that of the Group Compliance Officer.