Whistleblower Policy

Purpose of the Policy

The purpose of this policy is to encourage individuals to report, in good faith, any wrongdoing or malpractice that may adversely affect the Company, its stakeholders, or the public.

SECAP is committed to complying with all applicable laws and regulatory requirements, including guidelines issued by the Central Bank of Nigeria (CBN), and promotes a culture of ethical conduct, accountability, and transparency.

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Scope

This policy applies to all employees, directors, management, contractors, vendors, customers, and other stakeholders of SECAP.

It is intended for reporting serious concerns relating to misconduct or regulatory breaches and should not be used for personal employment grievances, which should be addressed through established HR procedures.

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What Can Be Reported

You are encouraged to report any concerns including, but not limited to:

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• Fraud, theft, or financial mismanagement
• Breach of laws, regulations, or regulatory directives
• Insider abuse or unethical conduct
• Bribery, corruption, or conflict of interest
• Misuse of company assets
• Conduct that poses a risk to the public or financial system
• Violations of internal policies and procedures
• Attempts to conceal any of the above

All reports must be made in good faith and with reasonable belief that the information disclosed is true.

How to Report

This policy applies to all employees, directors, management, contractors, vendors, customers, and other stakeholders of SECAP.

It is intended for reporting serious concerns relating to misconduct or regulatory breaches and should not be used for personal employment grievances, which should be addressed through established HR procedures.

‍Reporting Channels

Concerns may be reported through the following channels:

‍Email: whistleblowers@stillearthcapital.com

• Online Submission: Use the secure form below
• Regulatory Channel: anticorruptionunit@cbn.gov.ng (for matters involving senior management or the Board, where necessary)

Where possible, reports should include relevant details such as:

Date, time, and location

• Persons involved
• Nature of the concern
• Supporting information or evidence

Reports may be made anonymously; however, providing contact details may assist in investigation and feedback.

Whistleblowers who suffer any detriment as a result of reporting may be entitled to appropriate remedies in line with applicable laws and regulations.

Confidentiality & Protection

SECAP is committed to protecting whistleblowers who report concerns in good faith:

• All disclosures will be treated with strict confidentiality
• Anonymous reporting is permitted
• The Company prohibits retaliation, victimization, or harassment of any whistleblower
• Any act of retaliation will be treated as a serious violation and may result in disciplinary action

Whistleblowers who suffer any detriment as a result of reporting may be entitled to appropriate remedies in line with applicable laws and regulations.

How Reports Are Handled

All reports will be handled in a structured and timely manner:

• Reports are reviewed and assessed upon receipt
• Where applicable, acknowledgment is provided within five (5) business days
• Investigations are conducted by authorized personnel or committees
• Appropriate corrective or disciplinary actions are taken where necessary

Investigations may involve internal review, the Audit Committee, or relevant regulatory authorities where required.

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For more detailed information, please refer to the full Whistleblowing Policy document: