Whistleblowing at NASD

Our Commitment is to Protect the Integrity of Our Market

At NASD PLC, we are committed to upholding the highest standards of integrity, transparency, fairness, and ethical conduct within the Nigerian capital market. Accurate reporting and responsible conduct are essential to maintaining investor confidence, strengthening market integrity, and protecting the reputation of the NASD OTC Exchange.

We encourage employees, market participants, members, investors, and the public to report any suspected misconduct, unethical behaviour, regulatory breaches, or violations of applicable laws and policies. By speaking up, you contribute to a more transparent, accountable, and trusted marketplace.

All reports made in good faith are treated seriously and with appropriate confidentiality. We are committed to ensuring a safe, confidential, and respectful reporting process for everyone who chooses to speak up.

Whistleblowing — Reasons to Contact Us

We encourage employees, market participants, investors, and the public to report any suspected misconduct, unethical behaviour, transparency, or operations of NASD PLC and the NASD OTC Market. Examples of concerns that may be reported include, but are not limited to, the following:

• Violations of the Investments and Securities Act (ISA), NASD Rules, or SEC rules and regulations
• Fraud, insider trading, bribery, corruption, or other forms of misconduct
• Conflicts of interest, abuse of office, or unethical business practices
• Market manipulation or unfair trading activities
• Breaches of NASD policies, professional standards, or regulatory obligations
• Financial irregularities, misrepresentation, or concealment of information

Reports may be submitted through our confidential whistleblowing channels. Individuals may choose to remain anonymous, and all disclosures made in good faith will be handled with appropriate confidentiality and seriousness.

Submit A Report

How Your Report Will Be Handled

Once a report is submitted, it is reviewed through a structured and confidential process to ensure every concern is handled fairly, professionally, and objectively. NASD will typically:

1. Acknowledge receipt of the report where contact details are provided.
2. Review and assess the information submitted to better understand the concern raised.
3. Conduct an impartial investigation where necessary and appropriate.
4. Take corrective, disciplinary, or regulatory action where a report is substantiated.

We are committed to treating every report with seriousness, fairness, and confidentiality. Information shared will only be disclosed to individuals directly involved in reviewing, investigating, or resolving the matter.

NASD strictly protects individuals who report concerns in good faith and prohibits retaliation of any kind against whistleblowers.

Where disclosure is required by law or regulatory obligation, we will take all reasonable steps to safeguard your identity and confidential information.