ABOUT THIS POLICY: This policy explains when and why we collect personal information about our shareholders, investors and staff, how we use it and how we keep it secure and their rights in relation to it.

We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you. We reserve the right to amend this Data Privacy Policy from time to time without prior notice. We may be required to amend this Data Privacy Policy due to regulations. For any significant changes you will be notified but you are advised to check our website for the latest Privacy Policy. KINDLY CLICK FOR THE DATA PRIVACY POLICY à https://www.ficml.com/docs/Data-Privacy-Policy.pdf

THE PURPOSE OF THE POLICY: This Data Protection Policy states the basic principles on data protection for First Integrated Capital Management Limited . Ensuring data protection is the foundation of trustworthy business relationships and the reputation of First Integrated Capital Management Limited as an attractive employer.

It ensures the adequate level of data protection prescribed by the European Union Data Protection Directive and the Nigeria Data Protection Regulation 2019 for cross-border data transmission, including in countries that do not yet have adequate data protection laws. KINDLY CLICK FOR THE DATA PROTECTION POLICY à https://www.ficml.com/docs/Data-Protection-Policy.pdf

DATA SUBJECT ACCESS REQUEST POLICY

ABOUT THIS POLICY: SCOPE, PURPOSE AND USERS: This procedure sets out the key features regarding handling or responding to requests for access to personal data made by data subjects, their representatives or other interested parties. This procedure will enable First Integrated Capital Management Limited (further: “Company”) to comply with legal obligations, provide better customer care, improve transparency, enable individuals to verify that information held about them is accurate, and increase the level of trust by being open with individuals about the information that is held about them.

This procedure applies broadly across all entities or subsidiaries owned or operated by the Company but does not affect any state or local laws or regulations which may otherwise be applicable. This procedure applies to employees that handle data subject access requests such as the Data Protection Officer. KINDLY CLICK FOR THE DATA SUBJECT ACCESS REQUEST POLICY à https://www.ficml.com/docs/Data-Subject-Request-Policy.pdf

DATA BREACH POLICY

INTRODUCTION: First Integrated Capital Management Limited collects, holds, processes, and shares personal data, a valuable asset that needs to be suitably protected. Every care is taken to protect personal data from incidents (either accidentally or deliberately) to avoid a data protection breach that could compromise security.

Compromise of information, confidentiality, integrity, or availability may result in harm to individual(s), reputational damage, detrimental effect on service provision, legislative non-compliance, and/or financial costs. KINDLY CLICK FOR THE DATA BREACH POLICY à https://www.ficml.com/docs/Data-Breach-Policy.pdf

PRIVACY NOTICE

SCOPE: All data subjects whose personal data is collected, in line with the requirements of the Nigeria Data Protection Regulation.

Responsibilities - The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to First Integrated Capital Management Limited collecting/processing their personal data. All Employees/Staff of First Integrated Capital Management Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured. KINDLY CLICK FOR THE PRIVACY NOTICE à https://www.ficml.com/docs/Privacy-Notice.pdf

DATA SUBJECT DISCLOSURE FORM

KINDLY CLICK FOR DATA SUBJECT DISCLOSURE FORM à https://www.ficml.com/docs/Data-Subject-Disclosure-Form.pdf