Definitions

The terms set forth below have the following meanings as used in the Customer Agreement.

"Access Means" shall mean any logon, user ID, password, and authentication device by which the Account Holder may access the Account, Account features, or Service.

"Account" shall mean each account at HALO MICROFINANCE BANK LIMITED and HALO NIGERIA CAPITAL MANAGEMENT LIMITED established in the Account Holder's name alone, in the Account Holder's name together with others, or in which the Account Holder has a beneficial interest.

"Account Application" shall mean the online or app electronic forms the Account Holder fills and submits to open an Account with HALO, including all information provided by the Account Holder to HALO in connection with the opening or maintenance of the Account, and any amendments or subsequent applications submitted by the Account Holder to HALO.

"Account Holder" shall mean the person that is specified on the Account Application and in whose name the Account is opened. You must be at least 18 Years of age to be an Account Holder.

"Applicable Law" shall mean all applicable laws, rules, and regulations of the Federal Republic of Nigeria, the Central Bank of Nigeria and the Securities and Exchange Commission and the constitution, by-laws, rules, regulations, customs, and uses of the exchange or market and its clearinghouse, if any, where any transaction for an Account is executed; and the applicable rules of any self-regulatory organization such as the Nigerian Stock Exchange.

"ATM" shall mean an automated teller machine.

"Authorized Agent" shall mean any person or entity authorized by the Account Holder to provide instructions to HALO, including without limitation any person authorized by the Account Holder to make investment or trading decisions on behalf of the Account Holder.

"Banking Services" shall mean certain Electronic Funds Transfer (as defined below), ATM, debit card, and related banking services accessible through the Account and provided by Halo Bank or other depository institution.

"Business Day" shall mean Monday through Friday, excluding bank holidays and closings. Although HALO may conduct business on bank holidays, bank holidays are not considered Business Days for purposes relating to the Banking Services.

"Cash Account" shall mean an account with the Bank in which the Account Holder makes all purchases for cash settlement, without credit.

"Cash Balance" shall mean any cash balances in the Cash Account. Halo Bank is a CBN Licensed Microfinance Bank.

"CBN" shall mean the Central Bank of Nigeria.

"Data Provider" shall mean the information processors and data consolidators from which HALO receives Market Data.

"Debit Balance" shall mean an Account balance representing amounts owed to HALO.

"Electronic Funds Transfer" shall mean any transfer of funds that the Account Holder initiates or authorizes through an electronic payment system.

"Event of Default" shall mean (i) any default on any Account Holder’s liabilities under this Customer Agreement when due; (ii) Account Holder's becoming bankrupt, insolvent, or subject to any bankruptcy, insolvency, or similar proceeding, or where all or substantially all of their assets become subject to a suit, levy, enforcement, or other legal process where a secured party maintains possession of such assets; or (iii) where any representation or warranty made or deemed made under the Customer Agreement proves false or misleading in any material respect when made or deemed made.

"Force Majeure Event" "Force Majeure Event" shall mean any act beyond HALO's control, including any earthquake, flood, severe or extraordinary weather conditions, natural disasters or other act of God; fire; acts of war; acts of foreign or domestic terrorism; insurrection, riot, strikes, labor disputes, or similar problems; accident; action of government; government restriction; exchange or market regulation; suspension of trading; communications, system, or power failures; cybersecurity incident; epidemic, pandemic, or disease outbreak; and equipment or software malfunction.

"Losses" shall mean any and all costs, claims, liabilities, losses, judgments, awards, settlements, taxes, penalties, actions, damages, charges, expenses, or fees (including any special, indirect, incidental, punitive, or consequential loss or damage, attorney fees, and costs of collection) of any nature whatsoever.

"Market Data" shall mean all data distributed by HALO regarding bids, offers, and market transactions and all information based on any such data.

"Password" shall mean personally selected confidential password which restricts access to the Account to authorized persons.

"PIN" shall mean personal identification number.

"SEC" shall mean the Nigerian Securities and Exchange Commission.

"Service" shall mean the banking services Halo Bank may offer from time to time and the investment and asset management services that Halo Asset Management may offer from time to time and other services that HALO may offer from time to time.

General Account Terms

I/We ("Account Holder"') hereby confirm and agree to the following terms and conditions in relation to all banking and other financial transactions between me/us and Halo Micro Finance Bank ("the Halo Bank" or "Bank").I/We further agree that where the, services to be provided by the Bank are not regulated by the Terms and conditions of this Account Opening Agreement or any other Agreement including the Electronic Banking User Agreement, they shall be regulated by customary banking practices in Nigeria. These terms are applicable to all accounts opened with Halo Microfinance Bank Ltd (“The Bank”) and all banking transactions between the Account Holder and the Bank.

Account Holder hereby confirm and agree to the following terms and conditions in relation to all investments, asset management and other financial transactions between me/us and Halo Nigeria Capital Management Limited ("the Halo Asset Manager"). These terms are applicable to all accounts opened with Halo Nigeria Capital Management Limited ("the Halo Asset Manager") and all transactions between the Account Holder and Halo Asset Manager.

1.I/We hereby apply to open an account for banking and related financial services of the Bank. The Bank shall have no obligation to open, create or permit the operation of the requested account until receipt of all specified requirements for the account. The Bank reserves the right to reject the creation of the account or close the close the account (if it has been opened) where any information supplied is found to be false, incorrect or misleading.

2. We hereby apply for the opening of an account for investment and asset management with Halo Nigeria Capital Management pursuant to the applicable terms and conditions. Halo Asset Manager shall have no obligation to open, create or permit the operation of the requested account until receipt of all specified requirements for the account. Halo Asset Manager reserves the right to reject the creation of the account or close the close the account (if it has been opened) where any information supplied is found to be false, incorrect or misleading.

3. /We declare that the information given in this account opening form is true.

4. I/We agree that any information found to be false, incorrect or misleading may cause the Bank to reject this application or close my/our account if it had been opened.

5. I/We agree that any information found to be false, incorrect or misleading may cause the Halo Asset Manager to reject this application or close my/our account if it had been opened.

6. The Account Holder agrees to promptly notify the Bank and Halo Asset Manager of any subsequent change in any of the account information supplied.

7. The Account Holder agrees to maintain the minimum balance and all other conditions applicable to all accounts, including Savings, Current and Domiciliary and the Bank, at its sole discretion reserves the right to close the account where the conditions are not maintained or where the account has been operated illegally or to further a criminal activity.

8. The Account Holder agrees that unless there is an agreement in writing with the Bank, only tellers sitting across the counters are authorized to handle cash and cheque transactions. The Account Holder further agrees that the Bank will not be liable for funds handed over to unauthorized staff outside normal banking hours and/or outside the Bank premises.

9. The Account Holder agrees to assume full responsibility for the genuineness, correctness and validity of all endorsements appearing on all cheques, orders, bills, notes, negotiable instruments, receipts and other documents deposited in the Account Holder’s account.

10. The Account Holder agrees to be personally liable for the repayment of any overdraft with interest or obligation arising from or in connection with the account and the Bank is hereby authorized to debit the Account(s) with all interest, commission and/or other banking charges (including legal charges) incurred in connection with the account.

11. The Bank is hereby authorized to undertake all "Know Your Customer" KYC procedures specified by applicable law and regulations and Bank policies including the confirmation of Customer's details and legal status at the appropriate government entity or parastatal. I/We hereby authorize the Bank to debit Customer's account without further notice to Customer for the attendant costs of such KYC procedures.

12. The Bank may, without prior notice, increase or change the minimum balance requirements for Customer's account(s) or alter the applicable interest rate (s) for or the charges relating to such account(s) or any of them.

13. The Bank Is authorized to transfer money from any deposit or other account Account Holder maintains to any other account(s) Account Holder maintains with the Bank whose balance is below the required minimum.

14. The Account Holder agrees that In addition to any general lien right of set-off or similar right prescribed by law, the Bank shall be entitled, without notice, to combine and consolidate all or any of Account Holder's account (s) including but not limited to cash, cheques, valuables, deposits, securities, negotiable Instruments or other assets belonging to Account Holder with the Bank (without any liabilities to the Bank) and/or to set off or transfer any or all amounts owed by Account Holder or related party to the Bank against any and all money which the Bank may hold for Account Holder's account or any other credit be it cash, cheques, valuables deposits, securities negotiable instruments or other assets belonging to Account Holder whether held on current deposit, or other account whether in Naira or any other currency hereinafter referred to as "foreign currency").

15. When effecting any set-off the Bank shall be entitled at Its absolute discretion, with or without notice to Account Holder to convert any Naira or foreign currency into the currency in which the amount owed was incurred applicable official exchange rate for the currencies in question prevailing in Nigeria at the time of such conversion.

16. The Bank shall be and is hereby instructed to act on any Instructions given on behalf of Customer for or in relation to Customer requiring foreign exchange including but not limited to: the purchase or sale of any foreign exchange; the opening from time of documentary letters of credit to

the intent that this shall not be a general authority but shall require specific instructions; the signing and settlement of exchange contracts; and the signing and obtaining delivery of merchandise against t rust receipts.

17. Customer undertakes to provide all exchange control documents that would be required for any business requiring foreign exchange and further undertakes to indemnify HALO for any loss, liability, damage or expenses resulting from the Customer's default.

18. The Customer agrees to hold the Bank harmless and free from any responsibility for any loss of funds deposited with the Bank due to any future governmental order. law. levy, tax, embargo. Exchange restriction or other cause beyond the Bank's control.

l9. The Bank shall be entitled to retain and not repay any amount whatsoever that is owed to Customer or which the Bank holds on Customer's behalf and until all amounts owed by Customer or the related party to the Bank have been repaid or discharged in full and, for so long as such amounts have not been discharged or repaid In full, the Bank shall be entitled to appropriate any amounts so owed to Customer or held on Customer's behalf In or towards the payment and discharge of the amounts owed by Customer or the related party to the Bank.

20. Where the Bank, in the absence of any previous agreement as to rate of interest and costs and charges that will apply If Customer's account (s) becomes overdrawn, in its absolute discretion allows Customer to make any drawing that results In Customer's account (s) becoming overdrawn, the Bank shall be entitled to charge such rate of interest and Impose such charges as, in its absolute discretion, I considers appropriate in the circumstances and Customer agrees to pay such interest and charges to the Bank on demand.

21. The Bank shall not be held liable for any loss of funds deposited with the Bank due to any future governmental order, law, levy, tax, embargo, moratorium, exchange restriction and all other causes beyond the Bank’s control.

22. In addition to any general lien or similar right, to which the Bank as a banker may be entitled by law, the Bank may at any time and without notice to the Account Holder combine or consolidate all or any other accounts with any liabilities to the Bank and set off or transfer any sum or sums standing to the credit of the Account Holder or other related parties towards satisfaction of the Account Holder’s liabilities to the Bank whether such liabilities be actual or contingent primary or collateral and several or joint.

23. The Account Holder agrees to repay any facilities obtained from the Bank as and when due. Where the Account Holder fails to repay the facility as agreed, and the facility becomes delinquent, the Bank shall have the right to report the delinquent facility to the CBN through the Credit Risk Management System (CRMS) or by any other means, and request the CBN to exercise its regulatory power to direct all banks and other financial institutions under its regulatory purview to set-off the Account Holder’s indebtedness from any money standing to the credit of the Account Holder in any bank account and from any other financial asset they may be holding for the Account Holder’s benefit.

24. The Account Holder covenants and warrant that the CBN shall have the power to set-off any of the Account Holder’s indebtedness from all such monies and funds standing to the Account Holder’s credit/benefit in any and all such accounts in other banks or from any other financial assets belonging to the Account Holder and in the custody of any such bank.

25. The Account Holder hereby waives any right of confidentiality whether arising under common law or statute or in any other manner whatsoever and irrevocably agrees not to argue to the contrary before any court of law, tribunal, administrative authority or any other body acting in any judicial or quasi-judicial capacity.

26. The Account Holder shall not issue cheques without adequate funds in the account and the Account Holder shall accept all responsibility and liability arising from the issuance of cheques. The Bank shall be obligated to report the issuance of dud cheques to relevant Credit Bureau Registries and Security Agencies for investigation and prosecution.

27. If any cheque credited to the Account Holder’s current account is returned dishonoured, the same may be returned to the Account Holder through the last known address either by bearer or post.

28. The Account Holder agrees to be bound by these and other terms and conditions regulating the operations of the bank account(s) and other financial services including but not limited to Electronic Banking, Mobile Banking, Card services, Telephone Banking, Automated Teller Machines and Money Transfer services.

29. The account relationship hereby established shall be governed and construed in accordance with Nigerian laws and by reference to the accepted principles and practices of banking.

30. Any claim in respect of any dispute, differences or controversy arising out of or relating to or in connection with the opening and operation of the accounts shall be referred to arbitration in Nigeria under the Arbitration and Conciliation Act Cap A18, LFN 2004. The dispute shall be resolved by a sole arbitrator to be appointed by the Chairman of the Chartered Institute of Arbitrators UK (Nigerian Branch) and the Award/Decision of the arbitrator shall be final and binding on the parties. The language to be used in the arbitral proceedings shall be English. Notwithstanding anything to the contrary anywhere in these terms, the Bank reserves the right to elect to bring legal proceedings against the Account Holder in any court of competent jurisdiction in respect of any dispute arising out of relating to or in connection with these terms and conditions:

31. Provided that in the event of any disputes, no suit or proceedings of any kind shall be brought against the Bank or Halo Asset Manager by the Account Holder before the expiration of a period of thirty (30) days after written notice of intention to commence the suit (Claim Notice) shall have been served on the Bank or Halo Asset Manager by the Account Holder or its agent; and such notice shall clearly and explicitly state the cause of action, the particulars of the claim and the relief which it claims against the Bank or Halo Asset Manager.

32. The Bank and Halo Asset Manager reserve the right to apply restrictions to the accounts and make necessary disclosures to appropriate legal, regulatory and tax authorities at any time. If an Account Holder is or becomes resident in the US, the Account Holder shall promptly notify the Bank and complete and return to the Bank as soon as reasonably possible any relevant US tax or waiver documentation that applies to the Account Holder and/or relevant US tax or waiver documentation which the Bank may request from time to time.

33. It is agreed that the Bank and Halo Asset Manager shall have the right to modify the nature, conditions and stipulations of these general terms and conditions including the rate of interest, commissions and other conditions to any account by written notice to the Account Holder or by notice posted on the HALO website. Any such amendments shall be binding on the Account Holder from the date of the said notice whether or not the Account Holder actually received the notice.

ELECTRONIC BANKING & TRANSACTIONS AGREEMENT

I/We (“Account Holder”) hereby confirm and agree that the following terms and conditions shall govern my/our electronic banking transactions with Halo Microfinance Bank Ltd (“the Bank”):

“Access Code” means either the PIN, Password, Internet Token code, Secure Message (Email and SMS) codes, Username, Card Verification Value (CVV) or Card Verification Code (CVC) through which the Account Holder will access the Service.

“Account” means a current or savings account or other account(s) maintained with the Bank at any of the Bank’s branches in Nigeria.

“ATM” means Automated Teller Machine that dispenses cash to or receives cash/cheque from account holders with the use of a debit card or credit card.

“ATM Card” means the credit or debit card used by an Account Holder for processing transactions through the ATM and via the internet.

“Mailing Address” means the Account Holder’s mailing address in the Bank’s record as updated from time to time.

“PIN” means your personal identification number.

“POS” means Point of Sale.

“Secure Message Facility” means the facility within the e-Banking Service that enables the Account Holder to send electronic messages (mobile app interface, web app interface, e-mail, SMS and other similar means) to the Bank, including without limitation free-format messages, fixed format messages or instructions to make payments, requests to for cheque books, banker’s drafts or the purchase and sale of securities and interest in mutual fund.

“Service” means the Electronic Banking and Related Services of the Bank and its affiliates including mobile apps, web apps, ATM and POS services, Internet Banking, Telephone Banking, Mobile Banking. Secure Message Facility, USSD Banking and Bills Payment Services.

The Service allows the Account Holder to give the Bank instructions by use of the Access Codes through telephone, mobile app, secure message (Email and SMS) and USSD services for the following purposes of:

a. Obtaining information regarding Account Holder balances at the last date of business with the Bank.

b. Obtaining information regarding any instrument in clearing, or any credit standing in the Account Holder’s account as the last date of transaction on the said Account Holder’s account.

c. Authorizing the Bank to debit the Account Holder’s account to pay specified utility bill such as Telephone bills, Electricity bills, Water Rates and/or any other bills as specified by the Account Holder subject to validity of such bill payment under the Service.

d. Authorising the Bank to effect a transfer of funds from the Account Holders’ account to any other account with the Bank or any other bank.

e. Authorizing the Bank to effect any stop payment order.

f. Authorizing the Bank to debit Account Holders’ account and load same amount into a debit card.

The Bank on its part shall endeavour to carry out the Account Holder’s instruction promptly, except in unforeseen situations such as Act of God, force majeure, system failure and any other causes outside of the Bank’s control

The Account Holder understands that his/her Access code is used to give instructions to the Bank and accordingly undertakes:

That under no circumstance shall the Access code be disclosed to a third party. Not to write the Access Code in order to avoid same being compromised. The Account Holder instructs and authorizes the Bank to comply with any instructions given to the Bank through the use of the Service. Where an Account Holder notifies the Bank of his/her intention to change his/her Access Code arising from loss of memory of same, or that it has become known to a third party. the Bank shall with the consent of the Account Holder delete same and thereafter, allow the Account Holder to enter a new Access Code PROVIDED that the Bank shall not be responsible for any loss that occurs between the period of such loss of memory of the Access Code or its being authorized to a third party and the time a report is duly lodged with the Bank. The Account Holder shall bear full responsibility for any instruction given by any means of his/her Access codes. Accordingly, the Bank shall not be liable for any fraudulent, or erroneous instructions received by means of the Account Holder’s Access codes. The Account Holder’s Access code must be changed immediately before it becomes known to any third party. The Account Holder is therefore obliged to notify the Bank whenever his/her Access Code and or password becomes compromised. The Account Holder may be charged an applicable monthly fee and/or usage fee upon signing-on for the Services whether or not the Account Holder utilizes the Services during the period in question. The Bank shall not be liable for any loss or damage, whether direct or indirect, special, incidental or consequential including but not limited to damages for loss of profits, goodwill, use or other intangible losses arising out of or in connection with the Services or use or inability to use the Service, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation, transmission, computer virus or line or system failure, whether or not the Bank or its representatives thereof were advised of the possibility of such damages.

The Account Holder undertakes:

To, always, provide true, accurate, and up-to-date information about himself/herself as requested by the Bank, and agrees not to misrepresent his identity or information, which may include user name, password or other access codes for such accounts. Not to use the Services for illegal purpose or for transmission of material that is unlawful, libelous and obscene and further agrees that the right use of this Services is personal and not assignable or transferable. In consideration of the Bank providing the Services, the Account Holder further agrees:

That where an ATM Card is issued to the Account Holder, the card shall be kept secured always and the PIN, CVV and CVC will not be disclosed to any third party for any reason whatsoever. That all transactions at any ATM, POS terminal or via the internet made with the Account Holder’s ATM card and access codes shall be treated as having been authorized by the Account Holder. That if any account that may be accessed by the Account Holder’s card is a joint account with more than one signatory, all transactions at any ATM, POS terminal or via the internet that are made with the ATM card and Access Codes shall be treated as having been authorized by all the joint holders of the account. That cash withdrawals made with the ATM Card and Access Code shall not exceed the maximum limit as may be specified by the Bank from time to time. That cash withdrawals at the ATM shall be deemed to have been concluded at the point when the ATM dispenses cash to the Account Holder via the cash tray. The Bank accepts no liability whatsoever for any subsequent event occurring after cash has been dispensed. That the ATM Card issued to the Account Holder remains the property of the Bank and the Bank at its sole discretion may cancel the ATM Card or request its return at any time. That the ATM Card will be promptly returned to the Bank on demand and that the ATM may impound the ATM Card at any time if the circumstances so warrant. That the card shall expire on the date indicated thereon and may at the discretion of the Bank, be renewed. That the Bank shall not be liable for any machine malfunction, strike or dispute or any other circumstances affecting the use of the card where such matters are not within the direct control of the Bank. To be liable for all losses arising from use of the card by any person having possession of it with the Account Holder’s consent or due to the Account Holder’s negligence.

The Bank reserves the right to charge fees and commission and debit the account of the Account Holder for such fees and commissions, as it may deem appropriate for the use of the Services. That if The ATM Card is lost or stolen, the Account Holder shall promptly make a written report to The Bank or its nearest branch and take necessary steps as the Bank may request assisting in the recovery of the card. The Account Holder further agrees to be liable for any loss arising from the use of his/her cards or PIN, CVV or CVC by any unauthorized person up to two working days after the Bank receives written notification of the loss of the card. If the ATM Card is lost, missing or stolen, or the Access Code is forgotten, the Account Holder shall promptly report such loss in writing or through the Account Holder management system to the Bank and shall obtain a new card from the Bank at a prescribed fee. That his/her rights under the Service are personal and therefore not assignable or transferable. That the Bank may vary the terms of the Service at any time without notice to the Account Holder.The Bank reserves the right to modify, suspend or discontinue the Services entirely at any time without notice. In order to maintain the security and integrity of the Services, the Bank may also suspend Account Holder’s access to the Services at any time without notice. The Account Holder agrees that the Bank shall not be liable to him/her or any third party for any modification or discontinuation of service.

ALERTS (SMS, EMAIL and IN APP)

I/We, the Account Holder(s) confirm and agree that the use of Halo Microfinance Bank Ltd (the "Bank") Alert and Statement Banking Service shall be subject to the following terms and conditions:

I hereby accept responsibility for the confidentiality and security of your alert message and shall ensure that my mobile phone is kept in safe custody and that I alone have access to alerts. The alert banking service is an information service which is given after the occurrence of all transactions; messages sent by alerts are therefore presumed and treated as having been authorised by me and the Bank shall therefore have no liability whatsoever to me. Where I operate a joint account or an account with more than one signatory for this service, all transaction messages shall be treated as having been authorized by me and the Bank shall therefore not be liable to me if it turns out that such transactions were carried out without due authorization. the Bank shall not be liable for any loss arising from my inability to receive notification messages due to system down time arising from circumstance beyond your control, including strikes and dispute; System maintenance, upgrading or similar circumstance; and failure of service provider to deliver SMS on time or other similar communication outage or delay.

I/We agree to pay the Bank fees and commission as may be specified from time to time, for the provision of this service. I hereby authorize you to debit any of my account(s) with such fees and commission. I/We agree that my/our rights under this agreement are personal and therefore not assignable or transferable. If you provide by e-mail any confidential information requested by me, I agree that you shall not be liable if the information provided is lost or intercepted, altered or misused by a third party. Where my mobile phone is lost, missing or stolen, I undertake to make a report to you within 24hours. You shall not be liable for any information that is disclosed to any person due to my negligence. You may terminate this service with or without notice if circumstances so warrant.

INDEMNITY FOR DEBIT/CREDIT CARDS

I/We have agreed to be solely liable for all consequences that might arise from the use of my card on various websites that require no pin, OTP or other conditions as determined by the merchant

I/We being mindful of the fact that circumstances could arise in the course of the usage of the Card that could lead to any loss(es) as a result from the exposure of the card details, card cloning, storage of the card’s details and possible use of the card and my/our data by unauthorized persons/parties and the carrying out of unauthorized activities using the my/our details, have agreed to execute an indemnity in favour of the Bank against any liability, loss, damage, claim or distress which the Bank may suffer in the course of the transaction.

NOW, THIS DEED WITNESSES AS FOLLOWS:

1. In consideration of the Bank providing Card based transactions to me/us, I/we hereby hold the Bank harmless and unconditionally and fully indemnifies the Bank against any liability, loss, damage, injury, claim or distress which the Bank may suffer as a result of completing the transaction.

2. I/We hereby irrevocably undertake to truly indemnify the Bank at all times and hold the Bank harmless against any loss, claims, demands, liabilities, actions, damages and in the event of the commencement of any actions, investigations and proceedings, whether civil or criminal, to bear the cost and expenses associated with such action, investigation or proceedings which may be occasioned in consequence of enabling the acceptance of my card for web transactions for sites that do not request for second level authentication and to pay and/or the Bank on demand without contestation or cavil the amount all resultant charges and I/we hereby waive all right to contest the amount or nature of claims under this indemnity.

3. To this end, I/we hereby authorize the Bank to debit my account(s) with the Bank for any such sums that the Bank may pay expend or lose under the terms of this Indemnity.

4. My/Our obligation herein shall not be reduced by any claim by me/us against the Bank, its Directors, agents, privies, assigns, successors, employees or any other person whomsoever acting under the Bank’s authority.

5. This indemnity shall be continuing security in respect of any and all matters connected to or arising from the Bank processing such Transaction[s] and shall be governed by the laws of the Federal Republic of Nigeria.

Current and Accurate Information; Account Ownership

The information the Account Holder has provided on the Account Application is current, accurate, truthful, and complete. The Account Holder agrees to notify HALO of any change to the information provided on the Account Application promptly, but in any event within 30 days of such change. The Account Holder agrees to indemnify and hold HALO harmless from and against any and all Losses arising out of or relating to the Account Holder's failure to provide true and accurate information on the Account Application or to update such information. The Account Holder further represents that no one else has an interest in the Account except for the Account Holder.

Fees and Commissions on Asset Management

The Account Holder shall be charged fees or commissions as may be applicable to the Account or any transaction in the Account based on the applicable fee related to the instruments or investment plan services offered to the Account Holder. In addition, the Account Holder agrees to pay all taxes applicable to the Account, any transaction in the Account, or the use of any Service. The Account Holder authorizes HALO to automatically debit the Account for any such fees, commissions, charges, and taxes.

The fees and charges applicable to the Account for the Service are generally set forth in the Plan Description, Product Description or Fee Schedule. The Plan Description, Product Description and Fee Schedule is available on Halo or on the Halo Invest App and is incorporated by reference into this Customer Agreement. HALO may, in its sole discretion, modify the Fee Schedule from time to time or at any time, with or without notice. Modifications to the Plan Description, Product Description or Fee Schedule are effective as of the date of publication or the effective date as otherwise indicated by HALO. Continued use of the Account or Service following modification of the Plan Description, Product Description or Fee Schedule will evidence the Account Holder's consent.

Applicable Law

All transactions in the Account are subject to Applicable Law. In no event will HALO be obligated to effect any transaction or act on any instruction that it believes would violate Applicable Law. The Account Holder agrees that HALO and the Account Holder are each obligated to comply with Applicable Law. The Account Holder acknowledges that the Service is inherently a Nigerian service, subject to Nigerian laws and regulations. HALO shall have no duty to determine whether the Account Holder is in compliance with Applicable Law, and HALO shall not be liable to the Account Holder as a result of any action or inaction taken by HALO to comply with Applicable Law. If there is a change in any Applicable Law that is inconsistent with any provision herein, the affected provision shall be deemed modified or superseded, as the case may be, by the Applicable Law, and all other provisions of this Customer Agreement shall in all respects continue in full force and effect. The Account Holder acknowledges and agrees that the Account Holder does not have a private right of action with respect to any Applicable Law.

Investment Plans, Products and Types

Halo Asset Manager offers many different investment plans, products and types. Although HALO may provide educational tools about account types, the Account Holder is responsible for selecting the investment plans, products and types that is appropriate for the Account Holder's needs and circumstances.

Traditional Investment Plans

HALO offers various Investment Plans that enable the Account Holder to invest periodically or for set periods to meet their financial goals. Investment Plans are invested in Federal Government of Nigeria bonds and bills and other money market securities (collectively “Money Market Investments”) or other instruments or securities as defined in the Plan description. The yields (interest to be earned) on the Money Market Investments and other Investments are displayed to the Account Holder prior to the Account Holder’s investment where applicable. Some investments such as investments in stocks, etc do not have interest but earn dividends and appreciation (or depreciation) in value. The nature of all such investments are described in the Investment Plan description.

Halal Investment Plans

HALO offers various Halal Investment Plans that enable the Account Holder to invest periodically or for set periods to meet their financial goals. If the Account Holder selects Halal Investment Plans the investment is made in Halal and sharia compliant investments that do not pay interest but may offer a return consistent with sharia principles.

Investment Products

HALO offers various Investment Products that enable the Account Holder to invest in funds and other securities to meet their financial goals. Investment Products are individually described setting out the investment product and the terms of the investment. Additional information of each Investment Product is set out, including, where appropriate, investment prospectus and other relevant offering documents.

Investment Account Deposits

Halo Asset Manager accepts deposits to the Investment Cash Account via transfers and debit cards processed through the Halo Invest App and Halo website. Deposits in the Investment Cash Account are to be used for the purpose of making investments in Investment Products or Investment Plans. Halo Asset Manager credits the Account Holder’s Cash Account for maturity payments, sales proceeds, interest, dividends, and other distributions on investments by the Account Holder.

Preauthorized/Automatic Deposits and Transfers

The Account Holder may agree to Preauthorized Electronic Funds Transfers to be made to the Account to facilitate and fund investments in Investment Plan(s) or Investment Product(s). The Account Holder agrees that if recurring or other electronic payments are made into the Account, the payments may be applied to the Investment Plan(s) and Investment selected by the Account Holder.

The Account Holder may request that HALO stop a previously authorized transfer to the Account by making appropriate request in the Account Holder’s account settings.

Cooperation in the Event of Loss or Fraud

The Account Holder agrees that, in the event of loss or theft or of any fraudulent occurrence in the Account, the Account Holder will report such loss or fraudulent occurrence promptly to HALO and the police. The Account Holder agrees to provide a copy of any police report to HALO on request. The Account Holder agrees to cooperate fully with the police and with HALO in any investigation of such fraudulent occurrence and will complete any required affidavits promptly, accurately, and thoroughly.

Liability for Unauthorized Electronic Funds Transfers

The Account Holder is responsible for maintaining the secrecy of their Log-in credentials including PINs or passwords. The Account Holder is responsible for informing Halo of any fraudulent activity on their account.

The Account Holder understands that, except as limited by Applicable Law, the Account Holder is liable for all unauthorized transactions made with the Account Holder's Log-In credentials that occur prior to the time the Account Holder notifies HALO that an unauthorized transaction has taken place, or that the Account Holder's password or PIN has been lost or stolen.

Interest Rate Information

Interest paid on Investment Plans are calculated using the interest rates, calculation methodology, and compounding frequency set by HALO, which are subject to change by HALO from time to time without prior notice. The current simple rate at which interest is paid on Cash Balances and on Investment Plans and the corresponding annual percentage yield at which Cash Balances and Investment Plans would earn interest each are as specified on the Halo App or the Halo. Generally, interest information is displayed net of all fees. Therefore, displayed interest rates reflect the annualized rate that the Account Holder will actually earn.

Account Statements

The Account Holder may access their Account information at any time through the Halo Invest App or the Halo website. The Account Holder may request an Account statement from HALO by making a request to HALO customer service.

Information Made Available Through the Service

The Account Holder agrees to use the Service for lawful purposes, for personal and non-commercial use, and as permitted by this Customer Agreement. The Account Holder agrees that they are permitted to store, display, analyze, post, and print the information made available to the Account Holder through the Service only for the Account Holder's own use. The Account Holder will not transmit through the Halo Invest App or Halo website any material that violates or infringes in any way on the rights of others or that would encourage conduct that may give rise to civil or criminal liability. The Account Holder will not modify, copy, publish, transmit, license, participate in the transfer or sale of, reproduce, create derivative works from, distribute, redistribute, display, or in any way exploit the Service. The Account Holder will not upload, post, decompile, reverse-engineer, disassemble, modify, copy, distribute, transmit, reproduce, republish, license, display, sell or transfer, or create derivative products from the Service.

The Account Holder will not publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of HALO. The Account Holder will not use, alter, obscure, or remove any copyright, trademark, or any other notices that are provided to the Account Holder in connection with the information. The Account Holder represents and warrants that: (i) the Account Holder will not use the Service in contravention of this Customer Agreement, (ii) the Account Holder will use the Service only for the benefit of the Account and not on behalf of any other person, and (iii) with the exception of applications specifically approved by HALO, the Account Holder agrees to not use (or allow another person to use) any software, program, application, or other device, directly or indirectly, to access or obtain information through the Service or to automate the process of accessing or obtaining such information.

Privacy Policy

The rights and responsibilities of HALO and the Account Holder regarding the collection, processing, use, retention, and disclosure of the Account Holder's personal information and the Account Holder's rights with respect to such information are set forth in the Privacy Policy published on the Halo website, as amended from time to time. Such rights and responsibilities are further defined by Applicable Law. In the event of any controversy regarding HALO's collection, processing, use, retention, or disclosure of any information about the Account Holder, the Account Holder agrees that its remedies are expressly limited to those specifically provided by Applicable Law.

Compliance with Laws

The Account Holder agrees to comply with Applicable Law. The Account Holder may not use their Account or the Service for illegal activity. The Account Holder agrees to indemnify, defend, and hold HALO harmless from every action, proceeding, claim, loss, cost, and expense (including attorney fees) suffered or incurred by HALO due to any government entity's seizing, freezing, or otherwise causing HALO to assert control over any Account or funds in an Account of the Account Holder when purportedly caused by or arising out of the Account Holder's action or inaction.

Modification of Customer Agreement or Service

HALO may amend or terminate this Customer Agreement at any time subject to Applicable Law. Any amendment to or modification of this Customer Agreement will be posted to Halo when made and will be effective as of the effective date noted therein.

Severability, Waiver, and Effectiveness

If any provision of this Customer Agreement is held to be invalid, void, or unenforceable by reason of any law, rule, administrative order, or judicial decision, that determination will not affect the validity of the remaining provisions of this Customer Agreement. No provision of this Customer Agreement can be, nor will it be deemed to be, waived, altered, modified, or amended.

Consent to Electronic Approval and Electronic Delivery

The Account Holder agrees to electronic consent, electronic signatures and other consent provided by electronic means on the Halo Investment App and Halo website as valid and binding consent to the actions or agreements thereby consented to. The Account Holder also agrees to electronic delivery of contracts and account or other information on the Halo Investment App and Halo website or by email. By agreeing to electronic delivery, the Account Holder is giving their informed consent to electronic delivery of all Account Communications (as defined below). "Account Communications" means all current and future Account statements, trade confirmations, notices, disclosures, regulatory communications (including prospectuses, proxy solicitations, and the Privacy Policy and any updates thereto), and other information, documents, data, and records regarding the Account and the Service (including amendments to this Customer Agreement) delivered or provided to the Account Holder by HALO.