Consumer Duty and Treating Customers Fairly

• FIDBANK UK as an authorized financial services institution, has a strong focus on customer satisfaction. Our mission is to be a respected and recognised bank, and our Consumer Duty (the Duty) and Treating Customers Fairly (TCF) policy is integral to that objective.
• Our TCF policy is structured according to the principles provided by the Financial Conduct Authority to ensure we consistently deliver fair outcomes to our customers who may be out of the scope of the Duty. FIDBANK UK will continue to ensure that the fair treatment of those customers is central to the firm’s activities.
• The FCA introduced a new Consumer Principle 12 under the Duty that requires firms to act to deliver good outcomes for retail customers. The Duty imposes a higher and more exacting standard of conduct on firms that is supported by the three cross-cutting rules: to act in good faith, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives. FIDBANK UK will, therefore, imbibe the standards set under the Duty to give retail customers good outcomes.
• The Chief Executive and the Management Risk Committee (the “MRC”) of FIDBANK UK have responsibility for reviewing the Duty and TCF Policy Statement in the light of developments in FIDBANK UK's economic environment, business activities, organisation, infrastructure, risk mitigation techniques and applicable regulations. Ultimate responsibility for the Duty and TCF Policy Statement rests with the Board of Directors of FIDBANK UK.
• The purpose of this Duty and TCF Policy Statement is to provide information and background on how we deal with these important FCA initiatives designed to ensure that firms treat customers fairly, protect consumers and promote more customer-focused products and services in every aspect of their business. It affirms FIDBANK UK's commitment to achieving the desired outcomes of the Duty and TCF and sets out the Bank's strategy for achieving those outcomes.
• We acknowledge that the FCA considers Consumer Duty and TCF cultural issues and that senior management will only succeed in achieving the desired outcomes if the Duty and TCF are firmly embedded in the firm's culture. The key cultural drivers are Leadership, Strategy, Management and Controls, and "Tone from the Top".

FIDBANK UK is focused on delivering the following outcomes for its customers:

• Customers are confident that they are dealing with a bank where the fair treatment of customers is central to the bank's culture
• Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly
• Customers are given clear information and are kept appropriately informed
• We do not provide our customers with advice as our regulatory scope of permission does not allow us to do so
• Customers are provided with products that perform as they have been led by FIDBANK UK to expect, and the associated service is of an acceptable standard

Customers do not face unreasonable post-sale barriers to change products, switch providers, submit a claim or make a complaint. The duty supports these additional outcomes:

• Customers are provided with products and services that offer fair value: consumers receive fair prices and quality
• Customers receive suitable products and services and receive good treatment
• Customers have strong confidence and levels of participation in the products and services we offer to them
• We design and offer products and services to meet diverse consumer needs

We care about our customers, and for that reason

• C- Customer First
• R- Respect
• E- Efficiency
• S- Shared Ambition
• T- Tenacity

We refer to these as "Our CREST Values"

FIDBANK UK is committed to complying fully with the FCA Conduct of Business, TCF and Consumer Duty rules and encouraging a culture of fairness and friendliness towards its customers. That:

• Customers should clearly understand the nature of the services we provide, including our terms, conditions and tariff or charges
• Customers should clearly understand the risks inherent in, and benefits from, any product offered to them
• We must communicate in an open, transparent and easily understandable manner and have a clear understanding of our customers' banking and service requirements
• We will not promise to provide services which we are not able or equipped to deliver

Underpinning the Duty outcomes are three cross-cutting rules that further set out how FIDBANK UK will act to deliver good outcomes for retail customers under the Duty. That:

• Customers are confident that we will act in good faith towards them - We will be honest, fair and open in our dealing and act consistently with the reasonable expectations of our customers
• We will act to avoid causing foreseeable harm to our customers through our actions and omissions
• We will enable and support retail customers to pursue their financial objectives in relation to our products or services throughout the customer journey and life cycle of our products or services

Staff members are encouraged to keep customer interests as the focal point of their work. As such:

• Training and competence programs will reinforce the standards of the Duty and the fair treatment of customers.
• Our staff will possess the competency to deliver TCF-friendly products and products that comply with the Duty.
• We will resolve errors and complaints as quickly as possible, and our complaints process must be clear, unambiguous and impartial.
• Staff behavior that results in unfair treatment of customers or poor outcomes for retail customers will not be tolerated and may result in action being taken against the individual concerned.
• We will implement control procedures and management information to enable management to monitor the effectiveness of compliance with this policy.

We handle complaints fairly and record, monitor and report them sensibly. In dealing with complaints, we undertake to identify common underlying causes of complaints and take action to eliminate the root cause. We consider whether an error might have affected a wider class of customers and what should be done to remedy this. Senior management pays attention to the outcomes of complaints, which can serve as an important source of intelligence about the health of our business and internal processes. We measure the length of time taken to deal with a complaint, the outcome, and the way in which the outcome is communicated to the customer to ensure that we are treating our customers fairly.

The FCA defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. This means that anyone can become vulnerable at any point in their lives for many different reasons e.g. illness (including mental health issues), bereavement, financial difficulties, or loss of employment. If we become aware that a customer or potential customer may be vulnerable through a change in personal circumstances, we take reasonable actions to ensure that such customers are not at risk of undue detriment. Our customer-facing staff are trained in TCF and Duty principles, which helps them identify and consider aspects of vulnerability and what remedial steps may be taken where vulnerabilities are suspected or identified in line with the FIDBANK UK Vulnerable Customers policy.

Since November 2024, the FCA has strengthened expectations under the Consumer Duty relating to vulnerability management, including firms' responsibility to evidence how they identify vulnerable customers, tailor communications, and monitor outcomes. FIDBANK UK will ensure these enhanced standards are embedded into customer journeys, record-keeping and staff training processes.

Senior Management:

• prescribes and oversees a risk management process and methodology for the identification of risks and the design and documentation of effective mitigating controls
• regularly reviews the management information needs of the Bank to ensure that MI produced are relevant to its risks
• ensures it is available to all relevant team members training and coaching which equips them to understand their responsibilities
• regularly reviews and oversees staff remuneration including those related to performance, to ensure consistency with the Bank’s Duty and TCF approach
• ensures that the Bank rigorously promotes our customers core values to embed a culture of achieving good customer outcomes and Treating Customers Fairly.

Signed

Johnson Ememandu

MD/CEO