Client Agreement

Who We Are

This Client Agreement is between you (the investor, referred to as “you” or “the client”) and Kudimata Securities Ltd, a Nigerian company registered with the Corporate Affairs Commission. We operate a digital investment app called Kudimata Invest.

Our sponsoring broker is Blue Marina Securities Limited (CAC 746044, SEC file 1507, 10 Keffi Street, S.W., Ikoyi, Lagos). Blue Marina is a licensed broker-dealer registered with the Securities and Exchange Commission of Nigeria. We act as a sub-broker and route all trade orders through Blue Marina for execution on the Nigerian Exchange Group (NGX).

For any questions about this agreement, contact us at support@kudimata.securities.

What This Agreement Covers

This agreement sets out the terms under which we provide the Kudimata Invest app to you. It covers how to open an account, how we verify your identity, how to place orders, how to fund your wallet, how fees apply, and what happens if your account is suspended or closed. It also explains our role and the role of Blue Marina Securities.

Current Test Environment Notice

The app is currently running in a test environment and is available only to invited testers. Market data and order fills shown in the app are simulated for testing purposes. They are not real NGX market data, and no real order execution is taking place. No real money is at risk in the current test environment. When the platform moves to production, it will connect to Blue Marina Securities for real order execution and the NGX Market Data API for real prices. Live trading will begin only after SEC approval is granted and internal go live approvals are complete.

Eligibility

To open an account, you must be at least 18 years old, a resident of Nigeria, and legally able to enter into a binding contract. You must provide true and accurate information about yourself during onboarding. If any information changes after your account is opened, you must update it in the app or contact us at support@kudimata.securities.

Account Opening and KYC

To open an account, you will need to provide:

• Your email address and a password.
• Your Bank Verification Number (BVN).
• A government-issued ID (NIN, international passport, or driver’s licence).
• A live selfie taken within the app for liveness verification.

We use LumiID (with Smile Identity as an alternate provider) to verify your identity. If the automated check cannot clear your case, our staff will review your submitted documents and selfie directly. We may ask for additional information if needed.

Your KYC status is shown in the app in real time. If your application is rejected, you may resubmit a limited number of times before the case is closed.

Suitability and Risk Warnings

Before your first trade, you must complete an investor suitability questionnaire, read and acknowledge a risk disclosure, and accept this Client Agreement. The questionnaire helps us understand your investment experience and risk tolerance.

If you try to place a trade that does not match your recorded risk profile, the app will show you a warning. You must acknowledge the warning before the trade can proceed. Your risk profile will be refreshed at least every 24 months or when your circumstances change.

Investing carries risk. The value of your investments can go down as well as up. You may lose some or all of the money you invest. Past performance does not guarantee future results. We do not provide personal investment advice unless expressly stated in writing.

Our Role and Blue Marina’s Role

Kudimata Securities Ltd. is a sub-broker. We operate the app, manage your account, verify your identity, handle your wallet, and route your orders. We do not execute trades directly on the exchange.

Blue Marina Securities Limited is our sponsoring broker. Blue Marina receives your orders from us, executes them on the NGX, and returns the results. Blue Marina holds client assets and handles trade settlement.

We do not delegate our registered functions to any third party without the prior approval of the Securities and Exchange Commission.

Orders and Execution

You can place two types of orders in the app:

• Market orders buy or sell immediately at the best available price.
• Limit orders buy or sell at a specific price you choose. If your limit price is already close to the current market price, the order may fill automatically. If your limit price is away from the current market price, the order will rest in a queue for staff review before it is filled or cancelled.

In the current test environment, all order fills are simulated. No real execution occurs.

When the platform moves to production, your orders will be sent to Blue Marina Securities over a secure, encrypted connection. Blue Marina will execute them on the NGX and return the results. We will compare our records against Blue Marina’s records at the end of each trading day. Any mismatch will be investigated before the market opens the next day.

You can track the status of every order in the app from placement through fill, rejection, or cancellation.

Funding and Withdrawals

You can pay using Flutterwave. Supported methods include card, bank transfer, and USSD. You can withdraw to the bank account you have saved.

Every deposit, withdrawal, and trade settlement is recorded in your transaction history. You can view the details of each transaction in the app.

In the current test environment, no real money is moved. Funding and withdrawals are simulated.

Fees and Charges

Fees may apply to trades, funding, withdrawals, and account maintenance. All fees are shown in the app before you confirm any transaction. A full fee schedule is available in the compliance documents section of the app. We will notify you in the app before any fee change takes effect.

Statements and Records

You can download your account statements from the compliance documents section of the app at any time. We keep records of your orders, transactions, and communications in line with SEC Rule 70. Trade orders and wallet transactions are retained for 12 years. Client communications are retained for 7 years. The audit trail is retained for 12 years.

Account Restrictions or Suspension

We may suspend or restrict your account if:

• We suspect fraudulent or unauthorised activity.
• We are required to do so by law or by a regulator.
• You breach this agreement or the Terms of Service.
• We need to verify your identity or additional information.

If your account is suspended, we will tell you the reason. You can contact us at support@kudimata.securities to resolve the issue. Our staff must record a reason for every suspension or reactivation, and this reason is permanently stored in the audit trail.

Complaints

If you have a complaint, contact us at support@kudimata.securities. We will acknowledge your complaint within 1 business day and provide a substantive response within 10 business days. If you are not satisfied with our response, you may escalate to the Securities and Exchange Commission of Nigeria.

Liability

We are responsible for providing the app with reasonable care and skill. We are not liable for losses caused by:

• Market movements or the performance of any investment.
• Outages or failures at third party providers (Flutterwave, LumiID, SendGrid, Cloudflare, FiberOps Tech, Blue Marina, NGX).
• Events outside our reasonable control, including network outages, force majeure, or regulatory action.
• Your failure to protect your passcode or device.

We do not guarantee that the app will be available at all times. We will carry out planned maintenance during the notified windows and will give you notice where possible.

Changes to This Agreement

We may update this agreement from time to time. When we do, the new version will be published in the app with a new version number and effective date. You will be asked to review and accept the updated version before your next trade. The previous version you accepted will be kept in the audit trail.

Governing Law

This agreement is governed by the laws of the Federal Republic of Nigeria. Any dispute will be resolved in the courts of Nigeria, unless we agree otherwise in writing.

Acceptance

By tapping “I Accept” in the app, you confirm that you have read, understood, and agreed to this Client Agreement. Your acceptance is recorded with the date, time, device identifier, IP address, and the exact version of this document.

Document Version: 1.0 Effective Date: 17 August 2026 Owner: Kudimata Securities Ltd.