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ETHICS AND COMPLIANCE MESSAGE

The “Ethics & Compliance Message” is a message to remind all employees of the need to comply with all
applicable laws, regulations, corporate ethical standards and policies in the conduct of our business. It is
imperative that every one of us focuses on compliance as an integral part of our business responsibility.
The protection of our franchise and the sustainable growth of our business as well as delivering on our
business goals are dependent on conducting our operations within the letter and spirit of all laws,
regulations, ethics and policies that apply to and govern our activities. It is important that we conduct
our activities and discharge our duties and functions in line with these laws, regulations, ethics and
policies. We are required to be familiar with the following:

The Compliance Manual

The Identities of the Compliance Resource Officers within the Bank

Whistle Blower Telephone Numbers/Email addresses

Access Bank Anti-Bribery and Corruption Policy

UK Bribery Act

Corrupt Practices and Other Related Offences Act

U.S. Foreign Corrupt Practices Act etc.

Policy on Activities on Staff Account(s).

Staff Handbook

Declaration of Asset

Declaration of Gift

Group Information System Security

Ethics and Conflict of Interest Policy

Market Abuse and Insider Dealing Policy

Access Bank Code of Conduct

Consequently, I am forwarding the information as a five-part appendix to this Memorandum.

Part A of the appendix is the Compliance Policy Statement which you should retain. Part B of the
appendix contains the identities of the Bank’s Compliance Resource Officers. These officers are available
to provide guidance to staff on all Compliance risk related issues. Everyone is encouraged to contact
them as necessary.

Part C is the information on the whistle blower hotlines and email addresses. Part D contains the
Attestation Form and the required policies and applicable laws all staff must be familiar with.

Part E contains red flags for lifestyle monitoring of all staff for Managers and Above. It also contains the
account declaration field which requires employees to input their related staff account (If any) and
check the necessary box before submitting on the electronic link provided for this purpose.

All members of the Management team in all Access Bank businesses globally have direct responsibility
to ensure that activities under their oversight are undertaken and carried out in a manner consistent
with our Compliance Manual, while the Country, Subsidiary, Group and Departmental Heads have
primary responsibility for compliance in the country, subsidiary, group and department respectively.
Each department has a Compliance Officer who provides first line guidance for the group and
departmental staff. Furthermore, each Branch Manager and the Branch Conduct & Compliance staff are
the Conduct & Compliance Officers in each respective branch with the Back-up Branch Manager as the
back-up Compliance Officer.

Every staff should report without fear of retribution any suspected violation of the Compliance Manual
or any wrongdoing by another staff of the Bank to the Chief Conduct & Compliance Officer or through
the Bank’s whistle blowing channels.

Supervisors should print and circulate hard copies of this reminder to all staff who do not presently have
e-mail access.

PART A: COMPLIANCE POLICY STATEMENT

The purpose of this memorandum is to reinforce and underscore our commitment to compliance with
corporate governance principles; code of professional conduct; ethical standards and policies, and with
the laws and regulations that affect our business activities both locally and internationally.
As you know, it is the Policy of Access Bank that all activities must comply with the legal and regulatory
framework to which we are subject and, we must maintain high personal, professional and ethical
standards. Ignorance of laws, regulations and internal policies is no excuse for non-compliance. The
cornerstone of this Policy Statement is individual responsibility at every level, including at management
and non-management levels, as described below.

Each employee is responsible and accountable as an individual for:

Understanding and complying with the ethical standards established by Access Bank and stated in the
Compliance Manual and in the Code of Conduct which is made available to all employees. In addition, all
staff must ensure that they, attend at least one compliance training or program in the year; in house and
external courses, e-learning, webcast, seminars, conferences, etc. The Bank will ensure that all Directors
and employees within the Group are trained and extend same to its vendors and customers.

Understanding and complying with the Bank's Corporate Governance Framework, all the laws, rules,
regulations and business standards that apply to the employees’ function as may be imposed by
Nigerian laws and regulations, as well as local laws and regulations in respective jurisdictions where we
maintain presence.

Consulting with supervisor, legal counsel and compliance officer, as appropriate, when there are
questions regarding compliance or concerns of compliance failure or violation.

Managers are additionally responsible for:

Providing their staff with compliance instruction, advice and guidance, including referral to legal
counsel or compliance resource as necessary.

Conducting periodic self-assessments of compliance within their areas of responsibility.

We have established a Compliance Program that is informed by Access Bank’s Policies and standards as
well as the requirements of applicable Laws and Regulations. An essential element of this program is an
effective and on-going process of self-assessment. A committee made up of appointed Compliance
Resource Officers meets quarterly to review specific compliance issues facing the business and monitor
the Bank’s progress in implementing corrective action where required. All countries are required to put
in place similar and appropriate structures in their respective jurisdictions.
We must constantly remind every staff of Section 1.18.1.2 of the newly amended Money Laundering
(Prohibition) Act 2011 and Terrorism (Prevention) Act 2011 gazette by the Federal Government, which
provides that no financial institution or its officers shall benefit from violation of extant AML/CFT laws
and regulations.

The Compliance culture in the Bank is in line with international best practice and set priorities for the
management of compliance risk is consistent with this fact. The Board has set the right tone for
compliance transformation and sustainability and carried along all the relevant stakeholders in line with
the bank’s strategy of “promoting good corporate governance”.

Management’s priority for us all is to focus on driving and delivering sustainable liability growth and
profitability across the business. This is vital given the nature of the regulatory headwinds and increased
dawn raids/spot checks observed in recent times. We need to achieve a 100% target whilst still in full
compliance and observing of good personal conduct.

The offer, promise, payment, transfer, request, agreement to receive anything of value, whether directly
or indirectly, to or from any person (whether a private person, corporate entity, or public official), in
order to induce that person (or any other person) to perform their roles improperly or, in the case of a
public official, in order to influence them with the intention of obtaining or retaining business or an
advantage in the conduct of business is not acceptable as there is zero tolerance for bribery and
corruption in the Bank.

Our aim is to maintain our key transformation compliance focus which is as follows:

Setting the right tone at the top: defining the right tone for compliance by the Board and Senior
Management and consistently promoting ‘positive culture’ across the Bank;

Increasing regulatory intelligence watch: to be abreast of developments within the regulatory

environment, we will strengthen our relationship with regulatory bodies to enable us to proactively
manage our regulatory risks;

Effectiveness of controls: an effective compliance culture will facilitate constructive and effective
controls as staff are conscious of doing the ‘right thing always’. The principle of ‘the three lines of
defense’ will be emphasized;
Accountability: employees (particularly business units) need to understand the core values of the
organization’s compliance culture and be rewarded or held to account for their behaviors; and

Incentives: In an effective compliance culture, reward for compliance will be geared toward the long-
term interests of the bank and reflected in the way we conduct business leading to increased customer
satisfaction and profitability to the bank

The objectives mentioned above will be driven by the following:

Better regulatory intelligence through better relationship with regulators

Improved controls through embedding controls in our systems

Empowering the first line of defense

Leveraging on Artificial Intelligence to improve Digital Compliance

Accordingly, failure of any officer to follow the institution’s internal procedure will be considered a
serious misconduct which will attract termination of appointment and offender blacklisted from
employment in the financial service industry. More especially for offences arising from conspiracy with
customers, the Central Bank also requires financial Institutions to report such staff for blacklisting.

Employees are enjoined to refer to the Bank’s Compliance Manual and Compliance Resource Officers for
guidance.

PART B: COMPLIANCE RESOURCE OFFICERS

Designation

Name

E-mail address

Mobile
Chief Conduct & Compliance Officer

Pattison Boleigha

pattison.boleigha@accessbankplc.com

+234-8022924308

Anti-Money Laundering Compliance Officer

Uyoyou Ewhe

uyoyoukaro.ewhe@accessbankplc.com

+234-8033291341

Int’l Sanctions & Anti-Boycott Compliance Officer

Ihunanya Onuoha

Ihunanya.Onuoha@accessbankplc.com

+234-8023036436
Legal Compliance Officer

Fatai Oladipo

fatai.oladipo@accessbankplc.com

+234-8035100130

Conflict of Interest/Gift Report Officer

Bolaji Agbede,

bolaji.agbede@accessbankplc.com

+234-1-4619775

Anti-Fraud Compliance Officer

Ifeanyi Emefiele

ifeanyi.emefiele@accessbankplc.com

+234-8022922308

Reputational and Regulatory Compliance Officer

Sunday Ekwochi

sunday.ekwochi@accessbankplc.com

+234-7034177024

Financial Reporting Compliance Officer

Seyi Kumapayi

oluseyi.kumapayi@accessbankplc.com

+234-8023130935

Customer Complaints Relationship Officer

Yinka Tiamiyu

olayinka.tiamiyu@accessbankplc.com

+234-8023220367

Resolve or Refer Command Centre Officer

Ogor Chukudebelu

Chukudebeluo@accessbankplc.com

+234-8080120736

Anti-Bribery & Corruption Compliance Officer

Yinka Jimoh Abdulraheem

yinka.abdulraheem@accessbankplc.com

+234-8033096733

Government Affairs Officer

Uyoyou Ewhe

uyoyoukaro.ewhe@accessbankplc.com

+234-8033291341

Margin Loan Compliance Officer

Omobola Faleye
Faleyeo@accessbankplc.com

+234-8008085718781

PART C: WHISTLE BLOWER TELEPHONE/EMAIL ADDRESS

“Whistle Blower Process” involves making employees aware of the reporting requirement of suspected
internal violations, including violations of Access Bank Plc’s Ethical Standards / Conflicts of Interest
Policy, the Staff Investment Policy, Confidential Information Policy, laws and regulations, as well as the
appropriate mechanisms to do so.

All wrongdoings and any suspected wrongdoing perpetrated by an

employee/vendor/supplier/consultant etc. must also be reported to Conduct & Compliance or through
the Bank’s or KPMG Ethics lines or emails.

Whistleblower contact information:

PART D: ATTESTATION FORM

All Access Bank employees, directors, and officers have the responsibility to be aware and comply with
the letter and spirit of all policies, procedures, guidelines and regulatory requirement. They are to
conduct all banking and investment business in accordance with the ethical standards, laws and
regulation governing its operating environment locally and internationally. These include but not limited
to the following:

S/N
Policy

Content

Reference

Employees Code of professional conduct

Employees and Officers of the Bank must abide by the norms, ethics and stipulated conduct as
contained in the staff handbook and code of conduct policy.

Link: HERE

Compliance with the AML/CFT/KYC policies and regulation

Access Bank expects its Directors and employees to abide by the AML/CFT/KYC laws, guidelines, policies
and procedures as contained in the Compliance manual and other Local and International regulation.

Section 2.1-2.15

Link: HERE
3

Market Abuse and Insider Dealing policy

Access Bank has established guidelines on which its Directors and employees are permitted to trade in
money and capital market instrument and expects them to abide by it.

Section 5.1-5.4

Link: HERE

Ethics and Conflict of Interest policy

No employee of Access Bank should t engage, without prior approval of the Bank in writing in any
business for which the bank is licensed such as currency dealing, lending, financial advisory services etc.

Section 9.5

Link: HERE

Anti-Corruption policy
Access Bank has set out principles on bribery and corruption and provided information and guidance to
staff on how to recognize and deal with the issues.

Section 2.0

Link: HERE

Policy on Activities on Staff Accounts

Employees of the bank must abide by the required ethical conduct as contained in the Policy on
Activities on Staff Accounts.

All accounts where a staff is a signatory or joint signatory should be declared to Compliance Advisory &
Support Unit.

Staff members are required to declare the accounts of their spouses or any other related accounts to
the Compliance Advisory & Support Unit and declare their interest in other companies and /or
companies which have relationship with the bank or competitors to Human Resources (HR).

Section 7 - Policy on Activities on Staff Accounts

Link: HERE

7
Group Information System Security Policies

The purpose of this policy is to establish management’s criteria for accessing the Bank’s information and
information systems, to forestall uncontrolled or unauthorized access that may result in security
breaches, or the misuse of corporate resources.

This is a stand-alone policy and can be found on the employee central with reference code:
ABP.CIC.0713.085

Link: HERE

PART E: EMPLOYEE LIFESTYLE MONITORING (Applicable to only Managers and above)

As part of the Banks effort to ensure that employees act and portray themselves and the Bank ethically
and with integrity, all supervisors (Managers and Above) attest that: They will uphold the Bank’s ethical
standards and hold staff under their supervision to the same standards and insist on staff’s integrity in
their lifestyles, dispatch of their duties, as well as their personal engagements which could negatively
impact the image of the Bank.

Declaration:

For Account Declaration:

Do you have other related accounts in the bank? Yes No

kindly enter your staff account number (to auto populate your details) before checking the box for
submission. Your
I Your Name with account number Your account number and staff ID Your Staff ID do declare that I have
read, do understand and will abide by the ethics, policies and procedures of the bank as contained in the
Access Bank Compliance Manual and other regulations relating to the banking business globally and
pledge to be in observance of them all.