KYC Policy – Subsi

SUBSI STORES LIMITED KNOW YOUR CUSTOMER (KYC) POLICY Effective Date: 11th DAY of APRIL, 2026 1. INTRODUCTION 1.1 Purpose This Know Your Customer (KYC) Policy outlines the procedures adopted by Subsi Stores Limited trading as (“Subsi.ng”, “we”, “us”) to: • Verify the identity of customers and vendors • Prevent fraud, impersonation, and financial crimes • Support Anti-Money Laundering (AML) compliance • Ensure a secure and trustworthy e-commerce environment 2. LEGAL AND REGULATORY FRAMEWORK Subsi Stores Limited complies with all applicable Nigerian laws and regulations, including: • Money Laundering (Prohibition) Act 2011 (as amended) • Terrorism (Prevention) Act • Guidelines issued by the Nigerian Financial Intelligence Unit • Consumer protection oversight by the Federal Competition and Consumer Protection Commission • Data protection requirements under the Nigeria Data Protection Regulation 3. KYC APPROACH (RISK-BASED MODEL) We adopt a risk-based and tiered KYC framework: 3.1 Tier 1 – Basic Users (Low Risk) • Full Name • Email Address • Phone Number Used for: account creation and low-value transaction 3.2 Tier 2 – Verified Users (Medium Risk) • Residential Address • Date of Birth • Government-issued ID • Selfie or identity verification Used for: active buyers and standard transactions 3.3 Tier 3 – High-Risk / High-Value Users • Source of funds • Occupation or business activity • Bank account details • Additional supporting documentation Used for: high-value transactions, vendors, or flagged accounts 4. CUSTOMER IDENTIFICATION PROCEDURES 4.1 Individuals We collect and verify: • Full legal name • Date of birth • Residential address • Valid government-issued identification • Contact details (email and phone number) 4.2 Corporate Entities / Vendors We collect: • Company name and CAC registration number • Certificate of incorporation • Business address • Tax Identification Number (TIN) • Nature of business 4.3 Ownership and Control For corporate customers: • Directors’ details • Ultimate Beneficial Owners (UBOs) • Authorized representatives and identification 5. VERIFICATION METHODS We may verify customer information through: • Government ID validation • Address verification • Phone/email verification (OTP) • Biometric or selfie verification • Third-party verification services 6. ENHANCED DUE DILIGENCE (EDD) EDD shall be applied where higher risk is identified, including: • High-value transactions • Suspicious account activity • Politically Exposed Persons (PEPs) • High-risk jurisdictions EDD measures include: • Source of funds verification • Additional documentation requests • Manual compliance review 7. ONGOING MONITORING KYC is a continuous process. We: • Monitor transaction behavior • Flag unusual or suspicious activity • Update customer risk profiles • Re-verify users when necessary 8. RECORD KEEPING 8.1 Documentation We securely retain: • Identity documents • Transaction records • Verification data 8.2 Retention Period Records shall be retained for a minimum of 5 years or as required by Nigerian law. 9. REPORTING OBLIGATIONS Suspicious transactions or activities shall be reported to the Nigerian Financial Intelligence Unit in accordance with legal requirements. 10. DATA PROTECTION AND PRIVACY All personal data is processed in accordance with the Nigeria Data Protection Regulation We ensure: • Secure data storage • Restricted access • Lawful processing Users have the right to: • Access their data • Request corrections • Request deletion (subject to legal obligations) 11. NON-COMPLIANCE Failure to provide required KYC information may result in: • Restricted account access • Delayed or declined transactions • Account suspension or termination 12. TRAINING AND AWARENESS Employees shall receive regular training on: • KYC procedures • Fraud detection • Regulatory compliance 13. INTERNAL CONTROLS AND REVIEW We conduct: • Periodic compliance reviews • Internal audits of KYC processes • Updates based on regulatory changes 14. ENFORCEMENT AND PENALTIES Violations of this Policy may result in: • Disciplinary action • Termination of employment • Legal or regulatory consequences 15. POLICY UPDATES This Policy will be reviewed periodically and updated to reflect: • Changes in law • Operational risks • Business growth 16. CONTACT INFORMATION Company Secretary / Compliance Unit Email: support@subsi.ng Phone: 09064678987