Ask Adebmulty Investment Ltd

Date of Implementation: 08/02/2025

1. Purpose

This policy establishes clear guidelines for ethical, legal, and prudent investment and financial operations within Ask Adebmulty Investment Ltd. It ensures compliance with regulatory requirements, promotes risk management, and upholds the company's financial integrity.

2. Scope

This policy applies to all employees, management, and stakeholders engaged in investment, financial planning, asset management, and related activities.

3. Regulatory Compliance

• Local and international financial laws
• Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations
• Securities and Exchange Commission (SEC) guidelines
• Tax compliance laws
• Risk management and financial reporting standards

4. Investment Policy

4.1 Investment Objectives

• Preserve capital while achieving sustainable returns.
• Ensure diversification to mitigate risk.
• Maintain liquidity to meet financial obligations.

4.2 Permitted Investments

• Government and corporate bonds
• Equities and mutual funds
• Real estate investments
• Private equity and venture capital (with approval)
• Alternative investments (as approved by the Board)

4.3 Prohibited Investments

• Investments violating ethical guidelines or laws
• Speculative trading without authorization
• Unregulated or high-risk assets that threaten financial stability

5. Financial Risk Management

5.1 Risk Assessment

• Conduct periodic risk assessments on all investments.
• Implement internal controls to mitigate risks.
• Utilize stress testing and scenario analysis.

5.2 Internal Controls

• Segregation of duties for investment decisions and execution.
• Dual authorization for financial transactions.
• Independent audits and compliance reviews.

6. Code of Conduct

• Maintain transparency in all financial transactions.
• Avoid conflicts of interest in investment decisions.
• Adhere to insider trading laws and confidentiality obligations.
• Report any unethical behavior or financial misconduct.

7. Procedures for Investment Approval

• Proposal Submission: Investment proposals must include detailed risk analysis, expected returns, and due diligence reports.
• Review Process: The Investment Committee evaluates proposals based on financial health, market conditions, and risk factors.
• Approval & Execution: Approved investments are executed by authorized personnel following compliance procedures.
• Monitoring & Reporting: Investments are regularly tracked, with quarterly reports and compliance checks.

8. Anti-Money Laundering (AML) & KYC Compliance

• All clients and investment partners must undergo KYC verification.
• Transactions above the legal threshold must be reported to relevant authorities.
• Employees must complete annual AML compliance training.

9. Reporting & Accountability

• Monthly and annual financial reports must be submitted to senior management.
• External audits will be conducted to ensure compliance.
• Any discrepancies must be reported to the compliance officer immediately.

10. Enforcement & Disciplinary Actions

Failure to comply with this policy will result in disciplinary action, including termination, legal consequences, and financial penalties.

11. Policy Review & Updates

This policy shall be reviewed annually and updated as required to align with regulatory changes and company objectives.

Approval:

(Authorized Signatory – CEO/CFO/Board Chair)

Date: 08/02/2025