Chapel Hill Denham

Chapel Hill Denham is a leading independent investment banking, securities trading, and investment management firm. The firm is Nigeria’s most trusted advisor, focused on providing unbiased advisory, execution, and investment services to corporations, governments, institutions, and individuals involved in investing in and developing Nigeria and Africa. This policy (the “Code”) summarises the values, principles and business practices that guide Chapel Hill Denham’s (“CHD” or the “Firm”) business conduct and provides guidance on the ethical guidelines expected of the Firm’s employees. The Code encompasses the Firm’s values and principles, considers the laws and relevant regulatory rules of the jurisdictions in which we operate as well as international best practice. The Code supplements the Company’s existing employee policies, including those specified in the Staff handbook, and other policies and procedures that have been adopted by the Firm. The Code is not intended to address all laws, rules, policies or circumstances involving ethical conduct, however, it contains guidance to enable common sense and good judgement to be used in determining appropriate conduct.