Policy Statement

POLICY STATEMENT

The purpose of this Insider policy is to promote compliance with the applicable securities laws by May & Baker Nigeria Plc and all directors, officers and employees thereof, in order to preserve the reputation and integrity of May & Baker Nigeria Plc as well as that of all persons affiliated with it.

The policy provides guidance on what constitutes Insider Trading and how it will be
Managed and monitored by May & Baker Nigeria Plc (“MBN”or“the Company”).

POLICY OBJECTIVES

This policy was reviewed and adopted by the Board of Directors of the Company to:

1. Provide guidance to the Directors and Executive/Senior Management personnel of the Company to assist them in recognizing and dealing with purchase or sale of shares of the Company

2. To assist the Board in prevention of Insider Trading Activities

3. To ensure that trading in the Company’s shares are conducted within approved
regulatory framework

4. To ensure that relevant legislation, rules and regulations in respect to Insider
Trading are adhered to

5. To protect the company and its staff from reputational damage, fines and levies that
may be imposed by the various regulators as a result of improper identification and management of conflict of interest situations.

6. To prevent the use of material non-public information of the Company by its
Directors, Executives and Senior Management

APPLICABILITY

This Policy is applicable to all directors, officers and employees of May & Baker Nigeria Plc especially any person listed as an Insider under this policy.

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