Privacy Policy

Last Updated: September 27, 2024

Introduction

Personal Information is as important to us as it is to our customers. At FSDH Asset Management Limited (“FAML”), we are committed to protecting your information. By ‘your information’, we mean any information provided to us by you or a third party. FAML will only process where we have obtained your explicit consent or are otherwise lawfully permitted to do so.

This Privacy Policy explains what information FAML (as Data Controller/Processor) collects, how we collect it, share, use, and protect your personal information in connection with the business relationship.

Security of personal information

Safeguarding your personal information is our main concern. We maintain physical, electronic and procedural safeguards that comply with applicable federal laws to secure your information from unauthorized access and use, accidental or unlawful alteration and destruction, and other unlawful or unauthorized forms of processing.  We engage in the continuous training of our employees in the proper management of personal information. When we use other companies to provide services, we require them to protect the confidentiality of personal information they receive.

 At FAML, we take data privacy very seriously and we provide our customers with all necessary data security to protect such personal information from unauthorized access. We require any third parties who carry out any work on our behalf to comply with appropriate compliance standards to protect your information. We are pleased to announce that we comply with the requirements of the Nigeria Data Protection Act (NDPA). As an FAML customer, be assured that we will keep protecting your information as we have always done.

The information we collect

FAML will only collect your information in line with relevant regulations and laws.

How do we collect information?

FAML will only collect your information in line with relevant regulations and laws.

How do we collect information?

We may collect information from a range of sources, and it may relate to any of the products or services we currently provide or may have provided in the past.

 We collect your personal information when:

  • you open an account or perform transactions such as making subscriptions or redemptions/liquidations from your investment account.
  • you seek advice about your investments
  • you seek information concerning complaints and disputes
  • you provide account information such as your personal details e.g. name, gender, date and place of birth; contact information such as address, email address, and mobile numbers, provide your employment information
  • you provide information concerning your identity e.g. photo ID, passport information, National ID card and nationality
  • you use your login credentials on our web platform and mobile apps
  • we conduct necessary investigations i.e., due diligence checks, and AML/CFT/CPF checks and obtain information that we need to support our regulatory obligations, e.g. information about transaction details, detection of any suspicious and unusual activities.

Note that we may collect information about your computer (or mobile device), including where available your IP address, operating system and browser type, for system administration or for our own commercial purposes. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

How we use your information

  • FAML will only use your information when you have provided your consent or when the Company is required by the law to do so.
  • We use the information we collect to provide customers with excellent products and services, to manage our business and to offer an enriched and enhanced customer experience.
  • We make appropriate use of your data to manage transactions, respond to your requests, and to provide you with more relevant products and services.
  • We use your information to deliver our products and services, carry out your instructions, and provide Web or Mobile App product and services.
  • We use this information to detect and prevent financial crimes including fraud, financing for terrorism and money laundering, this is to ensure security and business continuity.
  • We will use your information to meet our compliance obligations, to comply with laws and regulations and to share with regulators when necessary.
  • We may also use personal information we have about you such as your email address to deliver advertising to you directly or on our websites, provide updates on special deals and offers that might interest you (unless you tell us otherwise).
  • We may send you general announcements or important news about your account, request your feedback and we believe you should be able to select what kinds of information you receive from us via email.
  • We may need to record conversations you have with us including phone calls, face-to-face meetings, letters, emails and any other kinds of communication. These recordings may be used to check your instructions to us and improve our product and service delivery.

Who we share your information with

The Company, in efforts to provide you with excellent products and services, may need to outsource its product delivery, this will be done in line with relevant regulations and laws. We may share your information in order to provide you with products or services you’ve requested.

We may also share your information where we have a public or legal duty to do so, when we need it to conclude regulatory reporting and when we have requested and received your permission to share it.

Individual rights

  • The right to be informed

To emphasize the need for transparency over the usage of personal data, we ensure fair processing of information typically through this privacy policy.

  • The rights to access

Individuals have the right to access information the Company holds, access their personal data and other supplementary information and obtain information about how we process it.

  • The right to restrict processing

Individuals have a right to ‘block’ or withdraw their consent to our processing of your information, which you can do at any time. When processing is restricted, we are permitted to store personal data, but not further process it.

  • The right to rectification

Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. The Company must also inform the individuals about the third parties to whom the data has been disclosed where appropriate

  • The right to erasure

Individuals have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing. The Comaony will make sure that this right is protected.

  • The right to data portability

We will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability.

  • The right to automate decision making and profiling

Individuals have the right to query a decision/profiling that we make/do about a product or service that they have applied for and that was made solely by automated means.

  • The right to object

Individuals have the right to object to our processing of their information in some circumstances.

Individual Responsibility

Individuals are responsible for making sure the information provided to the Company is accurate and should inform the FAML on any changes as it occurs, this will enable us to update your information with us.

Why We Collect Your Data (Legal Basis)

S/N

Lawful Basis

Description

1

Performance of a contractual agreement

Processing of personal data is necessary for the performance of a contract to which the individual is a party or for the Company to take pre-contractual steps at the request of the individual. E.g. To provide and manage the financial services to the customer.

2

Fulfilment of a legitimate interest

Processing is necessary under the legitimate interest of the Company, unless these interests are overridden by the individual’s interests or fundamental rights. E.g Validating KYC details.

3

Consent of the data subject

The individual has given their consent to the processing of their personal data.

4

Processing in the public interest

Processing personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. E.g. Processing data based on law enforcement agency’s request.

5

Compliance with a legal obligation

The processing of personal data is necessary for compliance with a legal obligation to which the Company is subject to. E.g. Data is processed as a requirement of regulatory authority.

6

Protection of a vital interest

Processing personal data in order to protect the vital interests of the data subject or another individual. “Vital interests” will include interests essential for the life of the data subject or another individual. It applies if it’s necessary to process personal data to protect someone’s life. E.g. in case of memory loss.

Cookies

A cookie is a small file that is placed on your computer’s hard drive. Its functions include storing your login and session statuses, recording your user preferences and analyzing web traffic.

Cookies enable websites and applications to store your user preferences in order to enhance your overall website experience by better understanding your preferences, likes and dislikes. They also allow websites to identify when users are logged on their site and when they return to their site, test new content and analyse web traffic with data analytics.

Besides the data you select to disclose and share with us, we cannot access your computer or any other information about you with cookies.

Although most browsers automatically accept cookies, you can amend your browser settings to disable cookies. This may however prevent you from fully experiencing the website as it was intended.

Head, Compliance

Adedayo Bello

BACKGROUND

Adedayo joined FSDH Asset Management team in 2021 as the Chief Compliance officer, where he coordinates all the regulatory and statutory Compliance of the Company. Prior to joining FSDH Asset Management Limited, he has worked with notable Financial Institutions within the Capital market.

He is a finance professional with over 15 years of experience in Investment Banking. He was Head Compliance at AIICO Capital Limited, and equally functioned as Internal Control Officer, Acting Team Lead, Investment/Treasury Operations, and member of a Reconciliation Team in the same organization.

He commenced his Financial Institution journey/career at United Capital Securities Limited, a subsidiary of United Capital PLC (Formerly UBA Capital) where he worked in various units like Operations, Reconciliation & Resolutions, and Business Development departments.

Adedayo holds a B.Sc. in Geology from University of Ado-Ekiti and Masters’ degree in Exploration Geophysics from Federal University of Technology, Akure. He is an accredited Compliance Officer with the Securities and Exchange Commission as Sponsored Individual.

Head, Operations

Chinedu Nnadi

BACKGROUND

Chinedu Nnadi holds a Bachelor of Science degree in Statistics from Nnamdi Azikiwe University, Awka, Anambra State. He is currently running his Post-Graduate Diploma in the University of Lagos, Akoka, Yaba, Lagos.

Chinedu is an Operations Specialist spanning over 17 (seventeen) years beginning from Union Systems Limited where he worked as the Systems Support/Analyst before joining the Operations Unit of Asset & Resource Management Co. Ltd (ARM Investment Managers). His time at ARM was one in which he was a key member of the Operations Unit where he was involved in organization-wide process improvement with his involvement in the Business Process Review (BPR) which identified inefficiencies and proposed improvements that led to timely execution of Strategic and Tactical transformation. This review greatly impacted on process efficiency, overall organizational effectiveness through transformation of resources, migration and adoption of relevant Information Technology tools for Operational efficiency.

He later joined Nova Asset Management Limited (NOVAMBL) as the Team Lead, Capital Market Operations where He was responsible for setting up of the Operations unit from the onset, from there, he joined FSDH Asset Management Limited where he currently sits as the Head of Operations.

Chinedu is vastly skilled and knowledgeable in the Nigerian Asset Management Operations and Regulations. Business Optimization, Process automation and Transaction processing, systems re-engineering. He is a driver of technology and operational initiatives.

He is happily married and has undergone professional trainings on Personal Improvements, Systems and Process Improvements, Financial Market Fundamentals.

Chief Investment Officer

Taofik Oyeniyi

BACKGROUND

Taofik Oyeniyi is the Chief Investment Officer at FSDH Asset Management Limited. He has over two and half decades of experience in the financial services industry across Treasury/Money market activities, Funds management, Balance Sheet and Liquidity Management, Business Development, Credit Analysis, and Structuring.

He started his Banking career in 1997 as an Executive Trainee at Equity Bank after a brief stint as an investment Officer at Compass Finance and Investment. He grew to the position of Chief Dealer before joining Intercontinental Bank as a Regional Head of Treasury in the Treasury and Investment Banking Division. In 2005. He joined Skye High Financial Services in 2010 as an Executive Partner and Division Head of Treasury and Funds Management. He worked in this capacity up until joining TAJ Bank as the Treasurer and Divisional Head of Treasury and Investment in 2019. He joined Radix Pension Managers in 2021 as the Divisional Head of Investment and Treasury.  He was responsible at Radix for formulating the overall Investment strategy for all funds managed, supervising Portfolio Managers in various investment activities, and ensuring funds are invested in line with asset allocation.

Taofik is a graduate of Business Administration and a holder of   MBA (Finance Major) degree from Obafemi Awolowo University, Ile-Ife. He is a Chartered Accountant (ACA), an Associate Member of the Chartered Institute of Bankers of Nigeria (CIBN), and a CFA Chartered Holder.

Chief Financial Officer

Funmi Olutebo

BACKGROUND

Funmilayo Oletubo is a finance professional with years of experience in business strategy, financial and performance management, liquidity management, operations control, risk management, taxation, project management and process optimization.

She is the Chief Financial Officer at FSDH Asset Management Limited “FSDH AM’”, where she acts as a strategic business partner for creating value and executing the firm’s financial strategies.

Before joining FSDH AM, Funmilayo started her career with Integrated Software Services Limited where she gained extensive knowledge for driving the efficiency of business with technology and financial solutions. She shortly after joined Chapel Hill Denham as an Investment Officer where she rose through the ranks to become an Assistant Vice President, finance and operations supporting the Investment Management, Securities Trading, Investment Banking and Trusteeship businesses. She was responsible for coordinating several responsibilities as: budget preparation, financial reporting and analysis, consolidated financial reporting, external audit liaison, management performance reviews, regulatory reporting, automation and system enhancement, asset and liability management, alternative fund accounting, investment accounting, standard operating policy development and compliance with the International Financial Reporting Standards {IFRS}.

She holds a BSc in Applied Accounting and Accounting from Oxford Brookes University, Glasgow, United Kingdom and Babcock University, Ilishan Remo, Nigeria respectively. She is a Fellow of the Association of Chartered Certified Accountants (ACCA), Member of the Institute of Chartered Accountants of Nigeria (ICAN) and Chartered Institute of Taxation of Nigeria (CITN).

She is happily married, passionate about socio-economic development and runs an NGO aimed at supporting the less privileged.

Head, Sales, FSDH Asset Management

Margaret Agbonlahor

BACKGROUND

Margaret joined the FSDH Asset Management team in 2020 as the Head of Sales, where she drives the various market segments; HNIs, Institutions and Retail. She has over 20 years of banking experience, with expertise in Sales, Business Development, Marketing and Portfolio Management. She is also an approved Corporate Client adviser. Before she joined FSDH, Margaret was a Team Lead for Core Banking Finacle Software Application change at Infosys, Bangalore India. She has garnered a deep understanding of the Fixed Income, Money Market and Equities Market, and attended several courses on Wealth and Portfolio Management. She holds a BSc. in Business Administration from the University of Benin and an MBA from the University of Lagos.

Non-Executive Director, FSDH Asset Management

Nike Ogunjimi

BACKGROUND

Nike is a finance professional with over 18 years of experience in investment management, financial advisory and commercial banking.

Over the span of her career, she has worked at several leading firms in the Nigeria financial services industry. She is currently a Director at Kuramo Capital Management where she focuses on investment management and investor relations activities. Prior to Kuramo, Nike was part of the Client Solutions team at Standard Chartered Bank Nigeria and provided financial advisory solutions to the bank’s local blue-chip clients.

She also worked at Afrinvest Limited and, as a senior member of the Investment Banking team, she led the execution of numerous headline M&A mandates for notable Nigerian companies. She was a member of the firm’s Management Team and had oversight responsibility for the Finance unit, alongside her investment banking duties.

Nike has also worked at ARM Investment Managers where, as part of the Investment Management team, she was responsible for covering various sectors on the Nigerian Stock Exchange as well as international financial markets. She holds a BSc. Insurance from University of Lagos, Nigeria and an MSc. Finance from University of Leicester, UK.

Managing Director, FSDH Asset Management

Toyin Owolabi

BACKGROUND

Mr. Owolabi has over 20 years of banking experience and is the Group Head of Financial Institutions, responsible for developing and managing the relationship with all non-bank financial institutions and other institutional clients. Before joining FSDH, he worked at FCMB and at different times oversaw Financial Institutions, Correspondent Banking and Structured Funding. He was also the Head of treasury at IMB international Bank. Mr. Owolabi’s educational background includes a bachelor’s degree in Agriculture from the University of Ilorin and an MBA from Business School Netherlands. He has attended numerous local and international courses and in addition to financial institutions, was responsible for wealth management and correspondent banking at FSDH Merchant Bank.

Non-Executive Director, FSDH Asset Management

Kelechi Okoro

BACKGROUND

Kelechi was at Argentil Capital Partners where he originated and executed infrastructure transactions. Prior to Argentil, he worked with the Infrastructure and Natural Resources Group of the International Finance Corporation (IFC), and at ARM Investment Managers (with ~USD 2bn AUM), both in Nigeria. He holds a Bachelor’s in Human Physiology from the University of Ibadan, and an M.B.A. from Lagos Business School. He serves as a Non-Executive Director.

Non-Executive Director, FSDH Asset Management

Yasmin Belo-Osagie

BACKGROUND

She was a border in England before proceeding to Princeton where she graduated cum laude in History (major) and Finance (minor) in 2011. She attended Le Cordon Bleu (a hospitality education institution), in Paris and London. She studied at Harvard Law School and at Stanford Graduate School of Business, graduating with a JD/MBA in 2019. After her graduation from Princeton, Belo-Osagie worked with McKinsey & Company as a business analyst till 2013. While at McKinsey & Company, she met Afua Osei with whom she co-founded She Leads Africa. She serves as a Non-Executive Director with FSDH Asset Management Limited.

Non-Executive Director FSDH Asset Management

Folashade Ogunde

BACKGROUND

Mrs. Folashade Ogunde graduated with a B.Sc. (Hons) degree in Economics from the University of Ife (1984) (now Obafemi Awolowo University, Ile-Ife). She is a Fellow of the Institute of Chartered Accountants of Nigeria (ICAN) (2005) and an associate member of the International Facility Management Association (IFMA) (2015). She started her professional career with the firm of Deloitte Haskins & Sells (Chartered Accountants), where she gained accounting and audit experience, and had a stint in Treasury Management at Bancroll Savings & Loans Limited (1993 to 1995) and International Funding Group (Nig.) Limited (1991 to 1992) before joining UAC of Nigeria Plc in 1997. She has held such positions as Management Accountant, UAC Foods; Divisional Commercial Director, Mr. Bigg’s (now UAC Restaurants), Group Treasurer, UAC of Nigeria Plc and Executive Director, Finance at UACN Property and Development Company.

Chairman, FSDH Asset Management

Folashade Laoye

BACKGROUND

She is a graduate of University of Lagos (BSc Accounting, 1990) and qualified as an Associate member of the Institute of Chartered Accountants of England and Wales in 1995 and the Institute of Chartered Accountants of Nigeria in 1997. She trained with Coopers & Lybrand, UK (now PricewaterHouseCoopers) from 1991 to 1995 and worked with the Corporate Finance Unit of First Securities Discount House (“FSDH”) from 1995 to 1997. She holds a Master of Business Administration from Harvard Business School. She has been instrumental in charting the growth strategy of Hygeia for several years. She serves as the Chairman of the FSDH Asset Management Limited Board of Directors.