Definitions
- Client: Refers to the individual or entity engaging in investment services with DLM Asset Management.
- Services: Refers to the investment products, fund management, financial advice, and any other services provided by DLM Asset Management.
- Eligibility To use our services, you must:
- Be at least 18 years old or have legal capacity to engage in financial contracts.
- Provide accurate, current, and complete KYC information.
- Comply with applicable laws and regulations.
Account Creation and Maintenance
Clients must register for an account by providing necessary personal and financial information. You agree to maintain the confidentiality of your login credentials and notify us immediately of any unauthorized access to your account.
Investment Risk
All investments carry some level of risk, and past performance is not indicative of future results. You acknowledge that by investing in any DLM Asset Management products, you are accepting these risks.
Fees and Charges
DLM Asset Management may charge management fees, performance fees, or transaction fees depending on the type of service or product chosen. Detailed fee structures are provided in the respective product documentation.
Termination of Service
DLM Asset Management reserves the right to terminate or suspend access to your account if it is believed that you have violated any terms and conditions, or if required by law.
Limitation of Liability
In no event shall any indemnified person be liable to you for any damages whatsoever, including but not limited to indirect, incidental, special, punitive, or consequential damages, arising out of or in connection with your use of this web portal, content, and/or user information. This includes, but is not limited to, the quality, timeliness, suitability, accuracy, or utility of the information provided through DLM Asset Management or for any investment decisions made based on such information, whether the damages were foreseeable and whether DLM Asset Management has been advised of the possibility of such damages. This limitation of liability shall apply to the fullest extent permitted by law in the applicable jurisdiction, and in no event shall DLM Asset Management's total cumulative liability to you exceed the amount you paid to us as fees.
Dispute Resolution
Any disputes arising from the use of our services will be resolved through arbitration as per the laws of the Federal Republic of Nigeria. Changes to These Terms We reserve the right to modify or update these terms at any time and will notify clients of any substantial changes.
Confirmation Of Investment
Transaction instructions are considered received only upon confirmation from the Company via email. If you do not receive a confirmation of receipt for your instruction, please verify your account status or reach out to our Customer Experience team at asset@dlm.asset.group before resending the instruction. This precaution helps prevent duplication, as the initial instruction may still be in process. Neither the Company nor any Indemnified Person will be liable for any duplicated transactions resulting from a lack of confirmation of the instruction(s).
Liability For Use On Our Website
You are strongly advised to review all information carefully before engaging in any transactions or investments, as the content on this Website may not always be current or complete. The Company will not be liable for any losses incurred if you fail to verify the details prior to investing. If you are uncertain about the products and services you wish to subscribe to, we recommend reaching out to us or consulting an independent financial adviser or broker for guidance. The Company will exercise reasonable care in verifying the reliability of information provided by third-party sites linked through this website. However, we do not have control over the content of those sites and will not be responsible for any losses incurred due to your use of such external websites.
Disclaimer
Please be aware that the information provided on this Website is intended for general purposes only. While we strive to keep all such information accurate and up to date, we make no warranties, either express or implied, regarding the accuracy, completeness, suitability, or availability of the information contained herein or any related products, services, or graphics. Any reliance placed on this information is strictly at your own risk. The Company will not be liable for any loss or damage, including but not limited to indirect or consequential losses, or any loss or damage whatsoever resulting from the loss of data or profits arising from your use of this Website. While we aim to maintain the smooth operation of this Website, we will not be liable for any interruptions or downtime caused by technical issues beyond our control. We strongly advise you to keep all passwords and personal information, including login details, secure, as the Company will not be responsible for any loss or damage arising from the use of your login details in connection with this Website.
3. KYC Update Discussion: Making Employment History Optional
Our Rationale for Making Employment History Optional After careful consideration, we propose making the employment history section optional for the following reasons: Client Flexibility: Some clients, especially retirees, students, or individuals transitioning between jobs, may not have recent employment history, and this could hinder their account registration process. Regulatory Alignment: Current SEC and CBN regulations do not mandate the collection of employment history as a compulsory KYC requirement for all clients, particularly in non-commercial banking scenarios. Data Minimization: Collecting only the necessary information aligns with data protection principles and client privacy concerns. As employment history does not directly influence investment risk assessment in all cases, omitting it for certain clients improves their onboarding experience.
Our Risk Mitigation Mechanism to the Above
While we suggest making this field optional, DLM Asset Management will implement the following safeguards to ensure compliance and risk management:
- Enhanced Due Diligence (EDD): For clients who opt not to provide employment history, we will conduct additional background checks using other available KYC data, such as BVN verification and financial transaction history.
- Tiered Approach: For high-net-worth individuals (HNIs) and politically exposed persons (PEPs), employment history will still be required as part of enhanced due diligence.
Internal Discussions and Feedback
We understand that making this field optional will require internal alignment with the compliance and legal teams to ensure consistency with our risk management policies. We anticipate further feedback on:
- Impact on onboarding timelines and client satisfaction.
- Adequacy of alternative verification methods.
- Internal system updates to reflect this optional field in the KYC forms.