INTERNATIONAL ENERGY INSURANCE : CORPORATE GOVERNANCE REPORT

S/No.

Items

Details

i.

Company Name

International Energy Insurance Plc

ii.

Date of Incorporation

March 26, 1969

iii.

RC Number

RC. No. 6126

iv.

License Number

RIC – 020

v.

Company Physical Address

FF Towers, Plot 13/14 Ligali Ayorinde

Street, Victoria Island, Lagos.

vi.

Company Website Address

vii.

Financial Year End

31stDecember

viii.

Is the Company a part of a Group/Holding Company?

Yes/No

If yes, please state the name of the Group/Holding Company

Yes

Norrenberger Advisory Partners Limited

ix.

Name and Address of Company Secretary

Detail Nominees

DCS Place, 8 DCS Street, Off Remi Olowude Way, Lekki Phase 1, Lagos.

x.

Name and Address of External Auditor(s)

Messrs. Doyin Owolabi & Co., 14, Falolu

Street, Off Itire Road, P.O.Box 16, Surulere, Lagos.

xi.

Name and Address of Registrar(s)

Meristem Registrars & Probate Services

Limited, 123, Herbert Macauley Way, Adekunle – Yaba, Lagos.

xii.

Investor Relations Contact Person

(E-mail and Phone No.)

[email protected] 08037239256

xiii.

Name of the Governance Evaluation Consultant

DCSL Corporate Service Limited

xiv.

Name of the Board Evaluation Consultant

DCSL Corporate Services Limited

S/No.

Names

Position Held

Gender

1.

Mr. Olasupo Sogelola

Managing Director/CEO

Male (Resigned

November 13, 2025)

2.

Dr. Joyce M. Odiachi

Executive Director, Technical

Female

3.

Mr. Uyi Osagie

Chief Finance Officer/Operations

Male

4.

Dr. Olawale Awosina

Chief Compliance Officer

Male

5.

Mrs. Confidence Yinusa

Chief Marketing Officer

Female

Principles

Reporting Questions

Explanation of application or deviation

Part A – Board of Directors and Officers of the Board

Yes/No

Principle 1: Role of the

i) Does the Board have an approved Charter which sets out its responsibilities and terms of reference? Yes/No

If yes, when was it last reviewed?

Yes, the Board have an approved charter.

Board

“A successful Company is headed by an effective Board which is responsible for providing entrepreneurial and strategic leadership as well as promoting an ethical culture and responsible corporate citizenship. As a link between stakeholders and the Company.

Yes

2022

The board is to exercise oversight and control to ensure that management acts in thebest interest of the shareholders and other stakeholders while sustaining the prosperity of

the Company”

Principle 2: Board

i) What are the qualifications and

First

The Directors have over 100 years of

Structure and

experiences of the directors?

Degrees,

combined experience in corporate

Composition

Masters,

management and business administration.

“The effective discharge of the responsibilities of the Board and its committees is assured by an appropriate balance of skills and diversity (including experience and gender)

withou t compromising competence, independence andintegrity ”

and

Ph.Ds.

They have all excelled in their various

fields.

ii) Does the company have a Board-approved diversity policy? Yes/No If yes, to what extent have the

diversity targets been achieved?

Yes

The Board pays attention to diversity.

iii) Are there directors holding concurrent directorships? Yes/No

If yes, state names of the directors and the companies?

Yes

Mr. Anthony Edeh

Mr. Mijindadi Mohammed

Norrenberger Advisory Partners Limited.

Norrenberger Pensions Ltd.

iv) Is the MD/CEO or an Executive

Director a chair of any Board

No

Committee? Yes/No

If yes, provide the names of the

Committees.

Principle 3: Chairman

“The Chairman is responsible for providing overall leadership of the Company and the Board, and eliciting the constructive participation of all Directors to facilitate effective direction of the Board”

i) Is the Chairman a member or chair of any of the Board Committees? Yes/no

If yes, list them.

No

ii) At which Committee meeting(s) was the Chairman in attendance during the period under review?

None

iii) Is the Chairman an INED or a NED?

NED

iv) Is the Chairman a former MD/CEO or ED of the Company? Yes/No

If yes, when did his/her tenure as

MD end?

No

v) When was he/she appointed as Chairman?

June 2022

vi) Are the roles and responsibilities of the Chairman clearly defined? Yes/No

If yes, specify which document

Yes

Board Charter.

Principle s

Reporting Questions

Explanation on application or deviation

Principle 4: Managing Director/ Chief Executive Officer

“The Managing Director/Chief Executive Officer is the head of management delegated by the Board to run the affairs of the Company to achieve its strategic objectives for sustainable corporate performance”

i) Does the MD/CEO have a contract of employment which sets out his authority and relationship with the Board? Yes/No

If no, in which documents is itspecified?

Yes

Letter of employment

ii) Does the MD/CEO declare any conflict of interest on appointment, annually,

thereafter and as they occur? Yes/No

No

There is no conflict or perceived conflict of interest to declare.

iii) Which of the Board Committee meetings did the MD/CEO attend during the period under review?

Finance, Investment & General-Purpose Committee (F I & GPC), Statutory Audit Committee (SAC), Enterprise Risk Management Committee (ERM), Board Audit and Compliance Committee (BACC) and Nomination, Governance

and Remuneration Committee (NGRC).

iv) Is the MD/CEO serving as NED in any other company? Yes/no.

If yes, please state the company(ies)?

No

v) Is the membership of the MD/CEO in these companies in line with the Board-approved policies? Yes/No

No

The MD is not a member of any Company.

Principle 5: Executive Directors

Executive Directors support the Managing Director/Chief

Executive Officer in the operations and management of the Company

i) Do the EDs have contracts of employment?

Yes/no

Yes

The ED has a contract of employment.

ii) If yes, do the contracts of employment set out the roles and responsibilities of the EDs? Yes/No

If no, in which document are the roles and

responsibilities specified?

Yes

The letter sets out the roles and responsibilities of the ED

iii) Do the EDs declare any conflict of interest

on appointment, annually, thereafter, and as they occur? Yes/No

No

There is no perceived conflict to be declared.

iv) Are there EDs serving as NEDs in any other company? Yes/No

If yes, please list

No

v) Are their memberships in these

companies in line with Board-approved policy? Yes/No

Yes

Principle 6: Non-Executive Directors

Non-Executive Directors bring to bear their knowledge, expertise and independent judgment on issues of strategy and performance on the Board

i) Are the roles and responsibilities of the NEDs clearly defined and documented?

Yes/No If yes, where are these documented?

Yes

Board Charter

ii) Do the NEDs have letters of appointment specifying their duties, liabilities, and

terms of engagement? Yes/No

Yes

iii) Do the NEDs declare any conflict of

interest on appointment, annually, thereafter and as they occur? Yes/No

Yes

iv) Are NEDs provided with information relating to the management of the company and on all Board matters? Yes/No

If yes, when is the information provided

Yes

When Board packs are circulated to the NEDs, and when they are required or necessary.

to the NEDs

v) What is the process of ensuring the completeness and adequacy of the

information provided?

Yes

Verification of available information through primary sources, where possible.

vi) Do NEDs have unfettered access to the EDs, Company Secretary and the Internal

Auditor? Yes/No

Yes

The NEDs have unfettered access to the Eds, the Company Secretary and the Internal Auditor.

Principle 7: Independent Non-Executive Directors

i) Do the INEDs meet the independence criteria prescribed under Section 7.2 of

the Code? Yes/No

Yes

Yes, the INED does.

Principle s

Reporting Questions

Yes/N o

Explanation on application or deviation

Independent Non-Executive

Directors bring a high degree of objectivity to the Board for sustaining stakeholder trust and confidence”

ii) Are there any exceptions?

No

No exceptions.

iii) What is the process of selecting INEDs?

Our process for selecting INEDs is established under Section 7 of the

NCCG 2018.

iv) Do the INEDs have letters of appointment specifying their duties, liabilities and

terms of engagement? Yes/No

Yes

v) Do the INEDs declare any conflict of interest on appointment, annually,

thereafter and as they occur? Yes/No

No

There is no conflict or perceived conflict of interest.

vi) Does the Board ascertain and confirm the independence of the INEDs? Yes/No

If yes, how often? What is the process?

Yes

Annually, through board evaluation.

vii) Is the INED a Shareholder of the Company?

Yes/No

If yes, what is the percentage

shareholding?

No

viii) Does the INED have another relationship with the Company apart from directorship and/or shareholding? Yes/No

If yes, provide details.

No

ix) What are the components of INEDs remuneration?

Medical Allowance, Vacation

Allowance, Sitting Allowance, and Annual Director’s Fee.

Principle 8: Company

i) Is the Company Secretary in-house or

outsourced?

Secretary

Outsourced

“The Company Secretary support the effectiveness of the Board by assisting the Board and management to develop good corporate governance practices and culture within the Company”

ii) What is the qualification and experience of the Company Secretary?

The Company Secretary is a Firm of Legal Practitioners.

iii) Where the Company Secretary is an

employee of the Company, is the person a member of senior management?

No

The Company Secretary is a Law Firm.

iv) Who does the Company Secretary report to?

The Board of Directors

v) What is the appointment and removal

In accordance with the provisions

process of the Company Secretary?

of the Companies and Allied

Matters Act 2020 and the contract

of Engagement.

vi) Who undertakes and approves the performance appraisal of the Company

Secretary?

The Board of Directors

Principle 9: Access to

i) Does the company have a Board-approved policy that allows directors access to independent professional advice in the discharge of their duties? Yes/No

If yes, where is it documented?

Yes

The Board Charter

Independent Advice

“Directors are sometimes required to make decisions of a technical and complex nature that may require independent

ii) Who bears the cost for the independent professional advice?

The Company

externa

l expertise”

iii) During the period under review, did the Directors obtain any independent professional advice? Yes/No

If yes, provide details.

No

Principle 10: Meetings of the Board

“Meetings are the principal vehicle for conducting the business of the Board and successfully fulfilling the

i) What is the process for reviewing and

approving minutes of Board meetings?

During Board Meetings

ii) What are the timelines for sending the minutes to Directors?

Within 2 weeks of the meeting

iii) What are the implications for Directors who do not meet the Company policy on

meeting attendance?

The Director will not be re-elected after retirement at the AGM.

Principle s

Reporting Questions

Yes/N o

Explanation on application or deviation

strategic objectives of the

Company”

Principle 11: Board

Committees

“To ensure efficiency and effectiveness, the Board delegates some of its functions, duties and responsibilities to well-structured

committees

, without abdicating its

responsibilities”

i) Do the Board Committees have Board-approved Charters which set out their responsibilities and terms of reference?

Yes/No

Yes

The Board Committee have its approved Charter

ii) What is the process for reviewing and approving minutes of the Board

Committee meetings?

At the Board Committee meetings

iii) What are the timelines for sending the

minutes to the directors?

Within 2 weeks of the date of the meeting

iv) Who acts as Secretary to board committees?

The Company Secretary

1. What Board Committees are responsible for the following matters?

   1. Nomination and Governance

   2. Remuneration

   3. Audit

   4. Risk Management

1. Board Nomination, Governance and Remuneration Committee.

2. Board Nomination, Governance, and Remuneration Committee.

3. Statutory Audit Committee (SAC) and Board Audit and Compliance Committee (BACC).

4. Enterprise Risk Management Committee

vi) What is the process of appointing the chair

of each committee?

Usually, by consensus of the Board

The committee responsible for Nomination and Governance

vii) What is the proportion of INEDs to NEDs on

the Committee responsible for Nomination and Governance?

The Committee is made up of only NEDs.

viii) Is the chairman of the Committee a NED or

INED?

NED

The Chairman of the Committee is a NED.

ix) Does the Company have a succession plan policy? Yes/No

If yes, how often is it reviewed?

Yes

3 Years

x) How often are Board and Committee charters, as well as other governance

policies, reviewed?

3 Years

xi) How does the committee report on its

activities to the Board?

During Board Meetings

Committee responsible for Remuneration

xii) What is the proportion of INEDs to NEDs on the Committee responsible for

Remuneration?

The Committee is made up of only NEDs.

xiii) Is the chairman of the Committee a NED

or INED ?

NED

Committee responsible for Audit

xiv) Does the Company have a Board Audit Committee separate from the Statutory Audit Committee? Yes/No

Yes

The Company has a Statutory Audit Committee in compliance with CAMA 2020, and Board Audit and Compliance Committee (BACC) in

compliance with NCCG 2018.

xv) Are members of the Committee responsible for Audit financially literate?

Yes/No

Yes

xvi) What are their qualifications and

experience?

B.Sc., MBA, PhD, and ACA.

xvii) Name the financial expert(s) on the Committee responsible for Audit

Mr Osomo Folorunso Omotola, Dr Chamberlain Peterside and Anthony Edeh.

Principle s

Reporting Questions

Yes/N o

Explanation on application or deviation

xviii) How often does the Committee responsible

for Audit review the internal auditor’s

reports?

Quarterly

xix) Does the Company have a Board approved internal control framework in

place? Yes/No

Yes

There is a Board-approved Internal Control Framework.

xx) How does the Board monitor compliance with the internal control framework?

Through Internal Control Reports

xxi) Does the Committee responsible for Audit review the External Auditor’s management letter, Key Audit Matters and management response to issues raised? Yes/No

Please explain.

Yes

They meet to review management letters from the External Auditor and report to the Board.

xxii) Is there a Board-approved policy that clearly specifies the non-audit services that the external auditor shall not

provide? Yes/No

yes

xxiii) How many times did the Audit Committee hold discussions with the head of the internal audit function and external auditors without the management during the period under

review?

Quarterly with the Internal Auditor, and Annually with the External Auditors

Committee responsible for Risk Management

xxiv) Is the Chairman of the Risk Committee a NED or an INED?

NED

xxv) Is there a Board-approved Risk Management framework?

Yes/No?

If yes, when was it approved?

Yes

February 14, 2023

xxvi) How often does the Committee review the adequacy and effectiveness of the Risk Management Controls in place?

Date of the last review

Quarterly October 28, 2025

xxvii) Does the Company have a Board-approved IT Data Governance Framework? Yes/No

If yes, how often is it reviewed?

Yes

3 Years.

xxviii) How often does the Committee receive

and review compliance report on the IT Data Governance Framework?

Quarterly

xxix) Is the Chief Risk Officer (CRO) a member

of Senior Management and does he have relevant experience for this role? Yes/No

Yes

The CRO is a member of the Senior Management Team.

xxx) How many meetings of the Committee

did the CRO attend during the period under review?

Four Meetings

Principle 12: Appointment to the Board

i) Is there a Board-approved policy for the

appointment of Directors? Yes/No

Yes

“A written, clearly defined, rigorous, formal and transparent procedure serves as a guide for the selection of Directors to ensure the appointment of high-quality individuals to the Board”

ii) What criteria are considered for their

appointment?

Competence in the required field.

iii) What is the Board process for ascertaining

that prospective directors are fit and proper persons?

By conducting evaluations and background checks.

1. Is there a defined tenure for the following:

   1. The Chairman

   2. The MD/CEO

   3. INED

Yes

1. Not more than 3 terms of 3 years each for the Chairman.

2. Not more than 10 years, 5 years each.

3. Not more than 3 terms of 3 years each for the INED.

Principle s

Reporting Questions

Yes/No

Explanation on application or deviation

1. NED

2. EDs

1. Not more than 3 terms of 3 years each for the NED.

2. Not more than 10 years, 5 years each.

v) Please state the tenure

Not more than 3 terms of 3 years for

INEDs, NEDs and 2 terms of 5 years each for Executives.

vi) Does the Board have a process to ensure that it is refreshed periodically? Yes/No?

Yes

Board Trainings

Principle 13: Induction and

i) Does the Board have a formal induction

Yes

Continuing Education

programme for new directors? Yes/No

“A formal induction programme on joining the Board as well as regular training assists Directors to effectively discharge their duties to the Company”

ii) During the period under review, were new Directors appointed? Yes/No

If yes, provide date ofinduction.

No

iii) Are Directors provided relevant training to enable them effectively to discharge their duties? Yes/No

If yes, provide training details.

Yes

Chartered Institute of Directors

NAICOM/COLLEGE OF INSURANCE

2025 Insurance Directors’ Conference:

Transforming the Insurance Industry

Through ESG Principles.

iv) How do you assess the training needs of Directors?

Based on request and on a need basis

v) Is there a Board-approved training plan?

Yes/No

Yes

vi) Has it been budgeted for? Yes/No

Yes

Principle 14: Board Evaluation

“Annual Board evaluation assesses how each Director, the committees of the Board and the Board are committed to their roles, work together and continue to contribute effectively to the achievement of the Company’s objectives”

i) Is there a Board-approved policy for evaluating Board performance? Yes/No

Yes

ii) For the period under review, was there any Board Evaluation exercise conducted? Yes/No

No

Not yet.

iii) If yes, indicate whether internal or external. Provide date of last evaluation.

2024

External. The previous Board evaluation was conducted in 2025 against the 2024 Financial Year.

iv) Has the Board Evaluation report been presented to the full Board? Yes/No

If yes, indicate date of presentation.

Yes

October 31, 2025.

v) Did the Chairman discuss the evaluation report with the individual directors?

Yes/No

Yes

vi) Is the result of the evaluation for each

Director considered in the re-election process? Yes/No

No

It will be considered during the 2026 AGM.

Principle 15: Corporate

i) For the period under review, has the Company conducted a corporate governance evaluation? Yes/No

If yes, provide date of the evaluation.

No

Not yet

Governance Evaluation

“Institutionalizing a system for evaluating the Company’s corporate

governance practices ensures that its

ii) Is the result of the Corporate Governance Evaluation presented and considered by

the Board? Yes/No

No

The Corporate Governance Evaluation will soon commence.

governance

standards, practices and processes are adequate and effective”

iii) If yes, please indicate the date of last

presentation.

iv) Is the summary of the Corporate Governance Evaluation included in the annual reports and the Investors portal? Yes/No

Yes

The Corporate Governance Report forms part of our annual report. This will

definitely be included in the annual

report to be shared with Shareholders,

and will be inserted in the investors’

portal.

Principle 16: Remuneration Governance

i) Is there a Board-approved Directors’

remuneration policy? Yes/No

If yes, how often is it

reviewed?

Yes

Yes, there is a Board-approved Directors’ Remuneration Policy.

3 Years.

Principle s

Reporting Questions

Explanation on application or deviation

“The Board ensures that the

Company remunerates fairly, responsibly and transparently so as to promote the achievement of strategic objectives and positive outcomes in the short, medium and long term”

ii) Provide details of directors’ fees, allowances and all other benefits paid to them during the period under review

Chairman – N5m P.A, Sitting Allowance – N500k per sitting.

NEDs – N4m P.A & Sitting Allowance

– N400k per sitting.

NEDs Transportation per meeting inter-State N400k

NEDs Hotel per night – N100k Vacation & Medical Allowance – $10k

iii) Is the remuneration of NEDs presented to shareholders for approval? Yes/No

If yes, when was it approved?

Yes

Yes, it was approved.

iv) What portion of the NEDs’ remuneration is

linked to company performance?

None

v) Is there a Board-approved remuneration policy for Executive and Senior management? Yes/No

If yes, to what extent is remuneration linked

to company performance?

Yes

To a reasonable extent, the company has a performance-based structured payment.

vi) Has the Board set KPIs for Executive Management? Yes/No

Yes

vii) If yes, was the performance measured against the KPIs? Yes/No

Yes

viii) Do the MD/CEO, EDs and Company

Secretary receive a sitting allowance and/or directors fees? Yes/No

No

1. Which of the following receive sitting allowance and/or fees:

   1. MD/CEO

   2. ED

   3. Company Secretary

   4. Other Senior management staff

None

x) Is there a Board-approved clawback policy for Executive management? Yes/No

If yes, attach the policy.

Yes

Principle 17:

Risk

Management

“A sound framework for managing risk and ensuring an effective internal control system is essential for achieving the strategic objectives of the Company”

i) Has the Board defined the company’s risk

appetite and limit? Yes/No

yes

ii) How often does the company conduct a risk assessment?

Regularly

iii) How often does the board receive and review risk management reports?

Quarterly

Principle 18: Internal Audit

“An effective internal audit function provides assurance to the Board on the effectiveness of the governance,

ris k management and internal control systems”

i) Does the company have an Internal Audit function? Yes/No

If no, how has the Board obtained adequate

assurance on the effectiveness of internal processes and systems?

Yes

The Company has an internal audit function.

ii) Does the company have a Board-approved

internal audit charter? Yes/No

Yes

iii) Is the head of internal audit a member of

senior management? Yes/No

Yes

iv) What is the qualification and experience of

the head of internal audit?

BSC, MSC & FCA (23 Year

Experience)

v) Does the company have a Board-approved annual risk-based internal audit plan?

Yes/No

Yes

vi) Does the head of the internal audit function

report at least once every quarter to the committee responsible for audit, on

the

Yes

Principle s

Reporting Questions

Explanation on application or deviation

Adequacy and effectiveness of management, governance, risk and control environment; deficiencies observed and management mitigation plans? Yes/No

Yes

vii) Is there an external assessment of the effectiveness of the internal audit function at least once every three years by a qualified independent reviewer appointed by the Board? Yes/No

If yes, when was the last assessment?

This was conducted by Messrs. Pedabo

Yes

in March 2025.

viii) Who undertakes and approves the

performance evaluation of the Head of Internal Audit?

The Statutory Audit Committee and the

Board Audit and Compliance

Committee.

Principle 19:

i) Does the company have a Board-approved whistleblowing framework? Yes/No

If yes, when was the date of lastreview

January 2023, and it is currently being

Whistleblowing

Yes

reviewed by KPGM.

“An effective whistleblowing framework for reporting any illegal or unethical behaviour minimises the Company’s exposure and prevents

recurrence”

ii) Does the Board ensure that the whistleblowing mechanism and are process reliable, accessible to all stakeholders, guarantees anonymity and protection of the whistleblower? Yes/No

Yes

1. Is the Audit committee provided with the following reports on a periodic basis?

   1. Reported cases

   2. Process and results of Investigated cases

Yes

Principle 20: External Audit

“An external auditor is appointed to provide an independent opinion on the true and fair view of the financial statements of the Company to give assurance to stakeholders on the reliability of the financial statements”

i) Who makes the recommendations for the

appointment, re-appointment or removal of external auditors?

The Statutory Audit Committee.

ii) Who approves the appointment, re-appointment, and removal of External Auditors?

The Board of Directors

iii) When was the first date of appointment of the External auditors?

Monday, August 3, 2020.

iv) How often are the audit partners rotated?

5Yrs

Principle 21: General

i) How many days prior to the last general meeting were notices, annual reports and

any other relevant information dispatched to Shareholders?

At least twenty-one days before the meeting.

Meetings

“General Meetings are important platforms for the Board to engage shareholders to facilitate greater understanding of the

ii) Were the Chairmen of all Board Committees and the Chairman of the Statutory Audit Committee present to respond to Shareholders’ enquiries at the last meeting? Yes/No

Yes

Yes, they were present at the AGM.

Company’s business,

governance and performance. They provide

shareholders with an opportunity to exercise their ownership rights and express their views to the Board on any areas of interest”

Principle 22: Shareholder Engagement

“The establishment of a system of regular dialogue with shareholders balance

1. Is there a Board-approved policy on Shareholders’ engagement? Yes/No

   If yes:

   1. when was it last reviewed?

   2. Is the policy hosted on the

company’s

website?

Yes

2022

Yes

Principle s

Reporting Questions

Explanation on application or deviation

their needs, interests and

expectations with the objectives of the Company”

ii) How does the Board engage with Institutional Investors and how often?

On a need basis as often as may be necessary and through meetings, publications and announcements

Principle 23: Protection of Shareholder Rights

“Equitable treatment of shareholders and the protection of their statutory and general

rights, particularly the interest of minority

shareholders, promote good governance”

1. Does the Board ensure that adequate and timely information is provided to the shareholders on the Company’s activities? Yes/No

Yes

Principle 24: Business Conduct and Ethics

“The establishment of professional business and ethical standards underscore the values for the protection and enhancement of the reputation of the Company while promoting good conduct and investor confidence”

1. Does the company have a Board-approved Code of Business Conduct and Ethics (COBE) that guides the professional business and ethical standards? Yes/No

   If yes:

   1. Has the COBE been communicated to all internal and external Stakeholders?

      Yes/No

   2. Is the COBE applicable to any or all of the following:

      1. Board

      2. Senior management

      3. Other employees

      4. Third parties

Yes

Yes

All

ii) When was the date of last review of the policy?

2024

iii) Has the Board incorporated a process for identifying, monitoring and reporting

adherence to the COBE? Yes/No

Yes

iv) What sanctions were imposed for the period under review for non-compliance

with the COBE?

The resignation of the MD/CEO and some staff members.

Principle 25: Ethical Culture

“The establishment of policies and mechanisms for monitoring insider trading, related party transactions,

1. Is there a Board- approved policy on insider trading? Yes/No

   If yes:

   1. When was the last date of review?

   2. How does the Board monitor compliance with this policy?

Yes

2023

Through reports

conflict of interest and other corrupt activities, mitigates

the adverse effects of these abuses on the Companyand promotes good ethical conduct and investor confidence”

1. Does the company have a Board-approved policy on related party transactions? Yes/No

   If yes:

   1. When was the last date of review?

   2. How does the Board monitor compliance with this policy?

   3. Is the policy applicable to any or all of the following:

      1. Board

      2. Senior management

      3. Other employees (Specify)

      4. Third parties (Specify)

Yes

2022

2022

Through reports

Yes, the policy applies to the Board, Senior Management, Substantive Shareholders of 5% and above, and Family Members.

iii) How does the Board ensure adequate

disclosure of Related Party Transactions by the responsible parties?

By effective report review

Principle s

Reporting Questions

Explanation on application or deviation

iv) Does the company have a Board-

approved policy on conflict of interest?

Yes/No

Yes

If yes:

1. When was the last date of review?

2. How does the Board monitor compliance with this policy?

3. Is the policy applicable to any or all of the following:

   1. Senior management

   2. Other employees (Specify)

2024

Through reports

All

Principle 26: Sustainability

i) Is there a Board-approved sustainability policy? Yes/No

If yes, when was it last reviewed?

2022

“Paying adequate attention to sustainability issues including environment, social, occupational and community health and safety ensures successful long-term business performance and projects the Company as a responsible corporate citizen contributing to economic development”

Yes

ii) How does the Board monitor compliance with the policy?

Through reports and reviews

iii) How does the Board report compliance with the policy?

In the Board meeting

iv) Is there a Board-approved policy on diversity in the workplace? Yes/No If yes, when was it last reviewed?

Yes

2022

Principle 27: Stakeholder

i) Is there a Board-approved policy on

stakeholder management and communication? Yes/No

Communication

Yes

“Communicating and

interacting with stakeholders keeps them conversant with the activities of the Company and assists them in making

informed decisions”

ii) Does the Company have an up-to-date investor relations portal? Yes/No

If yes, provide the link.

Yes

Ieiplcng.com

Principle 28: Disclosures

i) Does the company’s annual report include a summary of the corporate governance report? Yes/No

“Full and comprehensive disclosure of all matters material to

Yes

ii) Has the company been fined by any regulator during the reporting period? Yes/No

If yes, provide details of the fines and penalties.

Penalty from SEC and NGX for late

investors and stakeholders, and of matters set out in this Code,

Yes

filing of Audited Financial

Statements for the year ended 2024.

ensures proper monitoring of its implementation which engenders

good corporate governance

practice”