Governance, Disclosures & Legal Terms

1. Regulatory Status & Corporate Structure

Venoble Limited (“Venoble,” “the Company,” “we,” “us,” or “our”) is a research, benchmark, and advisory firm incorporated in Canada and registered with the Corporate Affairs Commission (CAC) of the Federal Republic of Nigeria.

Important Disclaimers

Venoble Limited is not a registered broker-dealer, investment adviser, transfer agent, or custodian in any jurisdiction. We do not hold client funds, execute securities transactions, or provide personalised investment advice.

• Research publications produced by Venoble are for informational and educational purposes only. They do not constitute investment advice, a solicitation, or an offer to buy or sell any security or financial instrument.
• Index products are benchmarks designed for reference and measurement purposes. They are not directly investable, and the publication of an index does not constitute a recommendation to buy, sell, or hold any security.
• Advisory services are provided under bespoke engagement agreements with institutional clients and do not constitute regulated investment advice unless explicitly stated under a licensed arrangement.
• Capital management services, where offered, are facilitated through regulated third-party brokerage and custodial partners. Venoble acts as a technology platform connecting clients with licensed service providers.

Past performance of any index, benchmark, or investment strategy discussed in our publications is not indicative of future results. All investments carry risk, including the possible loss of principal.

2. Index & Benchmark Governance

IOSCO Alignment

Venoble’s index methodologies are designed with reference to the IOSCO Principles for Financial Benchmarks (2013), the internationally recognised standard for benchmark governance, quality, and accountability. This includes adherence to principles governing:

• Governance and accountability of the benchmark administrator
• Quality and integrity of benchmark determination methodology
• Quality of input data and data sufficiency
• Transparency of benchmark determinations
• Complaints handling and audit trail maintenance

Methodology Governance

• All index methodologies are published in full and freely accessible on our website.
• Material methodology changes are announced at least 30 calendar days before taking effect.
• All methodology documents carry version numbers and a public changelog with effective dates.
• Minor corrections (typographical, clarificatory, with no calculation impact) are applied immediately and logged in the changelog.

Data Governance

• All index inputs are sourced exclusively from official government publications and regulated market data. No proprietary vendor feeds or estimated data are used.
• If a primary data source revises previously published data, affected index levels are recalculated and a revision notice is published, including original values, revised values, reason, and effective date.
• All publications carry a publication timestamp (date and time, WAT). No publication is backdated.

Index Disclaimers

It is not possible to invest directly in an index. Index levels are published for reference and measurement purposes only. Exposure to an asset class or strategy represented by an index is only available through third-party investable instruments, if any exist. Index returns, as published, do not reflect the payment of transaction costs, management fees, or other charges. The imposition of such costs would cause actual investment performance to differ from published index returns.

Venoble indices are provided “as is” without warranty of any kind, express or implied. The Company does not guarantee the accuracy, completeness, or timeliness of any index data. Index levels may be subject to revision as described in the applicable methodology document. Recipients of index data should conduct their own due diligence and not rely solely on index levels for investment decisions.

Certain index data may include back-tested or hypothetical performance. Back-tested performance is not actual performance but is hypothetical. There are frequently material differences between back-tested results and actual results subsequently achieved. Back-tested data is clearly identified as such in all publications and data exports.

Data Usage Restrictions

Redistribution, reproduction, or commercial use of any Venoble index data, index names, or methodologies without prior written authorisation is strictly prohibited. Use of Venoble content for training, developing, or improving artificial intelligence, machine learning, or large language models (AI/ML/LLM) is prohibited without a separate written agreement. See our Terms of Use for the complete list of restrictions.

3. Research & Publications Compliance

Editorial Independence

Research and advisory conclusions are editorially independent from Venoble’s technology platform and capital management business activities. No business relationship, commercial interest, or client engagement influences the editorial content of our publications.

Publication Standards

• All publications follow a standardised template with clear methodology disclosure and data source citations.
• Every publication undergoes an internal compliance review before release, including verification of data sources, calculation accuracy, methodology consistency, conflict-of-interest review, and disclaimer completeness.
• Global macro context (e.g., Federal Reserve policy, USD dynamics, oil prices) is included only where it has a direct bearing on the African markets under analysis — not as standalone coverage.

Research Disclaimers

Venoble’s research publications are prepared for informational purposes only. They do not constitute investment advice, a recommendation, or a solicitation to buy, sell, or hold any security or financial instrument. The information contained in our publications is obtained from sources we believe to be reliable, but we do not guarantee its accuracy or completeness. Opinions expressed are current as of the publication date and are subject to change without notice.

Recipients should not regard any publication as a substitute for the exercise of their own judgement. Any investment decisions should be made in consultation with a qualified professional adviser who understands your specific circumstances.

4. Capital Management & Brokerage

Brokerage & Custody Arrangements

Where Venoble facilitates access to securities trading or portfolio construction, all brokerage and custody services are provided through regulated third-party partners:

• United States securities: Execution and custody through FINRA-registered, SIPC-covered brokerage partners. Client assets held at these partners are protected under applicable SIPC coverage limits.
• Nigerian securities: Execution and custody through Nigerian SEC-regulated and CBN-licensed partner institutions.

Venoble does not hold, control, or have discretionary authority over client funds or securities at any time. All client assets are held in accounts at the applicable regulated partner institution.

Platform Role

Venoble’s capital management technology platform provides portfolio construction tools, guided asset selection, dynamic allocation suggestions, multi-currency wallet management, and reporting capabilities. Clients retain full control over all investment decisions. The platform does not make investment decisions on behalf of clients.

Fee Disclosure

All applicable fees — including coordination fees, performance-based fees, foreign exchange conversion spreads, and any third-party charges — are disclosed to clients in advance of any transaction or plan activation. Fee calculations, collection methods, and historical fee records are accessible to clients through their account dashboard and quarterly statements.

Foreign Exchange

Foreign exchange conversions are executed through licensed FX providers. For each conversion, the market mid-rate, Venoble’s spread, and the all-in rate are displayed to the client before confirmation. No conversion is executed without explicit client consent.

5. Privacy & Data Protection

Venoble Limited processes personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), administered by the Nigeria Data Protection Commission (NDPC), and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada.

Our comprehensive Privacy Policy covers: categories of data we collect, lawful bases for processing, how we use and share data, international data transfers, data retention and security, cookies, your rights under Nigerian and Canadian law, our Data Protection Officer, and our data breach notification procedures.

Read our full Privacy Policy →

Key Commitments

• We do not sell personal data to third parties.
• We do not use advertising or cross-site tracking cookies.
• We process data only where we have a lawful basis (consent, contract, legal obligation, or legitimate interest).
• We have designated a Data Protection Officer, contactable at privacy@venoble.com.
• In the event of a data breach likely to affect your rights, we will notify the relevant supervisory authority within 72 hours and inform affected individuals without undue delay.
• You have the right to access, correct, delete, and port your data, and to lodge a complaint with the NDPC or the Office of the Privacy Commissioner of Canada.

6. Anti-Money Laundering & Know Your Customer

Venoble maintains an Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance programme in accordance with:

• The Money Laundering (Prohibition) Act 2022 of Nigeria and regulations issued by the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU).
• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) of Canada and regulations administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

KYC Procedures

All clients accessing Venoble’s capital management platform or entering into advisory engagements are subject to identity verification procedures before services are activated. This includes:

• Verification of identity using government-issued documentation.
• Verification of beneficial ownership for corporate and institutional clients.
• Collection of jurisdiction-specific tax certifications (e.g., W-8BEN for non-US persons, W-9 for US persons) where required by brokerage partners.
• Screening against applicable sanctions lists and politically exposed persons (PEP) databases.
• Ongoing monitoring and periodic review of client information.

Suspicious Activity Reporting

Venoble is obligated to file suspicious transaction reports with applicable authorities where there are reasonable grounds to suspect money laundering, terrorist financing, or other financial crime. We are prohibited by law from disclosing the existence or content of such reports to the affected party (“tipping off”).

7. Conflicts of Interest

Venoble operates two distinct but complementary business arms: a research, index, and advisory firm, and a capital management technology platform. We recognise that this structure creates potential conflicts of interest and maintain the following safeguards:

• Editorial independence: Research and index conclusions are editorially independent from commercial, advisory, and platform business activities. No business relationship or revenue consideration influences the content of our publications or index calculations.
• Personnel disclosure: If Venoble or its principals hold positions in securities or instruments discussed in a publication, this is disclosed prominently within the publication.
• Advisory conflict disclosure: Advisory engagements that could create conflicts with published research are disclosed in both the research publication and the advisory deliverable.
• Index integrity: Index calculation processes are rule-based and automated. No individual has discretionary authority to alter index levels outside the published methodology.
• Information barriers: Appropriate information barriers are maintained between business functions where necessary to prevent the misuse of material non-public information.

Clients or stakeholders who believe a conflict of interest has not been adequately disclosed or managed may contact compliance@venoble.com.

8. Intellectual Property

All content on this website, including but not limited to research publications, index methodologies, index data, analytical tools, trademarks, logos, and software, is the proprietary intellectual property of Venoble Limited or its licensors and is protected by applicable copyright, trademark, and intellectual property laws.

Permitted Use

• You may access, download, and print materials from this website for personal, non-commercial, informational purposes only.
• Brief quotations from research publications are permitted with proper attribution to Venoble Limited, provided the quotation does not misrepresent the context or conclusions of the original work.

Restricted Use

• Redistribution, reproduction, republication, or commercial use of any Venoble content without prior written authorisation is strictly prohibited.
• Use of Venoble index data, index names, or index methodologies for the creation, marketing, or management of financial products (including but not limited to exchange-traded funds, mutual funds, structured products, or derivatives) requires a separate index licensing agreement.
• Systematic or automated extraction of data from this website (scraping, crawling, or harvesting) is prohibited without express written consent.

For licensing enquiries, contact compliance@venoble.com.

9. Terms of Use

Use of the Venoble website and all associated services is governed by our Terms of Use. By accessing this website, you agree to be bound by those terms.

Read our full Terms of Use →

Key Provisions

• All content is provided “as is” without warranty of any kind.
• Your use of this website does not create a client, advisory, or fiduciary relationship.
• Redistribution, commercial use, or AI/ML training use of Venoble content requires a separate written agreement.
• It is not possible to invest directly in an index.
• Venoble disclaims all liability for damages arising from use of the website or reliance on its content.
• Governed by the laws of the Province of Ontario and the federal laws of Canada.

10. Forward-Looking Statements

Certain content on this website and in our publications, including market outlooks, economic forecasts, and analytical commentary, may contain forward-looking statements. These statements relate to future events or future performance and are based on current expectations, assumptions, and projections that are subject to risks and uncertainties.

Forward-looking statements are identified by words such as “may,” “will,” “expect,” “anticipate,” “believe,” “estimate,” “project,” “intend,” “forecast,” “outlook,” or similar expressions. Actual results may differ materially from those expressed or implied in any forward-looking statement.

Venoble undertakes no obligation to update or revise any forward-looking statement to reflect events or circumstances occurring after the date of publication. Forward-looking statements should not be relied upon as a prediction or guarantee of future results. Past performance of any index, benchmark, or investment strategy is not indicative of future results.

11. Complaints & Contact

If you have a complaint, concern, or enquiry regarding Venoble’s compliance practices, data handling, research publications, index methodologies, or any matter covered on this page, please contact:

We aim to acknowledge all complaints within five (5) business days and to provide a substantive response within thirty (30) business days. If you are not satisfied with our response, you may escalate your complaint to the relevant regulatory authority in your jurisdiction.

Regulatory Authorities

• Nigeria: Nigeria Data Protection Commission (NDPC); Securities and Exchange Commission (SEC Nigeria); Central Bank of Nigeria (CBN).
• Canada: Office of the Privacy Commissioner of Canada (OPC); Ontario Securities Commission (OSC); Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).