REAL ESTATE GOVERNANCE & POLICY HANDBOOK

PREAMBLE

This Real Estate Governance & Policy Handbook ("Handbook") sets out the internal governance framework, operational policies, compliance standards, and risk management principles of House Number Five Ltd ("the Company").

This Handbook is designed to:

• Institutionalise best practices in Nigerian real estate development;
• Protect the Company from legal, regulatory, financial, and reputational risk;
• Provide clarity, consistency, and accountability across all projects;
• Meet the expectations of investors, regulators, lenders, partners, and courts of law.

This Handbook shall be binding on all directors, officers, employees, consultants, agents, contractors, and representatives of the Company.

GOVERNING LAW

This Handbook and all policies contained herein shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including applicable statutes, regulations, common law principles, and equity.

PART A: LAND, TITLE & ACQUISITION GOVERNANCE

1. Land Acquisition & Title Due Diligence Policy

1.1 Objective

To ensure that all land acquisitions are legally valid, secure, and free from encumbrances.

1.2 Mandatory Due Diligence Requirements

• Verification of root of title;
• Searches at relevant land registries;
• Confirmation of Government Approval where applicable;
• Physical inspection and community verification;
• Legal opinion from external counsel.

1.3 Prohibition

No land shall be acquired without written approval of the Board or its delegated committee.

2. Anti-Fraud & Property Misrepresentation Policy

2.1 Zero Tolerance

The Company adopts a zero-tolerance stance on fraud, misrepresentation, or concealment in land transactions.

2.2 Staff Obligations

All staff must disclose conflicts of interest and refrain from unauthorised representations.

PART B: SALES, CLIENT & INVESTOR GOVERNANCE

3. Sales, Allocation & Subscription Policy

3.1 Nature of Allocation

Allocation confers a contractual right only and does not constitute legal ownership until full compliance and documentation.

3.2 Company Rights

The Company reserves the right to substitute, redesign, reallocate, or withdraw units where commercially or legally required.

4. Refund, Cancellation & Forfeiture Policy

4.1 General Rule

All payments are non-refundable except as expressly approved by the Company.

4.2 Default

Defaulting clients may forfeit payments subject to administrative deductions.

PART C: CONSTRUCTION & PROJECT DELIVERY

5. Construction Variations & Change Management Policy

The Company retains absolute discretion to vary designs, specifications, materials, and timelines.

6. Health, Safety & Environmental (HSE) Policy

The Company is committed to maintaining safe construction environments and complying with environmental standards.

PART D: ESTATE MANAGEMENT & POST-HANDOVER

7. Estate Rules, Use & Occupancy Policy

All occupants shall comply with estate rules governing use, modifications, and conduct.

8. Defects Liability & Maintenance Policy

Defects shall be addressed within the specified liability period, excluding wear and tear.

PART E: CORPORATE COMPLIANCE & ETHICS

9. Anti-Bribery & Corruption Policy

The Company prohibits bribery in all dealings and enforces strict compliance.

10. Whistleblowing Policy

Protected reporting channels are available for misconduct.

PART F: TECHNOLOGY & SMART CITY GOVERNANCE

11. Smart Infrastructure & Technology Use Policy

Data-driven systems shall be deployed responsibly and lawfully.

12. Cybersecurity & IT Acceptable Use Policy

All users must adhere to cybersecurity controls and acceptable use standards.

PART G: RISK, DISPUTE & INSURANCE

13. Dispute Resolution & Claims Handling Policy

Disputes shall be managed internally prior to litigation or arbitration.

14. Insurance & Risk Transfer Policy

The Company shall maintain adequate insurance coverage for all projects.

FINAL PROVISIONS

Amendment

This Handbook may be amended by Board resolution.

Compliance

Non-compliance may result in disciplinary or legal action.