Lotus Capital Whistle Blowing Form

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Our whistle blowing form provides a secure platform to encourage staff and relevant stakeholders to report suspected unethical conduct of employees, Management, and other stakeholders of the Bank in a confidential manner without any fear of harassment, intimidation or reprisal.
POLICY BRIEF
1.1 The Federal Mortgage Bank of Nigeria is committed to ensuring that its business processes and procedures are transperently and ethically conducted in accordance with the relevant legal obligations, statutes and regulatory directives.

1.2 This whistle blowing policy is in furtherance of the Bank’s desire to strengthen its value of integrity and its fight against corruption, financial crime, impropriety and related offences.

1.3 In this policy, ‘whistle blowing’ means the act of reporting any alleged unethical conduct of employees, Management, Directors and other stakeholders of the Bank by an employee or other person to appropriate authorities

1.4 A whistle-blower is any person(s) including the employee, Management, Directors, contributors, service providers, creditors and other stakeholder(s) of the Bank who reports any form of unethical behaviour or dishonesty perpetuated in the Bank to the appropriate authority

1.5 This policy and procedure manual sets out a framework for reporting and investigating all allegations of impropriety and any other misconduct. The policy takes cognizance of the requirements of section 3.1 of the Central Bank of Nigeria (CBN) ‘‘Guidelines for whistleblowing for banks and other financial institution in Nigeria’’, and section 5.3.1 of the ‘Code of Corporate Governance for Banks and Discount Houses’ both of May 16, 2014. It is consistent with the provisions of the two aforementioned regulatory policies with respect to definitions of whistle blowing and whistle blower.

PURPOSE OF THE POLICY
2.1This policy and procedure manual is intended to encourage staff and other relevant stakeholders to report suspected unethical conduct of employees, Management, Directors and other stakeholders of the Bank in a confidential manner without any fear of harassment, intimidation, victimisation or reprisal of anyone for raising concern(s) under this policy. Other objectives of this poilicy are;

I. To support the identification and resolution of any identified malpractice across all levels of the Bank;.

II. To provide a clear framework for reporting and escalating identified unethical conduct(s);

III. To prevent the circumvention of the Bank’s internal processes and mechanisms;

IV. To foster a culture of transperency, accountability and integrity in line with the Bank’s core values of Integrity, Professionalism, Accountability and Customercentricity among staff and the Bank’s other stakeholders;

V. To entrench a good corporate governance system in the Bank

SCOPE OF THE POLICY
3.1 The suspected acts of impropriety and unethical practices covered under this policy include:
a. All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment;
b.Failure to comply with legal obligations statutes and regulatory directives;
c.Actions detrimental to health and safety or the work environment;
d. Any form of criminal activity;
e. Improper conduct or unethical behaviour;;
f. Other forms of corporate governance breaches;
g. Failure to comply with regulatory directives;
h. Undisclosed or unreported connected transactions;
i. Insider abuse;
j. Non-disclosure of interests;
k. Attempt to conceal any of the above listed acts.

3.2 While the aforementioned acts are not exhaustive, discretion shall be applied to determine other unethical practices that should be reported under this policy.

3.3 For the purpose of clarity, this policy does not cover individual staff grieviances and other staff related matters covered in the Bank’s staff conditions of service. Individual staff grievances should be reported in accordance with the Bank’s grievance procedures.

BOARD AND MANAGEMENT COMMITMENT TO THE POLICY
4.1 The Board and Management of the Federal Mortgage Bank of Nigeria is committed to achieving the highest possible ethical standards in carrying out all its business operations and therefore, encourage staff and other stakeholders to disclose suspected acts of impropriety and unethical practices that may adversly impact the Bank through appropriate channels, without fear of reprisal or victimisation.

TIMELINE FOR INVESTIGATION
6.0 The Bank is committed to handling investigations in a prompt manner however, the dynamics of an investigation process may delay the conclusion of an inquiry.

Where feasible, the Group Head Internal Audit shall work towards the resolution of all raised concerns within four weeks and if for any reason, this cannot be achieved, he/she shall update the Managing Director and Chairman Board Audit Committee accordingly.

PROTECTION OF THE WHISTLEBLOWER
7.0 The Bank shall offer protection to whistleblowers who disclose concerns, provided the disclosure is made:

a. in the reasonable belief that it is intended to show malpractice or impropriety; and

b.to an appropriate person or authority.

While all disclosures resulting from whistleblowing shall be treated in a confidential manner and the identity of the whistleblower shall be protected, staff and stakeholders are encouraged to disclose their name when filing reports to make their reports more credible.

Anonymous disclosures shall also be considered on discretionary basis while taking into account the following factors

a. the seriousness of the issues;
b. the significance and credibility of the concern; and
c. the possiblity of confirming the allegation
Staff and other stakeholders should excercise due care in reporting their concern. Where malicious allegations are made, no action shall be taken. Whistleblowers must ensure that they do not make disclosure outside of the prescribed channels (e.g media-print or electronic), or their disclosures may not be protected.

The Bank shall not subject a whistleblower to any detriment on the grounds of a disclosure made in accordance with the provisions of this policy. Where a whistleblower feels he/she has been subjected to any detriment on account of a disclosure, he or she may present a complaint to the CBN. This is without prejudice to the right of the whistleblower to take appropriate legal action.

For the purpose of this policy, the word “detriment” includes dismissal, termination, redundancy, undue influence, duress, withholding of benefits and/or entitlements and any other act that has negative impact on the whistleblower.

POLICY REVIEW TIMELINE
8.0 In line with the Central Bank of Nigeria (CBN) ‘‘Guidelines for whistleblowing for banks and other financial institution in Nigeria this policy shall be reviewed every three (3) years.