A concern may be raised by a whistle blower through any of the following channels:

a. A dedicated email address: whistleblowing@fmbn.gov.ng, which should be under the superintendence of the GH (Internal Audit) and upon the reciept of any complaint/concern the GH (Internal Audit) shall bring same to the attention of the MD/CE within 24hours.

b. Via a form on the Bank’s website: www.fmbn.gov.ng/whistleblowing

c. A formal letter to the Managing Director/Chief Executive, Federal Mortgage Bank of Nigeria;

d. A formal letter to the Chairman Audit Committee;

e. A formal letter to the Group Head (ICT);

f. Any other channel that the Executive Management Committee may assign in future. Where the concern is recieved by staff other than the Managing Director or the Group Head Internal Audit, the recipient shall be required to;

g. Immediately forward the concerns to the Group Head, internal Audit, within 24 hours to ascertain the authencity of the concern.

h. If the concerns affects the Group Head, Internal Audit, the Managing Director shall be notified.

i. where issues affect a member(s) of the Executive Management, such issues should be referred to the Board via the Chairman, Board Audit Committee.

The concern(s) shall be presented in the following format;

j. Background of the concerns (with relevant dates)

k. Disclosure of any information connected with the activities of the Bank which indicates the following:

l. That an infraction has been committed;

m. That a person has failed to comply with relevant regulations, internal policies and procedures; and

n. That someone has concealed matters falling within (i) or (ii) above.

o. Reason(s) why the whistle blower is concerned about the situation. In line with the provisions of the FMBN Staff Conditions of Service, disciplinary measures shall be meted against any staff that recieves forwarded concerns and fails to refer same to the appropriate person.

Upon receipt of the concern of the whistleblower, the Managing Director/Chief Executive shall forward the concern to the Group Head, Internal Audit within two (2) working days, to determine its credibility and if there is a legitimate basis to initiate an investigation.

Where it has been established that there is need for an investigation, the Group Head, Internal Audit shall on reciept of the concern(s) acknowledge same from the whistle blower within two (2) working days whilst commencing investigation. The aim of the investigation shall be to:

 Establish if a malpractice has occurred based on the concern(s) raised, and if so, to what degree; and

 Mitigate the risk of further occurence of malpractice, loss of the Bank’s assets, reputational damage and where possible secure all sources of evidence.

Where necessary the Group Head Internal Audit shall provide an update on the progress of the investigation to the Managing Director and the whistleblower on a weekly basis.

Conclusion of Investigation and Action on Report

Upon conclusion of the investigation, the Group Head Internal Audit shall submit a report and recommend appropriate action(s) to the Executive Management Committee within two working days of the end of the investigation process.

Where concerns raised affect the Executive Management, such issues shall be referrred to the Board, through the Board Audit Committee within five (5) working days upon conclusion of the investigation.

The Board shall approve appropriate action to address the raised concerns within a reasonable timeframe (not to exceed a quarter).

Where the investigation reveals that the reported concern falls outside the scope of the policy, such matters shall be referred to the appropriate quarters for further action.

If however, the investigation reveals that the concern(s) raised by the whistleblower is frivolous, the Group Head Internal Audit shall refer such cases to the Human Resource Management Group for application of an appropriate disciplinary action to the concerned staff or group involved.

If the concerns are linked to an external party for clarity, service provider, developers etc and it is established that an impropriety has been perpetuated by same, the Bank shall review the Service Level Agreement with such party and if necessary terminate the agreement.

Where it is established that a criminal activity has taken place, the matter may be referred to the Nigerian Police Force, the EFCC, NDLEA etc and where necessary, appropriate legal action taken.

The Group Head Internal Audit shall provide the Chairman of the Board Audit Committee with a summary of cases reported and the result of the investigation on a quarterly basis.

In the event that a whistleblower is disatisfied with the outcome of an investigation or the recommended action(s), he/she is at liberty to escalate their concerns to the Chairman of the Board Audit Committee for further action. Their concerns must be raised within one week after the decision has been taken or such concerns shall not be entertained, unless such delay is supported by valid reasons.

An external whistleblower is at liberty to report to the approriate regulatory body or seek further redress in the court of law