Whistleblowing Policy
Policy Brief
1.1 The Federal Mortgage Bank of Nigeria is committed to ensuring that its business processes and procedures are transparently 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 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.
Purpose of the Policy
This policy and procedure manual is intended to encourage staff and other relevant stakeholders to report suspected unethical conduct in a confidential manner without any fear of harassment, intimidation, victimisation or reprisal. Other objectives include:
- To support the identification and resolution of any identified malpractice across all levels of the Bank;
- To provide a clear framework for reporting and escalating identified unethical conduct(s);
- To prevent the circumvention of the Bank's internal processes and mechanisms;
- To foster a culture of transparency, accountability and integrity in line with the Bank's core values of Integrity, Professionalism, Accountability and Customer-centricity;
- To entrench a good corporate governance system in the Bank.
Scope of the Policy
The suspected acts of impropriety and unethical practices covered under this policy include:
- All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment;
- Failure to comply with legal obligations statutes and regulatory directives;
- Actions detrimental to health and safety or the work environment;
- Any form of criminal activity;
- Improper conduct or unethical behaviour;
- Other forms of corporate governance breaches;
- Insider abuse;
- Non-disclosure of interests;
- Attempt to conceal any of the above listed acts.
Board and Management Commitment
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 adversely impact the Bank through appropriate channels, without fear of reprisal or victimisation.
Whistle Blowing Procedure
STEP ONE
Raising concern(s) by a whistle blower
A concern may be raised by a whistle blower through any of the following channels:
- A dedicated email address: whistleblowing@fmbn.gov.ng, which should be under the superintendence of the GH (Internal Audit) and upon the receipt of any complaint/concern the GH (Internal Audit) shall bring same to the attention of the MD/CE within 24 hours.
- Via a form on the Bank's website: www.fmbn.gov.ng/whistleblowing
- A formal letter to the Managing Director/Chief Executive, Federal Mortgage Bank of Nigeria;
- A formal letter to the Chairman Audit Committee;
- A formal letter to the Group Head (ICT);
- Any other channel that the Executive Management Committee may assign in future.
The concern(s) shall be presented including: background of the concerns (with relevant dates), disclosure of any information connected with the activities of the Bank which indicates that an infraction has been committed, that a person has failed to comply with relevant regulations, and reason(s) why the whistle blower is concerned about the situation.
STEP TWO
Investigation of Raised Concerns and Update on progress
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 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 and to mitigate the risk of further occurrence of malpractice, loss of the Bank's assets, reputational damage and where possible secure all sources of evidence.
STEP THREE
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 referred 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).
STEP FOUR
Dissatisfaction with the outcome of the investigation
In the event that a whistleblower is dissatisfied 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 appropriate regulatory body or seek further redress in the court of law.
Timeline for Investigation
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. 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
The Bank shall offer protection to whistleblowers who disclose concerns, provided the disclosure is made in the reasonable belief that it is intended to show malpractice or impropriety, and 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.
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. 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
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.
Report Suspected Misconduct
To report any suspected acts of impropriety and unethical practices, reach us via: