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.
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
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.
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.
5.1 The whistle blowing procedure outlines the steps that are to be taken by a whistle blower in disclosing acts of illegal or unethical behaviour. The following procedure shall guide the whistle blowing process:
|1.||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. A dedicated email address: email@example.com, 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.
|2||STEP TWO: Investigation of Raised Concerns and Update on progress of investigation.||
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.
|4.||STEP FOUR: Disatisfaction with the outcome of the investigation or recommended action(s)||
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
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.
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.
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.
To Report any suspected acts of impropriety and unethical practices, you can reach us via the following email