2025-01-17
The Nigeria Deposit Insurance Corporation (NDIC) has implemented a Whistleblowing Policy and Procedure to provide a confidential channel for employees and stakeholders to report workplace malpractices. This policy aims to encourage the reporting of unethical or illegal conduct within the Corporation without fear of harassment or victimization. The policy outlines the procedures for reporting, investigating, and addressing reported cases, while also ensuring the protection of whistleblowers and the integrity of the process. The policy covers financial malpractices, failure to comply with regulations, health and safety concerns, unethical behavior, and other misconducts that affect the corporation and its stakeholders.
Nigeria Deposit Insurance Corporation Protecting your bank deposits
NIGERIA DEPOSIT INSURANCE CORPORATION
WHISTLEBLOWING POLICY AND PROCEDURE
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CONTENT
1.0 INTRODUCTION
2.0 OBJECTIVES OF THE POLICY
0 SCOPE OF THE POLICY
0 FALSE PUBLICATIONS
0 COMMITMENT TO THE POLICY
1 SCOPE OF ANONYMITY
2 SANCTIONS AGAINST FALSE WHISTLEBLOWERS
3 PROTECTION OF WHISTLEBLOWERS
0 ROLES & RESPONSIBILITIES OF PARTIES
0 TYPES OF WHISTLEBLOWING
0 WHISTLEBLOWING PROCEDURE AND FORMAT
1 INTERNAL WHISTLEBLOWING PROCEDURE
1-1 REPORTING FORMAT FOR INTERNAL WHISTLEBLOWER
WHISTLEBLOWER
2 EXTERNAL WHISTLE-BLOWING PROCEDURE
WHISTLEBLOWER
MEMBERSHIP
0 TIME LIMIT FOR INVESTIGATION
0 COMPENSATION FOR WHISTLEBLOWER
0 FALSE/UNTRUE ALLEGATIONS
0 REPORTING
0 WITHDRAWAL OF REPORT BY WHISTLEBLOWER
0 RESIGNATION OF SUBJECT OF INVESTIGATION PRIOR TO THE CONCLUSION OF
INVESTIGATION
0 CUSTODIAN OF POLICY AND FREQUENCY OF REVIEW
0 DEFINITION OF TERMS
0 STAFF DECLARATION
0 WHISTLE-BLOWING FORM
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VISION:
"To be one of the best Deposit Insurers in the world"
MISSION:
"To protect depositors and contribute to the stability of the financial system through
effective supervision of insured institutions, provision of financial and technical
assistance to eligible insured financial institutions, prompt payment of guaranteed
sums and orderly resolution of failed insured financial institutions".
MANDATE:
a) Deposit Guarantee.
b) Bank Supervision.
c) Distress Resolution; and
d) Bank Liquidation.
PUBLIC POLICY OBJECTIVES:
a) Protecting depositors by providing an orderly means of compensation in the
event of failure of an insured financial institution.
b) Contributing to financial system stability by making incidence of bank runs less
likely; and
c) Enhancing public confidence by providing a framework for the resolution and
orderly exit of failing and failed insured institutions.
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To ensure high ethical standard in all its activities, the Corporation has established a
code of conduct and ethics which set out the standard of conduct expected of all its
staff across the Departments, Units and Zones within the Corporation.
In furtherance of this, the NDIC Whistleblowing Policy and Procedure provides a
channel for the Corporation's employees and other relevant stakeholders to raise
concerns about workplace malpractices, in a confidential manner; for the Corporation
to investigate alleged malpractices and take steps to deal with such in a manner
consistent with the Corporation's policies and procedures and relevant regulations.
This policy and procedure manual outlines the Corporation's Policy on whistleblowing
and the procedure for investigating and dealing with all reported cases of illegal and
unethical conduct and any other misconduct across the Corporation. It aims to create
an environment where employees, vendors, service providers, customers and other
stakeholders are able to raise concerns on misconduct, irregularities, or malpractices,
without fear of harassment and/or victimization and with an assurance that their
concerns will be taken seriously and investigated, and the outcome duly
communicated.
Whistleblowing is the act of reporting alleged unethical conduct of employees,
management, directors and other stakeholders by an employee or other person to the
appropriate authorities.
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A whistleblower is any person(s) including the employee, management, directors,
depositors, service providers, creditors and other stakeholder(s) of an institution who
reports any form of unethical behavior or dishonesty to the appropriate authority.
Employers and employees are key stakeholders and therefore expected to play a vital
role in deterring and detecting malpractices, wrongdoing, or irregularity. The process
of whistleblowing can be initiated either internally or externally. Employees are internal
whistleblowers who report incidents of misconduct in an organization involving a
peer/colleague, a supervisor or indeed a top management official. On the other hand,
external whistleblowers, who are mostly customers/suppliers report wrong doings of
employees to the appropriate authority.
For purpose of this policy, all Non-Executive Directors of the Corporation are
categorised as internal whistleblowers.
This policy aims to abate the fear of reprisal by way of harassment or victimization in
the hands of the organization or group of people accused. However, in order to gain
the protection afforded to whistleblowers by this guideline, such disclosures must
actually be made in good faith and the information provided must also be substantially
true, reliable, and substantiated.
The aim and objective of this policy is to encourage staff and other relevant
stakeholders to report perceived unethical or illegal conduct of employees,
management, directors, and other stakeholders across the Corporation to the
appropriate authorities in a confidential manner without any fear of harassment,
intimidation, victimization or reprisal of anyone for raising concern(s) under this policy.
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The report should however not be based on mere speculation, rumours or gossip but
on knowledge of verifiable facts or circumstances to indicate that the reportable
misconduct has occurred.
All staff are protected from victimization, harassment or disciplinary action as a result
of any disclosure, where the disclosure is made in good faith and is not made falsely or
for personal gain. An individual should exercise due care in reporting his or her concern.
Specific objectives of the policy are:
a) To ensure all employees feel supported in speaking up in confidence and
reporting matters they find suspicious involving improper, unethical, or
inappropriate conduct within the Corporation.
b) To encourage all improper, unethical, or inappropriate behavior to be identified
and challenged at all levels of the Corporation.
c) To provide clear procedures for reporting and handling such concern(s).
d) To proactively prevent and deter misconduct which could impact the
Corporations performance, damage the Corporations reputation, and threaten
depositors' funds and or interests.
e) To provide assurance that all disclosures will be handled seriously, treated as
confidential and managed without fear of reprisal by way of harassment or
victimization of any form.
f) To help promote and develop a culture of openness, accountability, and
integrity.
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This policy and procedure manual is designed to enable employees and other relevant
stakeholders to report any perceived act of impropriety which should not be based on
mere speculation, rumors and gossips, but on knowledge of facts. Reportable
misconducts covered under this policy include:
a) All forms of financial malpractices or impropriety such as fraud, insider abuse,
bribery, theft, and concealment.
b) Failure to comply with legal obligations, statutes, and regulatory directives.
c) Actions detrimental to Health and Safety in the work environment.
d) Improper conduct or unethical behavior that undermines universal and core
ethical values such as integrity, respect, honesty, accountability, and fairness.
e) Other forms of corporate governance breaches such as insider abuse and non-
disclosure of interests.
f) Sexual or physical abuse of staff, customers, prospective staff, service providers
and other relevant stakeholders.
g) Attempt to conceal any of the above listed acts; and
h) Any other that may affect the integrity of the process and the name of the
Corporation.
The above listed reportable misconducts or concerns are not exhaustive. However,
judgment and discretion are required to determine misconduct that should be reported
under this policy. The general guide in identifying reportable misconduct is to report
concerns which are repugnant to the interest of depositors' funds, the Corporation, and
the general public.
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Finally, staff can avail themselves of this Policy after exhausting the relevant provisions
under the staff rules and conditions of service, particularly where the rules did not
cover the conduct reported.
The Corporation will take all reasonable steps to protect its interest and image where
false and unfounded reports are made by any whistleblower against it. The Corporation
shall also provide all necessary assistance, including legal, to staff who have been
affected by untrue statements in the course of discharging their official duties.
The Corporation is committed to the highest standards of ethics, honesty, openness,
and accountability. In line with this commitment and in order to enhance good
Corporate Governance, transparency and safeguard the integrity of the Corporation,
this Whistleblowing Policy and Procedure Manual is intended to provide:
a) An avenue for raising concerns related to any illegal or unethical behavior such
as fraud, corruption and other misconduct.
b) Assurance that those who disclose such information will be adequately
protected, and that action would be taken on the disclosure.
c) The accused will be given a fair hearing and representation as the case may be;
and
d) Cover for cases of malicious allegation.
The Board and Management of the Corporation is committed to promoting a culture of
openness, accountability, and integrity, and will not tolerate harassment, victimization
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or discrimination of the whistleblower provided such disclosure is made in good faith
with reasonable belief that what is being reported is true. Therefore, employees,
stakeholders, and members of the public can raise legitimate concerns, without fear
and are given assurance that such concerns would be adequately addressed.
Whilst the Corporation encourages disclosure of identity by the whistleblower, where
possible, it also accepts disclosure under anonymity with re-assurance that such
identity would be protected at all stages in any internal matter, except with the consent
of the individual or in circumstances where the Corporation is unable to resolve the
concern without revealing such an identity: for instance, if external legal action flows
from the disclosure and the employee's evidence is required in court. If an allegation is
made in good faith but not confirmed by subsequent investigation, no action will be
taken against the person concerned.
Anonymous disclosures shall be considered on their merits taking into account the
following:
a) The seriousness of the issues
b) The significance and credibility of the concerns
c) Making relevant documents available
d) The possibility of confirming the allegation
whistleblowers in good faith and that is reasonable and true, involving all cases of illegal
and unethical conduct and any other misconduct, as particularly prescribed in Clause
directors and other stakeholders of the Corporation.
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to make their reports more credible.
2 SANCTIONS AGAINST FALSE WHISTLEBLOWERS
exercise due care in reporting the alleged misconduct.
Where there is a complain of false allegations, an Investigative Panel shall
be constituted to investigate the claim and afterwards submit its report of findings and
recommendations to Management and a copy to the Chairman, Audit Committee of
the Board.
Whistleblowers who make false claims, as determined by the Investigative Panel during
an investigation, will be subjected to sanctions as deemed appropriate by the
Management.
The Corporation does not protect false whistleblowers under this Policy.
The Corporation has an obligation to adequately protect the whistleblower. Therefore,
reprisal (by way of harassment or victimization) against any employee who in good faith
reports a concern about illegal or unethical conduct will not be tolerated. The
Corporation is also committed to maintaining confidentiality to the fullest extent
possible and provides assurance that all reports will be subject to appropriate
investigation and conclusion through an efficient process.
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all disclosures must be made in good faith and the information provided must be true.
the grounds that he/she has made a disclosure in accordance with the provisions of this
Policy.
contravention of the above, he/she may present a complaint to the Board Audit
Committee. This is without prejudice to the right of the whistleblower to take
appropriate legal action.
redundancy, undue influence, duress, withholding of benefits and/or entitlements and
any other act that has negative impact on the whistleblower or any other person
unjustly affected by the act.
The following are the roles and responsibilities of key parties in the whistleblowing
process:
a) WHISTLEBLOWER: Whistleblowers are expected to act in good faith and should
refrain from making false accusations when reporting his/her concern(s), and
also provide further evidence at his/her disposal to aid investigation of the issues
reported.
b) SUBJECT OF INVESTIGATION: The subject of investigation has a duty to cooperate
during the period of investigation including provision of relevant information,
documents or other materials as may be required by the investigator.
c) INVESTIGATOR/DIRECTOR, INTERNAL AUDIT: The Director, Internal Audit is
expected to handle all matters with high level of professionalism and
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The Director, Internal Audit has the responsibility of acknowledging all concerns reported.
The Director, Internal Audit shall on a quarterly (or need) basis provide a summary of all cases reported and the result of the investigation to the Managing Director and Chairman of the Board Audit Committee.
The Director, Internal Audit [Investigator shall be prohibited from discussing or disclosing matters under investigation.
d) HEAD/DIRECTOR OF HUMAN RESOURCES: The Director of Human Resources shall handle the report received at the end of an investigation in respect of staff/employees in line with the laid down disciplinary procedure as contained in the Corporation's staff handbook and conditions of service.
e) BOARD AUDIT COMMITTEE: The Chairman, Board Audit Committee (BAC) through the Board Secretary shall make available to all Committee members quarterly report submitted by the Head, Internal Audit on whistleblowing, and also treat all whistleblowing concerns brought to the attention of the committee with dispatch.
f) HEAD/DIRECTOR, ENTERPRISE RISK MANAGEMENT: Review, update the Whistleblowing Policy and procedure and obtain requisite Board approval. TYPES OF WHISTLEBLOWING
There are two categories of whistleblowers namely:
a) Internal whistleblowers - Employees, All Non-Executive Directors of the Corporation, who are expected to report incidents of misconduct involving peers, supervisors, or top management staff to the appropriate authority.
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This Whistleblowing procedure provides a mechanism for reporting any unlawful conduct and reassurance that exposing wrongdoing would not pose any risk to the whistleblower. The whistleblower should however make it clear that they are making their disclosure within the scope of the whistleblowing policy in order to ensure that the Director Internal Audit, conducts the investigation within the ambit of the policy and more importantly, protect the identity of the whistleblower if required.
An internal whistleblower may raise concerns either by declaration or anonymously through any of the following:
a) Formal letter or email to the Chairman, BAC, with a copy to the Director Internal Audit.
b) Text to a dedicated phone number.
c) Dedicated whistleblowing e-mail:
whistleblowing@ndic.gov.ng (Help Desk).
d) Electronically log on to www.ndic.gov.ng and click on the whistleblowing portal to report the misconduct.
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Changes to any of the channels detailed above would be promptly communicated to all
Stakeholders through the approved channels after which the policy would be amended
accordingly.
Where the concern is received by staff other than the Chairman, BAC or the Director
Internal Audit, the staff to which the concern is directed shall be required to document
and immediately forward the concern(s) to the Chairman BAC, with copy to the Director
Internal Audit. If the concerns affect the Director Internal Audit, the Chairman BAC must
be notified, with copy to the MD/CEO.
The concern(s) shall be presented in the following format:
a) Background of the concerns (with relevant dates);
b) Reason(s) why the whistleblower is particularly concerned about the situation;
and
c) Supporting evidence for the allegations that would be helpful in the investigation
process.
The Director Internal Audit shall within two business days of receipt of the concern from
the whistleblower:
i. Acknowledge receipt of the issue(s) raised; and
ii. Commence review to ascertain validity of claim and also determine whether the
concerns fall within the scope of whistleblowing or not.
The purposes of investigation are to:
i. Establish if a wrongdoing has occurred based on the concern(s) raised, and if so,
to what extent;
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ii. To minimize the risk of further wrongdoing, prevent any further loss of assets, damage to the reputation of the Corporation and/or threat to depositors' funds; and iii. Protect all sources of evidence.
The Director Internal Audit shall, upon conclusion of the investigation, submit a detailed report to the Board Audit Committee (BAC) for appropriate actions in line with the approved policies of the Corporation.
Disciplinary sanctions must however be ratified by Board of Directors (via CDC) depending on the grade of the staff involved and in line with the staff Disciplinary Policy/Procedure as stated in Chapter three (Discipline) of the staff handbook and condition of service. Where necessary, the Head Internal Audit will keep the whistleblower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions.
If dissatisfied with the outcome of the investigation, a whistleblower may have recourse to the Chairman, Board Corporate Governance Committee.
External whistleblowers could be depositors, suppliers, service providers and other stakeholders who report wrong doings of employees to the Chairman, BAC or the Director, Internal Audit. An external whistleblower may raise concerns either by declaration or anonymously through any of the following:
a) Formal letter to the Chairman, BAC, with copy to the Director Internal Audit.
b) Text to a dedicated phone number.
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c) Dedicated whistleblowing e-mail:
whistleblowing@ndic.gov.ng; (Help Desk).
d) Electronically log on to www.ndic.gov.ng and click on the whistleblowing portal to report the misconduct online.
Where the concern is received by staff other than the Chairman, BAC or the Director
Internal Audit, the staff to which the concern was directed shall be required to
document and immediately forward the concern(s) to the Chairman BAC, with copy to
the Director Internal Audit. If the concerns affect the Director Internal Audit, the
Chairman BAC would be notified, with copy to the MD/CEO and if the Chairman BAC is
involved, the Chairman Board Corporate Governance Committee would be notified and
vice versa.
An external whistleblower shall follow the following procedure while presenting the
concern(s) in the following format:
a) Background of the concerns (with relevant dates);
b) Reason(s) why he/she is particularly concerned about the situation; and
c) Evidence supporting the allegations would be helpful in the investigation.
The Director Internal Audit or the investigative panel as the case may be shall within
three (3) days of receipt of the concerns from the whistleblower:
i. Acknowledge receipt of the issue(s) raised; and
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ii. Carry out preliminary review to ascertain validity of the claim and also determine whether the concerns fall within the scope of whistleblowing or not.
The purposes of investigation are to:
i. Establish if a wrongdoing has occurred based on the concern(s) raised, and if so to what extent;
ii. To minimize the risk of further wrongdoing, prevent any further loss of assets and or depositors' funds, damage to the reputation of the Corporation; and iii. Protect all sources of evidence.
If preliminary investigation shows that the concern falls within the whistleblowing reportable concerns, then further investigation shall be carried out. If otherwise, the Director Internal Audit shall refer the matter to the appropriate authority for further action. If criminal activity has taken place, the matter may be referred to the enforcement agents for investigation and possible prosecution and where necessary, appropriate legal action taken. The Director, Internal Audit should notify Management who in turn, should notify the enforcement agents.
The Director Internal Audit shall, upon conclusion of the investigation, submit a detailed report to the Chairman, BAC for appropriate actions in line with the approved policies of the Corporation.
An employee who receives concerns from external whistleblower and fails to pass same to the appropriate authority within 24 (twenty-four) hours, shall be subjected to disciplinary actions by the Management and Board of the Corporation, in line with Chapter three (Discipline, subsection 0357 (1, e)) of the Corporation's Staff Conditions of Service.
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Where necessary, the Director Internal Audit will keep the whistleblower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions.
If dissatisfied with the outcome of the investigation, a whistleblower may have recourse to the Chairman, Board Corporate Governance Committee, which will not affect the fundamental right of the whistleblower to seek redress in the court of law.
Furthermore, the Director Internal Audit shall on quarterly basis, submit a summary of reported cases and outcomes to the BAC.
3 CIRCUMSTANCES FOR CONSTITUTING INVESTIGATIVE PANEL AND MEMBERSHIP
In a situation where the full complement of the Panel cannot be established, a representative not below the rank of Assistant Director shall be nominated from the affected Department(s).
The Corporation is committed to prompt resolution of all concerns or issues raised within a period of one month from the receipt of the petition. In the event that the
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investigation of whistleblowing complaint was not concluded within the stated period, the Director Internal Audit must keep the Chairman BAC abreast of progress, with copy to the MD/CE.
Whistleblowers, either internal or external, may be rewarded depending on the gravity of the case. Compensation may also be provided to whistleblowers who may have suffered loss in the course of the process. This is however at the discretion of the Board of Directors.
An employee who has suffered any detriment by reason of disclosure made pursuant to the provisions of this Policy shall be entitled to compensation and/or reinstatement provided that in the case of compensation, the employee's entitlement shall be computed as if he or she had attained the maximum age of retirement or had completed the maximum period of service, in accordance with his or her condition of service as may be determined by the Board on a case by case basis.
If a whistleblower makes allegations that are determined to be fabricated or false, disciplinary action shall be taken against such person(s) in line with Chapter three (Discipline, subsection 0356 (1, f)) of the Corporation's staff Conditions of Service.
Quarterly Reports are to be rendered to the Board Audit Committee and MD/CE. The Head, Internal Audit shall provide to the Chairman, BAC with a summary of cases reported and the result or progress of the investigation on an ongoing basis.
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Where the whistleblower withdraws his or her allegation, the investigation shall continue provided that the evidence gathered is sufficient as determined by the Board Audit Committee.
In the event that the subject of investigation resigns prior to the final resolution of the case against him/her, the resignation shall not be accepted as prescribed in the staff conditions of service until the investigation is concluded.
This policy document shall remain in the custody of the Enterprise Risk Management Department and shall be hosted by the Information Technology Department (ITD) on the official website of the Corporation. It shall be subject to review every four (4) years or as may be deemed necessary. All suggestions for review and or amendments shall be forwarded to the Director, Enterprise Risk Management Department who should convene the interdepartmental Committee for whistleblowing Policy for that purpose. Changes to any section of this document would be promptly communicated to all stakeholders. All staff are required to sign the Declaration form after every review.
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WHISTLEBLOWER
WHISTLE-BLOWING
COMPLAINT
INVESTIGATION
GOOD FAITH
MISCONDUCT
A whistleblower is any person(s) including the employee, management, directors, depositors, service providers, creditors and other stakeholder(s) of an institution who reports any form of unethical behavior or dishonesty to the appropriate authority.
The act of reporting an observed/perceived unethical misconduct of employees, management, directors and other stakeholders of an institution by an employee or other person to appropriate authority.
An allegation or concern that is subject to investigation by the appropriate authority.
A process designed to gather and analyze information in order to determine whether misconduct has occurred and if so, the party or parties responsible.
This is evident when a report or concern is made without malice or consideration of personal benefit and the employee has a reasonable basis to believe that the report is true; provided, however, a report does not have to be proven to be true to be made in good faith. Good faith is lacking when the disclosure is known to be false.
A failure by a staff member or other relevant stakeholder to observe the rules of conduct or standards of behavior prescribed by an organization.
SUBJECT OF INVESTIGATION A person who is alleged to have committed a misconduct.
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I have read and understood the Corporation's Whistleblowing Policy.
NAME OF STAFF:
STAFF NO:
DEPARTMENT:
SIGNATURE:
DATE:
Please return the signed copy of this page to Human Resource Department.
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NAME/TITLE OF SUBJECT(S) OF INVESTIGATION (mandatory):
ALLEGATION (mandatory):
LOCATION OF MISCONDUCT (mandatory): Department(s), Zone(s), Unit(s) or Desk(s)
DATE/PERIOD OF MISCONDUCT (mandatory):
IS THE ALLEGED MISCONDUCT ONGOING: (Yes) (No) or (Do Not Know) (mandatory):
AMOUNT INVOLVED (N) (optional):
SUPPORTING DOCUMENTS (mandatory):
WHISTLEBLOWER'S NAME (optional):
WHISTLEBLOWER'S TELEPHONE NUMBER (optional):
WHISTLEBLOWER'S ADDRESS (optional):
WHISTLEBLOWER'S e-MAIL (optional):
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