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ance Officer is responsible for monitoring compliance. anteed pay will include base pay and other guaranteed por-
tions while variable pay may be both performance-based
The Chief Conduct and Compliance Officer issues at the and discretionary.
beginning of the year an Ethics and Compliance message
to all employees. The message reiterates the Bank’s poli- The Bank has put in place a performance bonus scheme
cy of total compliance with all applicable laws, regulations, which seeks to attract and retain high-performing employ-
corporate ethical standards and policies in the conduct of ees. Awards to individuals are based on the job level, busi-
the Bank’s business. It enjoins staff to promote the fran- ness unit performance and individual performance. Other
chise and advance its growth in a sustainable manner while determinants of the size of individual award includes pay
ensuring compliance with relevant policies, laws and regu- levels for each skill set, which may be influenced by the rela-
lations. tive dearth of skills in a particular area.
The Bank complies with the Pension Reform Act on the
provision of retirement benefits to employees at all levels.
Dealing in Company Securities The Bank also operates an Employee Performance Share
Plan for the award of units of the Bank’s shares to its em-
In accordance with the provisions of the Rule 17.2 of the
Amendment to the Listing Rules of the Nigerian Stock Ex- ployees, subject to terms and conditions determined by the
change, the Bank implements a Securities Trading Policy Board of Directors.
that prohibits Directors, members of the Audit Committee, The Bank’s long-term incentive programme rewards senior
employees and all other insiders from abusing, or placing management staff for their loyal and productive service to
themselves under the suspicion of abusing price-sensitive the Bank. This is to ensure that they share in the Bank’s suc-
information in relation to the Bank’s securities. In line with cess and focus on its long-term sustainability. The justifi-
the policy, affected persons are prohibited from trading on cation for a long-term incentive plan for top management
the company’s security during a closed period which is usu- employees is very compelling. The stability, loyalty and
ally announced by the Company Secretary. The Bank has commitment of senior management employees need to
put in place a mechanism for monitoring compliance with be cemented by a long-term incentive programme.
the policy.
Whistleblowing Procedure
Remuneration Policy
The Bank expects all its employees and Directors to ob-
The Group has established a remuneration policy that serve the highest level of probity in their dealings with the
seeks to attract and retain the best talent in countries that Bank and its stakeholders. Our Whistleblowing Policy cov-
it operates. To achieve this, the Group seeks to position ers internal and external whistleblowers and extends to the
itself among the best performing and best employee re- conduct of the stakeholders including employees, vendors,
warding companies in its industry in every host country. This and customers. It provides the framework for reporting
principle will act as a general guide for the determination of suspected breaches of the Bank’s internal policies and laws
compensation in each country. The objective of the policy and regulations. The Bank has retained KPMG Professional
is to ensure that salary structures, including short and long- Services to provide consulting assistance in the implemen-
term incentives, motivate sustained high performance and tation of the policy. The policy provides that suspected
are linked to corporate performance. It is also designed to wrong doing by an employee, vendor, supplier or consultant
ensure that stakeholders are able to make reasonable as- may be reported through the Bank’s or KPMG’s Ethics lines
sessment of the Bank’s reward practices. The Group com- or e-mails, details of which are provided below.
plies with all local tax policies in the countries of operation.
Operating within the above principles, compensation for
country staff is based on the conditions in the local eco- Telephone
nomic environment as well as the requirements of local
labour laws. The Group Office usually commissions inde- Internal: +234-1-2712065
pendent annual compensation surveys in the subsidiaries External: The whistleblower is not billed for calls made
to obtain independent statistics regarding the local pay within the same network.
markets to arrive at specific compensation structures for
each country. Compensation will be determined annually at
the end of the financial year. All structural changes to com- The KPMG Toll Free Lines include:
pensation must be approved by the Group Office.
MTN: 0703-000-0026 &
Total compensation provided to employees will typically 0703-000-0027
include guaranteed and variable portions. The specific pro- AIRTEL: 0708-060-1222&
portion of each will be defined at the country level. Guar- 0808-822-8888
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Annual Report & Accounts 2017