Page 149 - ACCESS BANK ANNUAL REPORTS_eBook

or disciplinary proceedings. Stakeholders are encouraged public in all locations where the Bank operates,
to raise genuine concerns about misconduct, malpractices The reportable concerns include but are not limited to the
and unethical behavior at the earliest opportunity and in an following:
appropriate way.
• Any type of fraud or misconduct
It provides the framework for reporting suspected breach-
es of the Bank’s internal policies, laws and regulations. The • Purchase of inferior goods
Bank has retained KPMG Professional Services to provide • Purchase of goods at inflated prices
consulting assistance in the implementation of the poli-
cy. The policy provides that suspected wrong doing by an • Forgery (use of fake certificates, false declaration
employee, director, vendor or consultant may be reported of age, etc.)
through the Bank’s or KPMG’s Ethic Lines or e-mail details
which are provided in the Policy. • Leakage of confidential information

The Policy complies with the requirements of Section 3.1 • Concealment of any malpractice
of the Central Bank of Nigeria (CBN) Guidelines for Whistle- • Commission of offence by Access Bank’s
blowing for Banks and Other Financial Institutions in Nigeria employee
and Section 5.3.1 of the Code of Corporate Governance for
Banks and Discount Houses. • Conversion of the Bank’s assets

• Collusion with suppliers and customers to
defraud the Bank
OUR WHISTLEBLOWING POLICY
• Bribery and corruption
1. Objectives of the Policy
• Conflicts of interest and non-disclosure of
The objectives of this Whistleblowing Policy (‘The Policy’) interest in a transaction involving the Bank
are as follows:
• Sexual harassment
• To support the Bank’s corporate philosophy.
• Abuse of authority
• To enable the Bank to comply with the Central
Bank of Nigeria Guidelines for Whistleblowing • Other breaches of the Bank’s Code of Ethics or
for Banks and Other Financial Institutions in business principles
Nigeria.
• Connected transactions not disclosed or
• To encourage stakeholders to confidentially raise reported in line with regulations.
concerns about unethical violation of the Bank’s
policies and Code of Conduct • Insider abuse.
• To reassure the whistleblower of protection from • Attempt to conceal any of the aforementioned
possible reprisals or victimization if a disclosure acts.
has been made in good faith.
However, judgement and discretion are required to deter-
• To inform stakeholder of the avenues open to mine misconduct that should be reported under this Policy.
them to report concerns. The general guide in identifying reportable misconduct is to
report concerns that would be in the interest of the Bank
• To encourage stakeholders to identify and and the general public and for appropriate sanctions to be
challenge all improper, unethical or inappropriate applied.
behavior at all levels of the organization.

• To provide clear procedures for investigation and
handling of such concerns. 3. The Culture of Whistleblowing

• Proactively prevent and deter misconduct that In the drive to entrench the culture of whistleblowing
could damage the Bank’s reputation. among members of staff, quarterly trainings are held on the
benefits of whistleblowing and the channels through which
2. Scope of the Policy whistleblowers can report their concerns are also published
on the Bank’s website. Any person who reports any irregu-
The Policy applies to employees, management, directors larity, provided it is done in good faith and in compliance with
and other stakeholders such as contractors, shareholders, the provisions of the Policy, shall be protected against any
job applicants and the general
act of retaliation or intimidation. An employee who has suf-

Access BAnk Plc 149
Annual Report & Accounts 2017