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fered any detriment by reason of disclosure made pursuant      concerned about the situation.
               to the provision of the policy shall be entitled to compensa-
               tion and/or reinstatement provided that in the case of com-  Where there is no merit in a complaint by a whistleblower, or
               pensation, the employee’s entitlement shall be computed   it is clear that the person making such claim acted in good
               as if he had attained the maximum age of retirement or had   faith, the Chief Audit Executive shall ensure that the person
               completed the maximum period of service, in accordance   suffers no reprisal. However, when a person makes a report
               with  his  condition  of  service.  For  other  stakeholders,  the   in bad faith, particularly if it is based knowingly on false or
               whistleblower shall be adequately compensated.  misleading information, a report of finding should be kept
                                                              on the incident without any disciplinary actions against the
                                                              whistleblower.
               4.     Channels and Procedures of Whistleblowing  This is without prejudice to the fundamental right of the in-
                                                              ternal whistleblower to seek redress in a court of law.
               The Bank had provided both internal and external whistle-
               blowing channels.

               4.1 Internal Whistleblowing Procedure:         4.2 External Whistleblowing Procedure

               The internal whistleblowing channels are as follows:   The external reporting channel makes use of the KPMG
                                                              Ethics Lines and facilities. The KPMG Ethics line facilities are
               •      Formal letter to the Group Managing Director,      telephone lines, fax lines and email address. The telephone
                      Access Bank Plc or the Head, Internal Audit,       lines are open between 8:00 a.m and 5:00 p.m on work days
                      Access Bank Plc.                        only. While the fax number and e-mail address are always
                                                              available except during periods of maintenance.
               •      Call or text messaging to dedicated phone
                      numbers; 01-2712065 or IP 4160          Whether  the  whistleblower  discloses  his/her  identity,
                                                              KPMG will not provide any indication of the whistleblower’s
               •      Dedicated email address – whistleblower@
                      accessbankplc.com                       identity to Access Bank except KPMG has a written consent
                                                              from the whistleblower to provide his/her identity to Access
               •      Via Access Bank’s website – https://www.access    Bank.
                      bankplc.com/Pages/Customer-Support/
                      Whistle-Blower.aspx                     Telephone calls generally are recorded and information is
                                                              transcribed into a call sheet memo by KPMG for transmis-
               The Internal Whistleblowing Hotline shall be available during   sion to designated representatives of the Bank. Access
               working hours on work days only. However, the email chan-  Bank, its officers, staff, representatives or agents shall not
               nel will always be available and the information provided by   be entitled to have access to such tape recordings, fax
               the whistleblower shall be kept confidential.  messages or email messages received from whistle blow-
                                                              ers.  These  measures  are  necessary  in  order  to  maintain
               Where the concerns are received by a member of staff oth-  confidentiality  and  anonymity  of  the  whistleblowers.  Ac-
               er than the Group Managing Director/Chief Executive Of-  cess Bank will only have access to the call sheet memos
               ficer, Chief Conduct and Compliance Officer or Chief Audit
               Executive, the recipient of such report shall be required to:  •   Through the KPMG Ethics Line

               •      Immediately pass the concern to the Chief Audit       E-mail: kpmgethicsline@ng.kpmg.com
                      Executive and Head, Internal Audit Investigation
                      Access Bank Plc for prompt investigation   •   Toll free numbers for calls from MTN numbers
                                                                     only:
               •      If the concerns affect the Head, Internal Audit
                      Investigation or Chief Conduct and Compliance         0703-000-0026;  0703-000-0027
                      Officer, the Group Managing Director         •   Toll free number for calls from Airtel numbers
                      is notified. When a director or Board member is         only:
                      involved, such concerns shall be directed to the
                      Chairman of the Board Audit or Board           0708 060 1222; 0808-822-8888
                      Risk Management Committee.
                                                              •      Toll free number for calls from 9MOBILE
                                                                     numbers only:
                                                                     0809 993 6366
               The concern(s) shall be presented in the following format:

               •      Background of the concerns (with relevant
                      dates).
               •      Reason(s) why the whistleblower is particularly


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