1. Introduction

This policy is introduced in furtherance of the aim of improving corporate governance in the bank. It is also aimed at fulfilling part of the requirements of the Central Bank of Nigeria’s code of corporate governance. Whistle- blowing enables an organization to obtain early warning signals on what may be point wrong in the organization, especially in cases where it would be difficult to use formal communication channels. This is important where the issues involved are very sensitive and would require the confidentiality of the whistle blower. In other words whistle-blowing is a confidential channel open to all the stakeholders of the bank to report any wrongdoing to the management and board of the bank.

2) What should be reported?

2.1) Fraudulent activities

2.2) Illegal activities

2.3) Bribery and corruption

2.4) Gross misuse of bank’s assets including information asset

2.5) Conflict of interest and abuse of office on the part of any member of staff or director

2.6) Activities likely to endanger life or property

2.7) Insider dealings

2.8) Use of fake/forged certificates

2.9) Theft/leakage of information assets

2.10) Purchase of goods at inflated prices

2.11) Purchase of inferior goods

1.12) Concealment of any malpractice

2.13) Override of controls

2.14) Abuse of authority

2.15) Sexual harassment

2.16) Other unethical activities

3.0) What should be reported?

3.1 Employees

3.2 Directors

3.3 Clients

3.4 Vendors and Service Providers