Whistleblowing Policy

This policy document is vested in the Chief Compliance Officer, Head of Internal Audit and Managing Director who have overall responsibility for its implementation as detailed in s.10.1.2 and s.10.2.2.

It shall be subject to review every two (2) years or as required (if earlier) to keep it up to date with changes to the relevant regulation or best practices.  All suggestions for review and or amendments shall be forwarded to the Chief Compliance Officer for necessary action, including obtaining Management/Board approvals of the amended policy.

Application/Distribution of the Manual

The policy shall apply to all staff (core and non-core), customers and service providers.  The current version of this document shall be hosted on the official website of Alpha10 Group. All queries relating to its contents or application should be made to the Chief Compliance Officer and Head, Internal Audit.

Abbreviations

BARMC – Board Audit & Risk Management Committee

CBN – Central Organisation of Nigeria

CCO – Chief Compliance Officer

MD/CEO – Managing Director/Chief Executive Officer

SEC – Securities and Exchange Commission

CMO – Capital Market Operator

  1. Introduction

This policy is introduced in furtherance to the organization objective of improving corporate governance in the Organization. It is also aimed at fulfilling part of the requirements of the Securities and Exchange Commission’s [SEC] Code of Corporate Governance.

The investment and Securities Act, provides that an Employee of a Company shall have the right to disclose any information connected with the activities of his work place which tends to show that a criminal offence has been, is being or is likely to be committed, or that a person has failed, is failing, is likely to fail or otherwise omitted to comply with any legal obligation in respect to the performance of his/her duties. The SEC code of corporate Governance encourages CMOs to establish whistle blowing procedures that encourage [including by assurance of confidentiality] all Stakeholders [Staff, Customers, Suppliers, Applicants etc.] to report any unethical activity/breach of the corporate governance code using, among others, a special email or hotline to both the Organisation and the SEC.

In view of the above provisions, we have put together this policy, and it applies to Employees, who are often the first to realise that there may be something seriously wrong within the Organization. However, they may not express their concerns because they feel that speaking up would be disloyal to their Colleagues or to the Organization, due to fear of harassment or victimisation. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice. This policy also applies to other Concerned Persons (Contractors, Suppliers and other Third Parties).

Alpha10 is committed to the highest possible standards of openness, probity and accountability. In line with that commitment, we expect employees and others with serious concerns about any aspect of the Organization business to come forward and voice those concerns. It is recognised that certain cases will have to proceed on a confidential basis. This policy document makes it clear that employees or concerned persons can do so without fear of reprisals.

This Whistle blowing policy is intended to encourage and enable Employees or a Stakeholder concerned persons to raise serious concerns within the Organisation rather than overlooking a problem or blowing the whistle to the media or other bodies.

Whistle-blowing policy enables the Organization to obtain early warning signals on what may be going 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 channel open to all Employees and customers of the Organisation to report any wrongdoing to Management and the Board of the Organisation.

  1. Explanatory Forward

Alpha10 is committed to the highest standards of ethics, honesty, openness and accountability. In line with this commitment and to enhance good corporate governance, transparency and safeguard the integrity of our institution, the Whistleblowing Policy and Procedure Manual is intended to provide:

  • An avenue for raising concerns related to any illegal or unethical behaviour such as fraud, corruption and other misconduct
  • Assurance that those who disclose such information will be adequately protected and that action would be taken on the disclosure.

The guiding principles of the policy emanate from the SECs guidelines for Whistle-Blowing for CMOs, which mandates Organisations to establish adequate whistleblowing procedures and render quarterly returns to the SEC on all related breaches.

According to the intent of this policy, whistle-blowing is the reporting of alleged unethical conduct/behaviour of Employees, Management, Directors and other Stakeholders by an Employee or other person to appropriate authorities or non-compliance with applicable regulation.

The Whistle-Blowing Policy aims to create a work environment where Employees, Vendors, Service Providers, Customers and other Stakeholders can raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or retaliation, victimization and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated.

Employees are internal Whistle blowers who report incidents of misconduct in an organization involving a Peer/Colleague, a Supervisor or indeed a top Management official or the Organisation’s non-compliance with applicable regulatory standards.

External whistle-blowers who are mostly Customers/Suppliers report wrong doings of Employees to the Head Internal Audit, Chief Compliance Officer (CCO), and Managing Director/Chief Executive Officer respectively.

All Stakeholders (internal and external) are key and therefore expected to play a vital role in deterring and detecting malpractices, wrongdoing or irregularity while the Board and Management provides assurance to all whistle-blowers that there will be no reprisal by way of harassment or victimization arising from blowing the whistle. It is pertinent to note that this policy does not replace but complement the Organisations approved internal control, policies and guidelines

  1. Scope of the Policy

The policy is applicable to all Employees, Directors, Executive Management, Contract Employees or Concerned persons, Clients and 3rd party personnel seconded to Alpha10, and Business Partners in all the locations where they operate and further covers concerns raised by members of the public.

This policy and procedure manual is designed to enable Employees and other relevant Stakeholders report acts of impropriety to appropriate authorities. The report should however not be based on mere speculation, rumours or gossip but on personal knowledge of verifiable facts or circumstances to indicate that the reportable misconduct has occurred or likely to occur or still occurring.

All Staff are protected from victimization, harassment or disciplinary action due to any disclosure, where the disclosure is made in good faith and is not made maliciously or for personal gain.

  1. Objectives of The Policy

This policy aims to set out the organization written, formal whistle‐blowing policy, consisting of responsible and effective procedures for disclosure or reporting of misconduct and impropriety so that appropriate remedial action can be taken if concerns are deemed legitimate.

Our whistleblowing policy is therefore fundamental to the Organisation’s professional integrity. In addition, it reinforces the value it places on staff to be honest and respected members of their individual professions. It provides a method of properly addressing all concerns that individuals within the organization might have, while also offering whistle-blowers protection from victimization, harassment or disciplinary proceedings.

It is intended to encourage Staff and other relevant Stakeholders to report unethical or illegal conduct or other misconduct of Employees, Management, Directors and other Stakeholders to appropriate authorities in a confidential manner without any fear of harassment, intimidation, victimization or reprisal of anyone for raising a concern under this policy.

Specific objectives of the policy are to:  

  • Provide avenues for Employees or Applicable Persons to raise concerns in confidence and receive feedback on any action taken.
  • To ensure that Employees or applicable persons receive a response to concerns or reports of allegations that have been raised.
  • Inform Employees or Applicable Persons on how to take the matter further if they are dissatisfied with the response, and
  • Ensure accountability, transparency and individual responsibility by encouraging Employees to report irregularities in the work place in a responsible and ethical manner.
  • Reassure Employees and applicable persons that they will be protected from reprisals or victimisation for whistles blown in good faith.
  1. Types of concerns to be raised

The concerns to be raised cannot be exhaustively and conclusively listed in this policy, however, it is expected that as an Employee or Concerned Person, you would report the following;

  • Illegal/Criminal activities
  • Fraudulent activities
  • Insider dealing
  • Serious breach of fundamental internal control
  • Bribery and corruption
  • Contravention of the code of Business Conduct & Ethics e.g. insider dealing,
  • Conflict of interest, facilitation payments etc.
  • Abuse of office or responsibility in connection with unauthorized activity for personal gain
  • Gross misuse of organization assets including information assets
  • Intentional misrepresentations directly or indirectly affecting financial statements;
  • Sexual harassment or physical abuse
  • Other unprofessional or unethical behaviour
  • Deliberate concealment of the information tending to show any of the matters listed above.
  • Any other unethical or inappropriate behaviour or non-compliance with applicable regulatory standards not listed above.
  1. Commitment to The Policy

The Board of Directors and Management is committed towards promoting a culture of openness, accountability and integrity, and will not tolerate harassment, victimization or discrimination of the whistle blower. Whistle blower should ensure that the disclosure is made in good faith with reasonable belief that what is being reported is true.

  • All Employees, Stakeholders, and Members of the Public can raise legitimate concerns, without fear of reprisal and are given assurance that such concerns would be adequately addressed.
  • The Organization encourages disclosure of identity by the Whistle-blower, where possible, it also appreciates disclosure under anonymity with re-assurance that such identity would be protected at all stages of the investigation, except with the consent of the Individual or in circumstances where the Organisation 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.
  • The Organization encourages Staff who are concerned about possible reprisals if their identity is revealed to express their concerns in the disclosures made and is committed to ensuring that appropriate measures are taken to preserve their confidentiality.
  • The Organization commits to ensuring that the innocence of an individual accused of wrongdoing is protected throughout the investigation of the whistleblowing process until proven guilty.
  • The Organization shall ensure that an accused person is informed of the outcome of a whistleblowing investigation particularly when the accused is found to be innocent. Where the innocent victim of a whistleblowing report has suffered isolation, emotional and psychological hurt, rejection from colleagues, reputational damage, the Organisation shall provide counselling and/or requisite support to re-integrate the accused person into the Organisation’s business operations and protect such person from harassment of any kind.
  • No action will be taken against any Person who made an allegation in good faith but not confirmed by subsequent investigation, however, an Individual who makes an unsubstantiated claim, which is knowingly false or made with malicious intent, will be subjected to appropriate disciplinary action.
  • The Organization shall not protect or grant immunity to a Staff from the consequences of their own wrongdoing unless serious wrongdoing, when reporting more serious wrongdoing by others or by the Organization. If malicious or vexatious allegations are made, particularly if the Whistle-blower persists with making them, then disciplinary action may be taken against the Whistle-blower concerned.
  1. DEFINITIONS

Whistleblowing – the reporting of alleged unethical conduct of Employees, the Entity, Management, Directors and other Stakeholders by an Employee or other person to appropriate Authorities.

Disclosure – Disclosure of information that Staff or third party reasonably believes tends to show malpractice or misconduct.

Confidentiality – This is an express term in the contract of employment/engagement stating the non-disclosure of information observed in the conduct of duties. However, where a Whistle-blower discovers information that they believe shows malpractice, unethical conduct or illegal practices within the Organisation, then the option to disclose the information, without fear of reprisals for breach of confidentiality is made under this policy.

  1. WHO SHOULD BLOW THE WHISTLE  

Any Individual who has observed reportable misconduct can report his/her concerns to designated parties as prescribed by this Policy provided, they are made in good faith, and the disclosure is true and reasonable.

All staff should ensure that appropriate steps are taken to disclose any wrongdoing or malpractice of which they become aware as non-action/concealment will be deemed as complicity.

The disclosure should be made to an appropriate person or authority.

  1. TYPES OF WHISTLE BLOWING  

There are two categories of whistle blowers namely:

  • Internal whistle blowers – Employees who are expected to report incidents of misconduct involving Peer, Supervisor/Superior or Top Management Staff to relevant reporting point.
  • External whistle blowers – Customers, Suppliers, Service Providers and other Members of the Public who report wrong doings of employees to the Head Internal Audit, Chief Compliance Officer, the Managing Director/Chief Executive Officer, Alpha10.
  1. WHISTLE BLOWING PROCEDURE  

This Whistleblowing Procedure provides a mechanism for reporting any unlawful conduct at work and reassurance that exposing wrongdoing would not pose any risk to the Whistle-blower.

The Whistle-blower should however make it clear that they are making their disclosure within the scope of the whistleblowing policy to ensure that the recipient of the disclosure conduct the investigation within the ambit of the policy and more importantly, protect the identity of the whistle-blower if required.

10.1 Internal Whistle Blowing Procedure

An internal whistle blower may raise concerns either by declaration or anonymously through any of the following:

  •  Formal letter to the Managing Director/Chief Executive Officer (MD/CEO) of Alpha10 and/or the Head Internal Audit, Chief Compliance Office.
  •   Dedicated whistle blowing e-mail: whistleblowing@alpha10group.com
  •   Dedicated Fraud alert e-mail:  fraudalert@alpha10group.com
  • Directly to the Managing Director/Chief Executive Officer (MD/CEO)
  • Directly to the Head Internal Audit, Chief Compliance Officer.

Changes to any of the channels detailed above would be promptly communicated to all Stakeholders by the Organization through the approved channels after which the policy would be amended, accordingly.

Where the concern is received by Staff other than the MD/CEO, the Head, Internal Audit, Chief Compliance Officer, the Staff to which the concern is directed shall be required to;

  • Document and immediately forward the concern(s) to the Head Internal Audit, Chief Compliance Officer with copy to the Managing Director/Chief Executive Officer, Alpha10 Group.
  • If the concerns affect the Head, Internal Audit, Chief Compliance Officer, the Managing Director/Chief Executive Officer must be notified, and where such issues affect Executive Management or a Director, such concern shall be referred to the Board through the Board Governance & Remuneration Committee for appropriate action within a reasonable time.

10.1.1   Reporting Format  

The concern(s) shall be presented in the following format;

  •   Background of the concerns (with relevant dates).
  •   Reason(s) why the Whistle blower is particularly concerned about the situation.

Supporting evidence for the allegations, if available, would be helpful in the investigation.

 10.1.2 Investigating Process of Concern(s) by an Internal Whistle Blower   

The Head, Internal Audit shall within seven (7) days of receipt of the concern from the Whistle blower or from any of the authorized channels:

  • Acknowledge receipt of the issue(s) raised.
  • Commence review to ascertain validity of claim and determine whether the concerns

fall within the scope of whistle-blowing or not.

  • The Chief Compliance Officer will track the Turnaround time and provide further assurance on the investigation process; for which responsibility, still rests with Internal Audit Department. 

The purposes of investigation are:  

  •  To establish if a wrongdoing has occurred based on the concern(s) raised, and if so, to

what extent; and

  • To minimize the risk of further wrongdoing, prevent any further loss of assets, damage to the reputation of the organization and if possible, protect all sources of evidence.

 The Head Internal Audit shall, upon conclusion of the investigation, submit a detailed report to the MD/ CEO for appropriate actions in line with the approved policies of the Organisation. The Chief Compliance Officer and Head, Internal Audit will track the Turnaround time and provide further assurance on the investigation process; for which responsibility, still rests with Internal Audit.

Disciplinary sanctions must however be ratified by Management, or the Board of Directors depending on the grade of the Staff involved and in line with the Staff Disciplinary Policy/Procedure.

Where necessary, the Head, Internal Audit will keep the Whistle-blower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

If dissatisfied with the outcome of the investigation, a Whistle blower may have recourse to the Chairman, Board of Directors which will not affect the fundamental right of the internal Whistle-blower to seek redress in the court of law.

Furthermore, the Head, Internal Audit shall periodically submit a summary of reported cases and outcomes to the Chairman, Board Audit Committee (BAC).

 10.2 External Whistle Blowing procedure

An external Whistle blower are Customers, Suppliers, Service Providers and other Members of the Public who report wrong doings of Employees to the Head, Internal Audit or the Managing Director/Chief Executive Officer. An external Whistle blower may raise concerns either by declaration or anonymously through any of the following:
An external Whistle blower may raise concerns either by declaration or anonymously through any of the following:

  •  Formal letter to the Managing Director/Chief Executive Officer (MD/CEO) of Alpha10 and/or the Head Internal Audit, Chief Compliance Officer
  •   Dedicated whistle blowing e-mail: whistleblowing@alpha10group.com
  •   Dedicated Fraud alert e-mail:  fraudalert@alpha10group.com
  • Directly to the Managing Director/Chief Executive Officer (MD/CEO)
  • Directly to the Head Internal Audit, Chief Compliance Officer.

Changes to any of the channels detailed above would be promptly communicated to all Stakeholders by the organization through the approved channels after which the policy would be amended, accordingly.  Where the concern is received by Staff other than the MD/CEO the Head, Internal Audit, Chief Compliance Officer, the Staff to which the concern is directed shall be required to;

  • Document and immediately forward the concern(s) to the Head Internal Audit, Chief Compliance Officer with copy to the Managing Director/Chief Executive Officer, Alpha10.
  • If the concerns affect the Head, Internal Audit, Chief Compliance Officer, the Managing Director/Chief Executive Officer must be notified, and where such issues affect Executive Management or a Director, such concern shall be referred to the Board through the Board Governance & Remuneration Committee for appropriate action within a reasonable time.

10.2.1 Reporting Format

An external whistle-blowing shall follow the following procedure while presenting the concern(s) in the following format:

-Background of the concerns (with relevant dates)

-Reason(s) why he/she is particularly concerned about the situation.

Disciplinary measures in line with the staff Human Resource Manual shall be taken against any staff that receives concerns from an external Whistle-blower and fails to pass same to the appropriate authority.

10.2.2 Investigating Process of Concern(s) by an External Whistle Blower  

The Head, Internal Audit shall within 7 days of receipt the concern from the Whistle blower:

  • Acknowledge receipt of the issue(s) raised.
  • Carry out preliminary review to ascertain validity of the claim and determine whether the concerns fall within the scope of whistle-blowing or not.
  • The Chief Compliance Officer will track the Turnaround time and provide further assurance on the investigation process; for which responsibility, still rests with Internal Audit Department.

The purposes of investigation are to:

  • Establish if a wrongdoing has occurred based on the concern(s) raised, and if so to what extent; and
  • To minimize the risk of further wrongdoing, prevent any further loss of assets, damage to the reputation of the Organisation and if possible, protect all sources of evidence.

If preliminary investigation shows that the concerns fall within the whistle blowing reportable concerns, then further investigation shall be carried out. If otherwise, the Head, Internal Audit shall refer the matter to the appropriate quarters for further action. If criminal activity has taken place, the matter may be referred to the Police, and where necessary, appropriate legal action taken. The Head of Audit shall bring the matter to the attention of Management before notifying the Police.

The Head of Audit shall give update of the progress of investigation to the Whistle- blower if deemed necessary.

The Head of Audit shall, upon conclusion of the investigation, submit a detailed report to the MD/CEO for appropriate actions in line with the approved policies of the Organisation.

Where necessary, the Head of Audit will keep the Whistle-blower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

If dissatisfied with the outcome of the investigation, a Whistle blower may have recourse to the Chairman, Board Audit & Risk Management Committee which will not affect the fundamental right of the Whistle-blower to seek redress in the court of law.

Furthermore, the Head, Internal Audit shall periodically submit a summary of reported cases and outcomes to the Chairman, Board Audit & Risk Management Committee.

  1. ALTERNATIVE METHODS OF TAKING FORWARD A COMPLAINT
    • This policy is intended to provide Employees or Concerned Persons with an avenue to raise concerns with the Organization. Alpha10 hopes this will satisfy all Employees or Concerned Persons. If an individual feels it is right to take the matter outside this process, the following are possible contact points:
  • Individuals Solicitors.
  • The Audit Committee – appointed by the Board to scrutinise the Organisation’s finances and performance.
  • The Police – suspicions of fraud may be reported directly to the Police.

11.2 If Employees or Concerned Person do take the matter outside the organization, they need to ensure that any disclosure made is done in a reasonable and responsible way. A disclosure will be protected, even if it is proven to be unfounded, as long as it was made in good faith. However, any Employee or Concerned Person making a rash disclosure will not be protected. This can be checked with the Head of internal Audit who will also advise on ways to proceed

  1. How the allegation will be dealt with

The action taken by the organization will depend on the nature of the concern. The matters raised may;

  • Be investigated internally
  • Be referred to the Police.
  • Be referred to the external Auditor/Audit Committee

12.1. In order to protect individuals and the Organisation, initial enquires will be made to decide whether an investigation is appropriate and, if so, what form it should take. Concerns or allegations which fall within the scope of existing procedures will normally be referred for consideration under those procedures.

12.2. Some concerns may be resolved by agreed action without the need for investigation.

12.3. Where it is established that an investigation is necessary, the issues will be thoroughly investigated, using available evidence. The Whistle-blower may be called upon, if the report is not anonymous, to provide in strict confidence any available evidence necessary to confirm all the issues raised in the report.

12.4. If the report is not anonymous, the Whistle-blower will be the first to be apprised of the outcome

12.5. Where the allegations are confirmed, the Organization undertakes to take necessary disciplinary measures against identified offenders in line with Organization policy. Where injuries have been suffered by the Whistle-blower, the Organisation undertakes to provide necessary remedies as may be permitted by Organization policy.

12.6 Anytime that a report is received, it should be reported to the Board Audit & Risk Management Committee by the Head of Internal Audit.

12.7 The Head of Internal Audit will provide regular updates to the Board Audit Committee on all whistle blowing reports received, including the outcome of investigation, and remedial actions taken.

  • Within ten (10) working days of a concern being received, the Organization will write to the Complainant:
  • Acknowledging that the concern has been received;
  • Indicating how it proposes to deal with the matter;
  • Giving an estimate of how long it will take to provide a final response;
  • Telling them whether any initial enquires have been made; and
  • Telling them whether further investigations will take place, and if not, why not.

12.9 The amount of contact between the body considering the issues and the Complainant will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information will be sought from the Individual.

12.1.0 When any meeting is arranged, Employees or Concerned Persons have the right, if they so wish, to be accompanied by a work Colleague who is not involved in the area of work to which the concern relates.

12.1.1 The Organization will take steps to minimise any difficulties which Employees or Concerned Persons may experience as a result of raising a concern. For instance, if Employees or Concerned Persons are required to give evidence in criminal or disciplinary proceedings, the Organization will advise and support them through the procedures.

12.1.2 The Organization accepts that Employees or Concerned Persons need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, Employees or Concerned Persons will receive information about the outcomes of any investigations.

  1. TIME LIMIT FOR INVESTIGATION

In line with the policy of the Organization, Alpha10 is committed to prompt resolution of all concerns or issues raised. If the investigation of whistleblowing complaint was not concluded promptly, the Head of Audit must keep the Managing Director/CEO abreast of progress.

  1. PROTECTION/ SAFEGUARDS FOR WHISTLE BLOWER

The Organization has an obligation to adequately protect the Whistle blower. Therefore, reprisal against any Employee who in good faith reports a concern about illegal or unethical conduct will not be tolerated.

14.1 Harassment or Victimisation:  The Organization recognises that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal from those responsible for the malpractice. The Organization will not tolerate harassment or victimisation and will take action to protect Employees or Concerned Persons when they raise a concern in good faith. This does not mean that if an Employee or Concerned Person is already the subject of disciplinary or other Organisation procedures, that those procedures will be halted as a result of their whistle blowing.

14.2 Confidentiality:  it is recognised that Employees or Concerned Persons may wish to raise a concern in confidence.  Individuals who raise concerns will not have their identity disclosed without their prior consent. It must be appreciated, however, that in some situations the investigation process may not be concluded unless the source of the information and a statement by the Individual is produced as part of the evidence.

14.2.1 Anonymous Allegations:  This policy encourages Employees or Concerned Persons to put their names to allegations, concerns expressed anonymously are much less powerful, but they will be considered at the discretion of the organization. In exercising this discretion, the factors to be taken into account would include:

  • The seriousness of the issue raised;
  • The credibility of the concern; and
  • The likelihood of confirming the allegation from attributable source.

14.2.2 False/Untrue Allegations:  If an allegation is made in good faith and the reporter has a   reasonable belief in the truth of the allegation, and after due investigation it turns out that the allegation is untrue, there will be no indictment against such a Person.  However, if the reporter makes a malicious or vexatious allegations, disciplinary action may be considered and implemented.

In making whistle blowing reports, the Whistle-blower should ensure that:

  • The report is made in good faith;
  • He or she has a reasonable ground to believe that the report is true; and
  • He or she is not making the report for personal gain.

Where there are deliberate false allegations, the following disciplinary measures will be taken against the Whistle-blower.

a).   If the Whistle-blower is a Member of Staff, disciplinary measures will be taken in line with Organization policy and may in some cases, lead to dismissal.

b).  If the Whistle-blower is a Supplier or Service Provider, he or she may be blacklisted.

     14.2.3 Retaliation

We view retaliation or any form of reprisal by any Employee, Manager, Director, and Business Partner against anyone who reports a violation as a very serious offence. All cases of retaliation shall be reported to the Internal Audit Manager who after investigation shall refer the issue to the Disciplinary Committee for appropriate sanctions to be meted out.

Whistle-blowers either internal or external may be rewarded depending in the gravity of the case. Compensation may also be provided to Whistle-blowers who may have suffered loss during the process. This is however at the discretion of Management. In addition, a Whistle-blower may seek further redress from the SEC on issues within the scope of this policy. The Organisation guarantees the rights of all Staff, particularly accused Staff who have suffered any detriment by reason of disclosure. Compensation and/or reinstatement of such Persons shall be in line with the Organizations relevant internal policies.

  1. REPORTING

Reports can be made in writing by email or verbally by telephone or in Person. As much as   possible, all Whistle-blowers should ensure that the concrete issues raised are dealt with.

Where possible, concerns should be raised in writing. The background and history of the concern, giving names, dates and places if known, should be set out and the reason why the individual is particularly concerned about the situation. Those who do not feel able to put their concern in writing can telephone or meet the appropriate officer.

The Organization encourages all Whistle-blowers to put their names to the reports. However, reports can be made anonymously where the Whistle-blower feels it is in his/her interest to do so. It should be understood that anonymous reports are much difficult to investigate, especially in cases where there is insufficient documentary evidence. Before making anonymous reports, therefore, the Whistle-blower should ensure that the report contains pointers to credible sources that can be used to confirm issues raised in the report. The earlier the concern is expressed, the earlier it is to take action.

Although Employees or Concerned Persons are not expected to prove the truth of an allegation, they will need to demonstrate to the contracted that there are sufficient grounds for concern.

Advice and guidance on how matters of concern may be pursued can be obtained from your Head of Department or internal Audit Department.

15.1 Reports against Members of the Board, the Managing Director and the Executive Directors

Investigation will be handed by a Disciplinary Committee comprising the Chairman of the Audit & Risk Management Committee, the Chairman of the Finance and Investment Committee, an Independent Director and the Head, Legal

The Chairman of the Audit & Risk Management Committee will serve as the Chairman of the Disciplinary Committee.

The Head of the Internal Audit Department, Head of Risk Management, Chief Compliance Officer and the Head, Human Resources may be co-opted at the discretion of the Committee to provide technical input.

15.2 Reports against Other Members of Staff Other Than the Executive Directors

Investigation will be handled by a Disciplinary Committee comprising the Managing Director, Head of the Internal Audit Department, Chief Compliance Officer, Head of Risk Management, the Head of Human Resources, the Head, Legal and the Head of the Business Unit of the Employee against whom the report was made or the Supervisor of that Employee.

15.3 Where the Person to be investigated is one of the Persons listed above, such Person shall not take any part in the investigation process, nor meddle with available evidence in anyway whatsoever.

  1. The Responsible Officer

The Head of Internal Audit in consultation with the Managing Director/Chief Executive has overall responsibility for the maintenance and operation of this policy. The Head of Internal Audit will maintain a record of concerns raised and the outcomes (but in a form which does not endanger confidentiality) and will report as necessary to the MD/CEO and the Audit & Risk Management Committee.

  1.  Public Concerns

It is recognised that some Members of the Public may be reluctant or unaware of how to report incidents and concerns through these formal procedures. In order to reduce any barrier to reporting fraud within the Organisation, dedicated `Fraud Hotlines` have been established as shown below.

Fraud Hotline

For all areas of concern;

Fraud Hotline for the Organisation +234 913 444 4497

This line is only operated during office hours.

The objective of these Hotlines is to provide an avenue for the reporting of suspicions of fraud within the Organisation to the Organisation. All calls to the Organization will be dealt with by experienced Employees or Concerned Persons, and all concerns will be professionally investigated. Any Person who wants to remain anonymous may do so.

  1.  Review and Update

The Policy will be subject to review and update from time to time.

  1. Wider Disclosure

A Whistle-blower whether internal or external may elect to disclosure directly to any of the regulatory bodies that have oversights on the activities of Alpha10.