Principle 19 of the Nigerian Code of Corporate Governance (“NCCG”) 2018 requires that all organisations operating in Nigeria implement effective whistleblowing programmes.
Whistleblowing programmes help organisations become aware of suspected wrongdoing or risk of wrongdoing. Wrongdoing includes, but not limited to, fraud, theft, bullying, harassment, violation of policies or regulations, etc.
In 2022, the Association of Certified Fraud Examiners (ACFE) reported that 42% of occupational fraud were detected through whistleblower reports, with more than half of these coming from employees of the victim organisations.
An effective whistleblowing programme is built on three (3) core principles: trust, protection and impartiality.
Trust
- Guarantees Whistleblowers’ anonymity.
- Treats whistleblowing reports with confidentiality.
- Ensures management’s commitment is clearly communicated and supported with actions.
Impartiality
- Ensures consistent management action in the handling of whistleblowing reports.
- Ensures that all whistleblowing reports are treated transparently and in line with the established policies
Protection
- Ensures adequate protection for the whistleblower against retaliation of any form.
- Includes sanctions for violation of the non retaliation policy.
- Encourages stakeholders to report any wrongdoing witnessed in good faith that they will be protected.
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