Whistleblowing Policy

At Unity Bank, we encourage transparency, reliability and trustworthiness from all our employees, consultants, contractors/vendors and stakeholders alike in their interactions with our esteemed customers. To this end, we encourage that you report all inappropriate, unethical and unprofessional behaviour you have experienced or observed.

The Unity Bank whistleblowing policy is as follows;

Statement of Commitment  

The Board and Management of Unity Bank Plc (UB) is fully committed to ensuring open communication amongst employees and stakeholders. It is on the strength of this, that the Whistle Blowing Policy provides a channel for every employee/stakeholder, to comment freely and constructively on issues of concern in the workplace. UB is committed to ensuring that work related concerns brought to its attention through these channels are investigated in a timely and objective manner.      

Restriction  

This Whistle Blowing Policy is the property of Unity Bank Plc. It shall under no circumstances be reproduced, stored in a retrieval system or transmitted in any form, by any means, be it electronic, mechanical, photocopying, recording or otherwise without the express permission of the Chief Compliance Officer.  

Definition

The Whistle Blowing Policy is a rule/guiding principle that   establishes a channel for every employee/stakeholder, to freely comment constructively on issues concerning Unity Bank Plc or report any act that has or will have negative consequences to the organization without fear of disclosure of his or her identity.

Introduction 

To foster a healthy working environment within the institution, Unity Bank Plc developed robust policies around Ethics, Professional Conduct and Corporate Governance which are well documented and communicated to all Employees/Stakeholders which changes reflected in line with the industry standard. Due to the nature of these policies, their breach would normally be concealed by the perpetrators.  It is therefore imperative to create an environment that enables any stakeholder who is aware of any breach/misconduct to ‘blow the whistle’. 

The Bank has zero tolerance for any breach of the high standards and policies because of the damaging consequences to the Bank’s reputation from both business and regulatory perspectives. It is in this regard that The Bank has articulated its Whistleblowing Policy.

Objectives 

- To encourage well-meaning employees and stakeholders of the Bank to have confidence to raise serious concerns in the workplace, particularly with respect to issues that border on corporate governance, ethical and professional conducts

- To provide avenues through which these concerns can be raised without fear of victimization or reprisals.

- To provide adequate assurances that disclosures would be thoroughly investigated and disposed-off as appropriate and;

- To aptly communicate actions taken by Management to the Board, Regulators and other relevant stakeholders.

Reportable Incidents 

All stakeholders and employees can discreetly provide information by filling the Whistleblowing Reporting Form accordingly. 

However, if it is established at the end of a thorough investigation that employees or an employee reported or disclosed any information maliciously or baselessly with the intent to bring the Bank to disrepute or to mar/ undermine the integrity of people within and or associated with the Bank, such employee(s) shall be subjected to face the full measure of the Staff Disciplinary Policy and Procedure accordingly. In the case of ex-employee/ non-employee, the Bank shall take appropriate legal actions against such a person(s)/organisation.

The following is a list of some reportable incidents:

- Conflict of Interests

- Manipulation of Bank records/data

- Insider dealing 

- Suspected fraud 

- Leaking of confidential or proprietary information

- Improper/unethical conduct 

- All deliberate acts/omission/commission capable of posing a risk to the Bank’s stakeholders 

- Conducts/Omissions that can pose health, safety or environmental hazards 

- Mismanagement, gross wastage or misappropriation of Bank funds/assets

- Abuse of authority

- Accepting or seeking anything of material value from account holders, contractors, vendors, or persons providing services to the bank as inducement against the Bank's interest.

- Any act of discrimination or sexual harassment

- Unofficial use of Bank’s material/human assets

- Abuse of expenditure policy. 

- Abuse of Delegated Powers.

- Any other issue of relevance not mentioned in this section. 

Non Reportable Incidents

- Staff complaint about management decisions on recruitment, internal employment/deployment, promotions, incentive sharing and other job related issues which are covered under separate appropriate staff policies of the Bank.

- Customer complaints about the Bank’s products including pricing, service delivery and relationship management which are standards applicable and prevailing to all the Bank’s customers. 

- Complaints about supervisors, subordinates or fellow colleagues in matters relating to job responsibilities, on-the-job relationships and other matters that are of a private nature. 

- All other matters for which there exists a specific complaints procedure policy in the Bank.

Conflict of Interest

This is a situation where a Staff or Director of the Bank has a private interest sufficient to influence the objective exercise of his official duties or business of the Bank.

Protection for Whistle Blowers

In order to ensure protection for the whistle blower, all disclosures to the Bank should be made in good faith. The Bank encourages anonymous whistleblowing where genuine whistleblowers provide useful information through the approved whistleblowing channels.

A whistleblower is at liberty to disclose his/her identity but even where the identity of the whistleblower is disclosed, such identity shall remain confidential. 

All staff are protected from victimization, harassment or disciplinary action due to any disclosure of suspicious transaction or suspicious activity, where such disclosure is made in good faith and is not made maliciously or for personal gain. 

Where the confidentiality of the whistleblower is compromised, The Bank shall do everything within its power to protect such person from any harm or victimization of any kind.

Where a Whistleblower suffers damages by reason of disclosure made to the Bank; 

i. Employee(s): He/She/They shall be appropriately compensated and/or reinstated provided that in the case of compensation, the employee’s entitlement shall be computed as if he/she/they had attained the maximum age of retirement or had completed the maximum period of service in accordance with his/her condition of service.

ii. Other stakeholders: The Whistleblower shall be adequately compensated as may be determined by management. 

Undisclosed/Unknown Whistleblower: Where the identity of a whistleblower is known, no action shall be taken against him/her even though a disclosure reported in good faith could not be proved after investigation insofar as no injury is suffered by the Bank or any of its Stakeholders as a result of the malicious or unsubstantiated whistleblowing.

Procedure for Whistle blowing

- To aid prompt and thorough investigations, the whistleblower is urged to provide as much facts as possible, such as dates of events, reference documents e.t.c along with the disclosure.

- Disclosure Channels: Disclosures can be made through any of the following channels:

i. Telephone call to a hotline; 080-777-92009 The recipient of the call may ask the Whistleblower further questions to aid the investigation process.  To report via email - whistleblower@unitybankng.com. For whistle-blowing reports to CBN, please send an email to anticorruptionunit@cbn.gov.ng

ii.  Whistleblowing Boxes provided at designated locations at the Head Office and other business locations.

iii. By clicking on the “blow a whistle” link hoisted on the Bank’s website OR sent directly to whistleblower@unitybankng.com

iv. Direct confidential disclosures can be made to any of the underlisted Offices:

• The Chairman, Board of Directors

• The Chairman, Board Risk Management & Audit Committee

• The Chairman, Statutory Audit Committee

• Managing Director/CEO

• The Chief Audit Executive/Chief Inspector

Where a whistleblower chooses to remain anonymous, a call deal shall be reached between the whistleblower and the recipient at the point of reporting. This deal shall spell out pre-agreed time when the whistleblower should call back the hotline, at no cost, to offer further clarifications on the reported case. 

Standard of Proof 

It shall not be necessary for a whistleblower to prove that the act has occurred or would occur. A reasonable belief that the act has occurred is all that is required.

Process of Investigating reported cases 

Within 2 working days of receiving a report, the Chief Audit Executive shall immediately appoint an investigation team to discreetly work on the reported case. 

Subject to the complexity of each case, an investigation shall not exceed a maximum time of four (4) weeks to be concluded. 

Updates of investigated reported cases and disciplinary actions taken may discreetly be communicated to the whistleblower (where necessary).   

Reward Scheme  

The Bank shall, subject to its discretion, consider appropriate reward to staff whose disclosures lead to the protection of the Bank’s assets

Review of the Policy

Unity Bank Whistle Blowing Policy shall be reviewed every three (3) years from the date of operation of the existing policy and procedure in line with regulatory requirement.