Policy

Whistleblower Policy

Policy number	POL2019_02
Version	2
Responsible person	Ndubuisi Okoli
Approved by Board on	11th March 2019
Last Reviewed	11th Nov 2022

Introduction

The Board of Moneytronics Microfinance Bank (The Bank) is committed to operating legally (in accordance with applicable legislation and regulation), properly (in accordance with organizational policy and procedures), and ethically (in accordance with recognized ethical principles).

Employees are expected to cooperate with the Bank in maintaining legal, proper, and ethical operations, if necessary by reporting non-compliant actions by other people.  Correspondingly, employees who do assist in maintaining legal, proper, and ethical operations would not be penalized in any way. 

Purpose

The purpose of this policy is to:

• encourage the reporting of matters that may cause harm to individuals or financial or non-financial loss to the Bank or damage to its reputation;
• enable the Bank to deal with reports from whistleblowers in a way that will protect the identity of the whistleblower and provide for the secure storage of the information provided;
• establish the policies for protecting whistleblowers against reprisal by any person internal or external to the Bank;
• provide for the appropriate infrastructure;
• help to ensure the Bank maintains the highest standards of ethical behavior and integrity.

Policy

Concerns regarding illegal or corrupt behaviour

Where an employee of the Bank believes in good faith, on reasonable grounds, that any other employee, customer or service provider has breached any provision of the general law that employee must report their concern to

• their supervisor: or, if they feel that their supervisor may be complicit in the breach,
• the Managing Director (MD): or, if they feel that the MD may be complicit in the breach,
• the Bank’s nominated Whistleblower Protection Officer; or, if they feel this to be necessary, 
• a person or office independent of the Bank nominated by the Bank to receive such information, or
• the duly constituted authorities responsible for law enforcement in the area.

The person making their concern known shall not suffer any sanctions from the Bank on account of their actions in this regard provided that their actions

• are in good faith, and
• are based on reasonable grounds, and
• conform to the designated procedures.

Any person within the Bank to whom such a disclosure is made shall

• if they believe the behavior complained of to be unquestionably trivial or fanciful, dismiss the allegation and notify the person making the allegation of their decision;
• if they believe the behavior complained of to be neither trivial nor fanciful, ensure that the allegation is investigated, a finding is made, and the person making the allegation is informed of the finding.

Any such investigation shall observe the rules of natural justice and the provisions of procedural fairness.

Disclosures may be made anonymously, and this anonymity shall as far as possible be preserved by the Bank.

Concerns regarding improper or unethical behaviour

Where an employee of the Bank believes in good faith, on reasonable grounds, that any other employee, customer or service provider has breached any provision of the Bank’s articles of association, or its bylaws, or its policies, or its code of conduct, or generally recognized principles of ethics, that employee may report their concern to:

• their supervisor: or, if they feel that their supervisor may be complicit in the breach,
• the MD: or, if they feel that the MD may be complicit in the breach,
• a person or office independent of the Bank nominated by the Bank to receive such information.

The person making their concern known shall not suffer any sanctions from the Bank on account of their actions in this regard provided that their actions

• are in good faith, and
• are based on reasonable grounds, and
• conform to the designated procedures.

Any person within the Bank to whom such a disclosure is made shall

• if they believe the behaviour complained of to be unquestionably trivial or fanciful, dismiss the allegation and notify the person making the allegation of their decision;
• if they believe the behaviour complained of to be neither trivial nor fanciful, ensure that the allegation is investigated, a finding is made, and the person making the allegation is informed of the finding.

Any such investigation shall observe the rules of natural justice and the provisions of procedural fairness.

Disclosures may be made anonymously, and this anonymity shall as far as possible be preserved by the Bank.

You can report anonymously by email to whistleblower@mtronicsbank.com or a call to the bank’s dedicated ethics telephone line +234 1 710 0170

Procedure

Please refer to the Whistleblower Procedure, copies of which you can obtain from your Manager on request

Authorization