ࡱ > _ bjbj 4 b b U8 n n n n n 8 , r T D > ( f f f C B F G d q q q q q q q $ u x j q n #H C C #H #H q n n f f % =r K K K #H n f n f q K #H q K K n fi ^l f fq: ;I nj vq Sr 0 r j x I x @ ^l x n ^l #H #H K #H #H #H #H #H q q K #H #H #H r #H #H #H #H x #H #H #H #H #H #H #H #H #H 4 : THE NIGERIAN AVIATION HANDLING COMPANY PLC WHISTLE BLOWING POLICY INCLUDEPICTURE "http://www.iia.org.uk/media/563435/whistle_page_header.jpg" \* MERGEFORMATINET 2020 DOCUMENT CONTROL NUMBER: 00 Table of Contents TOC \o "1-3" \h \z \u HYPERLINK \l "_Toc516742258" APPROVAL PAGE PAGEREF _Toc516742258 \h 3 HYPERLINK \l "_Toc516742259" Revision: PAGEREF _Toc516742259 \h 4 HYPERLINK \l "_Toc516742260" Record of Revision PAGEREF _Toc516742260 \h 4 HYPERLINK \l "_Toc516742261" Distribution List: PAGEREF _Toc516742261 \h 5 HYPERLINK \l "_Toc516742262" Introduction PAGEREF _Toc516742262 \h 6 HYPERLINK \l "_Toc516742263" Policy Statement PAGEREF _Toc516742263 \h 6 HYPERLINK \l "_Toc516742264" Objective of Whistle Blowing Policy PAGEREF _Toc516742264 \h 6 HYPERLINK \l "_Toc516742265" Scope PAGEREF _Toc516742265 \h 7 HYPERLINK \l "_Toc516742266" The Policy PAGEREF _Toc516742266 \h 7 HYPERLINK \l "_Toc516742267" Procedure PAGEREF _Toc516742267 \h 8 HYPERLINK \l "_Toc516742268" Investigation PAGEREF _Toc516742268 \h 8 HYPERLINK \l "_Toc516742269" Safeguards PAGEREF _Toc516742269 \h 9 HYPERLINK \l "_Toc516742270" Disciplinary Action PAGEREF _Toc516742270 \h 9 HYPERLINK \l "_Toc516742271" The fundamental elements of this policy PAGEREF _Toc516742271 \h 9 HYPERLINK \l "_Toc516742272" Roles & Responsibilities PAGEREF _Toc516742272 \h 11 APPROVAL PAGE Document Title : WHISTLEBLOWING POLICY Document Reference : NAHCO-WBP-03.02 Issue No. & Revision No. : Issue3 Rev. 2 Revision Date : 18-03-2020 Prepared By: 1. Name: Solape Koledoye Designation: Head, Internal Audit & Compliance Signature:.. Date:. The undersigned nahco aviance personnel declare that they have read and understood the contents of this Policy. Reviewed and Recommended for Approval By: Name: Mrs. Olatokunbo A. Fagbemi Designation: Group Managing Director/ CEO Signature:.. Date:. ORGANISATIONAL APPROVAL Approved By: Dr. Seinde Fadeni Oladapo Chairman, Board of Directors Signature:.. Date:. Revision: Updated sheets are to be issued in the proper place and obsolete pages discarded. The holder of this policy is to record the receipt and review of each revision on this form. Record of Revision IssueRev. No.Revised by (Name)Effective Date10.Ahmed Bashir10/12/201321.Anthony Iyayi01/06/201832.Solape Koledoye18/03/2020 Distribution List: GROUP MANAGING DIRECTOR/CEO COMPANY SECRETARY HEAD, CORPORATE SERVICES CHIEF FINANCE OFFICER (CFO) HEAD, INTERNAL AUDIT & COMPLIANCE CARGO SERVICES MANAGER CHIEF OPERATING OFFICER MANAGER, ERM MANAGER, COMMUNICATIONS & CORPORATE SERVICES HEAD, HUMAN RESOURCES & ORGANISATIONAL DEVELOPMENT MANAGER, OUTSTATION OPERATIONS MANAGER, LAGOS OPERATIONS ENGINEERING & MAINTENANCE MANAGER SECURITY SERVICES MANAGER HEAD, ICT & SYSTEMS RAMP SERVICES MANAGER MANAGER, CARGO RAMP PASSENGER SERVICES MANAGER STATION MANAGER, ABUJA STATION MANAGER, PORT HARCOURT STATION MANAGER, KANO STATION MANAGER, KADUNA STATION MANAGER, UYO STATION MANAGER, ENUGU STATION MANAGER, AKURE STATION MANAGER, KEBBI STATION MANAGER, MAIDUGURI STATION MANAGER, YOLA STATION MANAGER, ASABA STATION MANGER, BENIN Introduction An important aspect of accountability and transparency is a mechanism to enable all individuals to voice out concerns internally but in a responsible and effective manner when they discover information which they believe shows serious malpractice. Consultation goes to the heart of the companys culture, and avoids an individual having to resolve a difficult ethical situation all alone. Staff should in the first instance consider consulting their Line Managers or Supervisors/ Leaders. If uncomfortable about taking up the matter through the companys normal reporting channels or with their Human Resources Contacts (Human Resources Partners), they may want to seek assistance from this whistleblowing policy. Our whistleblowing policy is therefore fundamental to the companys core values (Safety, Integrity, Reliability, Innovation and Respect for the Individual). In addition, it reinforces the value nahco aviance places on staff to be honest and respected members of their individual professions. It provides a method of properly addressing bona fide concerns that individuals within the company might have, while also offering whistleblowers protection from victimization, harassment or disciplinary proceedings. It should be emphasized that this policy is intended to assist individuals who believe they have discovered malpractices or impropriety. It is not designed to question financial or business decisions taken by the company nor should it be used to reconsider any matters which have been investigated under the harassment, grievance or disciplinary policies and procedures. Policy Statement The Board and Management of nahco aviance are committed to ensuring openness and communication in all the dealings of the company with its officers, employees, suppliers and all other stakeholders and publics with whom it engages for business and other relations. This is in line with the companys core values. The company recognizes that effective and honest communication is essential to maintain our core values and to ensure that negative business practices are detected and dealt with promptly with a v i e w t o p r e s e r v i n g t h e r e p u t a t i o n a n d i n t e g r i t y o f t h e c o m p a n y w i t h i t s v a r i o u s p u b l i c s . O b j e c t i v e o f W h i s t l e B l o w i n g P o l i c y T h e o b j e c t i v e o f t h i s p o l i c y i s t o e n c o u r a g e e v e r y o n e , w h e t h e r p a r t t i m e o r f u l l t i m e e m p l o y e e s , a g e n t s , c o n t r a c t o r s , s u p p l i e r s , s t a f f o f s u p p l i e r s , c u s t o m e r s o r p e o p l e h o w e v e r r e m o t e l y r e l a t e d t o t h e c o m p a n y , t o r e p o r t a n y b u s i n e s s m i s c o n d u c t w i t h o u t r i s k t o t h e m s e l v e s o r a n y i n h i b i t i o n o r v i c t i m i s a t i o n . A p p r o p r i a t e i n c e n t i v e s w i l l b e o f f e r e d t o a w h i s t l e b l o w e r w h o s e a c t i o n s i g nificantly promotes the Companys interests. Scope The policy covers all employees of nahco aviance and all other stakeholders as described above. The Policy This policy will apply in all cases where an individual genuinely and in good faith have reasons to believe that a misconduct is occurring, occurred or may occur within the nahco aviance operating environments, irrespective of location. Such misconduct will include but is not limited to the following: Commission or concealment of a criminal offence / f r a u d / t h e f t o r c o l l u s i o n t o c o m m i t t h e s a m e ; N o n c o m p l i a n c e w i t h L a w s o f t h e F e d e r a l R e p u b l i c o f N i g e r i a o r a l e g a l o b l i g a t i o n a n d b r e a c h e s o f s t a t u t o r y l e g a l o b l i g a t i o n s ; A n y i l l e g a l o r u n e t h i c a l o p e r a t i o n ; S e r i o u s u n p r o f e s s i o n a l o r u n e t h i c a l b e h a v iour, including harassment of any sort and/or bullying; Use of deception to obtain an unjust or illegal financial advantage for the business unit or personally; Miscarriage of justice; Endangering the health and safety of an individual; Damage to the environment; Breach of internal control; Intentional misrepresentation directly or indirectly affecting financial statements; Damage to our Ground Support Equipment and other infrastructure in the premises. Deliberateconcealment of information relating to any of the above. This policy is very distinct from the grievance procedure as enunciated in the companys employee handbook, i.e. the Conditions of Service. Procedure Talking to the whistle blowers: As soon as you become aware of a situation, you have the opportunity to make comments to the officers in charge of the whistle blowing lines (whose telephone numbers were published on nahco aviance website as indicated below which will not be held against you. The under listed e-mail address and phone nu m b e r s b y e l e c t r o n i c m a i l o r t e x t m e s s a g e ( S M S ) o r v o i c e c a l l c a n b e u s e d f o r t h i s p u r p o s e : E - m a i l : w h i s t l e b l o w i n g @ n a h c o a v i a n c e . c o m 0 8 1 4 2 1 1 2 7 2 0 - M T N 0 8 1 4 2 2 8 3 8 4 1 - M T N 0 8 1 4 5 5 9 1 4 3 1 - M T N 0 8 1 4 9 4 9 5 6 7 7 - M T N A l l i n s t a n c e s o f w h i s t l e b l o w i n g t o a n y of the above lines of communications will be logged in a register for and communicated to the Chairman of the Boards Governance & Remuneration Committee for directive on investigation as he may deem fit. Where the Head, Internal Audit & Compliance conducts the investigation, the report is sent to the Chairman of the Boards Governance & Remuneration Committee for further directive as appropriate. Investigation Once an allegation of misconduct is made and the Head, Internal Audit & Compliance is directed to conduct the investigation, the appropriate plan is agreed with the Chairman of the Boards Governance & Remuneration Committee. Once the investigation is completed, the report shall immediately be sent to the Boards Governance and Remuneration Committee. The whistle blower shall be advised of the outcome of the investigation as well as the corrective actions which are being taken so as to serve as an encouragement to the blower of the whistle. nahco aviance is committed to running its business w i t h o u t m i s c o n d u c t a n d e x p e c t s i t s e m p l o y e e s a n d o t h e r s t a k e h o l d e r s t o s h a r e t h i s o b j e c t i v e . H o w e v e r , t h e c o m p a n y a l s o r e c o g n i z e s t h a t w h i s t l e b l o w i n g i s a p o t e n t i a l l y s e n s i t i v e i s s u e . T h e r e f o r e , i f y o u h a v e r e a s o n t o b e l i e v e t h a t y o u a r e b e i n g v i c t i m i z e d or penalized in any way for whistleblowing or if you do not consider that you have had a satisfactory response to your disclosure, you should write directly to the Chairman of the Boards Governance & Remuneration Committee setting out the facts. Safeguards The Company would take all reasonable steps to protect the identity of whistle blowers. Any whistleblowing employee is protected against adverse employment actions (i.e. dismissal, demotion, suspension, harassment or other forms of discrimination) for raising allegations of misconduct by the Board of Directors of the Company and specific legislation in force in Nigeria. A whistleblowing employee is also protected even if the allegations proved to be incorrect or unsubstantiated, provided the disclosure is made in good faith under the honest belief that the information and any allegation therein are true. Disciplinary Action In the event that any allegation of misconduct is substantiated, appropriate disciplinary action will be taken against the responsible individual(s) up to and including termination of employment, dismissal from service and criminal prosecution by the relevant authorities. Furthermore, any act of retaliation or victimization against a whistleblowing employee will result in disciplinary action being taken against the perpetrator, up to and including termination of employment. The malicious use of the whistleblowing policy will result in disciplinary action against a whistleblowing employee, up to and including termination of employment. The fundamental elements of this policy All staff members are protected from victimization, harassment or disciplinary action as a result of any disclosure, where the disclosure is made in good faith and is not made maliciously or for personal gain. Where disclosures are made in the public interest, staff will have statutory protection. Any disclosure will be investigated fully including interviews with all the witnesses and other parties involved. Anonymity: The identity of the whistleblower will be protected at all stages in any internal matter. While the company can provide internal anonymity, it cannot guarantee this will be retained if external legal action flows from the disclosure. If the whistleblower prefers to make a disclosure outside the company, nahco aviance will not be accountable for maintaining anonymity, i.e. where the whistleblower has told others of the alleged infringement. Note: Whilst the company encourages self-identification of whistleblowers, anonymous calls will nevertheless be taken seriously and investigated fully. However, the effectiveness of any whistleblowing enquiry may be limited where an individual chooses not to be identified. Roles & Responsibilities S/N.Responsible OfficerResponsibilities1.WhistleblowerThe Whistleblower is expected to act in good faith and should report his/her concerns with adequate evidence to aid investigation of the case presented by him/her.2.SuspectIt is the duty of the suspect to cooperate with investigators by providing them with useful information, documents and materials required for a successful investigation.3.Investigator/ Head, Internal Audit & Compliance The Head, Internal Audit & Compliance shall exercise confidentiality, independence and professionalism in carrying out the investigation. The Head, Internal Audit & Compliance is expected to acknowledge all concerns reported by the Whistle Blower and revert to him/her on the progress of the investigation. The Head, Internal Audit & Compliance shall provide the Chairman of Audit Committee a summary of all cases reported and the outcome of the investigation conducted. 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