WHISTLE BLOWING
PROCEDURES
ZENITH PENSIONS
CUSTODIAN WHISTLE
BLOWING PROCEDURES
Background
The whistle blowing
guidelines issued
by Pensions Commission
protects employees
against detrimental
treatment or dismissal
as a result of any
disclosure by them
to the commission
of information normally
considered as confidential
in the interest
of all stakeholders
of the pension scheme.
What is Whistle
blowing?
Whistle blowing
involves the reporting
of events of misconduct
relating to or affecting
an organization
to enable the organization
take necessary actions.
It is when someone
raises a concern
about wrong doings
occurring in an
organization.
Who can
use the whistle
blowing procedures?
In line with Section
68 of the Pension
Reform Act (PRA)
2004, the Compliance
Officer of ZPC has
the statutory responsibility
to report any breach
of the PRA 2004,
codes, guidelines,
rules and regulations
issued by the commission,
in the course of
the company’s
business, to the
commission.
The directors, management,
employees, and any
other person(s)
that have dealings
with ZPC shall also
have the responsibility
to report breaches
to the commission.
When
should I use the
whistle blowing?
Whistle blowers
should report breaches
that are likely
to be of material
significance to
the Commission in
carrying out its
functions. A breach
is considered as
materially significant
in the following circumstances;
-
Act of dishonesty
including fraud,
bribery and
other corrupt
practices by
company’s
management
-
Misappropriation/diversion
of funds under
custody.
-
Failure to act
in the face
of deliberate
contraventions
of regulations,
guidelines and
rules issued
by the commission.
-
Other activities
inimical to
the sanctity
of pension administration
in Nigeria and
can result to
public loss
of confidence
in the scheme.
Protection
of a whistle blower
ZPC has undertaken
in writing to PenCom
that in the event
of its employee
blowing the whistle
on its unethical
or illegal operations
or activities, such
employee shall not
be victimized in
any way. The commission
shall be obliged
to employ appropriate
regulatory tools
to offer redress
to any employee
victimized on the
account of whistle
blowing.
Procedure
flow for whistle
blowing facility
-
A whistle blower
shall report
all concerns
in writing or
may contact
the appropriate
officers of
ZPC or the Commission.
The concern
should be reported
promptly through
the following
means:
-
I. In compliance
with the whistle
blowing guideline
issued by
Pencom, ZPC
has established
a dedicated
whistle blowing
feedback mail
address on
our website
www.zenithcustodian.com.
The whistle
blower has
the option
to include
sender name
or be anonymous.
Mails are
automatically
forwarded
to Managing
Director and
Head of Compliance
and Risk Management
of ZPC.
II.
Letters can
also be sent
directly to:
The Director
General,
National Pension
Commission
(PENCOM),
Plot 2774,
Shehu Shagari
Way,
Maitama District,
Abuja.
III.
In addition
the following
dedicated
lines are
available
for the whistle
blower to
call directly
to express
their concerns.
ZPC:
01 2792915
ZPC:
01 2792916
IV.
A suggestion
box has been
provided in
the office
where by staff
of ZPC can
report breaches
and make suggestions.
•
The whistle
blower shall
not be expected
to prove the
truth of an
allegation,
but must demonstrate
that there are
sufficient grounds
for the concern.
• A whistle
blower can report
an incident
anonymously
but he/she is
encouraged to
put his/her
name to his/her
allegations
as anonymous
reports are
considered at
the discretion
of the commission.
• The
commission shall
take into account
the seriousness
of the issues
raised, the
credibility
of the concern
and the likelihood
of confirming
the allegation
from reputable
sources.
An
effective whistle
blowing procedure
is regarded
as a key element
of good corporate
governance and
good risk management
culture.
•
REVIEW
AND UPDATE
The procedure
will be subject
to review and
update from
time to time
as the need
arises.
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