Mobile Money Payment Service Bank (‘MoMo PSB’ or ‘the PSB’ or the Bank) actively encourages employees to embrace its values and culture, especially in respect of upholding the highest levels of integrity. Consequently, the Bank’s employees are obliged to report any unlawful, irregular, or unethical conduct that they observe.

The PSB is also required by the CBN Guidelines for Whistle-Blowing 2014 and Nigerian Code of Corporate Governance 2018 to have a whistle blowing policy that includes the provision of dedicated hotlines. These guidelines apply to all employees of MoMo PSB.

Whistleblowing essentially means to alert others of misconduct or wrongdoing. You do not need to be certain as suspicion is adequate provided it is done in good faith.

MoMo PSB will apply the highest standards of accountability and corporate governance in response to cases of whistle blowing.

The PSB’s whistle blowing policy provides for the following:

• Where an employee discovers information, which s/he in good faith believes shows wrongdoing within the Bank, it should be disclosed without fear of reprisal.
• No employee shall be disadvantaged when reporting legitimate concerns.
• MoMo PSB undertakes to protect the identity of any employee who in good faith makes a report in accordance with the procedures set out in this policy; and
• The Bank will not protect the identity of any employee who maliciously makes false reports and appropriate disciplinary action will be taken in such cases.

The whistle blowing policy is not intended to be used to report petty disputes, grievances, false or misleading disclosures, matters currently under disciplinary enquiry and matters already pending before the courts.

A disclosure is deemed to have been made in accordance with the CBN Guideline if the whistle-blower discloses to the bank, CBN, and/or other appropriate body or agencies or exercises any other lawful option provided that such disclosure is true and reasonable.

1. Purpose of the Whistle Blowing Policy

MoMo PSB is committed to a policy of fair treatment and integrity in the conduct of its business.

This commitment rests on the fundamental belief that businesses should be conducted honestly, fairly and within the framework of applicable laws.

We need to proactively protect funds and resources under our custodianship from abuse or misdirection. Furthermore, PSB employees deserve to work for an organization that adopts and acts upon, the highest ethical values.

Thus, reporting misconduct by blowing the whistle is an act of care and loyalty to our fellow employees, shareholders, and other stakeholders.

2. Objective of the Whistle Blowing Policy
• To clarify what types of misconduct are reportable.
• To communicate and give assurance of the bank’s commitment to protect disclosures.
• To give assurance that MoMo PSB will do everything in its power to ensure that people who report misconduct in good faith are not retaliated against or victimized.
• To inform employees of the various ways of making a disclosure and to give clarity on these processes; and
• To indicate what the PSB’s responsibilities are when alerted to misconduct.

MoMo PSB shall treat all disclosures resulting from whistleblowing in a confidential manner; both confidential and anonymous whistle-blower identity shall be kept confidential.

Safety is a concern because those who benefit from misconduct may attempt to retaliate against or victimize a whistle-blower for loss, or potential loss, of that ill-gotten gain.

However, such adverse consequences can only materialize if the identity of the whistle-blower is known through a breach of confidentiality; and an anonymous whistle-blower cannot be victimized, provided that the whistle-blower also protects his or her own anonymity.

MoMo PSB assures you that we will not tolerate retaliation against any person who reported in good faith. A good faith report is made by a whistle-blower who believes the report to be true and relevant to the interests of the Bank.

Anonymous disclosures will also be considered and investigated accordingly should you prefer your identity to be unknown.

The Bank will not subject a whistle-blower to any detriment whatsoever on the grounds that s/he has made a disclosure in accordance with the provisions of this policy and/or the CBN Guidelines on Whistle Blowing.

Where a whistle-blower has been subjected to any detriment in contravention of the above, s/he may present a complaint to the CBN. This is without prejudice to the right of the whistle-blower to take appropriate legal action.

An employee who has suffered any detriment by reason of disclosure made in line with the provisions of this policy and/or the CBN Guidelines on Whistle Blowing will be entitled to compensation and/or reinstatement provided that in the case of compensation, the employee’s entitlement shall be computed as if he had attained the maximum age of retirement or had completed the maximum period of service, in accordance with his condition of service. For other stakeholders, the whistle-blower must be adequately compensated.

For this policy, the word detriment includes dismissal, suspension, demotion, intimidation, harassment, termination, redundancy, undue influence, duress, withholding of benefits and/or entitlements and any other act that has negative impact on the whistle-blower.

Other issues that could amount to ‘detriment’ include being transferred against their will, refused transfer or promotion, subjected to a term or condition of employment or retirement that is altered or kept altered to his or her disadvantage, refused a reference, or being provided with an adverse reference and denied appointment to any employment, profession or office.

MoMo PSB maintains the necessary internal systems and procedures to protect the interests of whistle-blowers. A whistle blower will not be victimized or disadvantaged in any way by the Bank. However, reporting in no way protects a whistle-blower from being subjected to legitimate disciplinary processes if the whistle blowing was not in good faith or the person is involved in any misconduct or wrongdoing.

Anyone but especially employees, management, directors, depositors, service providers, creditors, and other stakeholders in the bank, if they are aware of or have reasonable grounds to suspect any misconduct or wrongdoing associated with the bank’s activities.

Misconduct or wrongdoing is reportable when it has taken place, is taking place, or is reasonably likely to take place. Damage to the bank and its stakeholders may occur when any misconduct is not checked or addressed. The sooner misconduct or wrongdoing is reported, the greater the chances of mitigating any possible impact.

Importantly, in determining whether to report misconduct, harm is not only measured in terms of resources lost, or damage to a program or initiative, but may also damage the integrity and reputation of the bank and Group.

Reportable Conduct Categories

• Illegal or Unlawful Conduct: Conduct may be illegal or unlawful in terms of local and international laws and regulations. Criminal offences such as theft, fraud, bribery and corruption, or money laundering fall into this category and should be reported.
• Unprocedural Conduct: Conduct may be unprocedural when it violates any rules and regulations, policies and procedures of the bank, Group or those of any other party that impact on the PSB’s operations. It is particularly important to highlight those rules and processes that guide accounting practices and control financial reporting, auditing matters, and the like. These procedures are important for good governance, and breaching them may expose the bank, Group and its stakeholders to the risk of loss or reputational damage.
• Other forms of Unethical Conduct: MoMo PSB’s Conduct Passport provides guidance as to what the bank considers ethical and unethical. The Conduct Passport does not cover all unethical actions and if you believe that an activity is unethical, in other words, it goes against our values and culture, then you should report this or obtain advice on the matter. However, not all forms of unethical conduct should be reported using the whistle-blowing channels. For example, some kinds of conduct may be disrespectful, and therefore undesirable, without harming any serious interests other than personal feelings. For this type of conduct, it is recommended that employees refer to the Human Resources manual and, more specifically, to the Grievance Policy.
• Wasteful Conduct: Conduct constituting a gross waste of resources is a reportable category since responsible stewardship of resources is crucial to the success of the bank. All individuals in the service of the PSB have an obligation to ensure that resources are used prudently and efficiently. If resources were spent in a wasteful manner, and in breach of the trust under which they are provided to the bank, this would be reportable under the whistle-blowing mechanism. The misconduct in the abovementioned categories could include various types of activities. While it is not possible to list all these activities, we appeal to staff to be especially vigilant about the following issues:
  • Actions detrimental to Health and Safety or the Environment.
  • Other forms of Corporate Governance breaches.
  • Insider Trading.
  • Non-disclosure of Interest.
  • Attempts to conceal or suppress information relating to any of the above.

The Bank or Group carries out formal investigations when we have reason to believe that improper acts have been committed. Please make your complaint as specific as possible and include the following details:

• The alleged wrongdoing that you are reporting.
• Where and when (dates and times, if available).
• Who was involved?
• How the individual or firm committed the act.
• Why you believe the activity is improper.

You will not be expected to prove the truth of an allegation. When reporting you will, however, need to show that you have enough grounds for your concerns.

There are various ways of raising a concern or speaking up. Your preferred option will depend on the seriousness of the misconduct you are reporting and one you are most comfortable with.

1. Minor Misconduct

In cases of minor misconduct (i.e., if it is not illegal or it does not pose significant potential damage to the bank or any of its stakeholders), you are encouraged to:

• Approach the offending colleague directly if this will resolve or prevent the misconduct.
• Approach Compliance, your line manager, or any other manager in the bank or Group whom you trust.
2. Serious Misconduct or Illegal Activities

MoMo PSB’s Whistle Blowing line at the initial stage will be managed by Compliance and subsequently independently managed by an external consultant Deloitte. Tip-Offs Anonymous and any serious misconduct or illegal activities can be reported either by:

• Calling 08031230541
• Emailing whistleblowingreport@momopsb.com
3. What is Confidential Whistle Blowing

If you agree to the confidential disclosure of your personal details, then your name and contact details will be known to the Whistle Blowing Contact Centre and the team that will conduct the investigation.

MoMo PSB assures you that they will not reveal the whistle-blower’s identity to any third-party. The only exceptions to this assurance may be where the bank must comply with a legal obligation to breach confidentiality or when it is required to protect the direct and significant interest of the Group.

Where such situations exist, the bank will notify the whistle-blower and take all necessary steps to protect and ensure his or her safety. This shall also apply to Partially Anonymous Whistle blowing.

The CBN encourages stakeholders (whistle-blowers) to disclose their names when filing reports.

An advantage for the PSB of a confidential (as opposed to anonymous) report is that it is better placed to investigate the report since the whistle-blower can be contacted for further information if necessary.

4. What is Anonymous Whistle Blowing

A whistle-blower may choose not to reveal his or her identity. Anonymous whistleblowing is very safe, but it may be difficult to investigate the facts.

Using the Whistle Blowing Line is recommended for anonymous whistleblowing. The whistle-blower must take care not to reveal his or her identity while making the report and must also be careful not to let anyone else know that they made the report. If you choose to make an anonymous report via the whistle-blowing hotline, you will receive a reference number. You can call the hotline later for an update on the case by quoting the reference number.

5. What is Partially Anonymous Whistle Blowing

If you choose to be partially anonymous, your personal details will be known only to the Whistle Blowing Contact Centre that manages the tip-off hotline. At no time are these details disclosed to the Bank or Group. If required, the Whistle Blowing Contact Centre will contact you to obtain further information.

6. What is Third Person Whistle Blowing

If you prefer for someone to blow the whistle on your behalf, your personal details will be known only to the person who made the report. However, this will be treated as anonymous whistle blowing by the bank and the relevant process in this policy will apply.

If you decide to speak up through a third person, you should provide all necessary information for the investigation.

You might be in a situation where you have knowledge of misconduct and would like to get more advice while considering whether you should blow the whistle. You could approach a senior officer in the bank, Compliance, or a Group manager. Be aware that they have an obligation to act in the best interest of the PSB and Group. If you give them information about misconduct involving the Bank or Group, they have an obligation to report it.

For truly independent advice, you could speak to a lawyer or private practice. They may give free confidential advice specifically on whistle-blowing.

However, you have an obligation to ensure that whoever you speak to keeps the matter strictly confidential and does not leak information to a third-party such as the media. If information is leaked outside of the Bank and Group before you have exhausted your options within the organisation, it will no longer be regarded as a protected disclosure.

A grievance shall be defined as any complaint, dissatisfaction, or concern which an employee may have in connection with his employment. A grievance excludes a disciplinary case already receiving the attention of management but includes any feeling of victimisation, feeling of injustice, concerns, or problems.

Reporting a grievance is outside the scope of this Whistle-Blowing policy and guidelines. For more information on this, please refer to MoMo PSB’s Grievance policy.

MoMo PSB is committed to investigating and addressing all cases of reported misconduct.

To this end, the whistle-blowing investigation procedures set out all the steps that should be followed upon receipt of the report. This procedure also sets out the roles and responsibilities of the Ethics Office, and that of others charged with investigation and follow-up.

All whistle-blower reports received using the channels prescribed within this policy are sent to the Ethics Office.

In general, the Ethics Office will not conduct detailed investigations but will rather direct and classify reports for distribution to the appropriate departments such as Forensic Services or Head of Internal Audit.

The whistle-blower may follow-up for information on the outcome of the investigation of the report. If the report was anonymous, the onus is on the whistle-blower to contact the whistle-blowing hotline and provide the unique identity number.

The Ethics Office will obtain all relevant data on the whistle-blowing from the Whistle Blowing Contact Centre, for the investigation. The Head of Internal Audit and/or Ethics Office (where appropriate) shall review the outcome of reported cases and recommend appropriate action to the CEO. Where the reported issues affect Executive Management, such issues shall be referred to the relevant Board Committee.

1. Whistle Blowing Investigation Procedures:
• Upon receipt of a report from the Bank or any source, the Whistle Blowing Contact Centre will establish a unique ID number for the source, and if reported by telephone, will inform the caller of the ID number. Reports from all other sources will be logged by date and time received and a brief description of the nature of the reported misconduct.
• The Ethics Office will review all reports and will determine if there are grounds to undertake an investigation.
• The Ethics Office will review all reports within 15 business days of receipt. They may further carry out a preliminary investigation, if enough information is given, to assess whether an investigation is appropriate and, if so, what form it should take. Concerns or allegations which fall within the scope of other procedures, will normally be referred for consideration under those procedures.
• If further information is required and the report was confidential rather than anonymous, the investigator will contact the whistle-blower for further information.
• The action taken will depend on the nature of the concern. The matter raised may, among other possible actions, be:
  • Investigated internally.
  • Referred to the Nigerian Police Force or other relevant law enforcement agencies.
  • Referred to the relevant Board Committee or Group Committee.
• Some concerns may be resolved by agreed action without the need for investigation. In cases where the Ethics Office determines that an investigation is not warranted, the whistle-blower, if their identity is known, will be informed.
• In cases where numerous unwarranted or malicious reports are received from one person, the Ethics Office, and the Whistle Blowing Contact Centre, acting upon instruction from the Ethics Office, may refuse to log reports for this person.
• Where the Ethics Office determines that retaliatory action has been taken against staff or others for disclosing information to, or cooperating with, investigators, these retaliatory actions will be investigated and reported for appropriate actions.
• Firm action will be taken against employees who make malicious reports, i.e., who knowingly provide false information or make false accusations.
• All investigations will respect the rights of individuals and will be conducted with fairness and due process for all concerned. Unauthorized disclosures by investigators of information received may constitute misconduct for which disciplinary measures may be imposed.
2. Follow-up and Reporting:
• The Bank recognises that employees require assurance that their concerns have been properly addressed. However, the progression of investigations will be handled in a confidential manner and will not be disclosed or discussed with any persons other than those who have a legitimate right to such information. This is important to avoid damaging the reputation of suspected persons who are subsequently found innocent of alleged wrongful conduct, as well as the person making the report.
• The Ethics Office will give an update on the status or outcome of an investigation to the whistle-blower, if requested, without disclosing confidential information. An anonymous caller should initiate such an inquiry, citing the unique reference number.
• The Ethics Office and Head of Internal Audit will periodically report to the relevant Governance Committees on the number of hotline reports made, the nature of the reported misconduct, and the result of the investigations.
• The Head of Internal Audit shall review reported cases from the Ethics Office and recommend appropriate actions based on the result of the investigations to the bank’s MD/CEO and where issues affect Executive Management, these will be referred to the relevant Board Committee. The Board or CEO shall take appropriate actions to redress the situation within a reasonable time.
• The Head of Internal Audit shall provide the Chairman of the Board Audit Committee with a summary of cases reported and the outcome of the investigations.

For the policy to be sustainable, the bank will support it with structured training, periodic communication, and awareness programme. It is the responsibility of all managers to ensure that all employees are made aware of the policy and receive appropriate training and education about it.

• The Bank is responsible for ensuring uniformity with the implementation of this policy. The PSB has overall responsibility for the maintenance and operation of this policy. The Bank is, in turn, assisted by the Ethics Office, deployed Compliance Officers, and Forensic Services in implementing the policy.
• Parties with whom a complaint has been logged will maintain a record of concerns raised and the outcomes (but in a format that does not compromise confidentiality).
• Advice and guidance on how matters of concern may be pursued can be obtained from the Ethics Office.

This policy has been developed to provide a framework to ensure compliance with the CBN Whistle Blowing Guidelines 2014, Banks and Other Financial Institutions Act 2020, the CBN Code of Corporate Governance for Banks and Discount Houses 2014, and other relevant laws or regulations that may be issued from time to time; but it does not serve as an exhaustive list of all issues covered within the law or regulation.

Toll-Free Hotline

• 0800-00-MoMoPSB (0800 00 6666-772)

Email

• MOMOPSB@deloitte.com.ng

Web Portal Link

• https://tip-offs.deloitte.com.ng/

Mobile App

• Deloitte Tip-Offs Anonymous App