WHISTLE BLOWING PROCEDURE
Background
The National Pension Commission (“the Commission”) as part of its effort to engender transparency, issued guidelines on Whistle Blowing to provide direction on the process by which information that is ultimately in the interest of the Company and its stakeholders can be disclosed to the appropriate person(s), body or organization.
What is Whistle blowing?
Whistle blowing entails reporting of incidents of misconduct involving or affecting an organization to enable the organization take appropriate measures to deal with such incidents or their eventual outcome. An effective whistle blowing procedure is regarded as a key element of good corporate governance. The purpose of whistle blowing program is to encourage employees to disclose any malpractices or misconduct.
Objectives of the Policy
The objectives of this policy are;
 To support our corporate philosophy.
 To encourage employees to confidently raise concerns about unethical violation of the company’s policies and breach of professional codes of conduct.
 To reassure the whistle blower that he/she will be protected from possible reprisals or victimization if a disclosure has been made in good faith.
 To provide a transparent process for dealing with concerns (i.e. grievance or report of a suspected breach of law or company policy).
 To regularly communicate to members of staff the avenues open to them for the purpose of whistle blowing.

Scope of the Policy
This whistle blowing policy applies to all employees of FGPL and any other person who provides service to the company including contractors, consultants, vendors etc.
Who should blow the whistle?
Section 80 of the Pension Reform Act (PRA) 2014, obliges the Compliance Officers to report to the Commission, any breach of the Pension Reform Act 2014, codes, guidelines, rules and regulations issued by the Commission, in the course of the company’s business.
The directors, management, employees, and any other person(s) that have dealings with the PFA/PFC shall also have the responsibility to report breaches to the Commission.
All employees and other relevant stakeholders are also encouraged to raise genuine concerns about misconduct, malpractices and unethical behavior at the earliest opportunity in an appropriate way.

When should I blow the whistle?
A Whistle Blower should report breaches that are of material significance to Management or the Commission. For the purpose of this subject, a breach is considered materially significant in the following circumstances:
 Fraud, which means any act or omission, including a misrepresentation, that knowingly and recklessly misleads or attempts to mislead, a party to obtain financial or other benefit or avoid an obligation.
 Misconduct, which means failure of the company personnel to observe the Company’s codes of conduct.
 Acts of dishonesty including bribery and other corrupt practices by company’s management
 Diversion/misappropriation of pension assets under management
 Failure to pay retirement benefits correctly or promptly
 Acting or failing to act in the face of a deliberate contravention of the law, regulations, guidelines and rules issued by the Commission
 Cases of bullying, physical/sexual harassment and those concerning dignity at work.
 Poor corporate governance.
 Inadequate controls resulting in deficient administration
 General malpractices such as immoral, illegal or unethical conduct (including where someone’s health and safety has been put in danger.
 Collusive practices, which mean an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
 Any act that might impact negatively or adversely on the functions of the Commission or that can result in the loss of public confidence in the Nigerian pension industry.
How is a Whistle Blower protected?
The Commission shall seek to protect the identity of a whistle blower even in the course of an investigation, resulting from the report.
As required by the Whistle Blowing guidelines, FGPL has undertaken to write to that in the event of any of its employees blowing the whistle on its unethical or illegal operations or activities, such employee shall not be victimized.
The Commission is also obliged to employ appropriate regulatory tools to offer redress to an employee who is victimized for blowing the whistle.
Any staff member who reports an irregularity, provided that this is done in good faith and in compliance with the provisions of this policy, shall be protected against any acts of retaliation.
For the purpose of this policy, ‘retaliation’ is defined as any action or threat of action which is unjustly detrimental to the whistleblower because of his/her report, including, but not limited to harassment, discrimination and acts of vindictiveness, direct or indirect, that are recommended, threatened or taken against the whistle blower.
Specifically, where the whistle blower is an employee, the following shall apply to protect the whistle blower;
a) No PFA/PFC shall dismiss, suspend or terminate the appointment of a whistle blower without the prior consent of the Commission.

b) No PFA/PFC shall demote or redeploy a whistle blower without the consent of the Commission.

c) In case of the (a) and (b) above, the PFA/PFC shall provide the Commission with solid reasons for its proposed actions.

d) The PFA/PFC shall not in any way deny a whistle blower his/her entitlements in terms of promotions, salary increases, trainings and opportunities.

e) Any salary review or incentive that will affect the whistle blower negatively shall be referred to the Commission for approval, before implementation.

f) The whistle blower shall have the right to make to the Commission, any complaint, in writing against his/her employer, as he/she may deem necessary.

g) Where the Commission finds violations against the whistle blower, by the PFA/PFC it shall issue a letter of caution and direct the PFA/PFC to retract whatever actions taken.

Procedure for Whistle Blowing
A whistle blowing report shall be done in writing with minimum narrations good enough to explain the situation of concern. The whistle blower may also contact appropriate officers of FGPL or the Commission.
The following reporting channels are available for the Whistle Blower:
i. Dedicated Telephone number that can be used by both staff of FGPL and other concerned stakeholders to report breaches and/or make suggestions. Telephone; 01-2715510
ii. A dedicated e-mail address: whistleblower@firstguaranteepension.com
The e-mail box is administered by the Head Compliance. Incident Report is sent to the Managing Director based on reported issue.

iii. A link is created on the company website to upload information by staff of FGPL and other concerned stakeholders
iv. A suggestion box is provided where both staff of FGPL and other concerned stakeholders can report breaches and/or make suggestions.
In all these channels, the whistle blower has the option of indicating his/her name and other personal details or remains anonymous.
v. Letters can be sent directly to:
The Director General
National Pension Commission
No. 174 Adetokunbo Ademola Crescent, Wuse II
PMB 5170 Wuse II
Abuja

• Though a whistle blower can report an incident on an anonymously basis, the whistle blower is encouraged to put his/her name on the allegations made as concerns expressed anonymously may be considered at the discretion of the Commission
• While the whistle blower shall not be expected to prove the truth of an allegation, he/she shall need to demonstrate that there are sufficient grounds for the concern.
• The Commission shall take into account the seriousness of the issues raised, the credibility of the whistle blower, and the possibility of confirming the allegation from credible sources
• If an allegation is made in good faith, but it is not confirmed by the investigation, no action shall be taken against the whistle blower. If however, the whistle blower made allegations that were malicious or simply to cause anger, irritation or distress, disciplinary action may be taken against the whistle blower.
• Stakeholders who are unsure about whether to use this policy and procedure or require independent advice at any stage may contact appropriate officers of the Commission or FGPL.
Update and Review: This procedure shall be updated as the need arises.