Whistleblowing Policy

Introduction and Scope

Covenant Microfinance Bank Ltd. (CMFB) is committed to the highest standards of accountability and transparency. To reinforce this commitment, CMFB has established a Whistleblowing Policy as a critical component of its fraud risk management framework.

This policy is aligned with best practices and guidelines from the Central Bank of Nigeria (CBN) and the Financial Reporting Council of Nigeria (FRCN). It enables employees and external stakeholders — including customers, suppliers, consultants, and partners — to report unethical, illegal, or improper conduct without fear of retaliation.

The policy applies to all employees of CMFB, regardless of position, location, or function, as well as to third parties who interact with the Bank.

Reportable Misconducts

The policy covers a wide range of misconducts and unethical behaviors, including but not limited to:

• Abuse of power, company assets, or resources.
• Bribery, corruption, or facilitation payments.
• Fraud, financial malpractice, or accounting impropriety.
• Failure to comply with legal obligations, statutes, or regulatory directives.
• Improper conduct, unethical behavior, or criminal activity.
• Violation of the Bank’s policies, procedures, or Code of Ethics.
• Threats to the Bank’s or stakeholders’ interests, including fraudulent or discriminatory practices.
• Sexual harassment, physical abuse, or workplace intimidation.

Whistleblowing Procedures

Whistle-blowers can report concerns through several dedicated channels, which can be done confidentially or anonymously. The procedure involves these steps:

• Reporting Channels: A whistle-blower can submit a formal letter to the MD/CEO, Head of Internal Audit, Chief Compliance Officer, or Head of HR/Admin. Concerns can also be reported via dedicated hotlines or the bank's official email and website.
• Reporting Format: The report should include the background and history of the concern with relevant dates, reasons for the concern, and any supporting evidence to aid the investigation.
• Responsibilities: Whistle-blowers are expected to act in good faith and provide verifiable facts, not mere speculation or rumors. They should also provide further evidence to assist in the investigation.

Protection of the Whistleblower

The policy is formulated to protect whistle-blowers who disclose information in good faith and with the reasonable belief that a malpractice or irregularity has occurred. The Bank will treat all disclosures confidentially, and the identity of the whistle-blower will be kept confidential. The policy strictly prohibits any form of retaliation against a staff member for reporting an irregularity. Penalties, including disciplinary measures, will be taken against any staff who takes retaliatory action.

Policy Updates and Review

The Chief Compliance Officer is responsible for keeping the Board informed about whistle-blowing updates. The policy is subject to review every three years or as needed based on changes in the regulatory environment or best practices. All suggested amendments must be sent to the Chief Compliance Officer, and the Board has the authority to approve these updates.

The current version of the policy, approved in 2024, is version 1.0.