What is Whistle blowing?

Whistle blowing is when a worker reports suspected wrongdoing at work. This is officially referred to as ‘making a disclosure in the public interest’.
A worker can report things that aren’t right, are illegal or if anyone at work is neglecting their duties, including

• Someone’s health and safety is in danger;
• Damage to the environment;
• A criminal offence;
• The company isn’t obeying the law (like not having the right insurance); and/or
• Covering up wrongdoing

EXPLANATORY FORWARD

GEMMININGCOMPANY is committed to the highest standards of ethics, honesty, openness and accountability. In line with this commitment and to enhance good Governance, transparency and safeguard the integrity of our institution, the Whistleblowing Policy and Procedure Manual is intended to provide:

(i)An avenue for raising concerns related to any illegal or unethical behavior such as fraud, corruption and other misconduct

(ii)Assurance that those who disclose such information will be adequately protected, and that action would be taken on the disclosure. The guiding principles of the policy emanate from the Bank of England Guidelines for Whistle-Blowing for Banks and Other Financial Institutions in the United Kingdom (Guidelines) which mandates Banks to establish adequate whistleblowing procedures and render quarterly returns to the Bank of England on all related breaches.
According to the intent of this policy, and in line with the Bank of England Guidelines, whistle-blowing is the reporting of alleged unethical conduct of employees, management, directors and other stakeholders by an employee or other person to appropriate authorities.

The Whistle-Blowing Policy aims to create a work environment where employees, vendors, service providers, customers and other stakeholders can raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or victimization and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated. Employees are internal whistle blowers who report incidents of misconduct in an organization involving a peer/colleague, a supervisor or indeed a top management official. External whistle-blowers who are mostly customers/suppliers report wrong doings of employees to the Chief Audit Executive, Chief Compliance Officer(CCO), Group Head, Internal Control and Enhancement Group(GH, ICEG)and/or the Managing Director/Chief Executive Officer respectively. All stakeholders (internal and external) are key and therefore expected to play a vital role in deterring and detecting malpractices, wrongdoing or irregularity while the Board and Management provides assurance to all whistleblowers that there will be no reprisal by way of harassment or victimization arising from blowing the whistle.

It is pertinent to note that this policy does not replace but complement the firm's approved internal control, policies and guidelines.

OBJECTIVES OF THE POLICY

This policy and procedure manual is designed to enable employees and other relevant stakeholders report acts of impropriety to appropriate authorities. The report should however not be based on mere speculation, rumors or gossip but on personal knowledge of verifiable facts or circumstances to indicate that the report able misconduct has occurred or likely to occur. All staff are protected from victimization, harassment or disciplinary action due to any disclosure, where the disclosure is made in good faith and is not made maliciously or for personal gain. Report able misconduct includes without limitation to the following:

• All forms of financial malpractices or impropriety such as fraud, corruption,bribery or theft.
• Any form of criminal activity.
• Improper conduct or unethical behavior; that undermines universal and core ethical values such as integrity, respect, honesty, accountability, fairness etc.
• Failure to comply with regulatory directives, administrative or internal policy framework
• Failure to comply with legal obligations or statutes.
• Other forms of corporate governance breaches : Connected transactions, Insider abuse, Non-disclosure of interest.
• Sexual or physical abuse of any staff, customer, applicant, service provider and other relevant stakeholders.
• Conduct translating to gross waste of resources.

Attempt to conceal any of the above listed acts.This policy impacts all employees of the company, regardless of grade, location or function and all staff are encouraged to report any misconduct(s) listed above when they occur.
The Policy is to be read in conjunction with other approved conduct-related policies in the Bank.