Vitafoam Nigeria Plc is committed to upholding highest ethical and moral standard in the conduct of her business and in all dealings amongst employees and with all persons, corporate or individual dealing with the company or any of her employees in the course of business. This policy therefore aims to instill a culture of abhorrence of unethical practices by creating procedures for employees for to raise concerns in relation to the operation of the business of the company, report any malpractice, illegal acts or omissions by employees, and to provide an assurance to the complainant that he shall be protected from reprisals and victimization for exposing wrong doing by other employees in good faith.
Objective of the Policy
The aim of this policy is to eradicate all forms of inappropriate conducts fraudulent acts and unethical practices within the company and in our dealings and relationship with outsiders, shareholders and other stakeholders.
Application of the Policy
This policy shall apply to all employees of the Company and to outsiders who by any form of inducement or solicitation encouraged or acquiesced in the perpetration of inappropriate or unethical practices whether for benefit or not with the aim of compromising internal processes.
Procedures for raising Complaints (whistle blowing) by Employees
1. Any information or complaints on fraudulent acts and unethical practices may be made directly by any employee(s) to any member of the Whistle Blowing Committee of Vitafoam Nigeria plc (VNPLC) or by a letter with the name of the Complainant and left in any designated box marked “Tell Me Box” at the Company’s Head Office at 140, Oba Akran Avenue, Ikeja, its Distribution Centre at 78, Oba Akran Avenue, Ikeja, its factories at No. 4, Industry Road Aba, 13A, Mai Malari Road, Bompai Industrial Area, Kano and Plot 35, Anglo- Jos Industrial Estate, Buruku Road, Jos.
In the alternative, information or complaints may be sent by e-mail from a named and identifiable account to @ng.xxxx.com. Anonymous complaints may not receive any feedback from the Committee.
2. The information or complaint shall contain the following:
a. A brief narration of background or history of the subject matter;
b. Name(s) of person(s) involved in the actions which necessitated the complaint, the relevant date(s) of the events forming the subject matter of the complaint and place(s) where the wrong doing occurred;
c. Any witness or other useful information that can assist members of the Committee in the investigation;
d. How long the employee has been involved in this fraudulent act or unethical practices
e. A suggested remedy for the wrong doing in order to prevent future occurrences (This is optional)
3. The complainant is not required to prove beyond reasonable doubt the truth of his allegation. However, to discourage frivolous and vexatious complaints, there is need for the complainant to show that there are sufficient grounds for raising the concern and that having regard to the circumstances and facts available to him, there exist reasonable grounds for suspicion of fraud, wrong doing or mischief.
Whistle Blowing Committee
The Whistle Blowing Committee (Committee) is made up of the following employees of the Company:
a. The Group Managing Director
b. The Group Technical & Development Director
c. Group Head, Admin & Legal Services
Three members of the Committee including the GMD or GTDD shall form a quorum for its meeting.
Hearing of Complaints
Upon receipt of a complaint via any of the designated channels, the Committee shall within 72 hours acknowledge receipt of the complaint or information vide the same channel through which the information was received. Complaints shall be investigated and decided by the Committee which shall meet to decide if a prima facie case has been established by the complaint. If in the opinion of the Committee, a prima facie case has been established, the Committee may request for better particulars of the complaint if they have not been provided or if the information in the written complaint is insufficient.
Upon the completion of the investigation by the Committee, the Committee may take any of the following steps:
a. Dismiss the complaint for lacking merit
b. Satisfactorily explain the events which gave rise to the complaint
c. Initiate disciplinary action against the persons involved in the wrongdoing in line with the company disciplinary guidelines, to prevent a recurrence of the wrongdoing, or to abate the wrongdoing if it is ongoing
d. Where the complaint is in relation to an employment or labour issue, the Committee may call a meeting between the representatives of the Union and the HHR.
e. Recommend the nature of disciplinary action to be taken against persons named in the complaint, if necessary
f. Refer the complaint to the police if it borders on crime; the Economic and Financial Crimes Commission or the Independent Corrupt Practices Commission, if the complaint borders on fraud or financial crimes
g. Refer the complaint to other appropriate law enforcement agencies or regulatory bodies.
The Committee shall make known to the complainant its findings and the steps it has taken in respect of every complaint provided the complainant has stated his/her name and lodged the complaint through any of the proper channels as stipulated above.
If a complaint is not confirmed by the investigation, provided the complaint was made in good faith, no disciplinary action shall be taken against the employee. If however, it is discovered during or after the investigation that the complaint is malicious, frivolous, vexatious or brought in bad faith, the complainant shall be subject to disciplinary actions.
If after the investigation, the complaint does not establish any case against the persons named therein, the matter shall be taken as completed for all intent and purposes and the complaint file closed. An employee shall not raise the complaint again based on the same sets of facts, unless new evidence is furnished in support of the complaint in which case the complaint will have to be presented as a new and independent claim in accordance with Clauses 4 or 5 above.
All complaints raised in line with this policy shall be treated with utmost confidentiality. The complainant shall neither be named nor his identity revealed to the persons being investigated based on the complaint or to any other employee. The complainant may however, be called in during the interrogation of the person(s) named in the complaint to testify or resolve any grey areas of the investigation.
Implementation and Monitoring
All Line Managers and members of Committee shall be responsible for educating and providing clarification to staff on this policy.