Policy & Procedure

Whistle-blowing

BACKGROUND

• The aim of the CWIDI Whistleblowing policy is to encourage staff to assist in tackling fraud, corruption, unacceptable or unlawful conduct, and other malpractice. This Whistle-blowing policy is intended to encourage and allow serious concerns to be raised within the organization rather than overlooking a problem or ‘blowing the whistle’ outside.

For the purposes of this policy, the following are some examples of reasons for raising concern through the procedures set out in the policy:
(i) Fraud or corruption including offering, taking, or asking for bribes.
(ii) Breach of a legal or regulatory obligation (e.g., Data Protection, Fundraising rules)

(iii) Safeguarding
(ii) Dishonesty, unacceptable conduct, or other irregularities in dealing with customers and suppliers
(iii)Conduct which endangers the safety of any individual. (v) Breach of a contract or of a CWIDI policy(vi) Negligence
(vii) Deliberate covering up of evidence that shows any of the above has occurred.

POLICY

We strongly encourage staff to make the appropriate person aware of any concerns. That person will then be responsible for investigating the matter.

1. Who does this policy apply to?
This policy applies to all staff, contractors, and contact staff, including volunteers.

2. Procedure for Reporting

The individual should initially raise the matter with their line manager.

If for a specific reason, the individual(s) is unable to raise their concern with their manager, then they should speak or write to the Board secretary using the following emails and contact details: Mrs. Ginika Iloh +234(7062638128) email: ginika@concernwomen.org.ng

• Concerns may be raised verbally or in writing. We would encourage staff to give us as much detailed information about the concern as possible including details of how it came to their attention and any evidence they have. Including the name of the reporter i.e. putting your name to your allegation.

• Any concern that is raised with CWIDI will be investigated.

• For anonymous reporting, the individual should raise the concern with the board chairman using the following email and contact details: Mrs. Ginika Iloh: +234(7062638128) email: ginika@concernwomen.org.ng

• without putting his or her name.

• Where further action is required under this policy in relation to an
employee’s complaint, this will typically, in the first instance, take the form of an internal investigation. The internal investigator will be a Director, the Executive Director, or a trustee (as appropriate on a case-by-case basis). However, CWIDI may instead decide to arrange for a suitably qualified independent professional to undertake the investigation.

• During the investigation, the employee who reported the disclosure may need to be called upon for an interview. They will also be given appropriate updates on progress made during the investigation, whilst bearing in mind the need to respect the confidentiality of other workers as well. Once the investigation is complete:
–  The employee will be given a prompt and thorough explanation about the result of the investigation and any action CWIDI is likely to take as a result of it.
–   Where the allegation is deemed to be of a serious nature, an appropriate report will be submitted to the Board of Trustees.
–  Any action that the investigator decides is required will be taken.
–  If you genuinely believe that there is an issue that needs to be investigated and concern is raised in line with this policy, CWIDI will take action to ensure that they are protected from any victimization or harassment arising as a result, in line with the Anti-harassment and bullying policy. This will be the case even if the concern raised cannot be proven or does not prove to be well-founded.
investigated.

Although you are not expected to prove beyond doubt the truth of an allegation, you will need to demonstrate to the person contacted that there are reasonable grounds for your concern.

However, if a concern is raised that is known to be false, frivolous, or malicious, disciplinary action may be taken.

• As part of our commitment to encouraging employees to speak out if they have concerns, disciplinary action may also be taken against anyone who:
– victimizes or harasses any person as a result of that person genuinely raising concern under this policy, or
– deters or attempts to deter any person from genuinely raising a concern under this policy.

3. Protection and support for whistleblowers

It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising concerns. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should raise it formally using our Grievance Procedure.

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct, you may be subject to disciplinary action. [In some cases, the whistleblower could have a right to sue you personally for compensation in an employment.