Whistle Blower

PREMIUM PENSIONS LIMITED – WHISTLE BLOWING POLICY & PROCEDURE

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.

In furtherance of this, PPL Whistleblowing Policy and Procedure provides a channel for the Company`s employees and other relevant stakeholders to raise concerns about workplace malpractices, in a confidential manner; for the Company to investigate alleged malpractices and take steps to deal with such in a manner consistent with the Company’s policies and procedures and relevant regulations.

Section 68 of the Pension Reform Act (PRA) 2014, obliges the Compliance Officer of Premium Pension Limited 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 (contractors, service providers, analysts, consultant, job applicants, and the general public) with PPL, shall also have the responsibility to report breaches to the Commission.

A whistle blower should report any perceived act of impropriety which should not be based on mere speculation, rumour and gossip but on knowledge of facts and breaches that are of material significance to the Commission. For the purpose of this subject, a breach is considered materially significant in the following circumstances:

  • All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment
  • Failure to comply with legal obligations, statutes, and regulatory directives, rules and guidelines issued by the commission
  • Failure to pay retirement benefits correctly and promptly
  • Improper conduct or unethical behaviour that undermines universal and core ethical values such as integrity, respect, honesty, accountability and fairness
  • Connected transactions not disclosed or reported in line with regulations
  • Sexual or physical abuse of staff, customers, prospective staff, service providers and other relevant stakeholders
  • Diversion/misappropriation of Pension assets under management
  • 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 Nigeria pension industry

As required by the Whistle Blowing guidelines, It shall be the policy of the Company to protect whistle blowers and shall be treated with high level of confidentiality. The Company shall not subject a whistle blower to any undue victimisation.

Where a whistle blower feels unfairly treated owing to his/her actions, the whistle blower shall be at liberty to report to the Commission and any other regulatory body with oversight on the Company's business. This is without prejudice to the right to take appropriate legal action.

The Commission is also obliged to employ appropriate regulatory tools to offer redress to an employee who is victimised for blowing the whistle.

1. 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 PPL or the Commission, through the reporting lines below;

2. Where the concern is received by staff other than the MD/CEO or the Head of Internal Audit, the recipient of such concerns shall be required to:

  • Immediately pass the concern(s) to the Head of Internal Audit with copy to the MD, PPL
  • If the concerns affect the Head of Internal Audit, the MD/CEO of PPL shall be notified; and
  • where a Director/MD is involved, such concern shall be directed at the Chairman Board Audit Committee. The concern(s) shall be presented in the following format:

i. Background of the concerns (with relevant dates)
ii. Reason(s) why the whistle blower is particularly concerned about the situation

3. A suggestion box is provided at each of our regional offices including the Head office where both staff of PPL and other concerned Stakeholders can report breaches and/or make suggestions.

4. Letters can be sent directly to:

The Director General
National Pension Commission
Plot 174 Adetokunbo Ademola Crescent
Wuse II

5. The Head of Internal Audit shall on receipt of the concern(s) acknowledge receipt of the concern from the whistle blower within 5 working days, and immediately commence investigation

6. Upon conclusion of investigation, the Head of Internal Audit shall submit his/her report to the Human Resources or the appropriate authority for further action(s). Where necessary the Head of Internal Audit shall escalate to the Managing Director.

7. In the event that the whistle blower is not satisfied with the extent of investigation and or the action taken based on the outcome of the investigation, the whistle blower is at liberty to report to the ED of his/her Directorate; if still not satisfied, report to the MD/CEO and if he/she is still not satisfied, report to the Chairman of the Board Audit Committee for further action.

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