Principles
SOGON is committed to the prevention of fraud, corruption, bribery and any other forms of dishonesty and
will promote an anti-fraud, corruption and bribery culture. It is our policy to conduct all our business
honestly and ethically. We take a zero-tolerance approach to fraud, bribery and corruption. We are
committed to acting professionally, fairly and with integrity in all our business dealings and relationships
wherever we operate, implementing, and enforcing effective systems to counter fraud, corruption and
bribery.
Policy Statement
This Policy applies to the conduct of all staff, the SOGON Board of Trustees (Board), Council and Committees.
It also applies to volunteers, consultants, associates or agents of SOGON and any third party acting on its
behalf, which includes fixed-term staff, contractors, seconded staff, sponsors, or any other person associated
with SOGON, wherever they may be located (collectively referred to as ‘Staff’ in this Policy).
SOGON will investigate all suspicions of fraud, corruption and bribery committed by Staff, suppliers and
other third parties. SOGON requires all Staff to act honestly and with integrity at all times; and to report all
suspicions of fraud, corruption and bribery.
Applicable Anti-fraud, Bribery and Corruption Laws
SOGON will uphold all laws relevant to countering fraud, corruption and bribery in all the jurisdictions in
which we operate. However, we remain bound by both International and Nigerian laws including the United
Nations International Convention against Corruption 2004; African Union Anti-corruption Convention 2006;
Money Laundering (Prohibition) (Amendment) Act 2012; Fiscal Responsibilities Act 2010; Advance Fee
Fraud and Other Related Offences Act 2006; Independent Corrupt Practices and Other Related Offences Act
2000 (ICPC); and the Economic and Financial Crimes Commission Act 2004 (EFCC), in respect of our
conduct at home and abroad.
We take our legal responsibilities very seriously and will adhere strictly to specific rules that cover
facilitation payments (e.g. accepting bribes/gifts and making bribes) in Nigeria such as the Independent
Corrupt Practices and Other Related Offences Act 2000 (ICPC) and the Economic and Financial Crimes
Commission Act 2004 (EFCC).
Definitions
- Fraud – A deliberate intent to acquire money or goods dishonestly through the falsification of
records or documents. The deliberate changing of financial statements or other records by a Staff or
supplier of SOGON.
Bribery – Is the offering, promising, giving, accepting or soliciting of an advantage as an inducement
for action that is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or
provided to gain any commercial, contractual, regulatory or personal advantage.
- Corruption – Is an act of dishonesty or criminal offence committed by a person or organisation
entrusted with a position of authority, to acquire illicit benefits or abuse power for private gain.
Corruption may include many activities including bribery and embezzlement, though it may also
involve practices that are legal in many countries.
- Theft – Dishonestly acquiring, using or disposing of physical or intellectual property belonging to
SOGON or its beneficiaries.
- Facilitation of payments – Small bribes paid to speed up service are sometimes called facilitation
payments. Some organisations work in areas where such payments are the norm in the local culture,
often where the charitable need is extreme. Notwithstanding the small amounts usually involved,
they are still bribery payments and therefore, constitutes an unacceptable use of SOGON funds. The
one exception is when a local supplier does not have a bank account, and payment in cash is
unavoidable. In this instance, Staff must follow the SOGON Cash Procedure before making payment.
Responsibilities
Concerning the prevention of fraud, theft and abuse of position, specific responsibilities are as follows:
∙Ultimate responsibility for this Policy rests with the SOGON Executive Council to whom all enquiries
may be directed. The Council is responsible for periodically reviewing this Policy as required. In
producing this Policy due regard has been given to the provisions of the United Nation’s Universal
Declaration of Human Rights and this Policy complies with those provisions.
∙The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for SOGON or under its control. All Staff or agents of SOGON are
required to avoid any activity that might lead to, or suggest, a breach of this Policy.
∙Any Staff of SOGON who breach this Policy will face disciplinary action, which could result in
dismissal for gross misconduct. SOGON may also pursue criminal prosecution. SOGON reserves the
right to terminate any contractual relationship with consultants, associates, agents or contractors if
they breach this Policy.
∙The responsibility for the initial training and ongoing staff monitoring in relation to this Policy lies
with the Chairman and Secretary of SOGON with staff responsibilities. They are responsible for
establishing and maintaining a sound system of internal control that supports the achievement of
SOGON’s policies, aims and objectives.
∙The system of internal control is designed to respond to and manage the whole range of risks that
SOGON faces. The system of internal control is based on a continuous process designed to identify
the principal risks, evaluate the nature and extent of those risks and manage them effectively. This
includes:
oEstablishing appropriate mechanisms for reporting fraud risk issues and significant incidents
of fraud to the Board;
oMaking sure that all employed staff are aware of SOGON’s Anti-Fraud, Bribery and
Corruption and know what their responsibilities are in relation to combating fraud;
oEnsuring that appropriate anti-fraud training is made available to the Board, Executive
Council and Staff, as required;
oEnsuring that appropriate action is taken to minimise the risk of previous frauds occurring in
future.
Reporting Suspicions
It is often through the alertness of Staff and the general public that raise suspicions of the possibility of
fraud, bribery and financial irregularity.
All concerns must be reported immediately to the Secretary. The Chairman must be notified immediately by
the Secretary of all financial or accounting irregularities, or of any circumstances that may suggest the
possibility of irregularities.
If a member of the public has suspicions or evidence of fraud, bribery or corruption; please let us know by
contacting us:
By email: sogonlagos2016@yahoo.com
By post: Department of Obstetrics and Gynaecology, College of Medicine, University of Lagos, PMB 12003,
Lagos, Nigeria.
If you do not want to contact us directly, you can report independently to the Independent Corrupt Practices
& Other Related Offences Commission Hotline.
By phone: 0803-123-0280, 0803-123-0281, 0803-123-0282, 0705-699-0190, 0705-699-0191
Online: https://icpc.gov.ng/petition-submission/
Response Plan and Disciplinary Process
The SOGON Chairman will:
∙Facilitate a proper investigation by experienced staff and ensure the consistent treatment of
information regarding fraud and corruption, whilst having regard to the requirements of Data
Protection legislation.
∙When so notified, instigate an investigation by appointing a designated officer, auditor or other
adviser.
∙Work closely with the Executive Council of SOGON and other agencies, such as the Police to ensure
that all issues are properly investigated and reported.
∙Ensure malicious accusations are considered for disciplinary action.
∙In all cases of proven fraud, corruption or bribery, discipline must follow a fair procedure.
∙Decide that a warning is warranted, then the affected Staff shall be issued the appropriate warning
with reasons and with a witness present.
∙Set up a Disciplinary Committee comprising three (3) Executive Council members who shall consider
any evidence, mitigating circumstances, and documentation before deciding what the appropriate
sanction shall be.
∙Depending on the severity of the outcome of the Disciplinary Hearing, sanctions may include
immediate termination of employment or contractual agreement OR case referral to the Police and
Courts to ensure that all issues are properly investigated and punishment issued in accordance with
the laid down laws of the country.
∙Ensure maximum recoveries are made on behalf of SOGON.
Review
This Policy will be reviewed every two years by the Executive Council, which will ensure it reflects any
changes in best practice and legislation. Correct or remove any misleading or false content as quickly as
possible.
Once approved, all staff and trustees would receive training in the new Anti-fraud, Bribery and Corruption
Policy of SOGON.
Approved on behalf of the Executive Council and Board of Trustees of SOGON on Wednesday 30th May 2023
Signature:
Dr Kehinde Okunade
Secretary SOGON Lagos Sector
