Principles
SOGON in ensuring a high ethical standard in all its business activities has established a code of ethics which
set out the standard of conduct expected in the management of its businesses. All stakeholders and partners
are expected to comply with these standards in the discharge of their duties.
In furtherance of this, SOGON Whistleblowing Policy and Procedure provides a channel for the SOGON`s Staff
and other relevant stakeholders to raise concerns about workplace malpractices, confidentially; for SOGON
to investigate alleged malpractices and take steps to deal with such in a manner consistent with SOGON’s
policies and procedures and relevant regulations.
For this policy, whistleblowing is the act of reporting perceived unethical conduct of staff, executive
council/management, board of trustees, and other stakeholders by any staff or other persons to appropriate
authorities.
This policy and procedure manual outline SOGON`s Policy on whistleblowing and the procedure for
investigating and dealing with all reported cases of illegal and unethical conduct and any other misconduct
across the organization. This policy complies with the Federal Government of Nigeria’s Whistle-blowing
Policy launched on December 21, 2016.
Objectives of the Policy
This policy and procedure manual is intended to encourage staff and other relevant stakeholders to report
perceived unethical or illegal conduct of staff, executive council, management, board of trustees and other
stakeholders across the organization to appropriate authorities in a confidential manner without any fear of
harassment, intimidation, victimization or reprisal of anyone for raising concern(s) under this policy.
Specific objectives of the policy are:
a.To ensure all staff feel supported in speaking up in confidence and reporting matters they suspect
may involve improper, unethical or inappropriate conduct within the organization;
b.To encourage all improper, unethical or inappropriate behaviour to be identified and challenged at
all levels of the organization;
c.To provide clear procedures for reporting and handling such concern(s);
d.To proactively prevent and deter misconduct which could impact the financial performance and
damage SOGON`s reputation;
e.To provide assurance that all disclosures will be handled seriously, treated as confidential and
managed without fear of reprisal of any form; and
f.To help promote and develop a culture of openness, accountability and integrity.
Scope of the Policy
This policy and procedure manual is designed to enable staff and other relevant stakeholders to report any
perceived act of impropriety which should not be based on mere speculation, rumours and gossip but on
knowledge of facts. Reportable misconducts covered under this policy include:
∙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;
∙Actions detrimental to Health and Safety or the work environment;
∙Any form of criminal activity;
∙Connected transactions not disclosed or reported in line with regulations;
∙Insider abuse;
∙Non-disclosure of interests;
∙Sexual or physical abuse of staff, customers, prospective staff, service providers and other relevant
stakeholders; and
∙Improper conduct or unethical behaviour that undermines universal and core ethical values such as
integrity, respect, honesty, accountability and fairness;
∙Other forms of corporate governance breaches;
∙Attempt to conceal any of the aforementioned acts.
The above reportable misconducts or concerns are not exhaustive. However, judgment and discretion are
required to determine misconduct that should be reported under this policy. The general guide in identifying
reportable misconduct is to report concerns which are repugnant to the interest of SOGON and the general
public and appropriate sanctions applied.
This policy covers the activities of SOGON and all its implementation partners. The policy shall also be read
in conjunction with the whistleblowing guidelines that may be issued by funders or relevant regulatory
agencies with oversight of SOGON’s operations. This policy, however, does not cover individual staff
grievances and other employee-related matters already covered in SOGON’s staff handbook.
SOGON’s Commitment to the Policy
The Board and Executive Council of SOGON are aware that a robust internal system for staff and other
relevant stakeholders to disclose workplace malpractices without fear of reprisal shows that staff take their
responsibilities seriously, and also helps to avoid the negative publicity that often accompanies disclosures
to external parties. Hence the Board of Trustees and Executive Council are committed to promoting a culture
of openness, accountability and integrity, and will not tolerate any harassment, victimization or
discrimination of the whistleblower provided such disclosure is made in good faith with reasonable belief
that what is being reported is fact.
Policy Statement
SOGON is committed to the highest standards of openness, probity, accountability and high ethical behaviour
by helping to foster and maintain an environment where staff and other stakeholders can act appropriately,
without fear of reprisal. To maintain these standards, SOGON encourages employees and relevant
stakeholders who have material concerns about suspected misconduct or any breach or suspected breach of
law or regulation that may adversely impact SOGON, to come forward and report them through appropriate
channels (in certain cases on a confidential basis) without fear of retribution or unfair treatment.
SOGON conducts its business on the principles of fairness, honesty, openness, decency, integrity and respect.
This policy intends to encourage staff and other relevant stakeholders to report and disclose improper or
illegal practices or activities. SOGON is committed to investigating promptly any reported misconduct and to
protecting those who come forward to report such activities. SOGON further assures that all reports shall be
treated in strict confidence.
The SOGON`s operating procedures are intended to detect and prevent or deter improper activities.
However, the best systems of control may not provide absolute safeguards against irregularities. This policy
is intended to investigate and take appropriate action against any reported misconduct or concern.
Whistleblowing Procedure
The whistleblowing procedure involves steps that should be taken by the whistleblower in reporting
misconduct, and steps required for the investigation of the reported misconduct. The following procedures
shall guide the whistleblowing process:
a. Step One: Raising concern(s) by a whistleblower – medium and format.
An internal whistleblower may raise a concern through any of the following media (this can be done
either by declaration or in confidence/ anonymously):
. Formal letter to the Chairman or Secretary.
∙Dedicated email address:
sogonlagos2016@yahoo.com
Where the concern is received by staff other than the Chairman or Secretary, the recipient of such
concerns shall be required to;
∙Immediately pass the concern(s) to the Chairman or Secretary of SOGON.
∙If the concerns affect the Chairman or Secretary of SOGON, such concern shall be directed at
the Chairman Board of Trustees.
The concern(s) shall be presented in the following format;
∙Background of the concerns (with relevant dates)
∙Reason(s) why the whistleblower is particularly concerned about the situation.
Disciplinary measures in line with the staff handbook shall be taken against any staff that receives
concerns and fails to escalate. Also, disciplinary measures shall be taken against an internal
whistleblower who acted out of malice.
b.Step Two: Investigation of Concerns and update on the progress of the investigation.
On receipt of the concern(s), the Chairman or Secretary shall acknowledge receipt of the concern
from the whistleblower within 2 working days, and immediately commence an investigation. The
purposes of the investigation are to:
∙Establish if wrongdoing has occurred based on the concern(s) raised, and if so to what
extent; and
∙To minimize the risk of further wrongdoing, prevent any further loss of assets, or damage to
SOGON`s reputation and if possible protect all sources of evidence.
If the preliminary investigation shows that the concern falls within the whistleblowing reportable
concerns, then further investigation shall be carried out. If otherwise or the concern is outside the
reportable misconduct, then the Secretary on the directive of the Chairman shall refer the matter to
appropriate quarters for further action.
Where necessary the Secretary shall provide an update on the progress of the investigation to the
whistleblower if the concerns fall within the reportable concerns. However, if the concern raised by
the whistleblower is frivolous or unwarranted, the Secretary shall ignore such concern, and where
necessary disciplinary measures in line with Human Resources policy shall apply to the staff
involved.
c.Step Three: Report of Investigation and action on the report.
Upon conclusion of the investigation, the Secretary shall submit his/her report to the Chairman for
further action(s). Where necessary the Secretary shall escalate to the Board of Trustees. However,
Secretary shall submit quarterly reports to keep the Board of Trustees abreast of whistleblowing
developments with the approval of the Chairman.
All disciplinary action relating to the report shall follow SOGON`s disciplinary procedure as
contained in the staff handbook.
d.Step Four: Non-satisfaction with the result of the investigation/action
In the event that the whistleblower is not satisfied with the extent of the investigation and or the
action taken based on the outcome of the investigation, the whistleblower is at liberty to report to
the Chairman of the Board of Trustees.
The aforementioned whistleblowing procedure is, however, without prejudice to the fundamental
right of the whistleblower to seek redress in a court of law.
Time Limit for Investigation
It shall be SOGON’s policy to handle investigations promptly and as fairly as possible. While it might not be
possible to set a specified time frame for the conclusion of an investigation as the diverse nature of potential
concerns may make this impracticable, the Secretary shall endeavour to resolve all concerns within four
weeks. Where for any reason, a proper resolution is not achieved within this time frame; the Secretary shall
advise the Chairman accordingly, and report to the Board of Trustees.
Protection and Compensation for Whistleblowers
It shall be SOGON’s policy to protect whistleblowers who disclose concerns, provided the disclosure is made;
∙In the reasonable belief that it is intended to show malpractice or impropriety;
∙To an appropriate person or authority; and
∙In good faith without malice or mischief.
While all disclosures resulting from whistleblowing shall be treated with high confidentiality, staff and other
relevant stakeholders are encouraged to disclose their names to make the report more credible. However,
any anonymous report will also be reviewed.
SOGON shall consider unanimous disclosure based on:
∙The seriousness of the issues being reported;
∙The significance and credibility of the concern; and
∙The possibility of confirming the allegation.
SOGON shall not subject a whistleblower to any detriment. Where a whistleblower feels unfairly treated
owing to his/her actions, the whistleblower shall be at liberty to report to the Corporate Affairs Commission
and any other regulatory body with oversight of SOGON`s businesses. This is without prejudice to the right
to take appropriate legal action.
Where necessary, compensation of whistleblowers whether internal or external that have suffered detriment
shall be at the discretion of the Executive Council.
Any retaliation, including, but not limited to, any act of discrimination, reprisal, harassment, suspension,
dismissal, demotion, vengeance or any other occupational detriment, direct or indirect, recommended,
threatened or taken against a whistleblower because he/she has disclosed in accordance with this policy
will be treated as gross misconduct and dealt with accordingly.
Whistleblowers must ensure that they do not make disclosure outside of the prescribed channels (e.g.
media-print or electronic), or their disclosures may not be protected.
Ownership and Frequency of Review
This policy document remains the property of the SOGON Lagos Sector. However, its custody and
management shall rest with the Secretary of SOGON.
The policy would be made publicly available to allow all concerns of unethical behaviour to be reported by
both internal and external stakeholders.
This policy document and procedure manual shall be reviewed every two (2) years or as may be deemed
necessary. Once approved, all staff and trustees would receive training in the new policy.
All suggestions for review and or amendments shall be forwarded to the Secretary, SOGON Lagos Sector for
necessary action.
This whistleblowing policy document was approved on behalf of the Executive Council and Board of
Trustees of SOGON on Wednesday 31st May 2023
Signature:
Dr Kehinde Okunade
Secretary SOGON Lagos Sector
