Union Bank is dedicated to upholding the highest standards of integrity, transparency, accountability, and ethical conduct across all its operations.
The Bank actively encourages employees, customers, vendors, contractors, shareholders, and other stakeholders to report any suspected misconduct, unethical behaviour, regulatory violations, fraud, corruption, financial irregularities, or activities that may negatively impact the Bank, its customers, or the broader financial system.
The Bank maintains a strict zero-tolerance stance on retaliation and is committed to protecting any individual who, in good faith, reports a genuine concern.
Purpose of the Policy
This Whistleblowing Policy is established to:
- Provide a secure, confidential, and accessible mechanism for the reporting of concerns;
- Encourage the timely and proactive reporting of suspected misconduct or irregularities;
- Safeguard whistleblowers against any form of retaliation or victimisation;
- Ensure that all reported concerns are properly evaluated, investigated, and resolved in a fair and consistent manner
- Foster a culture of openness, accountability, and ethical conduct across the Bank.
Scope of the Policy
This Policy applies to:
- Employees (FTEs and Non-FTEs)
- Directors;
- Management;
- Contractors
- Consultants;
- Vendors and service providers;
- Customers;
- Shareholders;
- Other stakeholders.
The following activities are covered by this policy:
- All forms of financial malpractice, impropriety, fraud, including money laundering and other malpractices.
- Any form of criminal activity.
- Corporate governance breaches.
- Insider abuses.
- Non-disclosure of interests.
- Miscarriage of justice.
- Breaches and abuses of the Bank’s policies.
- Deliberate concealment or attempt to conceal any malpractice.
- Falsification of records. (use of false certificates, false declaration of age, etc.).
- Misconduct on the part of members of staff.
- Actions detrimental to Health and Safety or the environment.
- Bribery and corruption.
- Abuse of authority.
- Sexual or physical abuse of any staff, customer, applicant, service provider and other relevant stakeholders.
- Direct or indirect or veiled coercion to do/aid an abnormal job or inappropriate activity.
- Unprofessional conduct.
- Acts likely to tarnish the image of the Bank.
- Leakage of confidential data.
- Insider abuses such as cases of bullying, physical/sexual harassment and those concerning dignity at work.
- Any other activity which undermines the Bank’s operations and corporate values.
- Attempts to conceal any of the above.
Reporting Channels
Concerns may be reported through the following channels:
- Hotlines: 0800TIPOFFS (0800 847 6337)
- Web Portal: https://tip-offs.deloitte.com.ng/
- E-mail: tip-offs@deloitte.com.ng
- Bank’s Intranet portal (strictly for employees https://tip-offs.deloitte.com.ng/ )
The Bank is committed to maintaining the confidentiality of whistleblowers. All information relating to a report, including the identity of the whistleblower, shall be restricted to authorised personnel and disclosed strictly on a need-to-know basis.
Protection Against Retaliation
The Bank prohibits retaliation against any person who:
- Raises a concern in good faith;
- Participates in an investigation;
- Provides information relating to a whistleblowing report.
- Retaliation includes, but is not limited to:
- Dismissal;
- Unfair treatment;
- Harassment;
- Intimidation;
- Discrimination;
- Adverse employment actions.
Any person found to have retaliated against a whistleblower will be subject to disciplinary action.
False or Malicious Reports
A stakeholder’s right to protection under this policy does not extend to immunity for any complicity in the matters that are the subject of the report or an ensuing investigation or for reports made maliciously. If it is discovered that an individual has raised a concern falsely, maliciously or with a view to personal gain, such an individual will lose the protection provided under the Policy.
In this circumstance, if the individual is an employee of the Bank, the person’s actions will constitute misconduct, and the matter will be dealt in accordance with the Bank’s disciplinary procedures.
Additionally, the Bank reserves the right to take legal action against staff members who are known to have disclosed information outside of this Policy in an unjustified manner. Where the person is a third-party stakeholder, the Bank reserves the right to terminate the relationship forthwith.
Regulatory Reporting
Where required, matters arising from whistleblowing reports may be escalated to relevant regulatory, law enforcement or statutory authorities in accordance with applicable laws and regulations.
Commitment Statement
Union Bank is committed to fostering an environment in which concerns can be raised without fear of reprisal, and where principles of integrity, accountability, and responsible banking practices are consistently upheld.
Report concerns. See something , Say Something , Do something and Tell someone.
