This policy is introduced in furtherance of the aim of improving corporate governance in PAL Pensions. It is also aimed at fulfilling part of the requirements of PENCOM’s code of corporate governance. Whistle-blowing enables an organization to obtain early warning signals on what may be going wrong in the organization, especially in cases where it would be difficult to use formal communication channels. This is important where the issues involved are very sensitive and would require the confidentiality of the whistle blower. In other words, whistle-blowing is a confidential channel open to all the stakeholders of our PFA to report any wrong doing to the management and board of PAL Pensions.
2) What should be reported?
2.1 Fraudulent activities
2.2 Illegal activities
2.3 Bribery and corruption
2.4 Gross misuse of assets including information asset
2.5 Conflict of interest and abuse of office on the part of any staff or director
2.6 Activities likely to endanger life or property
2.7 Insider dealings
2.8 Use of fake/forged certificates
2.9 Theft/leakage of information assets
2.10 Purchase of goods at inflated prices
2.11 Purchase of inferior goods
2.12 Concealment of any malpractice
2.13 Override of controls resulting in deficient administration
2.14 Abuse of authority
2.15 Sexual harassment
2.16 Failing to act in accordance to regulations, guidelines and rules issued by the Commission
2.17 Other unethical activities
3) Who should report?
3.1 The Compliance officer
3.5 Vendors and service providers
3.6 Any other person(s) that have dealings with PAL Pensions PFA /UBA PFC
4) Procedure for making whistle-blowing reports
4.1 Whistle-blowing reports should be made using the Deloitte Ethics Line. The telephone lines and email address are given below:
Breaches could also be reported through the compliance officer or directly to the Commission – PENCOM.
4.2 The following procedure should apply for all telephone reports.
4.3 Reports sent through e-mail address
If you desire, Deloitte will give you feedback if you call back (for reports via phone) or through your email address (for reports sent via email)
5) Protection for whistle-blower
6) Obligation of the whistle-blower
In making whistle-blowing reports, the whistle-blower should ensure that:
6.1 The report is made in good faith
6.2 He or she has reasonable ground to believe that the report is true. The whistle-blower is encouraged to report even if he or she does not have all the relevant information.
6.3 He or she is not making the report for personal gain.
6.4 Reports should be made timely.
6.5 Although the whistle blower shall not be expected to prove the truth of an allegation, he/she shall need to demonstrate that there are sufficient grounds for the concern.
7) What happens after the report?
7.1 The issues will be thoroughly investigated, using all available evidence. The whistle-blower may be called upon, if the report is not anonymous, to provide in strict confidence any available evidence necessary to confirm all the issues raised in the report.
7.2 Regular feedback will be provided to the whistle-blower if he or she calls back for feedback. If the report is through an email address, feedback will be provided by Deloitte using that same email address
7.3 Where the allegations are confirmed, PAL Pensions will take necessary disciplinary measures against identified offenders in line with the company’s policy. Where injuries have been suffered by the whistle-blower, PAL Pensions undertakes to provide necessary remedies as may be permitted by the Company’s policy.