Whistleblowing policy

Nassure Microinsurance Nigeria Ltd (“the company”) is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all its operations. This whistleblowing policy is designed to encourage and enable employees, stakeholders, and third parties to report any concerns or suspicions of malpractice, unethical behaviour, or any form of wrongdoing within the company without fear of retaliation.

The purpose of this policy is to:

• Promote a culture of openness and accountability.
• Provide a safe and confidential avenue for reporting concerns.
• Ensure that reported concerns are addressed in a timely and appropriate manner.
• Protect whistleblowers from retaliation or victimization.

This policy applies to all employees, directors, agents, contractors, suppliers, clients, and any other third parties who have dealings with the company. It covers, but is not limited to, concerns about:

• Criminal activities, corruption, bribery, undisclosed conflicts of interest and blackmail.
• Any violation of any laws, rules, and regulations including unfair competition /antitrust, insider trading, money laundering and financing terrorism.
• Financial statement fraud such as the misrepresentation, falsification, concealment, misstatement, or omission of financial records.
• Other fraudulent statement related to non-financial management information such as Human Resources, strategic, commercial, asset management etc.
• Violation of company policy, including the code of conduct.
• Manipulation of company data/records, including theft and forging of official documents.
• Theft, misappropriation, misuse, substantial waste or any other abuse of the company’s funds, resources or assets.
• Disclosure of confidential/proprietary information to unauthorized personnel or using such information for personal advantage.
• Any act or omission which amounts to unsafe workplace practice by creating a substantial and specific danger to the lives, health or safety of employees, customers or other third parties.
• Harassment, discrimination, abuse or any mistreatment of any nature of employees, customers or other third parties;
• Inadequate behaviour at work, and /or any potential breach of local Labour Law and best practices
• Abuse of power/ authority by an officer of the Company.
• Coercive practices, meaning impairing or harming or threatening to impair or harm directly or indirectly, any party (internal or external) or the property of the party to influence improperly the actions of a party.
• Collusive practices, meaning an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
• Any other activities whether unethical or improper in nature and damaging the interests, operations, or mission of the company; and
• Concealment or attempts to conceal any of the above.

Reporting a Concern

The company encourages individuals to report concerns as soon as they arise. Reports can be made in the following ways:

• Confidential Hotline: Call our dedicated whistleblowing hotline at [insert phone number], available 24/7.
• Email: whistleblower@nassuremicroinsurance.com

All reports will be treated with strict confidentiality. The company is committed to protecting the identity of whistleblowers to the fullest extent possible, consistent with the need to conduct a thorough investigation.

The Company will maintain as confidential, the whistle blower’s identity unless:

• Such person agrees to be identified
• Such person makes his identity known by telling others about the alleged misdemeanour.

The Company shall inform the whistle-blower prior to revealing his identity where necessary.

While anonymous reports are accepted, we encourage whistle-blowers to provide their contact details to facilitate a more effective investigation. All reports, whether anonymous or not, will be taken seriously and investigated appropriately.

The company strictly prohibits any form of retaliation, harassment, or victimization against whistleblowers who report concerns in good faith. Anyone found engaging in such behaviour will face disciplinary action, up to and including dismissal. Where a whistle-blower has been subjected to any detriment, he may present a complaint to the Chairman, Board of Directors of the company.

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information, the company shall within 72 (seventy two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, the company shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to inform the Data Subject of the breach incident, the risk to the rights and freedoms of the Data Subject resulting from such breach and any course of action to remedy said breach.

• Acknowledgment: Reports will be acknowledged within [5] working days of receipt.
• Initial Assessment: The Whistleblowing Officer will conduct an initial assessment to determine the nature and extent of the concern.
• Investigation: A thorough and impartial investigation will be conducted. Depending on the seriousness of the concern, an independent external investigator may be appointed. Where necessary, the whistle-blower may be required to provide additional information to clarify the disclosure, provided this does not breach his confidentiality. Investigations may include interviews with all the witnesses and other parties involved.
• Outcome: The whistleblower will be informed of the outcome of the investigation where appropriate, considering confidentiality and legal constraints.

Reports made in good faith will be protected, even if they turn out to be unfounded. However, deliberately false or malicious reports will be treated as a serious disciplinary matter.

This policy will be reviewed annually or as needed to ensure it remains relevant and effective. Any changes will be communicated to all stakeholders and updated on the company’s website.

For any questions or further clarification regarding this policy, please contact:

• Shola Ojora
• Phone: +234 809 999 927
• Email:  shola@nassuremicroinsurance.com
• Office Address: ED Building , 47 Marina, Lagos, Nigeria

By implementing this whistleblowing policy, the company reaffirms its commitment to transparency, integrity, and ethical conduct in all its operations.