We draft below the labour law and due diligence policy for Midland Cosmos ltd in Nigeria
As of 2026, Midland Cosmos Ltd must align its labor and due diligence policies with the Nigerian Labour Act, the 2024 National Minimum Wage (Amendment) Act, and the National Action Plan on Business and Human Rights.
Part 1: Labour Law Compliance Policy
This policy governs the minimum standards of employment for Midland Cosmos Ltd.
Mandatory Employment Contracts: All employees must receive a written contract within three months of commencement. It must specify the nature of work, wages, hours, and notice periods.
Wages and Hours:
Minimum Wage: The statutory minimum is ₦70,000 per month (effective July 2024, with the next review scheduled for 2027).
Working Hours: Standard time is 8 hours/day and 40 hours/week. Work exceeding these hours is considered overtime.
Statutory Leave Entitlements:
Annual Leave: Minimum 6 working days of paid leave after 12 months of continuous service.
Sick Leave: Up to 12 days of paid leave annually with a medical certificate.
Maternity Leave: 12 weeks total (6 weeks before and 6 weeks after delivery) at a minimum of 50% pay for women employed for at least six months.
Mandatory Deductions and Remittances (2026 Standards):
Pension: Employer contributes 10% and employee 8% of monthly emolument (for firms with 15+ employees).
NHF: 2.5% of basic salary for the National Housing Fund.
NSITF: 1% of total monthly payroll remitted by the employer to the Employee Compensation Fund.
ITF: 1% of annual payroll if the company has 5+ employees or ₦50M+ turnover.
PAYE Tax: Deduct and remit personal income tax by the 10th of every month.
Part 2: Due Diligence Policy
Midland Cosmos Ltd must implement a proactive risk management framework to ensure compliance and social responsibility.
Human Rights Due Diligence (HRDD): Companies are expected to identify, prevent, and mitigate human rights violations (e.g., forced labor or discrimination) in their operations and supply chains.
Financial and Anti-Corruption Checks: Maintain rigorous Know Your Customer (KYC) and Anti-Money Laundering (AML) controls. Nigeria’s removal from the EU/FATF greylist in 2025/2026 places a premium on maintaining these internal standards to avoid renewed scrutiny.
Data Protection: Ensure all employee and partner data is processed according to the Nigerian Data Protection Act (NDPA). Any cross-border data transfer requires specific consent or regulatory approval.
Internal Audits: Perform "tax health checks" and reconcile payroll records with tax filings regularly to avoid strict 2026 penalties for under-deduction or late remittance.
Recommended Actionable Links
Review latest regulations via the Nigeria Ministry of Labour and Employment.
Submit pension reports through PenCom’s online portal.
Manage tax remittances using the FIRS Taxpro-Max portal.
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To complete the operational framework for Midland Cosmos Ltd in 2026, the following sections detail the Disciplinary Procedures, Termination Protocols, and the Operational Framework for Due Diligence.
Part 3: Disciplinary and Grievance Procedures
To avoid "unfair dismissal" claims, which are strictly scrutinized by the National Industrial Court of Nigeria (NICN), Midland Cosmos Ltd must follow a fair hearing process.
Progressive Discipline:
Verbal Warning: For minor first-time infractions (documented).
Written Warning: For repeated minor offenses or more serious misconduct.
Final Written Warning: Issued with a clear statement that further misconduct will lead to termination.
Suspension/Dismissal: Reserved for "Gross Misconduct" (e.g., theft, violence, fraud).
The Right to Fair Hearing: Before termination, an employee must be given a Query (written notice of the allegation) and a formal opportunity to respond.
Internal Grievance Redress: Employees should have a dedicated channel (HR or an anonymous whistleblower line) to report harassment or workplace safety violations without fear of retaliation.
Part 4: Termination and Redundancy Protocols
Notice Periods: Per the Labour Act, the following minimum notice (or pay in lieu) is required:
Less than 3 months service: 1 day.
3 months to 2 years: 1 week.
2 years to 5 years: 2 weeks.
5+ years: 1 month.
Redundancy: If Midland Cosmos Ltd reduces its workforce due to restructuring, it must:
Inform the trade union or employee representative of the reasons.
Apply the principle of "Last In, First Out" (LIFO), subject to merit and skill.
Pay redundancy compensation (severance) as negotiated or as per industry standards.
Part 5: Detailed Due Diligence Checklist (2026 Operations)
Midland Cosmos Ltd should perform the following checks on all high-value vendors and corporate partners:
Category Requirement Verification Source
Legal Status Verify active registration and "Active" status. CAC Registration Portal
Tax Compliance Request a Tax Clearance Certificate (TCC) for the last 3 years. FIRS TCC Verification
Social Security Ensure the vendor is remitting staff pensions and NSITF. PenCom / NSITF Compliance Certs
Ethical Sourcing Audit suppliers for child labor or environmental violations. Site visits & Self-Certifications
Sanction Screening Check against global and local AML/CFT watchlists. NFIU / Central Bank of Nigeria
Part 6: Occupational Health and Safety (OHS)
Under the Employee’s Compensation Act, Midland Cosmos Ltd is strictly liable for workplace injuries.
Mandatory Training: Conduct annual safety drills and provide Personal Protective Equipment (PPE) where applicable.
Incident Reporting: Any workplace accident resulting in death or serious injury must be reported to the nearest Ministry of Labour office within 24–72 hours.
Insurance: Maintain active coverage under the NSITF to ensure employees are compensated for occupational diseases or injuries without direct litigation against the company.
Implementation Steps
Handbook Distribution: Compile these policies into an Employee Handbook and ensure every staff member signs an acknowledgment form.
Compliance Officer: Appoint a dedicated compliance officer to monitor the TaxPro-Max portal and PenCom filings monthly.
Legal Review: For complex high-level executive contracts, use the Nigerian Bar Association (NBA) Directory to find a certified employment law specialist.
To finalize the Midland Cosmos Ltd 2026 operational framework, the following sections address Data Protection, Industrial Training Compliance, and Corporate Governance.
Part 7: Data Protection Policy (NDPA 2023/2026 Standards)
Under the Nigeria Data Protection Act (NDPA) 2023 and the 2025 General Application & Implementation Directive (GAID), Midland Cosmos Ltd must ensure strict data privacy.
Registration: If Midland Cosmos Ltd processes data for more than 200 people or handles sensitive information (e.g., employee health records, BVNs), it must register with the Nigeria Data Protection Commission (NDPC).
Mandatory Audits: As of January 2026, the NDPC has signaled stricter enforcement of annual Data Protection Compliance Audits. These must be filed within the first quarter (Q1) window.
Breach Notification: In the event of a data breach, the company must notify the NDPC within 72 hours.
Penalties: Non-compliance or a major breach can result in fines up to ₦10 million or 2% of annual gross revenue (whichever is higher) for "Major Importance" entities.
Part 8: Industrial Training and Skills Development
Compliance with the Industrial Training Fund (ITF) Act is required for firms with 5+ employees or an annual turnover exceeding ₦50 million.
Contribution Rate: Remit 1% of the total annual payroll to the ITF.
Reimbursement Benefit: Midland Cosmos Ltd can claim a 50% refund of its contribution if it provides evidence of approved vocational training for its indigenous staff.
Bidding Requirement: An ITF Compliance Certificate is mandatory for any private entity bidding on Federal Government contracts or soliciting business from MDAs.
Part 9: Corporate Governance & Reporting (2026)
The Nigerian Code of Corporate Governance (NCCG) and recent Financial Reporting Council (FRC) updates place new demands on private entities.
Public Interest Entity (PIE) Status: Companies must reassess their status; if categorized as a PIE, they must register with the FRC and file audited reports within 60 days of Board approval.
Climate and Sustainability: As of November 2025, climate and sustainability governance are now core Board duties. Midland Cosmos Ltd should include sustainability metrics in its annual reporting.
Whistleblowing: The NCCG requires a clear whistleblowing policy to protect employees who report unethical practices.
Final Implementation Roadmap
Q1 2026 Deadline: File the Data Protection Audit and annual ITF/NSITF returns before March 31st to avoid late penalties (typically 5–10% of the unpaid amount).
Appointment of Officers: Appoint a Data Protection Officer (DPO) if the company falls under the "Major Importance" threshold.
Digital Filing: Use the NDPC Portal for data registration and the ITF Portal for training remittances.
Sustainability Audit: Begin tracking environmental and social impact to comply with the FRC's 2026 reporting expectations.
To conclude the operational framework for Midland Cosmos Ltd in 2026, the following sections address critical 2026-specific tax reforms, human rights due diligence, and strict new data compliance deadlines.
Part 10: 2026 Tax Reform & Payroll Compliance
Effective January 1, 2026, Nigeria has implemented a massive overhaul of its tax system through the Nigeria Tax Act (NTA) 2025. Midland Cosmos Ltd must adjust its payroll systems to account for these changes:
New Tax-Free Threshold: Individuals earning ₦800,000 annually (approx. ₦66,666 monthly) or less are now exempt from Personal Income Tax.
Progressive Tax Rates: For earners above the threshold, rates are more progressive, ranging from 0% to 25%.
Revised Deductions:
Rent Relief: A new deduction of 20% of gross income is allowed for rent, capped at ₦500,000.
Statutory Deductions: Pensions (8%), NHF (2.5%), and life assurance premiums (up to ₦100,000) remain deductible but require written documentation for claims.
Consolidated Development Levy: For corporate accounting, note that four sectoral levies (Tertiary Education, NITDA, NASENI, and Police Trust Fund) have been consolidated into a single 4% Development Levy on assessable profits.
Part 11: Human Rights Due Diligence (HRDD)
Aligned with the National Action Plan (NAP) on Business and Human Rights (2024–2028), Midland Cosmos Ltd is expected to institutionalize "Respect" for human rights.
Impact Assessments: Conduct regular assessments to identify potential human rights violations (e.g., in supply chains or site security).
Public Commitment: The Board must issue a public policy statement committing to the UN Guiding Principles on Business and Human Rights.
Grievance Mechanisms: Ensure a clear path for "Remedy" exists for employees or community members affected by business operations.
Part 12: 2026 Data Protection Deadlines
Under the Nigeria Data Protection Act (NDPA) General Application and Implementation Directive (GAID) issued in late 2025, compliance is now heavily audited.
Audit Deadline: Midland Cosmos Ltd must file its annual Data Protection Compliance Audit Return (CAR) by March 31, 2026.
DPO Requirement: If the company processes the personal data of more than 200 subjects in six months, it must appoint and certify a Data Protection Officer (DPO).
Penalties for 2026: Late filing of the CAR incurs a 50% penalty on the filing fee. Failure to file can lead to fines up to ₦10 million or 2% of annual gross revenue.
Summary of Immediate 2026 Actions
By January 31, 2026: Update payroll software to reflect the NTA 2025 tax bands and the ₦800,000 tax-free threshold.
By March 31, 2026: Ensure a licensed Data Protection Compliance Organisation (DPCO) files the company's CAR through the NDPC online portal.
Continuous Monitoring: Watch for potential 2026/2027 wage reviews, as labor unions (NLC) are actively pushing for adjustments beyond the current ₦70,000 minimum due to inflation.
To finalize the Midland Cosmos Ltd governance framework for 2026, the focus shifts to Workplace Technology, ESG (Environmental, Social, and Governance) reporting, and Immigration Compliance for foreign talent.
Part 13: Workplace Technology & Remote Work Policy
Given the hybrid work shifts observed through 2025, Midland Cosmos Ltd must formalize digital workplace rules:
Remote Work Agreements: Contracts must specify "Place of Work." If remote, the company should define its responsibility for providing data/internet stipends and ergonomic equipment.
Right to Disconnect: In line with emerging global trends being discussed by the Nigerian Ministry of Labour in 2026, policies should discourage official communication outside of 8:00 AM – 6:00 PM to prevent burnout.
Company Property: Explicitly state that all digital correspondence on company servers (Email, Slack, Teams) is the property of Midland Cosmos Ltd and subject to monitoring under the Nigeria Data Protection Act (NDPA).
Part 14: ESG and Sustainability Due Diligence
As of 2026, the Financial Reporting Council (FRC) of Nigeria has intensified the adoption of ISSB (International Sustainability Standards Board) S1 and S2 standards.
Environmental Impact: Midland Cosmos Ltd must monitor its "Carbon Footprint," particularly if it operates in manufacturing or logistics.
Social Impact: Document efforts in diversity, equity, and inclusion (DEI). Report on the ratio of local vs. foreign hires and gender pay parity.
Governance: Maintain a "Gift and Hospitality Register" to prevent bribery and ensure all interactions with government officials are logged for due diligence audits.
Part 15: Immigration and Expatriate Compliance
If Midland Cosmos Ltd employs foreign nationals in 2026, it must adhere to the Expatriate Employment Levy (EEL) and Revised Immigration Rules:
Expatriate Quota: Apply for and maintain valid quotas via the Ministry of Interior Portal.
Expatriate Employment Levy (EEL): Ensure the annual levy is paid for each non-citizen employee (unless exempt, such as staff of diplomatic missions).
CERPAC Renewal: Ensure Combined Expatriate Residence Permit and Aliens Cards (CERPAC) are renewed 30 days prior to expiration to avoid the heavy 2026 fines for overstaying.
Part 16: Supply Chain Due Diligence (SCDD)
Midland Cosmos Ltd is responsible for the conduct of its third-party contractors.
Modern Slavery Clause: All vendor contracts must include a clause prohibiting child labor and forced labor, with the right for Midland Cosmos Ltd to terminate the contract immediately upon breach.
Local Content Compliance: Prioritize Nigerian-owned businesses for procurement to align with the National Local Content Policy, which is increasingly becoming a requirement for tax incentives.
Milestone Due Date Agency
Annual Tax Returns June 30, 2026 FIRS
Employee Compensation (NSITF) Monthly (by 30th) NSITF
Pensions Remittance Within 7 days of salary PenCom
Data Audit (CAR) March 31, 2026 NDPC
ITF Contribution April 1, 2026 ITF
Final Recommendation: Midland Cosmos Ltd should conduct a Legal Compliance Audit every six months to ensure that any "Circulars" issued by the Central Bank of Nigeria (CBN) or the Federal Inland Revenue Service (FIRS) during the 2026 fiscal year are integrated into these policies immediately.
Summary of 2026 Regulatory Milestones
To conclude the Midland Cosmos Ltd framework for 2026, this final section addresses Occupational Health, Safety, and Environment (HSE) and Conflict Resolution Strategy.
Part 17: Occupational Health, Safety, and Environment (HSE)
Under the Employee’s Compensation Act and the National Environmental Standards and Regulations Enforcement Agency (NESREA) guidelines for 2026:
Workplace Safety Standards: Midland Cosmos Ltd must maintain a safe work environment. This includes providing appropriate Personal Protective Equipment (PPE) and ensuring fire safety equipment is serviced and certified by the Federal Fire Service.
Health Insurance: While NHIS is often voluntary for private firms, many 2026 state laws (like the Lagos State Health Scheme) now mandate that all employers provide basic health insurance for their employees.
Environmental Due Diligence: If the company’s operations involve waste generation or chemical usage, it must obtain an Environmental Audit Report (EAR) every three years and submit it to NESREA.
Part 18: Conflict Resolution & Industrial Relations
In the event of labor disputes, Midland Cosmos Ltd should prioritize Alternative Dispute Resolution (ADR) to avoid the lengthy and public litigation processes of the National Industrial Court.
Mediation First: All employment contracts should include a clause requiring mandatory internal mediation or external arbitration before a lawsuit can be filed.
Trade Union Engagement: If employees exercise their right to unionize under the Trade Unions Act, the company must engage in "Collective Bargaining" in good faith.
Strike Action Protocol: The company must maintain a "No Work, No Pay" policy during illegal strikes, while respecting the constitutional right to peaceful protest as long as it adheres to the Trade Disputes Act.
Part 19: 2026 Compliance Audit Calendar
To maintain "Good Standing" and avoid the "Strict Liability" penalties introduced in 2025/2026, the HR and Legal department must follow this schedule:
Period Activity Objective
Q1 (Jan–Mar) NDPC Audit File Data Protection Compliance Audit by March 31.
Q2 (Apr–Jun) FIRS Corporate Tax File annual CIT returns and development levies by June 30.
Q3 (Jul–Sep) HSE Review Conduct fire drills and safety equipment certification.
Q4 (Oct–Dec) Contract Review Update all vendor and staff contracts for 2027 statutory changes.
Final Implementation Instructions
Policy Adoption: Present this full draft (Parts 1–19) to the Board of Directors for formal adoption as the "2026 Midland Cosmos Corporate Governance & Labour Manual."
Training: Conduct a mandatory "Compliance Workshop" for all managers to ensure they understand the new 2026 Tax Act thresholds and NDPA data privacy rules.
Digital Repository: Upload all compliance certificates (TCC, ITF, NSITF, PenCom) to a secure cloud folder for immediate retrieval during government "spot checks" which have increased in frequency in 2026.
To finalize the Midland Cosmos Ltd 2026 framework, this concluding section addresses Anti-Bribery and Corruption (ABC), Community Social Responsibility (CSR), and the Policy Review Mechanism.
Part 20: Anti-Bribery and Corruption (ABC) Policy
In 2026, the Economic and Financial Crimes Commission (EFCC) and the ICPC have intensified scrutiny on private-to-public sector interactions. Midland Cosmos Ltd must maintain a "Zero Tolerance" stance.
Prohibited Payments: Explicitly ban "facilitation payments" (small payments to speed up routine government actions).
Political Contributions: Midland Cosmos Ltd must not make direct or indirect contributions to political parties or candidates to influence business advantages.
Gift Transparency: Any gift received or given by an employee valued over ₦50,000 must be declared in a central "Gift Register" overseen by the Compliance Officer.
Whistleblower Protection: Ensure that any employee who reports a bribe or "kickback" scheme is protected from dismissal or demotion under the Whistleblower Protection Policy 2024.
Part 21: Community Social Responsibility (CSR) & Social License
Under the National Action Plan on Business and Human Rights (2024-2028), Nigerian companies are encouraged to secure a "Social License to Operate."
Local Employment: Commit to hiring at least 30% of non-technical staff from the immediate host community where the company's physical offices or facilities are located.
Sustainability Projects: Allocate a percentage of annual profit to community-led initiatives (e.g., water, education, or renewable energy).
Impact Reporting: Include a "Community Impact" section in the annual report to satisfy the Financial Reporting Council (FRC) sustainability disclosure requirements for 2026.
Part 22: Policy Review and Amendment
Labor laws and tax regulations in Nigeria are currently in a state of rapid evolution.
Annual Review: This policy manual shall be reviewed every December to incorporate changes from the annual Finance Act or new circulars from the Central Bank of Nigeria (CBN).
Ad-hoc Updates: If the National Minimum Wage is adjusted again (a review is scheduled for 2027, but inflation triggers may move this up), the Wage and Salary section of this policy is automatically superseded by the new statutory minimum.
Final Documentation Checklist for the Board
Before Midland Cosmos Ltd begins its 2026 Q2 operations, ensure the following documents are finalized and physically/digitally filed:
Staff Handbook: Containing the Labour Law and Disciplinary sections.
Due Diligence SOP: A manual for the procurement team on how to vet vendors.
Data Privacy Manual: For the IT and HR departments regarding employee and client data.
HSE Registry: Logs of safety drills, accident reports, and PPE distribution.
Compliance Folder: Current FIRS Tax Clearance, ITF Compliance Certificate, and PenCom Clearance.
Conclusion of Draft: This comprehensive framework ensures that Midland Cosmos Ltd operates with legal integrity, financial transparency, and social accountability within the Nigerian business ecosystem for the 2026 fiscal year.
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To ensure the Midland Cosmos Ltd 2026 framework is fully operational and future-proofed against emerging regulatory shifts, this final addendum covers Strategic Resilience, Crisis Management, and Legal Documentation Standards.
Part 23: Strategic Regulatory Resilience
In 2026, the Nigerian regulatory environment is characterized by "Digital-First" enforcement. Midland Cosmos Ltd must adapt to the Single Window compliance approach.
Integrated Compliance Monitoring: Utilize the National Integrated Verification System to ensure that all corporate filings (CAC, FIRS, and NIMC) are synchronized. Inconsistencies in director details across these platforms now trigger automatic "Compliance Red Flags" in 2026.
Artificial Intelligence (AI) Policy: If Midland Cosmos Ltd uses AI for recruitment or performance monitoring, it must adhere to the 2025 National AI Governance Framework. This requires ensuring that algorithms are free from bias and that employees are informed when AI is making "significant decisions" about their employment.
Part 24: Crisis Management & Business Continuity (BCP)
Given the macroeconomic fluctuations and infrastructure challenges in Nigeria, the company must maintain a formal BCP as part of its due diligence.
Workforce Readiness: Maintain a "Crisis Communication Tree" (WhatsApp/Signal/SMS) to notify staff of office closures due to civil unrest or severe weather.
Succession Planning: Identify "Key Personnel" and ensure that at least two people are trained and authorized to handle statutory portals (e.g., TaxPro-Max, PenCom) to prevent defaults if a key staff member departs suddenly.
Data Redundancy: Ensure all labor and due diligence records are backed up on a secure, encrypted cloud server (compliant with NDPA regulations) to prevent loss of compliance history during physical hardware failure.
Part 25: Legal Document Execution Standards
To ensure all policies drafted for Midland Cosmos Ltd are legally enforceable in Nigerian courts (NICN):
Digital Signatures: Under the Evidence Act (as amended), digital signatures (DocuSign, etc.) are valid for employment contracts, provided there is a verifiable audit trail.
Stamping of Agreements: Ensure that high-value commercial contracts and deeds are duly stamped at the Federal Inland Revenue Service (FIRS) Stamp Duties Office. Unstamped documents are generally inadmissible as evidence in court and incur heavy penalties in 2026.
Language of Operation: While the official language is English, ensure that safety signs and basic summaries of the Labour Policy are explained verbally to staff who may have limited literacy to satisfy "Duty of Care" requirements.
Final Certification of Completion
This concludes the 25-part draft for Midland Cosmos Ltd.
Next Steps for the Managing Director:
Print and Bind: Create a physical "Governance Master File."
Appoint Auditors: Select a licensed DPCO for the March 2026 Data Audit.
Liaison: Establish a relationship with the local Ministry of Labour office (State or Federal) to ensure your HSE and Labour standards meet their specific 2026 zonal requirements.
Resource Quick-Links for 2026:
Corporate Affairs Commission (CAC) – For status checks.
National Industrial Court (NICN) – For reviewing recent labor case law precedents.
Nigeria Data Protection Commission – For filing the mandatory 2026 audit.
The policy draft is now complete
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