We draft Whistle blowing policy of Midland Cosmos ltd in Nigeria
A whistleblowing policy for a Nigerian company like Midland Cosmos Ltd must align with the 2016 Federal Government Whistleblowing Policy and existing Nigerian corporate governance standards, which emphasize transparency and protection against retaliation.
The following is a draft policy structure designed to meet these requirements as of 2026 onwards.
Whistleblowing Policy: Midland Cosmos Ltd (Nigeria)
1. Policy Statement
Midland Cosmos Ltd is committed to the highest standards of openness, probity, and accountability. We encourage employees and external stakeholders to report any suspected malpractice or illegal activity without fear of victimisation, harassment, or retaliation.
This policy applies to all employees, directors, vendors, and contractors of Midland Cosmos Ltd. Reportable misconduct includes, but is not limited to:
Financial malpractice, fraud, or bribery.
Failure to comply with legal or regulatory obligations.
Health, safety, or environmental risks.
Abuse of office or misuse of company assets.
Deliberate concealment of any of the above.
3. Reporting Procedures
Concerns should ideally be reported in writing to provide concrete evidence, though oral reports are accepted.
Internal Channels: Reports should be directed to the Head of Internal Audit or the Chief Compliance Officer.
External Channels: If the concern involves senior management, reports can be made directly to the Chairman of the Audit Committee.
Anonymity: Whistleblowers may remain anonymous; however, providing a name is encouraged to facilitate a thorough investigation.
4. Whistleblower Protection
Midland Cosmos Ltd strictly prohibits any form of retaliation against a whistleblower who makes a report in good faith.
Confidentiality: The identity of the whistleblower will be kept secret to the fullest extent possible.
Legal Coverage: If an identity becomes known, the company will provide necessary legal coverage and protection.
Sanctions for Retaliation: Any employee found retaliating against a whistleblower will face severe disciplinary action, including possible termination.
5. Investigation and Feedback
Preliminary Review: Upon receipt, a review is conducted within 10 working days to determine if there is a credible violation.
Formal Investigation: If credible, an independent investigation is launched. Implicated persons will be given a fair chance to respond in writing.
Outcome: The whistleblower will be informed of the investigation result (e.g., founded or unfounded) within a reasonable timeframe.
6. False or Malicious Claims
While protecting genuine whistleblowers, the company will not tolerate malicious or vexatious reports. Any person found to have made a false allegation with the intent to cause harm will be subject to disciplinary or legal action.
7. External Reporting (Regulators)
If a whistleblower is dissatisfied with the internal outcome, or the matter involves significant public interest, reports may be escalated to relevant Nigerian authorities such as:
Federal Ministry of Finance (Whistleblowing Portal)
Economic and Financial Crimes Commission (EFCC)
Securities and Exchange Commission (SEC) (for listed concerns)
Note: This policy should be reviewed annually by the Board of Directors to ensure compliance with evolving Nigerian laws and corporate governance codes.
8. Scope of the policy
To complete the operational framework for Midland Cosmos Ltd, the following sections cover the governance, administration, and specific communication channels required to make the policy functional in the Nigerian business environment in 2026.
Midland Cosmos Ltd shall maintain dedicated, secure channels for reporting. These channels are managed by the Internal Audit Department to ensure independence from daily operations.
Dedicated Email: whistleblow@midlandcosmos.com.ng(pending)
Secure Hotline: +234 81 48272375 (Monitored only by the Head of Internal Audit).
Postal Address:
Attn: The Chairman, Audit Committee
Midland Cosmos Ltd Email address: ibikabram@gmail.com .
9. Roles and Responsibilities
The Board of Directors: Responsible for the final oversight of the policy and ensuring that management fosters a culture of transparency.
The Audit Committee: Evaluates the reports and oversees the conduct of investigations to ensure they are free from management influence.
Employees: Responsible for reporting any suspected wrongdoing immediately and cooperating with investigations while maintaining the confidentiality of the process.
10. Rewarding Whistleblowers (Incentive Clause)
In alignment with the Federal Government of Nigeria’s Whistleblowing Policy, where a report leads to the recovery of stolen company funds or assets, the Board may, at its discretion, recommend a financial or non-financial reward for the whistleblower, provided the report was:
Original and not already known to the company.
Submitted in good faith.
Directly responsible for the recovery.
11. Training and Awareness
To ensure all stakeholders are aware of their rights and responsibilities:
All new hires shall receive a copy of this policy during induction.
Annual "Ethics Awareness" workshops will be conducted for all staff levels.
The policy shall be published on the Midland Cosmos Ltd Official Website and internal staff portals.
12. Policy Review and Governance
This policy shall be reviewed every two years or as dictated by changes in the Nigerian Code of Corporate Governance (NCCG) or the Companies and Allied Matters Act (CAMA 2020). Any amendments must be approved by the Board of Directors.
Implementation Checklist for Midland Cosmos Ltd:
Appointment: Formally designate an Integrity Officer or use the Head of Internal Audit as the primary point of contact.
External Reporting: If the company is a public entity, ensure a link to the SEC Nigeria Whistleblowing Portal is provided to employees.
Legal Review: Have a Nigerian legal practitioner review this draft to ensure it meets specific sectoral requirements (e.g., if the company operates in the oil and gas or financial services sectors).
Approved by:
Name:____Ibikunle Abraham Laniyan___
Title: Chairman, Board of Directors
Date: January 1, 2026
8. Whistleblowing Channels & Contacts
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To finalize the Whistleblowing Policy for Midland Cosmos Ltd for 2026, the following sections provide the necessary administrative tools, legal context, and feedback loops to ensure compliance with the Nigerian Code of Corporate Governance (NCCG) 2018 and the Companies and Allied Matters Act (CAMA) 2020.
13. Investigation Timeline & Milestones
To maintain trust, Midland Cosmos Ltd adheres to strict timelines for processing disclosures:
Acknowledgment: A formal acknowledgment shall be sent to the whistleblower within 48 hours of receipt.
Preliminary Assessment: The Head of Internal Audit will determine if there is a prima facie case within 7 working days.
Investigation Commencement: If valid, a formal investigation begins within 10 working days of the initial report.
Final Report: Investigations should ideally be concluded within 30 to 60 days, depending on complexity. Any extension must be approved by the Audit Committee.
14. External Escalation & Regulatory Bodies
If internal resolution is not achieved or the matter involves high-level executive fraud, stakeholders are encouraged to contact relevant Nigerian regulators:
Financial Misconduct: Federal Ministry of Finance Whistleblowing Portal.
Corporate Governance/Public Listed Concerns: Securities and Exchange Commission (SEC) Nigeria.
Corruption/Bribery: Independent Corrupt Practices and Other Related Offences Commission (ICPC) or the Economic and Financial Crimes Commission (EFCC).
Banking/Financial Services: Central Bank of Nigeria (CBN) Whistleblowing Office.
15. Data Protection & Privacy
In compliance with the Nigeria Data Protection Act (NDPA) 2023, Midland Cosmos Ltd ensures that:
Personal data of the whistleblower and the accused is processed only for the purpose of the investigation.
Records are stored in a secure, encrypted database accessible only by the Compliance Team.
All data is disposed of securely after the statutory retention period (typically 6 years) unless legal proceedings are ongoing.
Appendix A: Whistleblowing Report Template
To be filled out and submitted via secure channels.
Nature of Incident: (e.g., Fraud, Safety Breach, Bribery, Harassment)
Date and Location: When and where did the incident occur?
Parties Involved: Names of individuals or departments suspected of misconduct.
Description of Misconduct: Provide a detailed account of the events.
Evidence/Witnesses: List any documents, emails, or other persons who can corroborate the claim.
Informant Particulars (Optional): Name and contact details (if not reporting anonymously).
16. Conclusion
The Board of Directors of Midland Cosmos Ltd reaffirms that this policy is a cornerstone of our corporate integrity. We believe that by protecting those who speak up, we protect the long-term sustainability of the company and the interests of our stakeholders in Nigeria.
Policy Effective Date: January 1, 2026
Next Review Date: January 1, 2028
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