Whistleblowing

If you see something wrong inside Viscount, say so. We will protect you for it.

Whistleblowing is how a bank finds out about the things its normal reporting lines cannot see: fraud, bribery, insider abuse, cover-ups, regulatory breaches, misconduct. This channel exists for staff, customers, suppliers, shareholders and anyone else with something to report, and it is protected by the Central Bank of Nigeria's whistleblowing guidelines.

Make a report How you are protected

Confidential, and anonymous if you choose Goes to Internal Audit and the board, not to management Retaliation is itself a reportable offence

What to report

Anything that a bank should not be doing, or letting happen

You do not need proof. You need a genuine belief that something is wrong. Investigating is our job, not yours.

Fraud, theft and forgery

By staff, agents, contractors or customers, against the bank or against customers, including manipulation of accounts, records or systems.

Bribery and corruption

Money, gifts or favours given or taken to influence a decision: a loan approval, a contract award, a KYC exception, a regulatory return.

Insider abuse

Loans to directors, staff or their relatives outside the CBN's limits, self-dealing, misuse of customer information, or trading on what one knows.

Regulatory and legal breaches

Anything that breaks CBN, NDIC, AML/CFT, data protection or consumer protection rules, including concealment of a breach or a false return to a regulator.

Misconduct and harassment

Abuse of position, harassment, discrimination or victimisation, including of a person who has already reported something.

Danger to customers or the bank

A control that has failed, a system that is unsafe, a risk being hidden, or a cover-up of any of the above by anyone at any level.

A complaint about your own account or a transaction is not whistleblowing; it goes to the support portal and is handled under the consumer protection process. A concern about the bank's conduct, wherever it comes from, belongs here.

How to report

Three routes, all of them away from the people you are reporting about

A whistleblowing report never goes to customer service, to the person's line manager, or to executive management. It goes to the functions the board has designated to receive it.

The whistleblowing formOn the support portal, the Whistleblowing category is a separate, encrypted form that routes only to Internal Audit. Customer-service staff cannot see it. You may leave your name or report anonymously.
Directly to the Board Audit CommitteeIf your concern involves Internal Audit itself or senior management, you may write to the Chair of the Board Audit Committee, a non-executive director, through the same form by selecting Board only. Management does not see it.
Directly to the Central Bank of NigeriaThe CBN operates its own whistleblowing channel for the banking industry. You may go to the regulator first, instead of us, or at the same time. Nothing in this policy restricts that.

Make a whistleblowing report

What helps us actInclude what you can. None of it is mandatory.

What happenedIn your own words. Facts, not conclusions, are most useful.

Who was involvedNames, roles or descriptions, if you know them.

When and whereDates, branch, system or account, as precisely as you can.

Any evidenceDocuments, screenshots, references. Do not take anything you are not entitled to.

Whether anyone else knowsAnd whether you have raised it before, and what happened.

How to reach you, if you wishOptional. Anonymous reports are investigated with the same seriousness.

You receive a reference number. If you report anonymously, keep it: it is the only way to follow up or add information.

What happens next

Every report gets the same process, whoever it names

Acknowledged within two working days

You receive a reference number immediately and an acknowledgement from Internal Audit, or from the Board Audit Committee if you chose Board only.

Assessed

Internal Audit decides whether the concern falls within this policy, whether it needs immediate protective action, and who is independent enough to investigate it.

Investigated

By Internal Audit, an independent director, or an external firm where the concern touches senior management or the audit function itself. People named are given a chance to respond.

Concluded and reported

Findings go to the Board Audit Committee and, where the guidelines require, to the CBN. You are told the outcome to the extent confidentiality and the law allow, normally within ninety days.

Protection

What we owe anyone who reports in good faith

The Central Bank of Nigeria's Guidelines for Whistleblowing in the Nigerian Banking Industry require every bank to protect whistleblowers. These commitments are Viscount's, and the board is accountable for them.

Confidentiality. Your identity is known only to those who need it to investigate, and is not disclosed without your consent unless the law requires it.
No retaliation. Dismissal, demotion, harassment, loss of business or any other detriment for reporting is prohibited, is itself reportable under this policy, and is treated as gross misconduct.
Good faith is enough. You are protected even if the investigation finds nothing wrong, provided you believed the concern was genuine. Only knowingly false or malicious reports fall outside the policy.
Anonymity respected. We do not attempt to identify an anonymous reporter, and anonymous reports are investigated with the same seriousness.
The regulator's door is always open. Nothing here limits your right to report directly to the CBN, the NDIC, the NFIU or law enforcement.
Board oversight. The Board Audit Committee reviews every report and its outcome, and reports on the whistleblowing channel to the CBN as the guidelines require.

Questions

About whistleblowing at Viscount

I am a customer, not staff. Can I use this?

Yes. The channel is open to customers, suppliers, agents, shareholders and members of the public, as the CBN guidelines require. If your concern is about the bank's conduct rather than your own account, this is the right place.

Can I really stay anonymous?

Yes. Leave the contact fields blank and the report carries no identifying information. Keep your reference number, since it is the only way to add information or ask about progress. Be aware that a very specific concern may, by its nature, point to who could have known about it; tell us if that worries you and we will take it into account in how we investigate.

What if my concern is about the Managing Director or a board member?

Select Board only when you submit. The report goes to the Chair of the Board Audit Committee, a non-executive director, and is not visible to management. Concerns about a board member are investigated by other independent directors or an external firm.

Will I be told what happened?

You will be told that the matter has been concluded and, to the extent confidentiality and the law allow, the outcome. You may not be told the detail of action taken against an individual, because they have rights too.

What if I reported and something bad then happened to me?

Report that, through the same channel, marked Board only. Retaliation against a whistleblower is gross misconduct at Viscount and a breach of the CBN guidelines, and it is investigated as a priority. You may also report it to the CBN directly.

What if I was involved in what I am reporting?

Report it anyway. Coming forward is taken into account and this policy protects you from retaliation for reporting. It does not, and cannot, grant immunity from the consequences of your own conduct, but those consequences are always lighter than for someone who was found out.

Speak up

A bank is only as honest as the people willing to say so

If you have seen something that should not be happening at Viscount, report it. Confidentially, anonymously if you prefer, and with the board behind you.

Make a whistleblowing report Board and committees